Extension of Class B PFAS Firefighting Foam Use

PFAS-Containing Firefighting Foam Ban

An Act Concerning the Use of PFAS in Class B Firefighting Foam
Federally Required Exemptions at Airports and Military Installations
Fluorinated Foam Use Extensions at Terminals and Chemical Plants

An Act Concerning the Use of PFAS in Class B Firefighting Foam

Public Act 21-191, An Act Concerning the Use of PFAS in Class B Firefighting Foam, effective July 13, 2021, implemented a phased ban of the use of firefighting foams containing intentionally-added per- and polyfluoroalkyl substances (PFAS). These foams are typically used for extinguishing Class B flammable liquid and petroleum hydrocarbon fires. Common labels for these foams include AFFF, AR-AFFF, FFFP, AR-FFFP, FP, and FPAR (“Fluorinated Foam”). The Fluorinated Foam ban was rolled out in phases:

Beginning July 13, 2021, the law banned the use of fluorinated foams for training or testing systems.
Beginning October 1, 2021, the law banned all remaining uses of fluorinated foams. Airports and those federally required by law to use such foams were excluded. Chemical plants, oil refineries, and flammable liquid terminal, storage, or distribution facilities were eligible to apply to DEEP for an extension, up to two years, in order to comply with the law.
Beginning October 1, 2023, the law banned airports, unless required by the federal government, from continuing to use fluorinated foams.
Federally required uses will continue to be allowed in Connecticut until prohibited by Federal law or one year after Federal law changes to no longer require such use.

Public Act 21-191 also required DEEP to identify suitable alternative fluorine-free firefighting foam(s) and authorized the State to organize a municipal AFFF "take-back" program. To learn more, visit the Reducing and Preventing Releases of PFAS-Containing Firefighting Foam webpage.

Federally Required Exemptions at Airports and Military Installations

The federal government has historically required certain entities, including military installations and FAA-certified airports, to utilize fluorinated firefighting foams.

The passage of Public Act 21-191 mandated that in the event that federal law no longer requires, but does not prohibit, the use of fluorinated foam, current federally required users in Connecticut will have one year to cease use of such foams. In the event that federal law changes to prohibit the use of such foams, any such entities in Connecticut will be required to immediately cease use of fluorinated foam.

The following are significant federal AFFF-related developments that affect Connecticut airports and military installations:

On March 18, 2024, the Federal Aviation Administration (FAA) issued CertAlert 24-04 to part 139 airports recommending the Department of Defense (DOD) aircraft rescue and firefighting (ARFF) apparatus foam change out guidance.
On March 5, 2024, Department of Defense (DoD) released a memo outlining guidance for changing out foam in aircraft rescue and firefighting (ARFF) apparatus. DOD recommendation is to drain the apparatus, rinse any AFFF-contaminated components, and refill with a DOD-approved fluorine-free foam.
On September 19, 2023, the FAA notified Part 139 airports and industry that there is now at least one fluorine-free foam (F3) that meets DoD’s new military performance-based specifications. The foam is approved, but not required, for use at FAA-certified airports. FAA has messaged that it is acceptable for airports to use both AFFF and F3 until an airport is able to fully transition over to F3.
On May 18, 2023, the Naval Research Laboratory published Fluorine-Free Foam (F3) Application Techniques and Firefighting Tactics.
On May 8, 2023, the Federal Aviation Administration (FAA) coordinated with the Department of Defense (DoD), the U.S. Environmental Protection Agency (EPA) and industry partners to produce the Aircraft Firefighting Foam Transition Plan to assist airports with transitioning to fluorine free foams (F3).
On January 6, 2023, the Department of Defense (DoD) released a new military specification (MIL-PRF-32725) outlining performance-based standards for fluorine-free foam (F3) liquid concentrate fire extinguishing agents intended for use on class B hydrocarbon liquid fuel fires in land-based applications. The specification is approved for use by all DoD departments and agencies.
On December 20, 2019, the National Defense Authorization Act (NDAA) for Fiscal Year 2020 was signed into law, requiring DoD to immediately stop training with AFFF and, with limited exceptions, to phase out overall use of AFFF at military locations by September 30, 2024. To achieve this goal, the NDAA also requires that DoD stop purchasing firefighting foam that contains detectable levels of PFAS for land-based use by October 1, 2023.

