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Rural and Regional Affairs and Transport References Committee
14/03/2019
Provision of rescue, firefighting and emergency response at Australian airports

SCULLY, Mr Brendan, Senior Technical Officer, Fire Protection Association Australia

STAINES, Mr Brett, Chairman, Special Hazard Fire Protection Systems TAC 11/22, Fire Protection Association Australia

Committee met at 13:11

CHAIR ( Senator Sterle ): I declare open this public hearing of the Senate Rural and Regional Affairs and Transport References Committee. The committee is hearing evidence for its inquiry into the provision of rescue, firefighting and emergency response at Australian airports. I welcome you all here today. This is a public hearing and a Hansard transcript of the proceedings is being made. Before the committee starts taking evidence, I remind all witnesses that in giving evidence they are protected by parliamentary privilege. It is unlawful for anyone to threaten or disadvantage a witness on account of evidence given to a committee, and such action may be treated by the Senate as a contempt. It's also a contempt to give false or misleading evidence to a committee.

The committee prefers all evidence to be given in public, but under the Senate's resolutions witnesses have the right to request to be heard in private session. It is important that witnesses give the committee notice if they intend to ask to give evidence in camera. If a witness objects to answering a question, the witness should state the ground upon which the objection is taken. The committee will determine whether it will insist on an answer, having regard to the ground that is claimed. If the committee determines to insist on an answer, a witness may request the answer be given in camera. Such a request may of course also be made at any other time. On behalf of the committee, I would like to thank witnesses for their submissions and for appearing here today.

I now welcome witnesses from Fire Protection Association Australia. The committee has received your submission, which it has numbered submission No. 2 and published on its website. Would you like to make any amendments or additions to your submission?

Mr Scully : No.

CHAIR: In that case, I'm going to offer you the opportunity to make an opening statement before we go to questions. Who'd like to open the batting?

Mr Scully : I will. FPA Australia is a not-for-profit organisation with over 1,650 members, incorporating over 8,500 individuals across the fire protection sector. Members include providers of both fluorine-free and fluorinated firefighting foams. As a result of keen focus in recent years on historical contamination resulting from the use of firefighting foams at sites across Australia, FPA Australia has developed guidance documents, including an information bulletin on the selection and use of firefighting foams, and delivered a number of seminars to highlight the issues associated with the correct selection of firefighting foams. Our position has been developed based on input from relevant stakeholders and in line with our vision, which is a safer community where loss of life, injury and damage to property and the environment are eliminated through effective fire protection.

Use of firefighting foams at airports is of critical importance to allow passengers to escape fires. Ensuring good aerodrome firefighting outcomes is strongly linked to foam performance. Although fluorine-free firefighting foams have been adopted in some Australian states and overseas for aviation risks, we recommend caution. Fluorine-free foams have significantly different physical and firefighting properties to the foams that they are replacing, and this can impact fire safety outcomes, especially in situations where seconds are critical to life safety. FPA Australia therefore recommends caution before placing government restrictions on the use of C6 fluorotelomer firefighting foams for airport and hangar applications.

FPA Australia also wishes to highlight concerns with the ICAO test protocols used to approve foams for use in the aviation sector, particularly in relation to Australia's climate. Protocols of the ICAO permit testing to be completed in ambient temperatures as low as 15 degrees Celsius, conditions far more favourable than experienced in Australia for most of the year. The protocol also allows a number of different fuels to be used for the test. These fuels have different flashpoints, and use of a different fuel can impact the performance of the foam. Finally, the test protocol uses delivery equipment which provides very favourable aspiration, better than what would typically be expected in actual use of the foam. To prove a foam will work effectively in an aviation incident, we believe the fire test method must consider the extremes of the Australian climate and use the most volatile type of fuel that may be encountered, while being applied to the fire with a delivery device that replicates the aspiration that will be delivered in the field.

In summary, we contend that the ICAO level B test should be amended. It should be conducted at much higher minimum temperatures, reflective of extreme Australian conditions. It should be conducted with Jet A-1 fuel and it should be conducted with foam nozzles that provide an expansion ratio that is typical of that available during an incident. This approach should be adopted regardless of if the foam used is fluorine-free or a C6 fluorotelomer foam type. We would welcome the opportunity to develop a suitable detailed test protocol that represents Australian conditions with Airservices Australia and other stakeholders.

Finally, we wish to highlight that most historical contamination has not been as a result of actual firefighting incidents. Most historical contamination was the result of poor practice during testing and training. This contamination could have been prevented by alternative testing and training practices. These practices are now widely adopted and the increased focus on the environment means such widespread contamination is unlikely to reoccur, regardless of the type of foam used at the facility. Thank you.

