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Practical action

Act BeforeCosts Escalate

Practical steps airports can take now to preserve claims and prepare for recovery.

  1. Preserve Records

    Keep foam purchase records, training logs, maintenance records, and disposal documentation.

  2. Identify Priority Areas

    Review training areas, hangars, storage locations, wash bays, drains, and outfalls.

  3. Evaluate Response Needs

    Assess sampling, transition planning, contractor scope, and budget exposure.

  4. Pursue Recovery

    Investigate claims against AFFF manufacturers before more costs are absorbed.

Steps for airports to take

Immediate operational and legal considerations

  • Immediately institute new training and systems testing methodology that does not require the discharge of AFFF, if not already in place.
  • Immediately discontinue the use of older AFFF formulations which contain PFOS and/or PFOA.
  • File Complaint to recover damages, including costs of environmental investigation and cleanup as identified below.
  • Evaluate whether to file a claim against the manufacturers of AFFF for the significant costs of sampling and remediation.
  • Formulate a PFAS sampling and mitigation plan for airport property – identify areas of concern (training areas, maintenance areas, storage areas, disposal areas, vehicle wash areas, drainage systems, and any area with documented AFFF discharge/release), identify potential exposure pathways, thoroughly sample soil and groundwater in all areas, and immediately implement containment/mitigation measures.
  • Once a comprehensive sampling plan is completed and PFAS contamination is delineated, a remediation plan should be developed.

For comprehensive information, please see “Use and Potential Impacts of AFFF Containing PFASs at Airports” (2017) published in the National Academy of Sciences as Airport Cooperative Research Program (ACRP) Report 173.