Contents


    Executive Summary

    Firefighting foam is a purportedly toxic substance frequently used as an effective fire suppressant. Class A foams were developed for fighting wildfires, while Class B foams were developed to fight fires caused by flammable liquids (grease, gas etc.). Recent studies have revealed serious health and environmental concerns associated with the use of certain types of aqueous film forming foam (AFFF), particularly per- and polyfluoroalkyl substances (PFAS). PFAS can be found in a variety of industrial and household products. AFFF, in addition to carrying with it significant health hazards, is also extremely detrimental to the environment. In recent years, a surplus of litigation has ensued, led by firefighting organizations, environmental groups, and state attorneys general, against the manufacturers and distributors of PFAS firefighting foams over their deleterious effects on human health and the environment.

    Background

    The Environmental Protection Agency, along with a variety of federal and state agencies have raised alarm over the use of PFAS and are looking at plans for non-thermal technologies that can be used to destroy PFAS. These foams contain a group of man-made chemicals that are bioaccumulative and toxic pollutants, sometimes called “forever chemicals.” The chemicals do not break down quickly and linger for a long time; exposure to them has been linked to a variety of illnesses, including cancers and organ damage to the liver, kidneys, and thyroid. Firefighters, military personnel, and airport workers have been deemed at high risk for developing cancers related to exposure to these foams. The insurance industry should be concerned over potentially significant liability arising out of exposure to these toxic foams, including potential payouts for workers’ compensation, violation of environmental regulations, negligence and more.

    PFAS are prevalent in firefighting aqueous film-forming foam (AFFF) solutions, which for decades have been used to extinguish flammable liquid fires. Most notably used by military installations and throughout airports, AFFF has been linked to the contamination of water in communities in which it was used. While federal action has been slow to eradicate the use of AFFF, states are leading the way against its use. For example, in 2018 the state of Washington banned the manufacture, sale, and distribution of class B firefighting foams. While the state initially permitted exemptions for the military, Federal Aviation Administration certified airports, petroleum refineries and terminals, and certain chemical plants, those exemptions were eliminated by legislation passed in 2020.

    There are currently more than 1,500 pending firefighting foam lawsuits asserting causes of action relating to cancer and other illnesses. A great number of these lawsuits target the two biggest manufacturers of AFFF foams, 3M and DuPont. Critical judgments against these manufacturers have been entered, exposing them and similar companies to uncertain future liabilities and the possibility of massive, consolidated actions. The significant uptick in firefighting foam-related litigation led Congress and numerous states to propose regulatory legislation that limits the uses for and availability of AFFF foams. In addition, the Environmental Protection Agency (EPA) has been exploring response plans as well as recommending that AFFF chemicals be added to those flagged for review by the Toxic Substances Control Act.

    Injuries and Damages

    Firefighting foam has been routinely used by firefighters in effectuating fire suppression for more than fifty years. While highly effective in combatting fires, the use of and exposure to PFAS chemicals that are contained within the forms pose serious risks. The combination of these risks may have significant consequences for insurers, particularly in the realms of workers compensation, company general liability policies, and environmental liability for long-term pollutants. In addition, many lawsuits filed against the manufacturers and distributers of AFFF have proceeded based on a tortious failure to warn theory of negligence. The victims claim that those manufacturers chose to make and sell AFFF despite being aware of various health and environmental hazards associated with PFAS chemicals. Lawsuits based on these causes of actions are uniformly calling for relief in the form of economic damages like medical costs and lost wages, non-economic damages like mental and emotional anguish and loss of consortium, and punitive damages, intended to punish the defendant manufacturers for intentional disregard or gross negligence of the risks of these foams.

    Worker’s Compensation
    Chemical-based firefighting foam has been sold for decades because of its effectiveness in extinguishing jet and petroleum fuel fires. However, major health organizations, including the Center for Disease Control (CDC), EPA, and American Cancer Society (ACS) noted that certain chemicals present in these foams have been linked to cancer in firefighters. The most common resulting cancers associated with PFAS include kidney cancer, testicular cancer, pancreatic cancer, bladder cancer, leukemia, lymphoma, neuroendocrine tumors, and prostate cancer.