A list of DoD approved F3 products can be viewed by searching the Qualified Products Database.

Fluorinated Foam Use Extensions at Terminals and Chemical Plants

Pursuant to PA 21-191, Sec. 1(b)(5) (CGS Sec. 22a-903a), chemical plants, oil refineries, and flammable liquid terminal, storage, or distribution facilities were eligible to apply to DEEP for an extension in order to comply with the law. Submission of a Request for Extension of Class B PFAS Firefighting Foam Use Form was required to request any such extension. The request needed to clearly (a) specify in the filing why such an extension is necessary and (b) indicate what containment, treatment, and disposal measures were to be employed to prevent releases of PFAS-containing class B firefighting foam into the environment until compliance could be achieved. Upon review of extension request materials, DEEP granted an extension of up to two years if it was determined that such extension was necessary to remove or repurpose a fire suppression system containing such foam.

The following tables show the PFAS Firefighting Foam extensions granted by DEEP.

All remaining approved extensions expired on October 1, 2023; release of AFFF after October 1, 2023 may therefore result in enforcement action by DEEP.

Owners of systems that self-reported to DEEP that they have converted to fluorine free foams (F3), or otherwise transitioned away from AFFF use, during the extension period are designated "Complete" in the "Facility-Reported Status" column of the tables below. Those facilities with an "In Progress" conversion status have communicated to DEEP that efforts are still underway to remove AFFF from their fire suppression systems.

Approved AFFF Use Extensions: Licensed Marine Terminals

Name	Address	Town	Facility-Reported Status
GB II Connecticut	1 Atlantic St.	Bridgeport	Complete
Global Companies	1 Eagles Nest Rd.	Bridgeport	Complete
Inland Fuel Terminals	154 Admiral St.	Bridgeport	Complete
Sprague Operating Resources	250 Eagles Nest Rd.	Bridgeport	Complete
New Haven Terminal	119 Frontage Rd.	East Haven	Complete
Buckeye PT Terminals	85 East St.	New Haven	Complete
Buckeye PT Terminals	134 Forbes Ave.	New Haven	Complete
Buckeye PT Terminals	280 Waterfront St.	New Haven	Complete
Gateway	400 Waterfront St.	New Haven	Complete
GB II	600 Connecticut Ave.	New Haven	Complete
Gulf Oil Limited Partnership	500 Waterfront St.	New Haven	Complete
New Haven Terminal	100 Waterfront St.	New Haven	Complete
Safety-Kleen	120 Forbes Ave.	New Haven	Complete
Shell Oil	481 East Shore Pkwy.	New Haven	Complete

Approved AFFF Use Extensions: Chemical Plants and Non-Marine Terminals

Name	Address	Town	Facility-Reported Status
Orafol	120 Darling Dr.	Avon	Complete
Kaman	50 Old Windsor Rd.	Bloomfield	Complete
Greenfield	58 Vale Rd.	Brookfield	Complete
Bedoukian	6 Commerce Dr.	Danbury	In Progress
RSA	36 Old Sherman Tpke.	Danbury	Complete
Pratt & Whitney	400 Main St.	East Hartford	Complete
Pratt & Whitney	1 Aircraft Rd.	Middletown	Complete
Devon Power	700 Naugatuck Ave.	Milford	Complete
King Industries	1 Science Rd.	Norwalk	Complete
Citgo	109 Dividend St.	Rocky Hill	Complete
Allnex	528 S Cherry St.	Wallingford	Complete
Global	80 Burbank Rd.	Wethersfield	Complete

Contact Information

For questions related to the foam ban, contact the State Fire Administrator at Foam.Survey@ct.gov.

For questions related to a fluorinated foam ban extension, email DEEP.MarineTerminals@ct.gov.

For general PFAS questions and information email DEEP.PFAS@ct.gov.

Related Webpages

Content last updated March 28, 2024.

Connecticut Department of Energy & Environmental Protection