Per- and polyfluoroalkyl substances and aqueous film-forming foam used in firefighting

Firefighting foams containing per- and polyfluoroalkyl substances (PFAS) are designed to extinguish Class B fires during emergencies, such as those involving flammable and combustible liquids, petroleum greases, tars, oils and gasoline, solvents, and alcohols. PFAS-based surfactants help to cut off the oxygen from the fire by contributing to the formation of a foam blanket and, more notably, a water film that glides over the surface of the burning liquid. These foams are mainly used by municipal fire services, in civil and military aviation, and in the chemical and oil industries, but can also be used to respond to fires in other industrial settings.

Aqueous film-forming foam (AFFF) is the most widely used and available of these foams and, for this reason, PFAS-containing firefighting foams are often simply referred to as AFFF. There are, however, other types of these foams with slightly different compositions used in specialized applications, such as alcohol-resistant AFFF (AR-AFFF) for polar solvents, or film-forming fluoroprotein foam (FFFP) and fluoroprotein foam (FP) for an added burn back resistance for deeper pool fires.

This information was prepared for reference only and includes some examples of actions and resources provided for guidance purposes only. This information is not to be understood as a legal document and does not supersede or modify any act, regulations or legal obligation, including an obligation to comply under any instruments referred to under the Canadian Environmental Protection Act, 1999 (CEPA). Links to external resources are provided for information purposes only and they do not constitute an endorsement or approval.

The Government of Canada has already acted on certain subgroups of PFAS that were determined to be toxic under CEPA. These include the following subgroups, which were added to Schedule 1 to CEPA and are regulated under the Prohibition of Certain Toxic Substances Regulations:

• perfluorooctanoic acid, its salts and its precursors (PFOA),
• long-chain perfluorocarboxylic acids, their salts and their precursors (LC-PFCAs); and
• perfluorooctane sulfonate, its salts and its precursors (PFOS).

On March 5, 2025, the Government of Canada published the State of PFAS Report, which concluded that the class of PFAS, excluding fluoropolymers, is toxic under CEPA. An associated Risk Management Approach for PFAS, excluding fluoropolymers, was also published and outlines the proposed risk management actions under consideration through a phased prohibition. 

The Government of Canada is continuing to take actions to address the class of PFAS to help protect human health and the environment, including by:

• Proposing regulatory actions to further restrict PFOA, LC-PFCAs, and PFOS. These actions will lead to a complete phase out the use of PFOA and LC-PFCAs in firefighting foams. 
• Proposing to take new risk management actions to restrict through regulations the use of PFAS, excluding fluoropolymers, not currently regulated in firefighting foams, which include those used to replace PFOA, LC-PFCAs, and PFOS.

Not all firefighting foams contain PFAS, but, when in doubt, it is best to assume that all products marked as “AFFF,” “AR-AFFF,” “FP” or “FFFP” contain PFAS. Other good indicators that a firefighting foam contains PFAS is if its ingredients or label include the term “fluorinated surfactants,” “fluorosurfactants,” “fluoroprotein,” “C6,” or “fluoro.”

It is not always easy to determine the type of PFAS an AFFF contains. PFAS may be listed as a proprietary ingredient or a trade secret on safety data sheets (SDS). They may also be present in concentrations too low to be reported.

Contacting the foam manufacturing is most often how to learn the type of PFAS an AFFF contains. AFFF can also be tested in a laboratory with a method that also screens for precursors, such as fluorotelomer-based substances. The total oxidizable precursor (TOP) assay is an example of this type of method.

AFFFs are typically sold as concentrates to be mixed with water in ratios of 1%, 3%, or 6% (concentrate/water). They are frequently divided into three categories depending on the type and/or composition profile of the PFAS they contain.

C8 AFFF is restricted in Canada through regulations, with a limited number of exemptions to accommodate the transition to alternatives to PFOA and/or LC-PFCAs. It is a fluorotelomer-based AFFF formulated with surfactants that include PFOA and/or LC-PFCAs. Most major firefighting foam manufacturers stopped producing C8 AFFF by 2016 in response to voluntary actions on PFOA and LC-PFCAs in Canada and the United States.