CHAIR: Thank you, Mr Scully. I'm going to go to Senator Gallacher because he's done an extensive body of work in this area.

Senator GALLACHER: To carry on from that theme, have you had any engagement with the ARFFS regulators regarding transition to different or new firefighting foams? Are you talking to people about that?

Mr Scully : Not directly, no.

Senator GALLACHER: You don't have any engagement with the people who are actually using the new foams?

Mr Staines : Not in the aviation sector so much, but certainly in private enterprise. Some of the association members are obviously involved with foam replacement activities for some of the airlines, including Qantas and those sorts of facilities. Some of the members are suppliers of foam to Airservices and other facilities. As an association, we haven't had any direct engagement with people like Airservices on this.

Senator GALLACHER: I also chair the Foreign Affairs, Defence and Trade References Committee, and we have an issue on almost every military facility and non-military facility in the country about PFAS and PFOA.

Mr Staines : Absolutely.

Senator GALLACHER: You're actually saying that you're the organisation that represents the industry that supplies these chemicals, for want of a better word, and you do not have any formal interaction with the operators, users or service providers on these facilities?

Mr Staines : I think that is probably a fair statement. We have had interaction with some of the environmental agencies, the federal department of the environment, but, yes, there has been no official engagement.

CHAIR: Have you tried, and you do not get a return phone call or are you sitting back waiting for the phone to ring?

Mr Staines : We have been very active over the last five years. As you know, this has been a very topical subject on environmental grounds. One of the concerns we've had as an association is that the environmental issues seem to have pushed the fire protection aspects into the back seat. We have done a lot of work to try and get some recognition out there that, yes, we accept that environmental issues are real and they need to be addressed, but please don't forget that firefighting foam's prime purpose is to put out fires, and being able to put out fires effectively is important in delivering good environmental outcomes. But it has been difficult to get that message across because the environmental headlines seem to have grabbed the oxygen from the room, if you like.

Senator GALLACHER: Your submission notes and promotes improvements to the legislation, codes and standards for improved fire industry outcomes. Are you interacting with the regulatory bodies in the government?

Mr Staines : Yes, we have been with the environmental departments nationally. We have been working hard.

Senator GALLACHER: How does that work? Is that a quarterly meeting?

Mr Staines : No, nothing that formal, nothing as systematic as that. Queensland is probably the leading driver on this in making regulatory changes, so we've had a lot of involvement or discussions with them over the years. We have had very few face-to-face meetings, I have got to say. We invited them to participate in some seminars and things that we have run. We have gone to seminars they have run. I think it would be fair to say that most of their concerns we agree with; however, we have not been satisfied with the attention given to the firefighting performance. We really do think that has been in a lot of cases overlooked and not given the attention it deserves.

Senator GALLACHER: Would you contend that you, as an expert body in the industry, would have a pertinent view on any of the improvements, legislative or otherwise?

Mr Staines : We've got representatives from all aspects of the industry, a large variety of backgrounds in the industry, and we are involved heavily in the development of standards and so on.

Senator GALLACHER: On the standards, are we using best practice international approaches to firefighting foam at the moment?

Mr Staines : Best practice in relation to what?

Senator GALLACHER: Do you believe that Australia is using the best practice international approaches to the use of firefighting foams?

Mr Staines : Industry has definitely changed its practices in the use of firefighting foams. Where we would have regularly discharged foams into the environment for the purposes of testing and training, those practices have obviously changed in recent years. From that point of view, yes, I think so. If you are asking about test standards as far as foam approvals and stuff, our concern is that some of the test protocols do not represent Australian conditions, so we may be eroding factors of safety that we previously have had.

Senator GALLACHER: Do we meet the ICAO requirements, though, in Australia?

Mr Staines : Foams that are being sold in Australia do pass the ICAO requirements. But, again, the concern we have is that the ICAO requirements are relatively easy to pass given the environmental parameters that they set, so you can do your testing at as low as 15 degrees Celsius. The higher the temperature, you would argue, the more difficult it is to put out the fire. So, as Australia has much higher temperatures than that typically for most of the year, we would suggest that that test parameter is not really appropriate for Australia.

Senator GALLACHER: With that in mind, what does your organisation feel on how things could and should be improved in Australia? How can we improve what we are currently doing?

Mr Staines : By setting realistic test parameters—that is one of them.

Senator GALLACHER: You have suggested that and no-one takes any notice?

Mr Staines : Yes, I think that is probably fair to say.

