POLICY FOR THE PREVENTION AND MANAGEMENT OF
POLLUTION FROM AQUEOUS FILM FORMING FOAM
(AFFF)
Version 1.0; June 2014
Purpose
The purpose of this policy is to ensure that pollution of the natural environment by Aqueous
Film Forming Foam (AFFF) is prevented. This will be achieved by prescribing measures to
achieve a zero release management system in accordance with the precautionary principle.
The AFFF Defence National Environmental Standard (DNES, to be read in conjunction with
this Policy) stipulates the minimum performance requirements to achieve a zero release
management system and the monitoring and reporting requirements.
This policy applies to all Defence Establishments where AFFF is stored or used. This policy
does not apply to the use of AFFF in emergency response where the safety of life and materiel
must be maintained before consideration is given to environmental impact. Emergency
response AFFF releases must be reported in accordance with the DNES requirements.
Where full compliance with this policy cannot be assured, alternative methods must be
proposed and endorsed by the Technical Authority, the Assistant Secretary Engineering and
Environment.
NOTE: This policy and the guidelines that have been specified must not be used for the
assessment of site contamination. Guideline levels are stipulated to define the presence
or absence of AFFF pollution only.
Background
AFFF is a water based fire fighting surfactant containing straight chain fluorinated
hydrocarbons that separate fuel from oxygen, suppressing the combustion reaction. AFFF
substances are toxic and persistent in the environment and are hazardous to human health.
AFFF includes but is not limited to the following substances:
 Perfluorooctanesulfonic acid (PFOS)
 Perfluorooctanoic acid (PFOA)
 Perfluorobutyric acid (PFBA)
 Perfluorobutanesulfonic acid (PFBS).
This Policy does not differentiate between different AFFF substances or products currently in
use and obsolete stock still in inventory; all AFFF substances regardless of type or origin are
covered by this Policy.
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For the purposes of this policy, the following definitions of pollution apply:
 A Pollution Event is an uncontained release of AFFF into the natural or built
environment that has the potential to cause environmental harm
 A Contained Release is any event where AFFF discharge is present in the
environment in such a manner so as not to have pollution potential e.g. fully contained
within a concrete proving ground or similar containment.
Regulatory Requirements
Legislation - Defence must comply with the Environment Protection and Biodiversity
Conservation Act 1999 (EPBC Act) to prevent significant environmental impacts and must act
to prevent impacts upon Matters of National Environmental Significance (MNES). Where
Defence activities have resulted in pollution of a state regulated environment, Defence must
comply with the relevant State or Territory environmental legislation and regulations.
Defence is also bound to implement all National Environmental Protection Measures (NEPM)
(as amended at 2013) enacted by the Standing Committee on Water and the Environment
(SCEW).
AFFF Pollution Guidelines –Defence has adopted the Minnesota Department of Health
(MDH) Health Risk Limits (HRL) and Health Based Values (HBV) for PFOS, PFOA, PFBA
and PFBS in water and the Minnesota Pollution Control Agency (MPCA) soil screening
criteria. These are interim guidelines and must be updated when more appropriate nationally
recognised guidelines become available. These guidelines are only to be used for determining
if AFFF pollution is present or absent. They must not be used for the assessment of site
contamination (i.e. after AFFF pollution has been confirmed), for which derived site specific
investigation levels are required. For site specific investigation levels please refer to the
Directorate of Environmental Remediation Program (DERP).
Responsibilities
Authority - The Assistant Secretary Engineering and Environment (ASEE) is the Technical
Authority for infrastructure engineering and environmental policy in Defence.
Implementation – The Senior Australian Defence Force Officer (SADFO) and Base Support
Manager (BSM) at each Defence Establishment are responsible for the implementation of this
policy at the site level. Senior Environmental Managers (SEM) and Regional Environmental
Officers (REO) shall facilitate and advise on the implementation of the policy.
Management of AFFF Fire Fighting Systems
AFFF pollution prevention on the Defence Estate must aim to achieve zero environmental
release and must follow the precept of Prevention, Preparedness, Response and Recovery. The
following requirements are mandated as the minimum to achieve AFFF pollution prevention:
1. All relevant Defence Establishments must develop a zero environmental release AFFF
Management System. This means that, with the exception of emergency response, no
AFFF is to be released into the natural environment under any circumstances. This
Management System must also address the full life cycle management of AFFF from
procurement to disposal
2. All relevant Defence Establishments must ensure that AFFF system operability testing
does not result in a Pollution Event
3. All relevant Defence Establishments must have in place an AFFF Pollution Response
and Recovery Plan to satisfy the requirements for pollution response as per the DNES
requirements
4. All relevant Defence Establishments must ensure that only approved AFFF products
are ordered, held and used in accordance with the requirements of DEF (AUST) 5706.
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Defence Establishments in possession of superseded inventory must ensure that it is
segregated from approved stock and marked as unfit for use
5. Defence Establishments engaged in fire training activities must ensure that no AFFF is
used in training activities; however training foam is acceptable for use.
Reporting
All spills or incidents shall be reported to the SEM/REO promptly. Incident reports must be
through environmentalincident@defence.gov.au in addition to local arrangements. Where a
large incident is concerned, the SEM is to assess whether the incident is likely to affect offsite
environments, and whether the incident should be reported to State environment authorities.
Michael Healy
A/HEAD INFRASTRUCTURE
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