    Because firefighters have been regularly exposed to these chemical carcinogens through their jobs, certain states like California, have established a statutory or judicial presumption that cancer in firefighters are per se work-related. Presumptions such as these have important effects on worker’s compensation insurance, which provides payment for lost wages and medical benefits to employees injured in the course of their employment. In exchange for such insurance, it is mandatory that employees relinquish their right to sue the employer for the tort of negligence. However, this system does not prevent firefighters and other public safety workers from suing the manufacturers and distributors of AFFF foam based on tortious causes of action where recovery is not limited to solely lost wages and medical expenses.

    Company General Liability
    Company general liability (CGL) insurance coverage protects businesses from liability for a variety of claims including bodily injury, property damage, and personal injury. CGL insurance is also used to cover litigation costs including attorney’s fees, settlements, and judgments. Firefighting foam manufacturers, including DuPont, Chemours, Preshtigo, and Chemguard have collectively paid out hundreds of millions of dollars in settlement costs for litigation stemming from AFFF pollution and environmental contamination. But current litigation including lawsuits brought by firefighters, members of the military, and airline workers have consolidated separate actions in multi-district litigation, hoping to achieve global resolution of claims for individuals who were exposed to the toxic PFAS chemicals and now have or are at heightened risk of having life-threatening cancers. Most likely these settlements will come from the individual companies’ general liability insurance, which covers common business risks like customer injury and property damage. But with the never-ending intake of new potential plaintiffs, the overall cost of the harm will likely be colossal and has the potential to exceed typical CGL policy coverage limits.

    Legislation and Regulation

    State Legislation and Regulation
    Various states passed legislation targeting PFAS chemicals and the use of toxic firefighting foams during the 2020 and 2021 legislative sessions. Examples of the pending state legislation and regulation are explored in turn:

    • California SB 1044 (2020)- Requires sellers of firefighter protective equipment to provide written notice if equipment contains PFAS. The bill also prohibits firefighting foam manufacturers from manufacturing or knowingly selling foam containing intentionally added PFAS.
    • Colorado HB 1119 (2020)- Outlines the authority of the state government to regulate PFAS chemicals and allocates funding to the Department of Public Health and Environment to address the use of toxic firefighting foams.
    • Georgia HB 458 (2019)- House bill prohibits class B firefighting foam for testing purposes if the foam contains PFAS chemicals.
    • Indiana HB 1189 (2020)- Prohibits the use of class B firefighting foams containing intentionally added PFAS for training and testing purposes unless the facility has implemented effective measures to prevent the release of the foam into the environment.
    • Maryland HB 619 (2020)- Prohibits the use of class B firefighting foam containing PFAS chemicals.
    • Michigan HB 4390 (2020)- Prohibits the use of Class B firefighting foam containing PFAS chemicals.
    • Michigan HB 4389 (2020)- Requires reports on the use of firefighting foam containing PFAS. The bill also requires the Department of Environment, Great Lakes and Energy to establish a collection program for firefighting foam containing PFAS chemicals.
    • New Hampshire SB 257 (2020)- Prohibits the use of firefighting foam containing PFAS.
    • New York SB 439 (2019)- Reduces the use of PFAS chemicals in firefighting activities.
    • New York SB 7880 (2020)- Prohibits the incineration of AFFF containing PFAS substances in certain localities.
    • Washington HB 2265 (2020)- Eliminates exemptions from the restrictions on PFAS use in firefighting.
    • Wisconsin SB 3130 (2019)- Prohibits the use of firefighting foams that contain intentionally added PFAS substances unless they are being used in emergency firefighting activities or fire prevention operations.

    Federal Legislation and Regulation
    Federal concern over firefighting foam and PFAS chemicals has dramatically increased over the past six years. The Environmental Protection Agency has led the way for regulating these forever chemicals, with Congress proposing corresponding legislation.

