Skip to main content
Marsh logo

Article

Burning issue: Preparing for changes in firefighting foam used in the energy industry

New global regulations aim to restrict the widely used fire suppressant aqueous film-forming foam (AFFF). Consequently, many manufacturers are beginning to phase out the production of these foams.

14/07/2025 · 3 minute read

New global regulations aim to restrict the widely used fire suppressant aqueous film-forming foam (AFFF). Consequently, many manufacturers are beginning to phase out the production of these foams.

As they transition to alternative firefighting foams, organisations must be aware of the risks and insurance considerations. Insurers also have a role to play in the transition, from understanding the mitigation strategies to supporting clients in proactively addressing risks.

The risk of major fires in installations that handle large quantities of hydrocarbon products is evident. Over the years, numerous fires have resulted in injuries and fatalities, large losses, extensive plant damage, and significant business interruption.

For decades, AFFF has been considered effective in extinguishing hydrocarbon fires across various settings, including aviation, marine, and energy and power installations. Despite its effectiveness, AFFF contains per- and polyfluoroalkyl substances (PFAS). Often referred to as “forever chemicals,” these non-biodegradable chemicals can potentially pose long-term risks to both human health and the environment.

In response to these concerns, new government regulations are restricting the manufacturing, use, transport, and sale of PFAS-containing products, directly impacting AFFF use. Insurers have also been increasingly mindful of potential exposure to liabilities arising from the use of substances containing PFAS chemicals from both an environmental pollution and health perspective.

As a result, many organisations are transitioning to fluorine-free foams, such as FFF, 3F, or triple F, which have proven to be effective in firefighting and are generally considered less toxic than AFFF. Organisations that have not yet begun this transition should proactively assess the potential scale and scope of the process sooner rather than later, including the changing legal and regulatory landscape, as well as potential impacts on insurance.

Debunking four myths when transitioning from AFFF to FFF

1. Myth: FFF is not as efficient as AFFF in putting out fires

High-performing FFF foams have consistently proven to be viable alternatives to AFFF, both in laboratory settings and in large-scale atmospheric storage tank fire scenarios. FFF foams have also met the National Fire Protection Association (NFPA) regulations regarding extinguishing capability.

 Unlike AFFF, which creates a film on hydrocarbon surfaces, FFF foams function by forming a physical barrier of bubbles that trap fuel vapors and prevent them from mixing with oxygen. As a result, the performance of FFF foams relies on the stability of the bubbles in the foam layer, necessitating firefighters to be instructed about the techniques and tactics required.

2. Myth: Regulations are inconsistent and, as a result, do not impact me

Although globally regulations may vary, the trend appears to be moving toward stricter controls on AFFF. Several countries — including Australia, Canada, Japan, and the US — are takings steps to restrict certain types of AFFF extinguishers. By July 2025, the use of AFFF extinguishers will be banned in Europe and the UK.

From January 2026, new regulations will prohibit ships from using and transporting fluorinated foams that contain perfluoro-octane sulfonic acid (PFOS), a specific type of PFAS. With as many as 40,000 vessels — including oil tankers, chemical tankers, rigs, offshore vessels, and engine room systems — carrying firefighting foams containing PFAS, owners and operators should be proactively addressing these changes. This includes planning for the removal, disposal, and replacement of existing foams to promote compliance with upcoming regulations.

Build organisational robustness is key to being better prepared and positioned for regulatory changes. For example, businesses can conduct comprehensive assessments of their existing fire suppression systems, identify and replace AFFF extinguishers with compliant alternatives, like FFF, and safely dispose of AFFF systems. Proactively transitioning to safer alternatives and collaborating with professionals, such as risk engineers, can help businesses comply with regulations and potentially minimise future disruptions.

3. Myth: All foams have compatible equipment and storage

AFFFs and FFFs differ in chemical composition and storage requirements, which may necessitate modifications to existing firefighting equipment. For example, some FFFs are non-Newtonian (they do not flow and act like water), whereas the majority of AFFFs are low-viscosity foam agents. This means that FFF foams may require different proportioning systems and updated sprayers that can handle the viscosity range. Additionally, the shelf life and long-term stability of FFFs can be affected by a number of factors, such as temperature exposure, storage conditions, and contamination. Some sites may not to require significant hardware modifications when transitioning foams, but this needs to be considered on a case-by-case basis.

