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Alternative Assessments Project Summary: The Case Example of AFFF

Advancing Alternatives Assessment and Informed Substitution for Chemicals of Concern 

Given increasing environmental and health concerns about the widespread use of aqueous film forming foam (AFFF) as a fire-fighting agent, the purpose of this research effort is to improve the ability of the Department of Defense (DoD) to make informed, efficient choices on non-fluorinated AFFF alternatives by strengthening and building consistency in the approaches used to identify, compare, and adopt alternatives. The project will serve as a model for addressing future chemical and material challenges. The research is not focused on development of a particular technology or alternative, but rather on methodological developments in alternatives assessments that focus on the evaluation of AFFF alternatives to ensure the availability and adoption of high-performing, safer, and more sustainable chemical products and processes.   

Project Objectives: 

  • Understand gaps to completion of a comprehensive alternatives assessment for AFFF by reviewing existing assessments;  
  • Develop generalizable approaches and guidance for defining a “safer” non-fluorinated AFFF alternative as well as determining “adequate” and “fit for purpose” performance for such alternatives, that can strengthen future alternatives assessments; and  
  • Understand lessons learned from existing efforts to accelerate development, commercialization, and adoption of safer alternatives to AFFF, including barriers and enabling factors. 

 Primary Research Questions: 

  1. Are existing evaluations and scoping studies for non-fluorinated AFFF alternatives sufficient to determine safer, high-performing alternatives, and what modifications/additions are needed to those assessments so they meet a “minimum” standard for the DoD and other users to be confident in the viability/safety of alternatives? 
  2. What are the criteria for defining a “safer” non-fluorinated AFFF alternative? 
  3. What constitutes “adequate” or “sufficient” performance non-fluorinated AFFF alternatives and can this be varied depending on the performance needs of a particular application (“fit for purpose” performance)?  
  4. What critical technology, market or policy factors holding back or accelerating development and adoption of safer, high performing non-fluorinated alternatives to AFFF? 
  5. What can be learned from DoD’s current effort to accelerate development of safe and effective AFFF alternatives that can improve the efficacy of efforts to address future materials challenges. 

The long-term goal of the Lowell Center for Sustainable Production (LSCP) at the University of Massachusetts Lowell’s initiative in partnership with the Northeast Waste Management Officials’ Association (NEWMOA) and the Toxics Use Reduction Institute (TURI) is to strengthen and expand the use of alternatives assessment methods, including consideration of performance and adoption. This will build sustainable capacity and infrastructure for the field of alternatives assessment to better government and industry in making informed choices to accelerate the adoption of high performing, safer, and more sustainable chemicals, products, and processes. AFFF alternatives will be used as a case study to support this goal and to further the DoD specific objectives around safe and effective fire-fighting foams.   

The timeline for this project is November 2020 – October 2021.  


Activity 1. Critical review of gaps in existing assessments of alternatives to AFFF. A systematic alternatives assessment is a critical approach to improve the selection of safer and feasible alternatives and reduce the possibility of regrettable substitutes. Through literature reviews and outreach with experts in the field, the LCSP team will identify and evaluate governmental and non-governmental assessments that have been conducted to date regarding primarily fluorine-free AFFF alternatives. We will compare these evaluations and assessments to the baseline components of a systematic alternatives assessment (using the National Research Council (2014) and Interstate Chemicals Clearinghouse’s (IC2) (2017) frameworks as a guide). The intention of this review is to understand the strengths and weaknesses of existing alternatives assessments to date on fluorine-free alternatives to AFFF paying attention to methods used, endpoints addressed, and how issues of uncertainty and data gaps were addressed. Based on this evaluation we will identify understandings to date and/or gaps that are needed to be filled in order to complete a sufficient, comprehensive evaluation of fluorine-free alternatives to AFFF.

We will publish the results of the review of existing assessments on alternatives to AFFF, including an analysis of lessons learned, as a concise report that will serve as the basis for discussion on additional needs in evaluating AFFF alternatives. We will use this assessment as the starting place for a deeper evaluation of methods and criteria used specifically in determining “safer” AFFF alternatives and “sufficient” and “fit for purpose” performance that will be undertaken in Activity 2.   

