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Foam Transition Consulting

Total Group provides consulting for facilities planning to change from fluorinated firefighting foam to non-fluorinated alternatives. We assess the existing fire suppression system, identify replacement foam options and help plan the transition with the people responsible for the facility.

Foam transition consulting scope

  • Existing system assessment: Review the current fire suppression system as the starting point for the transition discussion.
  • Replacement foam options: Identify non-fluorinated foam options for consideration against the site, hazard and system information available.
  • Transition coordination: Work with facility managers, fire safety professionals and the regulatory or project contacts involved in the change.

The consultation connects the existing system, the proposed foam change and the facility’s operating requirements. It is a planning service. Testing, cleaning, removal, transport, disposal, installation, engineering and commissioning are separate questions that should be confirmed for the project rather than assumed to be included.

Why the foam and system must be reviewed together

Firefighting foam is selected for the hazard and the way the system applies it. Class B foams may be used for flammable or combustible liquid hazards, but not all products have the same composition or use case. The Government of Canada identifies fluorinated products such as AFFF, AR-AFFF, FFFP and fluoroprotein foam, as well as fluorine-free alternatives. Product names and labels alone may not establish the full composition, so keep the safety data sheet, technical data sheet and manufacturer information with the transition record.

Canada’s federal guidance says fluorine-free alternatives should not be treated as automatic “drop-in” replacements for AFFF. A change can affect product suitability, application approach, equipment compatibility, proportioning and the evidence needed for the system and hazard. The proposed replacement therefore needs to be considered with the protected area, fuel or process hazard, discharge devices, proportioning equipment, storage arrangement and the system’s design and service history. See the Government of Canada guidance on PFAS and AFFF for the federal context.

Canadian regulatory and disposal context

In Canada, the applicable requirement depends on the product, the facility, the work and the jurisdiction. The Government of Canada’s current AFFF guidance states that the Prohibition of Certain Toxic Substances Regulations, 2025 came into force on June 30, 2026. It describes restrictions and time-limited transition provisions for C8 AFFF, including requirements to contain and dispose of releases from certain installed-system testing in an environmentally sound manner. It also explains that Canada is considering further controls for PFAS that are not currently regulated, including C6 AFFF. Proposed or planned federal measures should not be treated as enacted requirements until the applicable instrument is in force.

Foam identification is an early planning step. Canada’s guidance notes that C6 is not currently prohibited under the page’s source guidance, while PFOS-based AFFF has been prohibited since the end of 2013 subject to limited residual-equipment exemptions. It also warns that an SDS may not disclose every PFAS ingredient. Contacting the manufacturer or arranging appropriate laboratory analysis may be needed to clarify the product. Total Group can discuss the information available for the transition; the applicable legal conclusion remains a site- and product-specific matter.

Disposal is not a universal “pour-off” or drain-down decision. The federal guidance directs AFFF to an authorised hazardous-waste management facility and says provinces and territories approve, license and monitor waste operations. In Alberta, the government describes waste with corrosive, flammable, reactive or toxic properties as hazardous and points to legislation and guidance governing its management, recycling and disposal. Waste classification, containment, transport and receiving-facility requirements should be confirmed for the material and location. Do not assume that a foam labelled fluorine-free has the same waste pathway as a fluorinated product.

Testing is one part of the transition decision

Installed-system testing, acceptance or discharge work can answer different questions from a planning consultation. A dry or surrogate-liquid method, including PlanitSafe testing where relevant to the project, does not automatically replace every wet test, acceptance test or other requirement that may apply to the system, adopted code, insurer or authority. Confirm what the applicable jurisdiction and project documents require, what the selected method evaluates and how any release will be contained and managed.

The NFPA Fire Protection Research Foundation’s Firefighting Foams: Fire Service Roadmap identifies transition topics that include equipment cleaning, effluent disposal, proportioning, calibration, discharge containment, documentation and engineering concerns. These are useful questions for the project team. They are not a statement that every item is included in Total Group’s consulting scope or that one test establishes complete system readiness.

When to discuss a foam transition

A consultation can support planning when a facility is considering a non-fluorinated alternative, reviewing an existing foam inventory, coordinating a change with a maintenance window or shutdown, or bringing facility management, fire safety and project contacts into the same discussion. It can also help organise the questions that must be answered before a product change, system work or waste decision is assigned.

What to prepare for an inquiry

Share the information you have and identify gaps. Useful details include:

  • Current foam: Product name, label photographs, SDS or technical data sheet, concentration, approximate quantity and storage location. Include any proposed replacement product.
  • Protected hazard: Area or process protected, fuel or chemical involved, operating conditions and any known changes to the hazard.
  • System and equipment: Drawings, foam tank or container details, proportioning equipment, discharge devices, control arrangements and nameplate information.
  • Existing records: Inspection, testing, maintenance and commissioning records, prior deficiencies, system changes and available product or laboratory information.
  • Site timing and contacts: Reason for the change, target work window, access or operating restrictions, facility manager, fire safety lead, project team and any regulator, insurer or client requirements already identified.

Discuss foam transition planning

Tell Total Group which foam system you are reviewing, why you are considering a change and when you expect to make the decision. Include current foam information, the protected hazard, system records and any replacement product under consideration so the team can discuss the consulting requirements and the boundaries of the work.

For the wider service offering, visit Total Group Fire Services.

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Discuss foam transition planning