    PFAS Action Act of 2021
    The PFAS Action Act of 2021 (H.R. 2467), a bill under consideration by the United States Congress, would designate PFAS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). This designation would require the remediation of releases of PFAS chemicals into the environment, such as routine cleanup operations. The Act also requires the EPA to determine whether PFAS should be designated as toxic pollutants under the Clean Water Act and, if so designated, will require the EPA to establish standards to limit PFAS discharge from industrial sources into waters of the United States. Additionally, the Act requires the EPA to issue a final rule adding PFAS to the list of hazardous air pollutants, test PFAS for toxicity to human health, and to regulate the disposal of materials containing PFAS. Finally, the bill provides incentives to combatting PFAS, such as grants to help community water systems treat for PFAS contamination. As of August 2022, the PFAS Action Act passed in the House of Representatives but had yet to be heard in the Senate.

    National Defense Authorization Act
    On December 20, 2019, Congress passed the National Defense Authorization Act (“NDAA”). This lengthy law phases out the use of AFFF, subject to some limited exceptions, at all military sites by October 1, 2024. In the meantime, the NDAA forbids training exercises which cause any AFFF releases. Importantly, the provisions of the NDAA only apply to military facilities on property owned by the federal government, and do not apply to any civilian facilities. However, defense contractors should be aware of the provisions of the NDAA both for planning and risk mitigation purposes.

    EPA Health Advisory in 2016
    The EPA issued a health advisory in November of 2016 relating to drinking water contamination. While most people have been exposed to PFAS-related chemicals in consumer products, drinking water can be an additional source of exposure for communities where these forever chemicals contaminated water supplies. These communities are those neighboring PFAS manufacturing plants, including those that produce these chemicals for firefighting purposes. This advisory proposed a regulatory standard defining safe levels of PFOA and PFOS in drinking water at 70 parts per trillion.

    2019 PFAS EPA Action Plan
    In 2019 the EPA Issued a Per- and Polyfluoroalkyl Substances (PFAS) Action Plan to provide both short-term and long-term strategies to address the use of PFAS. The agency began with the Maximum Contaminant Level process for PFAS chemicals and developed maximum containment level for states and local water utilities via the Safe Drinking Water Act. The EPA Action Plan also moved to designate these PFAS chemicals as “hazardous” under the Comprehensive Environmental Response, Compensation and Liability Act (CERLCA, also known as Superfund). In addition to EPA contemplated listing these PFAS chemicals in the “Toxic Release Inventory” and announced a commitment to developing new and better methods to detect chemicals in water (drinking water, soil, and groundwater).

    2020 Action Plan Update
    In February 2020, the EPA issued a program update on its PFAS Action Plan to address PFAS in the environment. Since the initial plan was released in 2019, the EPA issued groundwater cleanup guidance and began developing a national drinking water regulation. The agency also ensured that use of PFAS class chemicals cannot be manufactured and imported without notification and review under the Toxic Substances Control Act. The update also reported that Congress had introduced 80 separate pieces of legislation in the 116th session addressing PFAS chemicals.

    Liability and Insurance

    Cut and paste straight from web page

    Litigation

    State-Led Litigation
    Many states attorneys general-initiated lawsuits against PFAS manufacturers over the harmful effects resulting from the professional use of firefighting foam. These lawsuits were later consolidated into multidistrict litigation in the District Court of South Carolina. The initial legal filings for the States of Maine and Florida are explained below.

