Trend Overview: What States Are Doing

The FSSA PFAS Task force continues to monitor regulations across the US. The focus of this update is on Nonessential Consumer Products (carpets, clothes, ski wax). States including Connecticut, Colorado, Illinois, Massachusetts, New Hampshire, New Jersey, North Carolina, and Rhode Island have proposed broad OECD style bans but have so far paused or rejected them.

Key State Snapshots Relevant to Suppression Industry

Maine – (2021 law)

• First consumer‑product PFAS ban.
• Potential for “currently unavoidable use” exemptions. Fire was not initially granted that exemption. We continue to pursue, as Maine granted other SNAP products to be exempt.
• Full ban by 2030.
• Reporting required since 2023.

Minnesota – HF‑2310 / “Amara’s Law” (2023)

• Bans 11 consumer product categories by January 1, 2025.
• Full ban by January 2032 unless designated 'currently unavoidable use' by MPCA.
• PFAS reporting required by July 1, 2026. Was initially January 1, 2026 but delayed to July 1^st by the Minnesota Pollution Control Agency.
• All manufacturers of products with intentionally added PFAS need to submit a report and pay a $1000 initial fee with $500 annual fees afterwards. No reporting exemptions.

New Mexico – HB 212 (signed Apr 8 2025)

• Phased product bans for cookware, firefighting foam, etc. starting in 2027
• SNAP listed materials, like most clean agents, are exempt. SNAP products are exempt from reporting
• Full ban by 2032 unless exempted via Environmental Improvement Board (EIB).
• PFAS reporting required by nonexempt manufacturers starting January 1, 2027; enforcement includes fines up to $15,000/day.

Take‑Away for FSSA Members

• Existing and emerging state laws target firefighting foam and suppression-related PFAS.

• Phased rollouts allow time for strategy adjustments on procurement and compliance.

• Exemptions for industrial/essential use exist but require proactive industry engagement.

• Stay informed on 'currently unavoidable use' definitions from state agencies.

• Help coordinate FSSA member action during critical rule‑making windows.

Map of Relevant PFAS Bills and Status by State

To My FSSA Family,

I hope everyone is enjoying their summer, whether that means poolside relaxation, family vacations, or just finding a few extra minutes of daylight after work to remember there's a world beyond special hazards, though let's be honest, we never really stop thinking about them.

FSSA recently submitted CAM 855-15 to help ensure that NFPA 12, 2001, and 2010 remain referenced in the upcoming 2026 edition of NFPA 855. These standards are essential for maintaining options when it comes to providing automatic fire control and suppression systems.

At the NFPA Technical Meeting, several FSSA members stood up to speak in support of the CAM - and it paid off with a favorable vote. This wasn’t a one-person effort. It came together because our members worked closely with one another and with other associations to get the language right and build support. It’s a great example of what can happen when we coordinate, collaborate, and speak with a unified voice.

A design tip exists that suggests using the Minimum Design Concentration (MDC) plus 15% extra clean agent combined with continuous air mixing ensures a proper hold time as required by NFPA 2001, 2025 edition. (All references to NFPA 2001 in this document refer to the 2025 edition unless otherwise noted.) An FSSA task group was assigned to verify whether this 15% additional clean agent provides a 10-minute hold time prediction for continuous mixing situations.

The task group used the simulation method given in NFPA 2001 to estimate the hold time for an enclosure with continuous air movement versus the predicted hold time in the same enclosure with air movement shut down at the time of discharge. This is the same method commonly used to fulfill NFPA 2001 system acceptance criteria.

Attached below is the final New Mexico PFAS bill that passed both houses and was signed by the Governor.  The law prohibits the sale of certain products containing PFAS in 2027 and 2028, and all products containing PFAS in 2032.  The law contains numerous exemptions including the following exemption for products listed as acceptable under SNAP:

(12) a product that contains intentionally added per- or poly-fluoroalkyl substances with uses that are currently listed as acceptable, acceptable subject to use conditions or acceptable subject to narrowed use limits in the United States environmental protection agency's rules under the significant new alternatives policy program; provided that the product contains per- or poly-fluoroalkyl substances that are being used as substitutes for ozone-depleting substances under the conditions specified in the rules.

read report

If you are attending the 2025 NFPA Conference & Expo, FSSA recommends the following voting guide at the NFPA Technical Committee Meeting June 19-20, 2025 following the NFPA Annual Convention:

CAM 10-4  -  FSSA Recommendation: Support

The FSSA Technical Committee reviewed the possibility of having an abort switch override a manual release for instances including:

• Disgruntled employee discharge
• Door Closure
• Damper Closure
• Power shunt

1. In review of NFPA 2001 (2025 ed) 9.6 we noted the Manual Release shall override the abort. After a short review we aborted the idea of an abort switch override of the Manual Release function.  We unanimously agreed that disgruntled employee discharge was not anything we can control and was not common.
2. We also reviewed NFPA 2001 (2025 ed) 9.4.7shutting down supplementary equipment.  This section is very non-descriptive and just says the devices for shutting down supplementary equipment shall be considered part of the system.  We agreed to review the possibility of suggesting to NFPA the adding of language to this section for the door closure, damper closure, and power shut down.  We asked the Technical Committee if anyone had any specific case scenarios that would require modification of the current standard.  To date no one has commented. 
3. Time Delays are covered in NFPA 2001 (2025 ed) 9.7.  Agreed this is sufficient language.

