Draft guidelines for use of long term retardants on the
Defence Estate
1.1
Selection/Approval of long-term retardants on the Defence Estate
Long term retardants which are currently endorsed for use in Australia by AFAC are USDA approved
chemicals. A complete list of long term retardants which have been approved according to USDA Forest
Services Specification 5100-304c is given in Appendix B. Long-term retardants in this list are evaluated
and approved only according to specified mix ratios and as such should only be applied in compliance
with recommendations. Information relating to the use of fire retardants on the Defence Estate is limited
to a minor reference in Section 6.41g of the MFPE which requires the Bushfire Incident Controller to be
aware of any restrictions that may be in place in regards to the use of fire retardants.
The listed chemical compounds which are unacceptable ingredients in any long-term retardant products
includes:

Sodium ferrocyanide (Yellow Prussiate of Soda or YPS)

Dichromates

Thiourea

Borate or other boron-containing compounds

Polychlorinated biphenols (PCB)

Polybrominated diphenyl ethers (PBDE)
It is therefore suggested that the Defence Estate should only use products which are currently on the list
of endorsed products as given in Appendix B.
1.2
Safe storage of long-term retardants
To meet the requirements of USDA Forest Service specifications 5100-304c for long term retardants,
testing of wet and dry concentrates is conducted to determine product stability, outdoor product stability,
corrosive behaviour and the resistance of wet concentrates and mixed products to microbial growth
(USDA, 2010). In order to meet these guidelines dry, wet and mixed concentrates must be able to be
stored outdoors for 52 weeks without evidence of discolouration or caking, with any lumps able to pass
through a 0.625 sieve (USDA, 2010). In addition to a lack of visible separation, wet and dry concentrates
also are tested for density, viscosity and pH at this stage to ensure that there are no visible changes to
chemical composition. Wet and dry concentrates should also be resistant to microbial growth, with no
evidence of establishment of microbial growth, concentrate discolouration or visible appearance (USDA,
2010). Wet and dry long term retardant concentrates are required to meet guidelines for corrosive
behaviour, with the maximum allowable limits for corrosion given in Appendix C. Specifications require
packaging of long-term retardants list:

The manufacturer's name or trademark

Product identification including formulation codes and production information codes

Volume of concentrate per container

Month and year of production.
The individual storage requirements of specific long-term retardant products are reported in product
Material Safety Data Sheets (MSDS). According to the MSDS for Phos-Chek D-75F AND D-75R and
Phos-Chek P-100F, the major products utilised by Australian fire fighting agencies, the primary
requirement for storage are to keep the chemical containers closed when not in use; and to prohibit
reuse of this container for nonindustrial purposes due to traces of product residue which occur in emptied
containers (ICL Performance Products, 2011; ICL Performance Products, 2006). Beyond these
recommendations, the MSDS suggest that best practice guidelines for storage of chemical products
should be followed. As such it is recommended that the following guidelines are applied on Defence
Estate to reduce the risk of any potential chemical hazardous incident:

Keep products in original containers to allow for an accurate stocktake of available chemicals

Store chemicals upright

Chemicals should be kept in an enclosed, secure environment to prevent unauthorised access

