Although PFAS can be found in a wide range of products and materials, firefighting foams are considered one of the major sources of contamination. Here, we explore the history and use of these foams and the potential liabilities.
As research into PFAS, (sometimes known as “forever chemicals”) continues to grow, the topic is starting to influence the conversations across the commercial real estate and development industries.
PFAS, short for Per-and polyfluoroalkyl substances, may already be affecting some development projects, with certain sites potentially requiring the need for re-evaluation of plans or remediation work before full approval can go ahead.
The Environment Agency (EA) has highlighted three well-studied PFAS* which are now heavily restricted under international law, these are: Perfluorooctane Sulfonic Acid (PFOS), Perfluorooctanoic Acid (PFOA) and Perfluorohexane Sulfonic Acid (PFHxS). These substances have been used in firefighting foams since the 1960s, and have been restricted in the UK since November 2023 under the Persistent Organic Pollutants (POPs) Regulations 2024.
The majority of assessment and clean up of land contamination is actioned via the planning regime. Part 2A of the Environmental Protection Act 1990 can also be used to deal with the worst cases – where no development is planned. Part 2A was devised to provide a way of addressing the risks and liabilities of significant legacy contamination, yet to date, no sites have been designated with PFAS as the contaminant that triggers the determination.
So, where does PFAS come from?
Although they were discovered in the 1930s, and have existed for over 70 years, they largely went unregulated until the early 2000s.
- PFAS are a group of man-made chemical substances first developed circa World War Two;
- Advances in fluorine chemistry during the 1930s, led to the accidental discovery of a white, waxy substance known as PTFE in 1938, (now widely used in multi-purpose lubricating sprays often used to loosen door hinges);
- That same year, DuPont chemist Roy Plunkett invented Teflon (known as PTFE, for their use as lubricants, sealants and waterproofing);
- In 1945, the technology-based materials and solutions company DuPont trademarked PTFE as Teflon, and in 1947, mass production of PTFE had begun in the UK;
- In 1956, the American company 3M introduced the stain-resistant product Scotchguard – which also utilised the PTFE substance;
- PFAS firefighting foams, (known as AFFF) were introduced in the UK in the 1960’s – to extinguish flammable liquid fires – primarily at airports, military bases and industrial sites.
Contamination hotspots in the UK
It’s estimated by the Environment Agency that there are approximately 10,000 PFAS contaminated hotspots in the UK, many of them linked to firefighting foam. The UK’s largest commercial streamer and broadcaster, ITV televised the documentary ‘In Our Blood’ in March 2026. The documentary investigated PFAS chemicals detected in the blood of residents in Bentham, North Yorkshire — home to Angus Fire, which manufactured and tested firefighting equipment (that used PFAS-based firefighting foams) at its factory between 1976 and 2024.
Following testing undertaken as part of the TV investigation, Dr David Megson, Reader in Chemistry & Environmental Forensics at Manchester Met, said: “I’ve done a few contamination studies in my time as a scientist. I think this one is the one that stands out for such a high proportion of people having elevated exposures of PFAS. It was quite staggering (1).”
Firefighting foams
Specialist firefighting foam was first developed in the 1960’s. However some of the chemicals that made it highly effective at extinguishing fires have since been linked to serious health risks, including cancer. In 2025, the manufacture and sale of fire-fighting foam, made using “forever chemicals” was banned in the UK in 2025. The EU is implementing a broad, precautionary ban on all PFAS chemicals in firefighting foams by 2030.
As a result of growing awareness and research, concerns around exposure have prompted the Fire Brigades Union to commission research into the impacts of PFAS exposure on firefighters (2).
Whilst the foam manufacturers may have acted within the law at the time of development and subsequent use, growing research into PFAS is increasing the awareness of potential long-term risks to both human health and the environment.
The challenge now lies in limiting the impact and harm that has already occurred.
PFAS at airports: the responsibilities and liabilities
Firefighting foams used at airports have historically been a major source of PFAS contamination, particularly those associated with fire fighter training areas. While many legacy foams containing PFAS such as PFOS and PFOA have now been phased out, some alternative fluorinated firefighting foams, containing shorter-chain PFAS (often referred to as C6 compliant foams) remain legal in the UK.
Following work by the Environment Agency to prioritise their actions, those airports with licensed discharge consents were selected by the Environment Agency to provide further information about PFAS. This monitoring alone has placed a significant liability on airports. The Policy Director from AirportsUK, Christopher Snelling has indicated an average of £200,000 per airport has been spent to monitor and understand the issue (approx. £5m in total across the UK) (3). Although the full extent of information gathered has not been published, any subsequent clean up of contamination could extend these costs significantly higher.
Conclusion
As the regulatory landscape continues to evolve, airports should take a proactive approach to managing PFAS-related risks. Given the increasing regulatory scrutiny of PFAS and the potential costs associated with investigation and remediation, airport operators should ensure that their environmental management strategies adequately address both historic and emerging PFAS obligations.
(*)https://engageenvironmentagency.uk.engagementhq.com/ea-role-with-pfas
