From: Commissioner
Sent: Friday, 19 February 2016 4:22 PM
To: - ALL STAFF
Subject: Possible contamination issues due to old AFFF foam
Importance: High


You may be aware due to recent media reports of the discovery of high levels of certain chemicals at the Williamtown RAAF Base. These chemicals may have come from historical use of firefighting foams that were withdrawn from service almost 10 years ago by all agencies, including FRNSW. Since the discovery at Williamtown all fire agencies have been working closely with the Environment Protection Agency (EPA) to identify sites that may have seen high usage of the subject foams. On 13 January 2016 representatives from EPA visited FRNSW training sites at Albion Park and Londonderry to undertake preliminary soil and water sampling. These visits and tests are a precursor to a wider effort by the NSW EPA to thoroughly identify and investigate legacy commercial and government sites where Aqueous Film Forming Foam (AFFF) may have been used in the past prior to being removed from service. 


Preliminary results of soil and water testing (taken from static water collection ponds) at Albion Park and Londonderry were received on 1 February 2016. The results indicated the presence of Perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA) in soil and water run-off pond samples from both locations. The levels in the ponds, as could be expected, were high, and the soil levels were relatively low but above background environmental levels. The EPA advised that these preliminary tests are indicative only, and point to the need for more extensive tests. These are currently being carried out. We are not the only users of these sites and not the only users of substances containing PFCs.


Training sites at Armidale, Wellington and Deniliquin were visited by EPA on 20 January and 4 February respectively. Samples were taken from these sites; with results from these tests pending. Other sites will also be tested.


While there are no international set standards for PFOS/PFOA levels, or established facts known about the chemicals possible impact on human health, we will be taking a ‘worst case’, comprehensive approach.


After consulting with the EPA, Department of Health and after discussions with the Fire Brigade Employee’s Union (FBEU) today about the emerging legacy issues of AFFF use, I have directed that further work take place to:


1. Clearly identify any areas of elevated levels of PFOS/PFOA through comprehensive expert testing

2. Provide comprehensive information about future actions to further identify and contain potentially affected soil and water

3. Provide all staff with the best possible information about health issues and offer support to anybody with health questions/concerns; and, importantly

4. Continue to work closely with the EPA, Health, other agencies and the FBEU to understand and disseminate facts and evidence of PFOS/PFOA as they arise.


In the meantime, anyone who has concerns about potential exposure side-effects is encouraged to contact the Employee Assistance Program (EAP) on 1300 360 364 if worried or anxious, or complete a NIIENM from. This is essential to ensure that those with concerns can speak to someone in complete confidence and record their details via NIIENM.


While blood testing does exist to determine an individual’s cumulative exposure to PFOS and PFOA, it should be noted: PFOS and PFOA blood testing does not help predict health effects; and the Department of Health recommends against it. Serum levels detected by blood tests do not provide an interpretable measure of health risk, i.e. detecting a specific PFOS or PFOA level does not enable an assessment of real or potential adverse health effects because little is known about any real or potential effects on humans. Notwithstanding, after consultation with the FBEU I have directed that voluntary testing be made available to any employee (pre 2008) who wants it.


Poly-fluorinated compounds are common in the environment and is probably present in everybody’s blood. Commonly known as PFCs, they have been used in a wide range of industrial processes and consumer products, including in the manufacture of non-stick cookware, specialised garments and textiles, aviation hydraulic oils, products used to protect fabric, furniture, and carpets from stains, metal plating, and in some types of fire fighting foam. FRNSW began phasing out fire fighting foams containing PFCs from 2000, and had completely ceased its use by 2007 with all known stores destroyed (by commercial incineration) as a result of a major recall campaign. 


Whilst there are no identified health affects definitely associated with PFOS/PFOA, their presence in the environment and in humans are emerging as national and international issues of concern This is why work is being done in NSW to identify legacy use issues and to identify areas in NSW where the chemical may be found in concentrated quantities. 


A working group of senior personnel from FRNSW has been established whose purpose is to work directly with NSW EPA, NSW Health, NSW DPI, local councils, staff and the community – providing critical advice, support and open communication as we continue to work on identifying any risks or issues relating to AFFF and PFOS/PFOA. The work of this group will be ongoing and all updates and further information should be regularly monitored via http://intranet/about-frnsw/news-listing/the-nsw-epa-investigation-program


The NSW EPA has announced today that the EPA’s PFC investigation program is tasking a precautionary approach to managing the historical legacy of PFC use in the NSW environment. It recognises that PFCs are ubiquitous in the environment in low concentrations, due to their wide use in textiles and leather products, metal plating, food packaging, firefighting foams, floor polishes, denture cleansers, shampoos, coatings and coating additives, in the photographic and photolithographic industry, medical devices and in hydraulic fluids in the aviation industry.


As such, the NSW EPA’s ongoing investigations will focus on sites where, in the past, the chemicals may have been used in large quantities, including airports, firefighting training facilities and some industrial sites, and where there are exposure pathways that may increase people’s contact with the chemicals, such as bore water usage, surface water usage or fishing sites.


I encourage you to keep up-to-date with the work being done within FRNSW to manage the legacy issues of PFOS/PFOA; make contact with EAP on 1300 360 364 and complete a NIIENM from if you have concerns. Familiarise yourself with the frequently asked questions available from NSW EPA, NSW Health, NSW DPI; and FRNSW Health and Safety. Be aware of your environment – follow directions in regard to areas to avoid contact with and the safety bulletin being issued today; and, keep informed of the facts. Your safety and well-being is of greatest concern to me and I want to make sure you are all aware of what is happening with this issue, now and into the future.


Greg Mullins AFSM
Commissioner.