    Florida
    Florida State Attorney General Ashley Moody filed a suit against several businesses — including DuPont, Chemours, Tyco Fire Products and Chemguard — alleging the known use of harmful PFAS materials that put state residents at an increased risk of cancer and other serious illnesses. The lawsuit is predicated on a tortious failure to warn theory. It claims that Defendants failed to warn the public about the dangers of forever chemicals contained in firefighting foams and that these foams were used in several locations in and around Florida. The foams have been used for decades to knock down fires that burn through liquid fuel at military bases, airports and industrial properties, the lawsuit says. PFAS or “forever chemicals,” these substances take an extremely long time to break down in the environment. They were also used in products like Teflon and Stainmaster carpets, the state’s lawsuit says, and put people at a significant risk for developing thyroid disease, kidney and testicular cancers, and abnormally high cholesterol.

    Moody’s office accuses manufacturers of multiple offenses, including negligence and creation of a public nuisance. The state’s lawyers wrote that the dangerous chemicals may have seeped into the ground and tainted drinking water. Attorney General Moody’s office says manufacturers knew or should have known that firefighting foams would endanger people and the environment. The complaint does not specify how much Florida seeks in compensation or other sanctions, but it says the state has already incurred costs to investigate contamination and anticipates subsequent expenses for environmental cleanup and helping sick residents.

    Maine
    Maine Attorney General Aaron Frey enlisted outside counsel to initiate a lawsuit against manufacturers of forever chemicals contained in firefighting foams. The lawsuit is expected to target manufacturers of PFAS and similar chemicals that have been used in a variety of products. PFAS-contaminated soil has been found in several locations around the state. Governor Janet Mills and state lawmakers set aside $60 million of a $1.2 billion spending package this year for PFAS relief.

    Firefighter Lawsuits
    Hundreds of current and former firefighters are suing manufacturers of AFFF specialized firefighting foam, which is highly effective at extinguishing fast-spreading fires. AFFF’s active ingredient is a group of chemical agents called per- and polyfluoroalkyl substances, commonly called PFAS. Elevated levels of PFAS were found in the firefighters’ blood late last year, and all have developed cancer or other serious health problems. Professional Firefighters Associations (PFAs) in several states, most recently Maryland, are also joining the fight for statewide PFAS bans. During a virtual news conference, Maryland PFA member Grant Walker told lawmakers that cancer has surpassed cardiac events as the number-one cause of death in firefighters over the last two decades.
    AFFF manufacturers have been dealing with PFAS-related claims for years, not only from firefighters but also from government entities and private residents exposed to PFAS in soil and water. In 2017, Chemours and DuPont paid over $670 million in settlements of toxic exposure lawsuits. In 2018, cases against the foam producers were consolidated into multidistrict litigation (MDL), which will all be handled under one South Carolina federal court for efficiency. There were more than 1,800 cases in the MDL by the end of 2021, with more to come as additional firefighter-plaintiffs continue to file suit and seek relief.

    In Re Aqueous Film-Forming Foams Products Liability Litigation MDL No. 2783 (D.S.C.).
    The Judicial Panel on Multi-District Litigation (JPMDL) ordered the transfer of all federal lawsuits to the United States Federal Court for the District of South Carolina. The cases reached the desk of the Honorable Richard M. Gergel for coordinated discovery and pretrial matters. As of August 2022, more than 2,700 AFFF plaintiffs were named in the lawsuit. While this January 2021 settlement resolved claims of drinking water contamination at one location, over 600 lawsuits alleging bodily injury and environmental contamination due to per- and polyfluoroalkyl substances (PFAS) — chemical components of AFFF. The consolidation comes as a solution to a flood of lawsuits led by various states, including New York, Massachusetts, Maine, and Florida, as well as litigation initiated by the Professional Firefighters Association. The litigation is currently in the discovery phase.

    These AFFF foam lawsuits present a challenge for defense lawyers looking to avoid billion-dollar settlements for exposure victims. Defendant companies are generally offering up the “government contractor defense” as a shield to liability. The government contract doctrine shields companies from liability for damages from products that meet specific qualifications needed to achieve military objectives; it is a common law defense based on the discretionary function exception of the Federal Tort Claims Act which can be raised in certain products liability cases, especially based on alleged design defects and failure to warn claims. Proof of the defense requires the following elements be met: that (1) the United States approved “reasonably precise specifications” for the product being supplied; (2) the product conformed to those specifications; and (3) the supplier warned the United States about dangers in the product known to them. Boyle v. United Tech. Corp., 487 U.S. 500, 512 (1988).

