Across the United States, major changes are underway regarding how the fire service uses certain chemicals that have long been used in firefighting equipment and operations.
For decades, firefighters have relied on products containing PFAS (short for per- and polyfluoroalkyl substances), especially firefighting foams, and some PFAS have also been used in certain types of protective gear. Today, however, PFAS are at the center of growing health concerns and rapidly evolving regulations.
Anyone who’s been in the fire service for any length of time has likely noticed they’ve been hearing more about PFAS every year. The challenge is that the regulatory landscape is complicated. Federal rules are changing, state legislatures are passing new laws, and equipment manufacturers are redesigning products to avoid using these chemicals.
Let’s take a look at the big picture and what it means for local fire agencies.
What Exactly Are PFAS?
PFAS are a large group of synthetic compounds that have been in use since the 1940s. They are sometimes called “forever chemicals” because they break down extremely slowly in the environment and can accumulate in soil, water, and living tissue (including in animals and people).
Simply put, these chemicals were used because they’re useful. They repel water, resist heat, and withstand chemicals. Because of this, they’ve shown up in a variety of different products over the years, including:
- Firefighting foam
- Protective clothing
- Nonstick cookware
- Water-resistant fabrics
- Food packaging
In the fire service, PFAS are commonly associated with aqueous film-forming foam (AFFF). AFFF is a specialized firefighting foam designed to quickly suppress fires involving flammable liquids such as gasoline, jet fuel, or industrial solvents. The foam spreads across the surface of the fuel, forming a film and foam “blanket” that suppress fuel vapors and helps separate the fuel from oxygen.
For decades, firefighting foam containing PFAS was widely considered the gold standard for suppressing fuel fires. However, research over the past two decades has associated exposure to PFAS chemicals with health risks including certain cancers, immune-system effects, and developmental harms. That research, along with concerns about environmental contamination, has driven a wave of regulatory action to phase out products like AFFF.
“PFAS are sometimes called ‘forever chemicals’ because they break down extremely slowly in the environment and can accumulate in soil, water and living tissue.”
Tightening Federal Requirements
Some of the rule changes have been coming from federal regulators, which have taken several significant steps that affect the fire service, though most federal actions do not directly regulate local fire departments.
One of the most important changes occurred in 2024, when the U.S. Environmental Protection Agency (EPA) designated PFOA (perfluorooctanoic acid) and PFOS (perfluorooctanesulfonic acid), including their salts and structural isomers, as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), more commonly known as the Superfund law.
CERCLA governs hazardous-substance cleanup, and redesignating PFAS chemicals in this way means releases at or above federal reporting thresholds can trigger CERCLA reporting requirements and potential cleanup action. The federal government has also tightened drinking-water rules for certain PFAS, although the EPA has continued adjusting the implementation timeline and broader rule framework. That’s why fire agencies should not assume they can dispose of PFAS-containing foam or gear through ordinary trash or drain disposal.
Recognizing that fire departments used AFFF to further their public safety mandate, the EPA also announced an enforcement-discretion policy indicating it generally does not intend to pursue local fire departments for CERCLA cleanup actions or costs, absent special circumstances.
While these federal policies matter, though, they’re not the biggest driver of PFAS-related change in the fire service. For many local departments, the most immediate operational changes are coming from state law.
States Now Leading PFAS Phase-out
In recent years, states have played a leading role in regulating PFAS used in firefighting foam and equipment. According to national legislative trackers, hundreds of PFAS-related bills have been introduced across dozens of states in the past several years.
These laws and regulations, which directly impact local fire departments, generally fall into four categories.
1. Restrictions on firefighting foam
One of the most common state rules is restricting or prohibiting the use of PFAS-containing firefighting foam for training or testing. States such as California, Colorado, and Washington, have enacted broad restrictions on PFAS-based AFFF, limiting its sale and use except in specific circumstances.
Historically, many departments conducted live foam training exercises during which foam was discharged onto the ground. Because PFAS chemicals are now known to persist in the environment, those exercises are now widely restricted.
Many state laws now prohibit the use of AFFF in training unless the foam is captured and properly disposed of, and some ban its use in training entirely. Recent examples include Arizona, Arkansas, and Connecticut, which restrict discharging PFAS-containing foam for training or testing, generally allowing it only if containment and proper disposal measures are in place.
Some states (including California, Colorado, and Georgia) have gone further by restricting the sale or distribution of PFAS-based firefighting foam, generally allowing it only for limited uses where no feasible alternative exists.
