Navigating the transition from AFFF: Ensuring risk management and business continuity

The shift from AFFF to PFAS-free alternatives is driven by the need to reduce environmental and health risks associated with PFAS chemicals. However, this transition is not without its challenges. Organizations must evaluate alternative options, navigate changing regulatory landscapes, and manage supply chain risks. With no one size fits all, the transition can look different from business to business requiring early planning and stakeholder engagement to address challenges effectively. 

One of the biggest challenges is the lack of drop-in replacements for AFFF, which necessitates a thorough assessment of fire suppression systems and equipment compatibility. Additionally, the regulatory landscape is constantly evolving, with varying requirements at state, national, and international levels. Businesses must consider alternative products that are compatible with their equipment and fire suppression systems.

To maintain business continuity during the transition, organizations must conduct thorough risk assessments, plan early, and communicate clearly with all stakeholders. This includes exploring compensatory measures, such as fire-watch or temporary maintenance activities, to mitigate risks during the transition period. Undergoing improper steps or rushing the process may lead to supply chain risks, environmental risks, as well as health and safety risks that could occur during the transition. 

Early planning and stakeholder engagement are critical to navigating the complexities of the AFFF transition. Organizations must also prioritize regulatory compliance, environmental responsibility, and supply chain management. Continuous improvement and applying lessons learned from each project are essential to achieving long-term success. Dylan and David spoke of the lessons learned from successful transitions which can be integrated as best practices for a business starting their journey.

Conducting a risk assessment and impact analysis to understand what the potential critical business functions are, your essential operations, and the site-specific environmental considerations is an imperative step to a successful transition. Completing thorough audit and inventory what fire suppression systems, and supporting infrastructure and assets, your business has can determine the business continuity risk expected and the asset life span to aid business future-proofing. Completing a risk assessment as part of early planning will improve your chances of maintaining business continuity and operational readiness.

Start early, map out your stakeholders and engage consistently. From insurers to facility users to contractors, having a well-developed line of communication before you start a transition will benefit your transition when trying to maintain fire suppression or other capabilities for business continuity.

Contingency planning, monitoring and review for unexpected challenges is also key to a successful transition. Throughout your AFFF transition you want to minimize operational disruptions, especially abortive work and be ready for real world emergencies. To minimize disruptions, have a backup plan and developed response plans that have defined roles, communication protocols, and procedures. Having a well-developed plan and a full understanding of the intent behind a transition will help mitigate potential risks.

Understanding compliance requirements and regulations is key to managing long-term liability and are important aspects of the AFFF transition. As the regulatory landscape continues to evolve, staying informed, working with industry specialists and regulatory bodies proactively is essential. Collaboration across different functions such as environmental compliance, operational readiness, and risk management is necessary to address the multifaceted challenges of AFFF transition.

Proactive waste stewardship will save money and avoid future liabilities and latent risk. Organizations should explore disposal options for AFFF, including solidification, incineration, as well as onsite treatment and destruction options feasibility. It is important to reduce the volume of waste and consider the environmental impact of different disposal methods. Development of a waste disposal plan that includes a disposal pathway evaluation as part of upfront feasibility and constraints review allows for clear decision-making and program planning. 

Regular training and awareness programs ensure that employees are familiar with the business continuity plans and their roles during a transition. This helps in building a culture of preparedness and resilience. Business continuity plans should be regularly reviewed and updated to reflect changes in the business environment, technology, and regulatory requirements. This ensures that the plans remain relevant and effective. Additionally, investing in training and awareness programs for employees on compliance and procedures and protocols for updated systems will reduce operational downtime. 

The transition from AFFF to PFAS-free or foam-free alternatives is a significant undertaking that requires careful planning, risk management, and stakeholder engagement. By learning from successful transitions and prioritizing regulatory compliance and environmental responsibility, organizations can navigate this complex process while maintaining business continuity and operational readiness.