    If the elements of the defense are met, the defendants can avoid liability and successfully argue that the government made them engage in the alleged unlawful conduct. This defense was tested in federal asbestos litigation, where defense attorneys argued that the U.S. government required asbestos-containing products in ships and aircraft. But plaintiffs’ attorneys argued the products were still defective for failure to meet element 3 of the defense: the product didn’t come with a warning. AFFF foam suppliers may have a more powerful argument on this defense, however, because their customers include military and civilian airports. These customers were required to buy fluorocarbon-based foams and were even required to discharge it several times a year for training exercises, using it to fight actual fires. Whether the defense applies to non-military contracts depends on the jurisdiction and some courts have held that the defense only applies to cases specifically involving military equipment. These companies contend that the government not only approved but enforced the precise qualifications for AFFF. In their motion for partial summary judgment filed on November 5, 2021, in the AFFF class action lawsuit in the MDL, the defendants claim that they were required to use fluorocarbons in the product. Legal analysts disagree over the prospective ruling on that motion.

    Dupont & Chemours Settlement
    Cost-Sharing Settlement
    In January 2021, DuPont, Chemours and Corteva announced a cost-sharing agreement worth $4 billion to settle lawsuits involving the use of highly toxic PFAS chemicals and firefighting foam. DuPont was the leading manufacturer of PFAS chemicals in the United States. But due to increased liability for risks posed by PFAS, Chemours was created in 2015 as a spin off from DuPont’s chemical division, and Corteva was created as a spin off from DuPont’s agricultural division in 2019. Chemours sued DuPont in 2019, after being named defendant in many PFAS lawsuits, claiming that DuPont’s liability estimates were “spectacularly wrong” and sought indemnification and contribution for PFAS litigation liability.

    Reliable data from environmental working groups demonstrated that companies like DuPont engaged in decades-long deception about PFAS. Animal studies conducted by DuPont show that the company knew or should have known by the 1960s that PFAS chemicals build up in the blood and pose undeniable risks to human health. DuPont and Chemours reached a binding memorandum of understanding resolving legal disputes relating to the 2015 spin off. The agreement established a cost-sharing arrangement and escrow account, worth more than $1 billion, for potential future legacy PFAS liabilities arising out of pre-July 1, 2015, conduct. Under the terms of the agreement, expenses will be split in half, with DuPont and Corteva responsible for 50% and Chemours responsible for the other 50%. Both companies agreed to share the costs of certain enumerated expenses over a period of no more than 20 years or an amount over $4 billion. Facing an uphill battle of state and federal litigation, other major chemical manufacturing companies like DuPont will likely engage in similar cost-sharing agreements that may affect payouts to litigants harmed by their production of PFAS chemicals.

    Ohio Settlement
    In February 2018, Ohio Attorney General Mike DeWine sued DuPont and its spin-off, Chemours Co., for alleged chemical dumping. The action sought restitution and damages for release of the toxic PFOA chemical from DuPont’s West Virginia plant into the Ohio River. The lawsuit alleged that the companies contaminated the natural resources of the state and put Ohio residents at risk for decades knowing that the chemical likely caused deleterious environmental and health effects. In January 2021 the companies agreed to settle pending cases in a multidistrict PFOA litigation in Ohio for $83 million.

    Future Outlook

    The immediate outlook of firefighting foam and PFAS chemicals at large will be one most likely defined by significant litigation and forthcoming regulation. Individuals, states, and federal agencies have taken a closer look at the effects of PFAS chemicals and moved toward stricter regulation to limit harmful effects on human health and the environment. These regulations tend to concern (1) discharge or use restrictions; (2) disposal and storage provision; (3) notification and reporting requirements; and (4) limitations on personal protective equipment (PPE). The latter form of regulation has been adopted in some states, including Iowa and New Hampshire, and includes the prohibition of PPE for firefighters that contain any PFAS materials. It is likely that more state and federal regulators will push for such a limitation on use of PFAS materials and firefighting foam.