CHAIR: What's their reason for just ignoring you? Did they come out and say, 'We disagree with you,' or is it that if they ignore you long enough you might go away?

Mr Staines : I don't know what the reason is, but certainly we haven't been overwhelmed with a response saying, 'This is why 15 degrees is relevant,' or whatever. The other thing to bear in mind is that the real driver in recent times has been environmental issues. People are tending to go to the fluorine-free foams, and that's fine. We've got no issue with fluorine-free foams provided they provide the level of fire performance required. The issue is that the fluorinated foams had levels of safety. They were very versatile and delivered very high-performance characteristics. Although the test protocol was still at 15 degrees Celsius, the foams would typically perform in various scenarios very effectively. We don't have the same confidence with the fluorine-free foams now. We're not saying they're no good; we're just saying that they need to be tested more rigorously than perhaps we would have done in the past. We had an extra safety factor with the performance of the types of foams that we were using. Fluorine-free foams have significantly different performance characteristics to the foams they're replacing, and typically they're not as good in some characteristics. That's why we have the concern.

Senator GALLACHER: Defence have a huge legacy issue around Williamtown, Oakey and the like, and they're struggling to deal with it despite all the energy that's been put into it. But, to turn it around a bit, are they putting the same amount of energy into preventing this from happening again by using the best available foams in their operations?

Mr Staines : The easy way out of this is to say, 'We're using fluorine-free foams.' That's to be seen to be doing something or to be seen to be doing the right thing. Our contention is that that might not actually give you the best environmental outcome. The real issue with historical contamination was not using the foam in firefighting; it was using the foam in testing and training. Regardless of the type of foam you used, if they'd have changed their training and testing practices, we could have eliminated that historical contamination. Going forward now, regardless of the type of foam used, we don't release foam into the environment like we used to, so you wouldn't expect that situation to continue.

Senator GALLACHER: I'm just trying to get my head around it. What federal department would cover off on these types of regulations in respect of firefighting foam? Is it CASA, or is it the department?

Mr Staines : I'm not sure. CASA or Airservices would be my guess.

Senator PATRICK: I've mucked around with AFFF in the past on a submarine. I'm just trying to understand why foam is the best option, and is that the case simply in the case of a burning aircraft? What's the reason for saying that foam is an important technique?

Mr Staines : Foam is a very versatile firefighting agent. The key reason it is used in fighting flammable liquids is that the firefighting agent will float on the fuel surface. It's lighter than the hydrocarbon.

Senator PATRICK: It works by smothering the fire of oxygen. Is that right?

Mr Staines : Correct. It does that through a number of mechanisms: it smothers the fire, it cools the fuel surface down and it prevents radiant heat releasing vapours from the fuel. It's got a number of properties. The key one though is that it will flow across the surface of the flammable liquid. If you just use water by itself, unless it is very finely atomised, it will just sink below the fuel surface. You could put a hose stream on it and it's not going to do anything to fight the fire. So foam is a very valuable tool in airports and aviation rescue situations.

Senator PATRICK: But there is nowhere else where they use other things like CO2?

Mr Staines : Not in modern accidents. You can use dry chemical powder or something like that, but again that tends to dissipate very quickly. You need large volumes of it. You can lay a blanket of foam and you'll have a period of time where you've got some fire securement.

Senator PATRICK: I presume you can also throw it into the engines. They had a problem with that Qantas flight in Singapore—

Mr Staines : I'm not sure whether they put foam in that or whether it was just water.

Mr Scully : In 2016?

Senator PATRICK: Yes.

Mr Scully : Yes, they did use foam. I believe it was an engine fire, and they managed to put the fire out relatively quickly—within five minutes, apparently. I believe they used a fluorinated foam to do that. There are two types of foam, AFFF and FFFP. AFFF is aqueous film-forming foam and FFFP is the more natural version, which is film-forming fluoroprotein. Both of them have fluorine. They probably used the traditional foams, not the new C6 variety, which is a different formulation.

Senator PATRICK: Just in terms of these foams, you have said that the environmental damage we are suffering from PFAS around the country is a function of not its primary use, which is putting out a fire on an aircraft, but training and other things. Is that because people have just sprayed this stuff on a lawn or whatever? What is the remedy in the training and the testing stages to ensure that the environment is not damaged?

Mr Staines : The remedy is not to use it in those applications. You want to use your foam for a fire. There are other techniques you can use to test systems and also to conduct fire training. Where people were using AFFF for their training and testing of systems, that is where most of the release to the environment has occurred, because the manufacturers and providers of the foam were essentially saying back then that with this stuff there is no problem. You can fertilise your yard with it or whatever. There is no consequence from using it. But we now know that that's clearly not the case.