These restrictions are pushing departments toward fluorine-free foam (F3), which does not contain PFAS chemicals.
2. Foam inventory reporting and containment requirements
Some states require departments to report certain uses or releases of PFAS-containing foam, particularly when it is discharged. Examples include California, Colorado, and Minnesota, each of which requires notification to state authorities when PFAS-containing firefighting foam is discharged or released, with specific requirements varying by state.
While requirements vary, some states (such as Colorado and Minnesota) require prompt notification — often within a defined timeframe — when PFAS foam is discharged during an incident. Other states require foam to be fully contained during testing, meaning departments must capture the foam and prevent it from entering soil, storm drains, or waterways.
States with such containment requirements include Colorado, Arkansas, and Arizona, where testing discharges are allowed only if containment and proper treatment or disposal measures are in place.
3. Turnout gear regulations
Another major regulatory shift involves firefighter protective gear.
Turnout gear (including jackets, pants, gloves, and boots) has historically incorporated PFAS in certain materials to provide water, oil, and chemical resistance and durability. But several states now restrict or ban protective gear containing “intentionally added PFAS.” Examples include Massachusetts, Illinois, and Connecticut.
Massachusetts enacted a law in 2024 that will prohibit the sale of firefighter turnout gear containing intentionally added PFAS beginning in 2027, while also requiring disclosure of PFAS in gear sold before that date.
Illinois adopted a similar law in 2025 that bans the sale of firefighter PPE containing intentionally added PFAS beginning Jan. 1, 2027, with manufacturer disclosure requirements beginning Jan. 1, 2026.
Connecticut also passed legislation requiring written notice when firefighting PPE contains intentionally added PFAS and establishing a phased restriction on the future sale of such equipment.
Other states — such as New York and California — have passed laws that require manufacturers to disclose whether gear contains PFAS. The New York law demands that manufacturers of firefighter PPE provide written notice if the equipment contains intentionally added PFAS. California enacted a similar disclosure requirement for firefighting PPE beginning Jan. 1, 2023.
Others (including Massachusetts and Illinois) have established future deadlines after which gear containing PFAS cannot be sold to fire departments in their jurisdictions.
Not surprisingly, these laws are contributing to increased development of PFAS-free turnout gear.
4. Foam take-back and disposal programs
Finally, several states have launched programs to help fire departments safely dispose of legacy foam stockpiles. States with state-run collection or disposal programs include Washington, Colorado, Michigan, and in some cases, New York. These programs are important because PFAS-containing foam requires specialized handling and cannot be disposed of through routine methods (like drains or landfills) without complying with applicable regulations.
Several states also offer:
- State-run foam collection programs. (Examples: Washington, Colorado)
- Manufacturer-supported take-back or stewardship programs. (Examples: New York, Maine)
- Grants for foam replacement. (Examples: Michigan, Pennsylvania)
- Reimbursement for foam disposal. (Examples: Colorado, Washington)
These programs can be especially helpful for small and volunteer departments, which may not have the resources to manage hazardous-material disposal on their own.
What Agencies Should Be Doing Now
For many departments, PFAS compliance is no longer a future issue. It is already affecting purchasing, training, storage, and disposal decisions. Because of this, fire chiefs and municipal leaders should be asking a few key questions:
- Do we still have PFAS foam in inventory? Many departments still have legacy AFFF stored in apparatus or training facilities.
- Are we conducting foam training safely? Training discharges are restricted in many states.
- What do our purchasing specifications say? New state laws may require PFAS disclosures or prohibit certain gear.
- Is there a state take-back program available? Some states now pay departments to turn in old foam.
- Have we assessed possible contamination risks? Former training areas, foam-use locations, and other sites where AFFF may have been discharged are increasingly under scrutiny for PFAS contamination.
Departments that address these issues proactively will be far better positioned as the regulatory landscape continues to evolve.
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Navigating the PFAS Transition
PFAS regulation is changing rapidly, and the fire service is in the middle of that transition. For many local fire departments, the most immediate operational requirements are now coming from state laws rather than federal regulations.
States are increasingly deciding whether PFAS foam can be used, when it must be phased out, whether turnout gear can contain PFAS, and how legacy foam must be disposed of.
For many departments, the shift away from PFAS has already begun. The next few years will determine how quickly it spreads across the entire fire service.
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