Developing a PFAS Worker Protection Program

Introduction

Protecting employees is of the utmost importance for any business. This is certainly true in the case of workers who use Aqueous Film Forming Foams (AFFFs) that potentially contain per- and polyfluoroalkyl substances (PFAS). AFFFs are chemical agents specifically designed to suppress and extinguish fires and vapors involving flammable liquids, such as oil, gasoline, jet fuel, and other hydrocarbons. AFFFs are composed of complex mixtures of approximately 15 to 18 percent fluorinated and nonfluorinated surfactants; exact formulations vary over time, even between formulations produced by the same manufacturer [1–4]. In this third part of our blog series, we will discuss occupational safety and industrial requirements related to the use of AFFFs as well as the strategies for developing a worker protection program. To learn more about SFFFs, read our first and second blogs in the AFFF series.

Some AFFF formulations have been found to contain perfluorooctanesulfonate (PFOS) and perfluorohexanesulfonate (PFHxS), as well as small amounts of other PFAS including, perfluorobutanesulfonate (PFBS), perfluoropentanesulfonate (PFPeS), perfluoroheptanesulfonate (PFHpS), perfluoropentanoic acid (PFPeA), perfluorohexanoic acid (PFHxA), and perfluoroheptanoic acid (PFHpA) [5–7]. Minimizing any unnecessary chemical exposure in the workplace and having a written plan outlining the steps for compliance is prudent. The ever-changing landscape of PFAS regulations, including recently proposed drinking water standards, release reporting requirements, and the designation status of PFAS as CERCLA hazardous substances highlights the importance of developing a PFAS worker protection program to reduce potential work-related exposures to PFAS via contact with AFFF and to minimize potential downstream liabilities.

History of AFFF and its potential for occupational exposure

Serving both emergency response and training objectives, AFFFs have been used extensively at airports, oil refineries, chemical manufacturers, military bases, train yards, ships, and other locations for their fire and vapor suppression properties [5,8,9]. As a result of their widespread use, there is potential for workers to be exposed to AFFF during active fire suppression activities and relevant training exercises [10] Multiple studies have shown elevated concentrations of PFAS in the blood or urine of firefighters following active firefighting operations in the United States and Europe [11–14]. In cases involving firefighters, exposure likely occurs via inhalation or oral intake of AFFF during occupational tasks, as dermal uptake of PFAS is considered a tertiary route of exposure behind oral intake and inhalation [10,15] Additionally, contaminated personal protective equipment (PPE) may increase the risk of hand-to-mouth transfer of these compounds, particularly if firefighting turnout gear and other pieces of equipment are not appropriately cleaned between operations [10].

Health risks associated with occupational exposure

PFAS compounds, such as PFOS or PFHxS, can take years to break down and be excreted by the human body following exposure [16]. Thus, bioaccumulation of PFAS is a concern, particularly for those who may have occupational exposures in addition to exposures that occur from products used in everyday life. Additionally, the clinical relevance of PFAS bioaccumulation is unclear with regard to human health effects [17].

Data about the health effects resulting from PFAS exposure are overall inconclusive based on a growing body of peer-reviewed literature. Some epidemiological studies link PFOS or PFOA exposure to altered immune response, lipid dysregulation, and kidney or testicular cancer [18]. However, the studies that provide such evidence of these effects have critical limitations that prevent clear conclusions from being drawn, including a lack of data on the underlying mechanism of action or a reliance exclusively on studies focused on animals that have physiological structures or responses that differ from those of humans [18]. Regardless, concern for potential health effects associated with PFAS has led to an increasing number of regulations related to human exposure [19–22]. These proposed regulations primarily target drinking water contamination and exposure for the general population, rather than occupational exposures.

The use of AFFF and its direct link to elevated PFAS concentrations in the human body, as well as the subsequent potential health outcomes, is woefully understudied. Additionally, an individual involved in firefighting activities may experience multiple co-exposures, including particulate matter, volatile organic compounds, and other combustion by-products that are associated with adverse health outcomes, such as cancer. These co-exposures further confound the investigation into AFFF-related health concerns.

PFAS Worker Protection Program

There are currently no nationally published best practices for preventing PFAS exposures in the workplace, primarily because federal agencies and sometimes even companies do not understand what chemicals or products in their supply chain contain PFAS. The U.S. Environmental Protection Agency (EPA) plans to rectify this through their finalized PFAS reporting rule which requires companies to report under TSCA, where applicable, information related to chemical identity, uses, volumes produced and processed, byproducts, environmental and health effects, worker exposure, and disposal.

Currently, the following PPE is recommended when AFFF is used: rubber gloves, P2 respirators, coveralls, splash-proof goggles, and closed footwear [23]. Full firefighting turnout gear is recommended for any active firefighting operations whether they involve AFFF or not. The decontamination of PPE before re-use may play a critical role in reducing potential exposure for first responders [10]. Although there is minimal guidance on specific decontamination procedures, the Interstate Technology and Regulatory Council (ITRC) recommends general PPE decontamination approaches, including the avoidance of hand-to-mouth contact during the use or cleanup of AFFF [10,23]. Laundering of all products in equipment specifically designated for decontamination is highly recommended. Additionally, the guidelines state that personal laundry machines should not be used so PFAS are not released into municipal water treatment systems. [23]

The lack of clear information regarding proper PPE and decontamination procedures for gear worn during AFFF use reveals a critical need for improved research, as well as stop-gap safety measures to protect those who may be exposed. A PFAS worker protection program is vital not only to protect the workforce from exposure and a company from liability but also to document job tasks where worker exposures might occur.  For example, a typical worker protection program involves the identification of areas where exposure might occur, evaluation of current PPE and decontamination procedures, and active or passive sampling methods to quantify the amount of exposure that is likely. From those data, Toxicologists and Industrial Hygienists can develop better safety protocols, including engineering and administrative controls, to reduce overall exposure for workers.

Ready to begin your AFFF transition journey?

References:

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2. Annunziato KM, Doherty J, Lee J, Clark JM, Liang W, Clark CW, et al. Chemical Characterization of a Legacy Aqueous Film-Forming Foam Sample and Developmental Toxicity in Zebrafish (Danio rerio). Environ. Heal. Perspect. 2020;128:097006.
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