C6 AFFF is not currently prohibited in Canada. It is a fluorotelomer-based AFFF formulated with PFAS that have shorter perfluorinated carbon chains than the prohibited PFOA and LC-PFCAs. C6 AFFF is often labelled as “C6,” or even sometimes incorrectly as "PFAS-free," to show it’s different from older C8 AFFF. Many major foam manufacturers have either stopped production of C6 AFFF or are stopping due to growing concerns about PFAS. Canada is proposing to place restrictions on C6 AFFF as outlined in the section Next steps for PFAS in AFFF.

PFOS-based AFFF has been completely prohibited in Canada through regulations since the end of 2013, but there are still a few exemptions to accommodate for residual levels of PFOS in firefighting equipment. The main manufacturer of this type of foam discontinued its production in 2001. “Light Water” is a common product name used for this type AFFF. Due to long AFFF shelf lives, this legacy AFFF may still be present in inventories.

The Prohibition of Certain Toxic Substances Regulations, 2012 (the Regulations) restrict the use, sale, offer for sale and import of PFOA, LC-PFCAs and PFOS, and products containing them. They include time-limited exemptions for critical uses of AFFF containing PFOA and/or LC-PFCAs to allow for the transition to alternatives, as well as exemptions to accommodate for persistent residual levels of these substances that remain in fire-fighting equipment from their prior use.

On May 14, 2022, the Government of Canada has published a draft proposed Prohibition of Certain Toxic Substances Regulations, 2022, which would repeal the current Regulations and would further restrict the use, sale and import of C8 AFFF and PFOS AFFF, by removing or providing time limits for most remaining exemptions. The final Regulations are expected to be published in the Canada Gazette, Part II, in 2025, and are to come into force six months after that.

The restrictions on PFOA, LC-PFCAs or PFOS do not apply to substances that are incidentally present and/or below certain maximum concentration thresholds.

The Prohibition of Certain Toxic Substances Regulations, 2012 include incidental presence exemptions for the following: 

• the use of AFFF that contains residual levels of PFOS at a maximum concentration of 10 ppm.
• the use and import of AFFF contaminated with PFOS in a military vessel or military firefighting vehicle returning from a foreign military operation.

When no quantitative threshold applies, such as for PFOA and LC-PFCAs in AFFF, the incidental presence of a substance is generally qualitatively understood for the purpose of the Regulations to be:

• a residual, trace contaminant or impurity that was not intentionally added to the formulation.

The section on Reuse firefighting equipment further below explains how the incidental presence exemption applies when firefighting equipment is being reused as part of a transition to alternatives.

The Risk Management Approach for PFAS, excluding fluoropolymers, lays out the Government of Canada's proposal to phase out of C6 AFFF through regulations. Timelines are to be determined and to be informed by public consultations. These actions would lead to the prohibition of all known remaining use of PFAS not currently regulated in firefighting foams and are meant to be complementary to other existing controls, such as those under the Prohibition of Certain Toxic Substances Regulations.

Key publications for the development of these regulations are planned as follow:

Summer/Fall 2025

• Consultation document to inform a proposed instrument for a minimum 60-day public comment period.

Spring 2027

• Consultation on a proposed instrument for a minimum 60-day public comment period.

At the latest 18 months after proposed instrument

• The final instrument is to be published.

These are planned timelines and are subject to change.

There are now many alternatives to AFFF, including foam, such as fluorine-free firefighting foams (F3 or SFFF), and non-foam fire suppression systems, such as encapsulator agents. Fluorine-free alternatives should not be considered as "drop-in" PFAS-free alternatives to AFFF. They often require firefighters to adjust their application techniques with these alternative foams, as well as their firefighting tactics.

The Government of Canada does not specify which alternatives should be used. It is up to AFFF users to find and use the appropriate alternatives for their fire-fighting needs.

When choosing alternatives to C8 AFFF, keep in mind that C6 AFFF will likely be subject to future restrictions as outlined in the section Next steps for PFAS in AFFF.