Activity 2. Develop approaches to define “safer” and address performance in alternatives assessments of AFFF. Most alternatives assessments to date do not have clear criteria of what is a safer alternative. Alternatives assessment frameworks outline what hazard criteria should be evaluated, however there is no agreed upon standard for determining a “safer” alternative. Is an alternative safer if there is lower hazard for persistence, but higher hazard for reproductive toxicity?  Indeed, the current MILSPEC for AFFF only lists two toxicological criteria for evaluating alternatives – aquatic toxicity and persistence. Lack of clarity of what is “safer” could lead to regrettable substitutions.  Performance is also a critical element in the adoption of safer alternatives, and both DoD and manufacturers have been evaluating performance and developing performance specifications and criteria for decades. However, there has been little effort to develop high-level, standard approaches for this element in the alternatives assessment process that address both the question of “sufficient” performance for non-fluorinated AFFF alternatives (given they are unlikely to meet the level of performance of fluorinated counterparts) and “is that level of performance needed for all applications”. We will address the “safer” and “sufficient performance/fit for purpose” elements through the following approaches: 

  1. Determining “safer”.  We will undertake a review of existing hazard assessment methodologies to understand what endpoints and processes are used to determine a “safer” alternative. We will review toxicological assessments of AFFF alternatives, including the GreenScreen® Certified criteria to understand what endpoints have been evaluated and how safer has been defined in the context of these assessments.  Based on this, and a recent approach presented to the OECD Ad Hoc Working Group on the Substitution of Harmful Chemicals, we will develop an approach and set of criteria for determining “safer” AFFF alternatives that can be adaptable to examining future chemicals challenges.
  2. Determining “sufficient” and “fit for purpose” performance.  We will conduct a literature review to evaluate performance evaluation approaches in existing alternatives assessment methods and studies in order to understand best practices in performance assessment.  We will review existing standards for AFFF for military and non-military applications as well as existing performance evaluations of non-fluorinated AFFF alternatives.  In doing this we will examine commonalities and differences (much of this is captured in the IC2 analysis) in understanding essential performance criteria. We will then convene experts from various standards bodies to understand what are the most important parameters for testing and given limitations of non-fluorinated alternatives what is “sufficient” performance, additional parameters necessary for demonstrating technical feasibility, and whether there are differences in performance needs depending on scenario (or if certain performance is even necessary), and what technological or systems design changes could be made to meet performance goals.  The goal of this discussion is to develop a “fit for purpose” approach to sufficient performance of AFFF alternatives that can help inform future MILSPEC development and R&D.   

We will use this work to develop draft guidance for the performance assessment element of alternatives assessment that can address considerations of “fit for purpose” and “sufficient” performance and how differences in performance needs across applications can be addressed in a systematic manner in alternatives assessments that could be used as a model for other chemical functions/ applications 

 Activity 3. Develop an understanding of lessons learned from actions to drive development and adoption of AFFF alternatives, including barriers/challenges. The defense and non-military communities require sufficient quantities of high-performing AFFF alternatives. The DoD and others have committed significant resources to develop, evaluate and adopt high performing AFFF alternatives. Understanding the actions that have been taken and barriers to the development and adoption of AFFF alternatives (including cost, changes in technology, sufficient supply, etc.) can provide an enhanced understanding of the barriers and success factors that facilitate and accelerate the transition to safer chemistry. Learning from a case of significant investment in development and adoption of alternatives can help build an approach to more effective action in the future. 

To understand lessons learned as well as barriers and enablers for development and adoption of safer non-fluorinated AFFF alternatives we will interview a representative sample of experts from DoD and branches of the military, experts in fire evaluation, and companies and researchers working on alternatives to understand the evolution of DoD’s efforts including successes/limitations of activities to date. We will also develop a more nuanced understanding of the barriers and accelerators to development and adoption of safe and effective AFFF substitutes, including policy, technology, research, and information limitations.  We will also identify 2-3 cases internationally that involve both new technology development (e.g., a new potentially safer, high-performing alternative) and existing technologies to explore barriers and enablers for both development and commercialization of AFFF alternatives as well as adoption.  

The results and lessons learned from the analyses will be written up in a concise report that outlines an approach for DoD and others to take to expedite informed action on future chemicals/materials of concern.  The draft report will also include a section derived from the case examples on effective government policies and market strategies to accelerate the development and adoption of safer AFFF alternatives.  (current link) 

 Better to use this link when available: 

DOD SERDP link: PRODUCTS” on the right 

Scaling Adoption of Alternatives to Per- and Polyfluoroalkyl Substances (PFAS) in Aqueous Film- Forming Foams (AFFF): Lessons Learned on Needs and Opportunities (2022)
Download: Report 

Guidance for Evaluating the Performance of Alternatives: Fit-for-Purpose Performance (2022)
Download: Report 

A Critical Review of Alternatives Assessments of Fluorine-Free Alternatives to Per- and Polyfluoroalkyl Substances in Aqueous Film-Forming Foams (2022)
Download: Report 

Criteria for Safer: Alternatives to Aqueous Film Forming Foam Products (2022)
Download: Report 

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Alternatives Assessment

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