Storage conditions should have impervious flooring and good ventilation

Wet chemical concentrates should not be stored above dry concentrates

Chemical storage should be at a suitable distance from other buildings, watercourses and drains
Where a retardant is introduced on the Defence Estate the product should be registered in the
CHEMALERT system (Defence inventory system).
1.3
Handling and use of long-term retardants
The anticipated health effects which occur from exposure to long-term retardants are considered to be
minimal as the chemicals contained in these products commonly occur in fertilisers, household cleaning
products, cosmetics and paints (Kalabokidis, 2000). It is suggested that the greatest potential danger
posed by long-term retardants will follow an atypical event during the mixing of long-term retardants or
incidents of fatalities if individuals are directly in the path of an aerial drop (Kalabokidis, 2000).
Research in to the effects of long-term retardants was carried out by Labat-Anderson Inc (2003) to
determine the health impacts of exposure to fire fighting chemicals. The suggested toxic doses and
reference doses for long term retardants are presented in Table 1. Results determined in this study were
affected by uncertainties around the data set related to the lack of long term toxicity test values,
necessitating an estimation of values based around previous research, unavailability of cancer slope
values for several chemicals and an absence of dermal penetration rates (Labat-Anderson, 2003).
However, from derived estimated values, it was determined that in most instances of exposure the
hazard quotient produced was less than one indicating a negligible risk caused by exposure to long term
retardants. Where high levels of exposure occurred e.g. during the loading of powder retardants, the
hazard quotient exceeded one, indicating a risk factor to personnel in these instances.
As outlined in the MSDS for USDA endorsed products, the most common risk posed by long-term
retardants occurs through inhalation of the powder based product. Inhalation may result in nasal and
respiratory tract infection leading to an allergic respiratory tract infection (ICL, 2011). To treat any
inhalation of the product it is suggested that the individual affected should be removed to a fresh air
environment, administer oxygen if breathing is difficult, with follow up medical attention to occur if
required (ICL, 2011). Other effects caused by exposure to long-term retardants include minor irritations
to skin and eyes. Should eye contact occur it is recommended that the product be removed with water.
To avoid any dermal reactions contaminated clothing should be thoroughly washed prior to reuse (ICL,
2011).
Given the recommendations presented in retardant MSDS and through studies by Labat-Anderson
(2003) it is recommended that full personal protection equipment, namely a helmet, self-contained,
positive pressure or positive pressure demand self-contained breathing apparatus, tunic and pants,
bands around arms, waist and legs, full face-piece, and protective covering for exposed areas of the
head be worn when working with long term retardants (Solberg Asia Pacific Pty Ltd, 2010). It is also
recommended that the Defence Estate should provide good ventilation in areas where chemical mixing
occurs to avoid inhalation of chemical dust. No mixing of chemicals should occur without appropriate
breathing apparatus.
Care should be taken to follow all recommended guidelines for handling and use of the chemicals on the
Defence Estate according to the requirements documented on the MSDS for each individual product.
It is recommended that all equipment should be thoroughly rinsed at the end of each day to minimise
potential impacts caused by corrosion. All rinse water generated within this process should be treated as
contaminated and disposed of appropriately (USDA, 2009).
It is recommended that wherever bushfire chemicals are handled a first aid kit including an eye wash unit
should be readily available.
Table 1
Toxicity and Reference doses for long-term retardants
Product
Oral LD50
Estimated Reference Dose
(mg/kg)
(mg/kg)
Phos-Chek D75-R
3967
0.20
Phos-Chek D75-F
4722
0.24
Phos-Chek 259-R
5050
0.25
Phos-Chek 259-F
3100
0.16
Phos-Chek G75-W
505
0.03
Phos-Chek G75-F
4200
0.21
Phos-Chek HV-R
5050
0.25
Phos-Chek HV-F
5050
0.25
Phos-Chek MV-R
5050
0.25
Phos-Chek MV-F
5050
0.25
Phos-Chek LV-R
5050
0.25
1.4
Operating procedures to avoid or minimise adverse environmental impact of
long-term retardants
Through the application of long-term retardants according to recommended guidelines and
implementation of buffer zones to sensitive aquatic and terrestrial environments it is anticipated that
there will be limited environmental impacts caused by application of chemicals. It must be noted that the
balance of the impact of wildfire versus the potential benefit caused by the application of retardant must
be assessed prior to its application on the Defence Estate. Studies by Little and Calfee (2002b) showed
that low concentration of ash caused fish gills to clog and lead to respiratory failure, therefore other fire
related factors such as ash and high temperatures may lead to far greater environmental consequences
than toxicities generated by the application of fire retardant chemicals. Assessment of prevailing weather
conditions, fuel hazard and potential for a significant fire event should be considered when determining
the suitability of application of fire retardant chemicals. The implementation of following procedures on
Defence estate can assist in reducing the environmental risk:

Use and storage of retardants is in accordance with the product specific MSDS.

Use only USDA Forest Service endorsed retardants on Defence Estate and remove older stocks. In
order to minimise environmental impacts it is recommended that only long-term retardants which are
endorsed according to USDA Forest Service specifications 5100-304c (listed in Appendix B) should
be used by Defence. Phos-Chek D75-R is extensively used by Australian Fire Authorities so adoption
of this chemical for use by the Defence Estate would reduce the risk of major environmental impact
according to its performance to date in Australian bushland environments. It is important for Defence
Personnel to continually monitor the occurrence of new USDA approved retardants which may be
superior in performance to Phos-Chek D75-R.

Identify areas containing threatened biota that may be sensitive to retardants in the Bushfire
Management Plan. Given the environmental impacts reported in Section Error! Reference source
not found. of this document, it is recommended that a precautionary approach be taken to avoid any
significant effect to aquatic or vulnerable ecosystems on Defence. Adoption of an approach similar to
Class A foams, where a 100 metre buffer zone is implemented when applying long-term retardants
around waterways and known incidents of susceptible threatened biota including fish and frogs is
recommended. Noting that retardants can be used as an effective means to limit fire spread into
sensitive areas through strategic application around the boundaries. A reporting process should be
implemented to facilitate the auditing of incidents of long-term retardants applications within 100m
buffer zones. A sample reporting template which is currently implemented by the USDA is provided in
Appendix C and could be tailored to the needs of Defence Estate to avoid any unnecessary process.
REFERENCES
ICL Performance Products (2006). PHOS-CHEK® FIRE RETARDANT GRADES D-75F AND D-75R
Material Safety Data Sheet.
ICL Performance Products (2011). PHOS-CHEK® P100-F Material Safety Data Sheet.
Kalabokidis, K. (2000). Effects of wildfire suppression chemicals on people and the environment- A
review. Global Nest: The International Journal, 2 (2), 129-137.
Labat-Anderson Inc (2003). Human Health Risk Assessment: Wildland Fire-Fighting Chemicals. Report
Prepared for Missoula Technology and Development Centre, USDA Forest Service.
Little, E. and Calfee, R. (2002b). Environmental Implications of Fire-Retardant Chemicals. Project
Summary Report prepared for the US Forest Service.
Solberg Asia Pacific Pty Ltd (2010). Solberg Fire Brake 3150A Class A Fire Fighting Foam Concentrate
Material Safety Data Sheet
United States Department of Agriculture (2009). Wildland Fire Chemicals Systems: Tactics and Product
Characteristics Aerial Application. [Accessed 28-5-12, http://www.fs.fed.us/rm/fire/wfcs/index.htm]
United States Department of Agriculture (2010). Fish Toxicity. [Accessed 29-5-12,
http://www.fs.fed.us/rm/fire/wfcs/performance/documents/FishTox_WE_Rev-043010.pdf]