Pipework, paperwork and the 23 October plan.

Europe makes about thirty thousand tonnes of firefighting foam a year. Eighteen thousand of those tonnes, on the Commission's own figures, still contain PFAS. About four hundred and seventy tonnes of the stuff leaves the foam each year in manufacture, in training and at fires, goes into ground and water, and stays there. That is the bill the Commission costed at about seven billion euros over thirty years.

On 2 October last year it adopted the regulation that ends it. The first of its dates is a month away.

THE DATES, AND THE ONE THAT MATTERS

Regulation 2025/1988 puts a new entry in the REACH restriction list. The limit is 1 milligram per litre for the sum of all PFAS in a foam. Above that, no placing on the market and no use from 23 October 2030, with earlier and later dates by application. The regulation treats selling a foam and using a foam as two different acts, and most of the summaries doing the rounds have glued them together.

Portables go first. From 23 October a portable with fluorinated foam cannot be placed on the market. Alcohol-resistant portables get until 23 April 2027. But a portable already on the wall can stay in service until the end of 2030. What stops next month is the sale of new ones.

Training and testing, and the public fire services, have until 23 April 2027. Functional testing of a fixed system is carved out, provided everything that comes out is contained. Seveso establishments, offshore oil and gas, military vessels and civilian ships that already had the foam on board before last October have until 23 October 2035. Airports do not. Civil aviation is written out of that derogation by name.

Then the part that matters. From 23 October, any site that intends to keep running a fixed system on PFAS foam, whether to 2030 on the general clock or to 2035 under one of the long derogations, has duties that start now. It must label the foam. It must collect unused stock and PFAS-containing waste, including water that has been through the foam, separately, where that is technically possible. It must send that waste for treatment that destroys the PFAS or changes it irreversibly. And it must write and keep a management plan, for fifteen years, covering use, treatment, cleaning, spills, and how it intends to get off the foam.

A site that means to run on fluorinated foam until 2035 therefore needs the paperwork in place by next month. The long derogation buys time on the foam. It buys none on the plan. And none of this pardons an old stock: the earlier bans on PFOS, PFOA and their relatives still sit underneath.

WHY IT READS LIKE A WASTE LAW

The fires were never the issue. The run-off was.

The case that put that into law was heard by the Supreme Court in Stockholm in December 2023. For decades the crews at the Blekinge air wing had trained with fluorinated foam. It went into the ground, the ground fed the Brantafors waterworks, and the waterworks supplied Ronneby. The court found that more than a hundred and fifty residents with elevated PFAS in their blood had suffered personal injury under the Product Liability Act, and that the municipal water company was liable. Nobody in that judgment was hurt by a fire. They were hurt by the water used to practise for one.

THE PART THAT IS NOT THE FOAM

Here is where it gets awkward for anyone who thought the job was to order a different drum.

Fluorosurfactants do not leave a system when the foam does. They cling to tank walls, pipe walls, fittings, valves and the proportioner. FireDos, which makes proportioners and has published its own cleaning guidance, says dry, encrusted residue is the normal state of a system that has run on fluorinated foam, and that water alone will not shift it. What soaks into plastics, it says, is low enough to ignore. The pipework is the problem.

The procedure it describes is a week of dirty water. Flush at fifty to sixty degrees until the drain stops foaming, three system volumes in their experience. Then fill the tank, the pipes and the fittings with the hottest water you have, leave it a day, drain it, and do that three more times. Change the seals. The first flushes are waste and have to go to a furnace hot enough to break the chemistry. FireDos puts that above eleven hundred degrees; a municipal incinerator runs at about eight hundred and fifty. That temperature is their guidance, not the regulation's, which asks only that the PFAS be destroyed. The later fills, they say, can go to sewer if you are careful and preferably if you have had them analysed. None of this is in the Official Journal. It is what the pipework requires.

The regulation knows it, too. A fluorine-free foam put into a cleaned system is allowed to carry up to 50 milligrams per litre of PFAS, fifty times the limit for new foam, because the pipes will give some of it back. Portables are excluded from that allowance. The number is the closest thing in the text to an admission.

So the transition has three parts, and most people are thinking about them in the wrong order. The last part is choosing a replacement agent. The middle part is getting the old agent and its residue out of the system and to somewhere that can destroy it. The first part, and the one with the date on it, is writing down what is in the building. The Commission's own guidance on making the change, published by ECHA, is the document to open before any of the brochures.

BRITAIN AND SWITZERLAND

None of this applies in Great Britain, where REACH is now its own system. The Health and Safety Executive has published its opinion that a restriction is the right measure, and a second consultation, on the costs, closed on 7 September. It is still a proposal. There is still no date.

Switzerland is outside the regulation too. The Federal Council has proposed aligning the Swiss chemicals ordinance with it, with the same one milligram limit and first dates from December this year. That is also a proposal.

In practice, a site in either country with a European parent, a European insurer or a European foam supplier will find the October date arriving anyway, as a question from someone else.

WHAT TO ASK

Three questions, in the order they matter.

What is in the system, in litres, and what does the data sheet say is in it? If nobody on site can answer that today, the plan cannot be written, and the plan is the thing with the date.

Where does the flush water go, and who will take it?

Who signs the plan, and who keeps it for fifteen years?

Choosing a replacement is the last item on that list. It is also the only one anyone is advertising.