Working with a trusted engineering team that understands the challenges of using different foams can enhance operational efficiency and safety. Marsh’s Risk Engineering team has extensive experience in supporting clients with the design, construction, operation, and maintenance of foam installations across various risk scenarios. We also collaborate closely with clients who are in the process of transitioning to new foam solutions or have already completed the transition.

4. Myth: Training in handling and safety procedures is unnecessary for using FFFs

The transition to FFFs requires adjustments in application methods and an understanding of this chemical’s performance characteristics. Training, testing, drills, and extinguishing exercises must be integrated into firefighting operational procedures. For example, FFF foams are more dependent on bubble formation and stability, so they should typically be applied gently to the surface of hydrocarbons (which is not as critical with AFFF). Regular reviews and adaptations of firefighting procedures are essential.

The role of insurance

The insurance market can actively support this transition, as effective management of the transition to FFF foams can significantly reduce overall risk exposure. For example, the removal of insurance industry disincentives for operators to make this necessary shift and supporting underwriters to understand and embrace new techniques. 

Proactive investment to mitigate future risks

Investments in fire safety preparation, education, and prevention are typically modest in comparison to potential fire losses. The best way to reduce fire risks and minimise damage is through comprehensive fire safety measures, including risk identification, enhanced prevention strategies, compliance with health and safety regulations, and training on emergency planning and response.

A key element of a robust risk management programme is understanding the risks and practical challenges associated with newer fire suppression methods, including FFF and elimination of AFFF products.

Marsh’s team of energy risk engineers is equipped to guide you in implementing effective fire safety measures tailored to your facility. We can assist in developing and maintaining a comprehensive maintenance plan and provide support for employee training.

For more information, please contact your local Marsh representative.  

Our people

Peter Clayton

Peter Clayton

Dubai Engineering Hub Leader, Marsh

  • United Arab Emirates

Francois Carletto

Francois Carletto

Power Risk Consultant, Energy risk engineering, Marsh Specialty

  • France

Related insights

photorealistic futuristic concept of renewable energy storage consisting of modern, aesthetic and efficient dark solar panel panels that are in pleasant contrast to the blue summer sky and white gravel on the ground, a modular battery energy storage system and a wind turbine system in the background. 3d rendering

Article

Trade, tariffs, and supply chain shocks: Risk engineers as strategic lookouts for the energy and power sector

10/07/2025
Team teamwork business join hand together concept, Power of volunteer charity work, Stack of people hand

Article

Bridging the utilities sector talent gap

19/06/2025
Placeholder Image

Article

Fusion energy: Delivering on the promise of carbon-free power

21/05/2025
Placeholder Image

Article

Battery Energy Storage Systems in the Nordics

19/05/2025
View more

Marsh is a business of Marsh McLennan. 

This document and any recommendations, analysis, or advice provided by Marsh (collectively, the “Marsh Analysis”) are not intended to be taken as advice regarding any individual situation and should not be relied upon as such. The information contained herein is based on sources we believe reliable, but we make no representation or warranty as to its accuracy. Marsh shall have no obligation to update the Marsh Analysis and shall have no liability to you or any other party arising out of this publication or any matter contained herein. Any statements concerning actuarial, tax, accounting, or legal matters are based solely on our experience as insurance brokers and risk consultants and are not to be relied upon as actuarial, tax, accounting, or legal advice, for which you should consult your own professional advisors. Any modeling, analytics, or projections are subject to inherent uncertainty, and the Marsh Analysis could be materially affected if any underlying assumptions, conditions, information, or factors are inaccurate or incomplete or should change. Marsh makes no representation or warranty concerning the application of policy wording or the financial condition or solvency of insurers or reinsurers. Marsh makes no assurances regarding the availability, cost, or terms of insurance coverage. Although Marsh may provide advice and recommendations, all decisions regarding the amount, type or terms of coverage are the ultimate responsibility of the insurance purchaser, who must decide on the specific coverage that is appropriate to its particular circumstances and financial position.

1166 Avenue of the Americas, New York 10036

Copyright © 2025, Marsh LLC. All rights reserved. 24-362084-GL