Senator PATRICK: But isn't it the case—and I'm just drawing back to my Navy experience—that there is nothing like getting thrown into a ship mock-up with a real fire and using hoses and having people trying to put out that fire? It gives you that realism where your adrenaline gets up and all those sorts of things?

Mr Staines : There are absolutely applications where you do want to use the real stuff in fire training, but you would want to make sure that the effluent as a result of that training is contained, treated and disposed of appropriately.

Senator PATRICK: So you're saying that if you did that, only use this on real fires? I presume they don't happen very often. How many times would we see a real fire at an airport in Australia?

Mr Staines : Not that often. That is part of the issue, I guess.

Senator PATRICK: If some other approach were to be used, I presume it would change the approach that you would take to firefighting and therefore the number of people and equipment that might be involved.

Mr Staines : Correct.

Senator GALLACHER: Before you go, your contention is that in the absence of fire—and we don't want one—we're not testing the appropriate and best chemicals for the best outcomes?

Mr Staines : Sorry, just the last bit of your sentence?

Senator GALLACHER: For the best outcomes possible: you're saying that we're testing it at 15 degrees internationally when we're more likely to be at 40 degrees.

Mr Staines : Correct.

Senator GALLACHER: What is the remedy for this? Is someone going to look at testing to get the best possible outcome in the absence of an actual fire?

Mr Staines : I guess why we're here is to try and raise the awareness of the issue that we believe exists. We think the testing regime needs to be modified for Australian conditions, because using the ICAO protocol, which is suitable for Europe, probably, may not be suitable for here. Whether there is a problem or not with the foam performance, we don't know unless we do the test. So we are just raising that, potentially, there is—

Senator GALLACHER: Is there a regime whereby you can actually clinically do a test like this? You can set it up?

Mr Staines : Yes. There is a standard test protocol. What we are suggesting is that some of the test—

Senator GALLACHER: Who is the responsible entity to organise and conduct that test?

Mr Staines : I'm not sure. I assume it would be CASA, but I don't know. I don't know who—

Senator GALLACHER: They have basically ticked off on a standard, which is 15 degrees, whereas most airports in Australia would be either the hottest or the coldest places on any given day—

Mr Staines : Correct.

Senator GALLACHER: given the amount of tarmac or whatever. So you're alerting this committee to the fact that it probably should be closer to 35 or 40?

Mr Scully : We believe that they may be using ICAO level B as a benchmark; we can't be sure. We're not CASA and we're not Airservices.

Senator GALLACHER: What sorts of costs would there be with a test like this? Is it a hugely expensive exercise?

Mr Staines : I wouldn't have thought hugely expensive. It's a small-scale test apparatus. If you had the equipment already, you'd be talking thousands or tens of thousands of dollars to do a test.

Senator GALLACHER: And, potentially, it could be proven that we haven't got the best possible foam—

Mr Staines : Or, alternatively, it could be proved that everything is okay. We don't know. The concern we have is that, with the foams we used to use, we had a high level of safety margin. What we're saying now is that the new foams don't have that same safety margin. Is the margin that we have sufficient to allow us to provide good fire protection under Australian conditions? We don't know. We think it does need to be—

CHAIR: And there have been no tests anywhere around the world on this stuff.

Mr Staines : There's certainly been a lot of independent testing by other manufacturers of competitors' products, where they claim to have an ICAO approval. Even under very favourable conditions, they haven't been able to replicate the result. There is widespread understanding within the manufacturing sector of firefighting foams that foams do have certificates, but we haven't been able to verify the performance ourselves. That's one of the problems with these things. As an end user or consumer, if the supplier provides you with a certificate that says that everything's okay, people take that at face value. What we're really saying is that you can't do that anymore. You really need to do some more validation yourself to prove that what they're telling you is correct. Unfortunately, over the last five years there have been a number of instances where what people have been told has proven not to be correct.

CHAIR: We are well aware of that. You only have to look at the quality of building—

Mr Staines : It's exactly the same issue.

CHAIR: that applies in this nation. It comes from China, predominantly, and I don't mind saying it as it is—it's true.

Senator GALLACHER: Is this area a state, territory or federal responsibility?

Mr Staines : I would have thought it's a federal responsibility.

Senator GALLACHER: We know that 44 million passengers go through Sydney Airport every year, so it would probably be worth investing a couple of bucks to make sure we've got the right gear—

Mr Staines : That's what we contend, yes.

CHAIR: Thank you very much for coming today. We do appreciate that.