ARFF & Recovery: Limitations in labelling

Mike Willson, Managing Director of Willson Consulting, asks whether firefighting foam warning labels actually deliver the accuracy and value we expect

There has been much discussion in the past about warning labels on foam drums. Do they create confusion, fear, or even prevent usage when the correct foam application could be highly beneficial? Sometimes problems arise; the labels themselves may bleach out, fall off or lead us into a false sense of security. They could even make us complacent by encouraging more usage than is really necessary or inadequate disposal, which may be harmful to our environment.

The UK Civil Aviation Authority (CAA) is proposing a new Qualified Products Listing (QPL) and environmental impact warning labelling system for firefighting foams, but does this deliver the best way forward?

There are concerns that product labels will not be comparable because variable toxicity test species are permitted, LC50 or EC50 data can be used, key legislative exemptions are omitted, latest science supporting C6 fluorotelomer surfactants has been ignored and implications that fluorine-free foams (F3) can somehow be treated differently seem incorrect, when all foam types have significant environmental impacts with the potential to pollute1. Important consideration of a foam type’s suitability for a specific application and location, fire performance capabilities, fuel pick-up problems, user safety aspects, and erosion of the ICAO Level B fire test also seem to be ignored.

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