PFAS in firefighting foam (AFFF) and equipment: State-by-state regulations

November 21, 2025

Read the full article (JD SURPA)

"Numerous states have either enacted or proposed regulations regarding per- or polyfluoroalkyl substances (“PFAS”) present in Class B Aqueous Film-Forming Foams (“AFFF”) used for firefighting, or PFAS present in firefighters’ clothing and equipment. This alert provides a comprehensive state snapshot regarding the status of these regulations across the United States, especially as significant portion of the federal activity involved with firefighting foam involves products used by the Department of Defense (“DOD”).

These regulations typically involve restrictions in four general areas:

  1. Discharge or Use Restrictions. These regulations usually limit or prohibit the use of AFFF in training or testing exercises, and may only allow the use of AFFF in active firefighting situations;
  2. Disposal, Storage, Inventory or “Take-back” Provisions. Some states have enacted state-run programs to purchase and dispose of AFFF, usually purchasing supplies from government agencies;
  3. Notification or Reporting Requirements. When continued use of AFFF is allowed, some states have required that businesses report specific details regarding their discharge; and
  4. Limitations on Personal Protective Equipment (“PPE”). Some states have limited or prohibited PPE for firefighters that contain PFAS compounds."

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