PFAS Firefighting Foam Decommissioning SWMS

Decommissioning legacy aqueous film-forming foam (AFFF) systems containing per- and polyfluoroalkyl substances (PFAS) is one of the highest-consequence chemical works currently undertaken in Australia. The task spans aerodrome hangars, Defence fire training grounds, bulk fuel terminals, and industrial sprinkler rooms — anywhere C8 or C6 fluorotelomer concentrates remain in tanks, pipework, proportioners, or contaminated concrete bunds. Work involves purging foam concentrate, capturing rinsate as Schedule 5/7 controlled waste under the PFAS NEMP 2.0, segmenting and bagging contaminated pipework, and triple-rinsing infrastructure to validated leachate limits. Because PFAS are persistent, bioaccumulative, and toxic, with PFOS and PFOA scheduled for phase-out under the Industrial Chemicals Act 2019, the work is a hazardous chemical task under WHS Regulation Part 7.1 and demands a documented Safe Work Method Statement before any system is breached. This SWMS converts NEMP, CASR, and WHS obligations into worker-level controls signed off at pre-start.

Hazards identified

7 hazards covered, sorted by priority.

Control measures

Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.

1. 1Elimination — Where feasible, replace AFFF systems with fluorine-free foam (F3) certified to ICAO Level B before decommissioning, eliminating ongoing PFAS handling exposure entirely.
2. 2Elimination — Decommission in-situ via closed-loop pump-out directly into approved transport tankers, eliminating open transfer steps and aerosol generation points across the work area.
3. 3Substitution — Substitute high-pressure water blasting with low-pressure recirculating rinse using captured potable water, reducing aerosol formation and rinsate volume requiring Schedule 7 disposal.
4. 4Substitution — Replace solvent-based pipework cleaning agents with validated alkaline surfactant rinses proven effective against C6 fluorotelomers in NEMP 2.0 Annex B trials.
5. 5Engineering — Install local exhaust ventilation with HEPA and activated carbon filtration at all breach points, maintaining 0.5 m/s capture velocity verified by anemometer pre-start.
6. 6Engineering — Bund the entire work footprint with welded HDPE liner extending two metres beyond pipework, draining to lined IBC for total rinsate capture and EPA-tracked manifest disposal.
7. 7Administrative — Restrict the exclusion zone via hard barricades, post PFAS hazard signage per GHS 9, and maintain a signed entry log with task-specific induction completed that shift.
8. 8Administrative — Implement biological monitoring baseline serum PFAS testing pre-project and at six-monthly intervals, with results managed under health monitoring records retained 30 years per WHS Reg 368.
9. 9PPE — Issue Type 3-B chemical splash coveralls, nitrile over butyl double-gloving with two-hourly changeout, and full-face APR with combined A2B2P3 plus fluorocarbon-rated cartridge.
10. 10PPE — Mandate supplied-air respirators (SAR) for any confined space entry or hot decontamination work, with escape cylinders and standby attendant per AS/NZS 1715:2009.

Applicable Codes of Practice

Worked example

At a regional aerodrome hangar decommissioning a 4,500-litre AFFF bladder tank and associated proportioner skid, the site supervisor opens the pre-start brief by walking the four-person crew through this SWMS at the bunded laydown area before any line is cracked. The crew confirms the closed-loop pump-out hose has been pressure-tested overnight and the HDPE bund liner extends two metres past the proportioner pit. Reviewing the hazards register, the leading hand flags that overnight rain has pooled inside the secondary bund — the SWMS rinsate capture control is escalated and a vacuum truck is positioned before pump-out commences. Each worker signs onto the document confirming they have completed serum PFAS baseline testing, their APR fit-test is current, and their butyl-lined gloves are within the two-hour changeout window logged on the entry board. Mid-task, a pinhole leak develops on the discharge manifold spraying fine aerosol; the supervisor calls a stop-work, the crew retreats to the decontamination line, and the SWMS is amended on the tablet to add a containment shroud control before work resumes. At shift end, the amended SWMS, entry log, waste manifest numbers, and rinsate volumes are uploaded to the project HSE register, satisfying NEMP 2.0 traceability and WHS Regulation 368 retention requirements.

Related legislation

• WHS Act 2011 (model)
• WHS Regulation 2025
• Managing Risks of Hazardous Chemicals CoP; PFAS National Environmental Management Plan

Frequently asked questions