PFOA, LC-PFCAs and/or PFOS may be found as impurities in C6 AFFF due to their unintentional production or release during the manufacture of other PFAS or in other industrial processes. The incidental presence exemption in the Regulations is meant in part to accommodate their potential presence in C6 AFFF because of these processes.

PFAS can be found as contaminants left over in fire-fighting system equipment because of past uses of foams containing these substances. These contaminants are known to be slowly released from the surfaces of equipment over time. This type of contamination is known as the "rebound effect." 

While rebound is difficult to eliminate, it is important to limit it by using a suitable decontamination method that only leaves trace levels of the prohibited PFAS. The incidental presence exemption in the Regulations aims to accommodate these residual levels of PFOA, LC-PFCAs and/or PFOS that persist in the equipment.

The Government of Canada does not specify which decontamination methods should be used to reach trace levels of contamination. It is up to AFFF users to find and use the appropriate methods for their fire-fighting applications. External resources like the AFFF Phase Out Transition Manual - arctic-council.org or the article Is Decontamination of PFAS From Fire Suppression Systems Required? can help with choosing the best fitting decontamination method. While testing for rebound in a laboratory after decontaminating, make sure to wait long enough for any remaining substances to be released from the equipment and to use a testing method that also screens for the precursors.

Since PFAS used in AFFF pose a risk to the environment and human health, it is important to use the best practices and available technologies throughout the entire life cycle of these substances to avoid releases to the environment and exposure to these harmful chemicals.

AFFF should only be used in emergency situations where a significant Class B fire hazard exists. You should follow proper procedures to prevent any environmental release, even during emergencies. Appropriate safe handling and storage practices should also be used to reduce occupational exposure to PFAS used in AFFF.

Avoid using AFFF for training; instead, use training foams designed to mimic AFFF but without PFAS.

When testing your firefighting systems containing AFFF, make sure to contain and dispose of all releases produced in an environmentally sound manner.

AFFF should be taken to an authorized hazardous waste management facility for disposal. In Canada, provinces and territories have jurisdiction over the approval, licensing, and monitoring of waste management operations, as well as establishing programs to divert waste from disposal. Contact your provincial or territorial authorities to find the appropriate facility for safe disposal.

The Basel Convention has adopted technical guidelines on persistent organic pollutants (POP) wastes, which provide guidance on their environmentally sound management, including how to dispose of them properly. For further information on this, please refer to the General technical guidelines on the environmentally sound management of wastes consisting of, containing, or contaminated with persistent organic pollutants - Basel.int.

External resources like the AFFF Phase Out Transition Manual - arctic-council.org, the PFAS Technical and Regulatory Guidance Document: Firefighting Foams - itrcweb.org or the Best Practice Guidance for Fluorinated Firefighting Foams - fffc.org can also help with determining best practices with AFFF, such as, in terms of foam selection, foam transition, containment and elimination of foam discharge, and disposal of foam and firewater.

• Class of per- and polyfluoroalkyl substances (PFAS)
• Risk Management Approach for Per- and Polyfluoroalkyl Substances (PFAS), excluding fluoropolymers
• Prohibition of Certain Toxic Substances Regulations, 2022 [Proposed]
• Prohibition of Certain Toxic Substances Regulations, 2012: overview
• Per- and polyfluoroalkyl substances (PFAS) and your health
• Canada's approach on chemicals substances
• Compliance and Enforcement Policy for CEPA
• Export of Substances on the Export Control List Regulations
• National Framework on Cancers linked to Firefighting
• Exemptions to the Canadian Aviation Regulations for fluorine-free foam
• Department of National Defence Firefighting Foam Transition

For general questions on activities on the class of PFAS, please contact the Substances Management Information Line:

Email: substances@ec.gc.ca

Telephone:  

• 1-800-567-1999 (Toll Free in Canada) 
• 1-819-938-3232 (Outside of Canada)

For questions on the Prohibition of Certain Toxic Substances Regulations and the groups of PFAS that are prohibited:

Email: interdiction-prohibition@ec.gc.ca