Understanding the US DoD's prohibition of AFFF incineration and your disposal responsibilities
At a glance
Due to new regulations and growing understanding of harmful PFAS chemicals, traditional AFFF incineration is prohibited for the US Department of Defense and discouraged for others. Alternative disposal options are crucial to avoid environmental and health risks associated with PFAS.
There is currently a lot of uncertainty surrounding appropriate disposal options for Aqueous Film Forming Foam (AFFF)—a fire suppressant commonly used in automated fire suppression systems and used by firefighters and military personnel to fight fires. Not so long ago, disposal of AFFF waste via incineration was thought to be a best management practice, with many AFFF waste generators prohibiting disposal of AFFF waste by any other means. However, industry standards are changing, and keeping up with and staying ahead of alternative disposal options can save you money and from future liabilities.
AFFF is a decades-long, relied-upon approach to extinguish fires. It also contains Per- and Polyfluoroalkyl Substances (PFAS) – a group of chemicals negatively harming the environment and are linked to cancers, weakened immune systems and a wide range of health problems in people. Companies and governments have a responsibility to properly dispose of AFFF that contains PFAS.
In a recent memo, the United States Department of Defense (DoD) announced that the National Defense Authorization Act (NDAA) now prohibits the incineration of DoD PFAS materials. This memo from the DoD not only eliminates incineration as an effective disposal method, but the directive also sets a new standard and expectation for others around the country.
Uncovering the issue with incineration – why it has become a cause for concern
PFAS waste management liabilities can be reduced by considering the DoD incineration ban.
How following the DoD’s lead can benefit AFFF waste management decisions
Because of this, it’s important to ask: Does following the lead of the DoD mitigate risks and what are they doing?
What does this mean for other wastes containing PFAS?
Although PFAS wastes are not currently regulated as hazardous waste under the Resource Conservation and Recovery Act (RCRA), managing and disposing of PFAS waste at a permitted hazardous waste disposal facility significantly reduces the long-term waste management liability of AFFF and other wastes containing PFAS.