FSSA has received a request from Tom Cortina, representing the Fire Fighting Foam Coalition (FFFC), asking FSSA members to consider financial support to oppose legislation in New York State (Senate Bill 3659) that requires the manufacturer to recall AFFF sold into the state. 

The existing NY law is here and the bill amending the law is here.  Though the recall obligation is squarely on the agent manufacturer it is not entirely clear that downstream sellers also share this responsibility.

Released January 21, 2025

Wet collections are natural history specimens immersed in liquid preservative solutions and typically stored or displayed in glass or plastic containers. The preservative solutions are predominantly ethanol, formalin or isopropanol.

The primary purpose of wet collections is for scientific research. In some instances, wet collections may be of species that are rare or extinct. These collections are not only irreplaceable, but they are also inherently hazardous to store and handle without proper precautions.

The following is a summary of new regulations published October 11, 2024 affecting companies that fill, recharge, recycle, and/or service fire suppression equipment containing HFCs.  Note that these reporting and recordkeeping requirements are in addition to agent test and recordkeeping requirements which became effective September 18, 2023 and the reporting requirements for recyclers of fire suppression HFCs which became effective in 2022.

Attached below is a copy of the Environmental Protection Agency (EPA) Final Rule (89 Fed. Reg. 82682, Oct. 11, 2024) on the management and reclamation of HFCs under the AIM Act. The Rule goes into effect on December 10,2024.

Here is a summary of the Rule’s requirements applicable to use of HFC (Hydrofluorocarbons) agents in fire suppression systems. References below are in 40 CFR Part 84 of the Code of Federal Regulations.

FSSA is in the process of preparing the agenda for the division meetings at the 2025 Annual Forum. If you are a FSSA Installer or Manufacturer Member, please take a minute to submit topics that you'd like to have discussed during the March 3 meeting. (Member login is required.)

MANUFACTURER MEMBERS SUBMIT TOPICS HERE

INSTALLER MEMBERS SUBMIT TOPICS HERE

The deadline to submit topics is January 13, 2025.

Tuesday, October 8, 2024 14:00 BST | 9:00 a.m. EDT

FSSA Members are invited for a kick-off event hosted by Latam PCI to mark the start of a series of international activities celebrating the official recognition of International Fire Prevention Day by the United Nations.

The U.S. Environmental Protection Agency has issued regulations to implement certain provisions of the American Innovation and Manufacturing Act of 2020. This rulemaking establishes an emissions reduction and reclamation program for the management of hydrofluorocarbons (HFCs) that includes requirements for:

• Effective January 1, 2030, only recycled HFCs may be used for the “initial fill” of newly manufactured fire suppression systems;
• Effective January 1, 2026, only recycled HFCs may be used to recharge and service fire suppression systems;  
• Effective January 1, 2026, fire suppression systems technician training is required, and
• Recycling of HFCs prior to the disposal of fire suppression equipment containing hydrofluorocarbons in compliance with the rule is mandatory.

The Rule will go into effect 60 days after it is published in the Federal Register. 

The July 2024 Halon Alternatives Research Corporation (HARC) Newsletter provides a very valuable and timely snapshot of where the industry is today on the regulation of PFAS substances used in fire protection. Read the full newsletter.

For the latest news and resources surrounding PFAS, visit the FSSA PFAS Resource Center.

Due to combined efforts, proposed legislation in Alaska was amended to remove “firefighting substance” and replace with “firefighting foam.” In early 2023, an Alaskan Senate bill was introduced with the intention of regulating the use of firefighting foams, but the wording referred to “firefighting substances.” There was concern that that this could be interpreted to also regulate clean agents.

As reported by HARC, there were combined efforts by a local fire equipment distributor in Alaska and lobbyists that work for the American Chemistry Council (ACC) to convince legislators to change the language so as to focus on firefighting foams containing PFAS and not clean agents. In the spring of 2024, an amendment was introduced and SB 67 was enrolled as a Law to become effective January 1, 2025.

Two certified amending motions on NFPA 72 will be balloted at the technical meeting on June 20, following the NFPA Conference (June 17-19 in Orlando, FL). The Automatic Fire Alarm Association (AFAA) has recommended to its members the following positions on these CAMs.

CAM 72-2  Support
CAM 72-6  Oppose

Calling FSSA Members in the NJ area:

The New Jersey Division of Fire Safety's Fire Protection Equipment Advisory Committee is looking for applicants that are members of FSSA to serve on this New Jersey committee.

The purpose of the committee is to make recommendations to the Commissioner of the Department of Community Affairs. Recommendations may include rules and regulations pertaining to professional training, standards, identification, and record keeping procedures for certificate holders and their employees, classifications of certificates necessary to regulate the work of certificate holders and other matters necessary to effectuate the sections of the Uniform Fire Safety Act. Pursuant to N.J.S.A.52:27D-25o, the Director of the Division of Fire Safety shall serve ex officio, as well as eleven public members appointed by the Governor.

Hello FSSA Members,

Are you attending the upcoming NFPA 2024 Conference June 17-19 in Orlando? If so, we invite you to join us for the following FSSA sessions:

Please share this information with anyone you may know who is or will be enrolled in a fire protection program and/or any schools that have a fire  protection program.  To qualify for a scholarship, the applicant must complete the FSSA Scholarship Application online form and upload the necessary documents to FSSA Educational Foundation Headquarters by Saturday, June 1, 2024.