Managing fire-fighting foams manufactured with PFAS chemicals

Find out what you need to do if your fire-fighting foam was manufactured using PFAS chemicals, including PFOS and PFOA.

March 2018

You may have heard that we are investigating whether fire-fighting foams held, or in use at, airports and other locations contain the PFAS chemical, PFOS.

PFOS is banned completely in New Zealand, and another PFAS chemical, PFOA, is not approved for use in fire-fighting foams.

This page tells you what you need to do if your fire-fighting foams contain PFOS or PFOA, and the rules for storing and disposing of these materials in general.

Note: this guidance does not apply to home and office fire extinguishers (powder and carbon dioxide extinguishers).

What are PFAS, PFOS and PFOA? Plus

PFAS is a large family of manmade chemicals which have been used in many different types of manufacturing since the 1940s, and in foams since the 1960s. PFOS (perfluorooctane sulfonic acid) and PFOA (perfluorooctanoic acid) are members of the PFAS family of chemicals.

Importing and manufacturing fire-fighting foams containing PFOS or PFOA was effectively prohibited in New Zealand in 2006 (under the Fire-Fighting Chemicals Group Standard).

PFOS is harmful in the environment and may affect human health from long-term exposure. Its use and management is restricted internationally under an agreement called the Stockholm Convention, as it is a persistent organic pollutant (POP).

The use of PFOA (and other PFAS chemicals) is already restricted by many countries around the world. PFOA is now under investigation internationally to see whether it too should be classed as a POP under the Stockholm Convention.

More on PFOS and PFOA in New Zealand - MfE website 

Fire-Fighting Chemicals Group Standard

More information about the Stockholm Convention on POPs - Stockholm Convention website

Which fire-fighting foams are likely to contain PFOS or PFOA? Plus

PFOS was used to make some brands of foam for controlling fires involving liquid hydrocarbon fuels, such as aviation fuel. The manufacture of foams containing PFOS was phased out in the early 2000s. PFOA-related compounds were later used in the manufacturing of some fire-fighting foams, so PFOA may be present in trace amounts in some products.

There may still be some foams containing PFOS being held or in use around the country, including at airports, bulk fuel terminals and other locations which handle large quantities of liquid hydrocarbon fuels.

Please see our Alert on 3M Light Water foams

Note: this guidance does not apply to home and office fire extinguishers (powder and carbon dioxide extinguishers).


How do I know if my product contains PFOS or PFOA? Plus

Ask the supplier or manufacturer of the product whether PFOS or PFOA are likely to be present. You could check the product’s safety data sheet. Be aware that even if you can’t see PFOS or PFOA-related compounds in the list of components, they may be present but listed as a ‘proprietary ingredient’.

For questions about your product, please contact the supplier or the manufacturer.

What should I do if I have a foam containing PFOS? Plus

New Zealand is bound by international rules (under the Stockholm Convention) to ensure that products containing PFOS and other persistent organic pollutants (POPs) are managed safely. The EPA has given directions for managing and disposing of POPs in New Zealand in the Gazette Notice: Hazardous Substances (Storage and Disposal of Persistent Organic Pollutants).

This section summarises the rules you need to follow. 

The rules for storing fire-fighting foams containing PFOS

Products containing PFOS may be held, pending environmentally-sound disposal, as long as they are stored safely. It must not be used for training, testing, fighting fires or released into the environment.

Products containing PFOS must be stored safely in containers that are located in buildings or places that:

  • are secure and suitable for the amount of material being stored
  • have adequate moisture control, ventilation and facilities for spill containment
  • minimise the risk of contamination of people, animals, crops and the environment
  • minimise the risk of contamination following fire, flood or other natural disaster, such as an earthquake

Do not mix different types of persistent organic pollutants together, or with other substances, in one container. These rules apply to all persistent organic pollutants (POPs) in New Zealand. 

Disposing of fire-fighting foams containing PFOS

Products containing PFOS must never be dumped in landfill or sewerage sites, or in the environment on land or in the water, even if they have been diluted or absorbed into an inert material. Never incinerate these products yourself.

To dispose of PFOS, the product and its container must be exported as waste for environmentally-sound disposal at a specialist site in another country. This is because products containing PFOS must be processed so that they are no longer a persistent organic pollutant (POP) and are no longer hazardous. This must be undertaken by organisations with expertise in disposal of these products. At present, there is no facility in New Zealand that can dispose of PFOS to meet international disposal standards, so they must be exported.

There are strict New Zealand and international rules to follow for collecting, transporting and exporting these products, which are underpinned by various pieces of national and international legislation. In New Zealand, you must follow the Health and Safety at Work (Hazardous Substances) Regulations for handling and tracking.

To export products containing PFOS for disposal, you will need to:

  • apply for an export permit from us under the Basel Convention (an international waste disposal agreement)
  • ensure that the rules for importing the PFOS into the destination country for disposal are met under the Basel Convention
  • for sea transport, comply with the Maritime Rules: part 24A – Carriage of Cargoes – Dangerous Goods and the International Maritime Dangerous Goods Code.

Apply for an export permit under the Basel Convention from the EPA

Hazardous Substances (Storage and Disposal of Persistent Organic Pollutants) Notice 2004

Health and Safety at Work (Hazardous Substances) Regulations 2017

Basel Convention Technical Guidelines for PFOS

Basel Convention Technical Guidelines for POPs

See our companion guide: How to dispose of fire-fighting foams containing PFOS

Managing fire-fighting foams containing PFAS chemicals (other than PFOS) Plus

All products containing PFAS chemicals, including PFOA-related compounds must be managed in line with the directions in the Fire Fighting Chemicals Group Standard, the Hazardous Substances (Hazardous Property Controls) Notice and the Hazardous Substances (Disposal) Notice.

To meet these requirements, foams containing PFAS should be disposed of in the same way as foams containing PFOS. This is because they are likely to be Class 9 hazardous substances in relation to the Hazardous Substances (Disposal) Notice.

Fire Fighting Chemicals Group Standard 2017

Hazardous Substances (Hazardous Property Controls) Notice 2017

Hazardous Substances (Disposal) Notice 2017

Health and Safety at Work (Hazardous Substances) Regulations 2017