    While PFAS manufacturers have been the primary focus of litigation thus far, business that stored, used, or disposed of the chemicals are expected to become the central target of future litigation. This will likely result in the filing of more lawsuits relating specifically to PFAS chemicals used in firefighting foam and shift the focus of the litigation from environmental contamination to individual exposure and health risks. Similarly, the use of firefighting foam could be likened to the asbestos litigation, where long-term effects of exposure were revealed slowly and resulted in ongoing litigation as well as economically staggering liability for corporate defendants. In the meantime, there is a positive movement in the firefighting community toward relying on biodegradable firefighting foam. Such reliance would maintain the flame suppressant characteristic of PFAS firefighting foam, while eliminating the health and pollution risks associated with these “forever chemicals.”

    References

    https://www.dolmanlaw.com/blog/afff-fire-foam-forever-chemicals/    
    https://www.propertycasualty360.com/2021/05/07/firefighting-foam-claims-the-pollution-exclusion/?slreturn=20220318143646  
    https://apnews.com/article/environment-north-dakota-williston-a5fb991b50beeee1e7d0c923b8adbad8  
    https://apnews.com/article/health-fires-environment-and-nature-business-6a16a02d2bce23ede7635f9bdceff919  
    https://www.epa.gov/newsreleases/epa-us-department-defense-and-state-partners-launch-technical-challenge-seeking  
    https://www.epa.gov/sites/default/files/2020-01/documents/pfas_action_plan_feb2020.pdf  
    https://www.legalexaminer.com/legal/defective-products/firefighting-foam-lawsuits/states-are-trying-to-restrict-the-use-of-firefighting-foam-due-to-potential-health-risks/  
    https://www.triallaw1.com/nyc-firefighter-injuries-exposure-to-pfas-through-firefighting-foam/#:~:text=Similar%20to%20that%20of%20asbestos,and%20ovarian%20cancer%2C%20among%20others  
    https://adamsferrone.com/2020-5-15-aff-workers-comp-may-2020-update-firefighting-foam-cancer/   
    https://www.lezdotechmed.com/blog/mass-tort/afff-lawsuit-update/  
    https://www.millerandzois.com/firefighting-foam-lawsuits.html  
    https://www.usfa.fema.gov/blog/ig-090221-2.html  
    https://www.ncsl.org/research/environment-and-natural-resources/per-and-polyfluoroalkyl-substances-pfas-state-laws.aspx  
    https://www.ewg.org/news-insights/news-release/dupont-chemours-and-corteva-reach-4-billion-settlement-forever-chemicals  
    https://abcnews.go.com/US/wireStory/dupont-chemours-reach-agreement-forever-chemicals-75448051  
    https://www.miamiherald.com/news/local/environment/article261019177.html
    https://www.usnews.com/news/best-states/maine/articles/2022-05-17/maine-attorney-general-plans-to-sue-over-pfas-contamination  
    https://www.legalexaminer.com/legal/defective-products/firefighting-foam-lawsuits/firefighters-suing-over-firefighting-foam-dangers/  
    https://www.yahoo.com/entertainment/ohio-ag-sues-dupont-chemours-114501228.html  
    https://www.jdsupra.com/legalnews/pfas-update-state-regulation-of-pfas-in-9746408/#:~:text=Also%2C%20beginning%20on%20October%201,alternative%20to%20such%20use%20before

    In the News

    2023

    2022

    • Wolverine Worldwide, 3M to pay $54M in PFAS class settlement - Garret Ellison, Michigan Live (09/21/2022)
      Wolverine Worldwide and 3M will pay $54 million to Michigan property owners harmed by PFAS contamination under a proposed settlement in a class action case filed in the wake of the pollution discovery five years ago.

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