How to dispose of fire-fighting foams containing PFOS

Find out more about your obligations for planning, managing and disposing of fire-fighting foams containing PFOS, and how we can help.

This guide covers what you need to do to organise the disposal of fire-fighting foams containing PFOS. These foams may be in storage in their original containers, decanted into other containers, or in fire-fighting equipment (including fire trucks).

This guide also covers the materials that come into contact with these foams during their use, storage, handling, collection, transport and disposal, including the rinsing water created while cleaning the equipment exposed to PFOS-containing foams.

This guide does not cover site remediation, for example, where PFOS-containing foams accumulated in soil, or where they spilled or soaked into concrete pads, or where groundwater has been contaminated.

What is the problem with PFOS? Plus

PFOS is a persistent organic pollutant (POP) which was banned for use in New Zealand from 2006 onwards in fire-fighting foams, and from 2011 in all other products. It is harmful in the environment (ecotoxic) and may affect human health after long-term exposure. It is illegal to release PFOS into the general environment in New Zealand. However, some stocks of PFOS-containing fire-fighting foams are still in New Zealand, and these need to be managed safely.

For this guide, the term ‘PFOS’, or perfluorooctane sulfonate, covers all PFOS chemicals: the parent acid PFOS, its salts and all PFOS-related compounds.

Foams containing PFOA, or other PFAS compounds, also need to be managed carefully, and information about this is included later on this page.

Which fire-fighting foams are affected? Plus

Foams manufactured before 2002 by 3M under the Light Water tradename contain PFOS. 3M voluntarily phased out making PFOS-containing foams starting in 2000. If other brands containing PFOS come to our attention, we will update this section.

Note: the foams affected are specialist foams designed for controlling fires involving hydrocarbon fuels, and other flammable liquids. They were used in airports and other facilities handling large quantities of liquid fuels.

PFOS foams were also used in some portable fire extinguishers (in Class B extinguishers for flammable and combustible liquids) but they are not found in household or office fire extinguishers (dry powder and carbon dioxide extinguishers).

What to do if you suspect you have PFOS foam on site Plus

1)     Stop using the foam for testing or training exercises immediately.

2)     Have your fire-fighting foam analysed as soon as possible to find out whether it does contain PFOS, if this is not certain.

3)     If PFOS is confirmed or suspected, ensure it is stored appropriately. There are rules you need to follow for storing fire-fighting foams containing PFOS - including adequate containment, labelling and spill control.

4)     Plan for its disposal.

 

For disposal, does the concentration of PFOS matter? Plus

Yes. When planning for disposal of the affected materials, the rules that must be followed in New Zealand depend on the concentration of PFOS present. These are based on international agreements called the Stockholm Convention and the Basel Convention. If the concentration of PFOS is 50 ppm (parts per million) or greater, the material must be treated as a POPs waste in accordance with these international agreements. Where the PFOS concentration is below 50 ppm (parts per million), the acceptance criteria at receiving landfills and trade waste facilities also apply.

Note: it is illegal to dilute foams or wastewater deliberately to reduce their PFOS concentration to less than 50 ppm to change the disposal criteria. This does not include the incidental dilution that occurs during the course of cleaning contaminated equipment.

Rules for materials with PFOS concentrations above 50 ppm

Materials containing more than 50 mg/kg of PFOS (or 50 ppm) must be stored prior to their environmentally-sound disposal at a specialist site. They must be processed so that they are no longer hazardous.

At present, no facility in New Zealand can dispose of materials with high PFOS content to meet international disposal standards, so they must be exported. This disposal should be undertaken by organisations with the capability to dispose of these products and must be compliant with legislation in the importing country.

These materials include the foams themselves and materials contaminated by the foams.

There are rules for organising the transport, export and disposal of PFOS-contaminated materials. You will need careful handling procedures and a hazardous waste export permit issued by the EPA. Information on how to arrange this is provided below, to ensure you are following New Zealand law.

It is illegal to dump materials containing concentrations of PFOS greater than 50 ppm in landfill or sewerage sites, or in the environment on land or in the water, even if they have been absorbed into an inert material. Never incinerate these products yourself.

See also the ‘Related Content’ section at the end of this page, which gives links to the legislation, for more information.

Rules for materials with PFOS concentrations less than 50 ppm

For solid waste

Landfill sites across New Zealand have strict rules about what they can and cannot accept as waste at their site. Class A landfills might be able to accept PFOS waste below 50 ppm, but check first with the landfill concerned. The acceptance criteria of each landfill are controlled under consents from their regional council.

For liquid waste

Wastewater systems across New Zealand have strict rules about what they can and cannot accept as trade waste into their systems. Acceptance criteria for various types of liquid trade waste are controlled by the local territorial authority. The acceptance criteria are different for each system and the wastewater treatment plant that receives the trade waste. Please check with the wastewater facility. The discharge consents for each wastewater treatment plant are controlled by their regional council.

This scientific report was produced to support wastewater treatment plant operators: 

Disposal of PFAS-containing wastewater to trade waste (pdf 453kb)

 

Planning and organising the disposal Plus

Follow these steps to make sure you follow the rules and stay within New Zealand law as you plan for, and manage the disposal of, high concentration PFOS materials and the materials used during the clean-up. Note also, consider whether it may be more cost-effective to completely dispose of equipment, rather than generate more PFOS-containing waste during the rinsing that is needed for decontamination.

  1. Find a technical expert in hazardous waste management. See our guidance below to see what we look for in technical experts. Contact us if you need further advice on finding a suitable expert.
  2. Arrange for the technical expert to create an end-to-end waste-management plan on your behalf. This plan will record the steps you will take to cease using the foam for emergencies and for the clean-up of your equipment (including foams stored in fire trucks). It will also record the steps for safely collecting, storing, transporting, exporting and disposing of the foam and contaminated materials. We give you more information about what to look for in an expert, and a checklist on what to include in a management plan, in the links below. If you have a mixture of materials that are easier to manage (e.g. PFOS-containing foam sealed within a container) and materials where the removal will be more complex (e.g. PFOS-containing foam in a fire truck), it is acceptable to consult different experts to help produce different sections of the plan.
  3. The company handling the waste should apply to the EPA for a permit to export any waste materials for disposal abroad. PFOS is a persistent organic pollutant (POP) and is defined as a hazardous waste, so a permit is needed to export it. Please be aware that granting a permit to export hazardous waste can take time: before we at the EPA can issue an export permit, we must first have consent from the destination country, and all other countries that the shipment will pass through.
  4. Follow the plan to dispose of the PFOS containing foam and contaminated materials.
  5. For all materials sent overseas for disposal, ensure that a copy of the completed paperwork (the Movement Form) is sent to the EPA once the waste has arrived at its destination and is disposed of. You may need to follow up with the overseas disposal organisation to ensure this happens.   

See a list of what we look for in technical experts (pdf 154KB)

What to include in a waste-management plan for PFOS fire-fighting foams (pdf 161KB)

See our guidance about applying for a permit to export hazardous waste

Please also see our companion guide, which gives additional information and links to the rules for storing foams containing PFOS and PFOA

Any questions? See our contact details at the end of this page.

Disposal of foams containing other PFAS chemicals Plus

This guide focusses on PFOS because it is not approved for use in New Zealand and, at the time of writing, PFOS had been discovered in the fire-fighting foams of some organisations.

PFOS is a member of the PFAS family of about 3,000 chemicals. Some other PFAS chemicals are also present in fire-fighting foams. Some of these are approved for use in New Zealand.

When a fire-fighting foam reaches the end of its useful shelf-life, it too needs careful disposal due to the PFAS content.

Although these are covered by different rules, foams containing PFAS compounds should be disposed of in a similar way to foams containing PFOS. This is because they are likely to be ‘Class 9’ hazardous substances. For more information, please see our companion guide and the links in our ‘Other Resources’ section below.

Please contact us if you have any questions about this. Our contact details are at the end of this page.

Companion guide on managing fire-fighting foams with PFAS, including PFOS and PFOA

Site remediation Plus

This guide does not cover site remediation, for example, where PFOS-containing foams accumulated in soil, or where they spilled or soaked into concrete pads, or where groundwater has become contaminated. We at the EPA do not regulate clean-ups of contaminated property, land or water.

Contact your Regional Council about the rules for site remediation. All investigations need to comply with Ministry for the Environment (MfE) Contaminated Land Management guidelines.

Contaminated Land Management guidelines - Ministry for the Environment website

Any questions? Please contact us Plus

For further information, please contact our Hazardous Substances Compliance team:

Phone: 0800 429 7827 (0800 HAZSUBS)

Email: Hazardous Substances Compliance team

 

For queries about exporting hazardous waste, read the guidance on our website or email us

Exporting hazardous waste

 

For media queries, please get in touch with our media team:

Email: media@epa.govt.nz