The U.S. Navy’s use of aqueous film-forming foam (AFFF) for fire suppression aboard ships poses significant environmental and health risks due to the presence of per- and polyfluoroalkyl substances (PFAS) in AFFF. The Department of Defense (DoD) has been a major source of PFAS pollution due to its frequent use of AFFF in firefighting and training. While AFFF is an effective fire suppressant, particularly for aviation fuel fires, its use has contributed to extensive PFAS contamination of groundwater and raises concerns about long-term environmental damage. In response to concerns about PFAS, Congress mandated that the DoD discontinue using AFFF on land. However, Congress allowed continued use of AFFF on ships.
This Note explores the environmental implications of AFFF use aboard Navy vessels, addressing both the current regulatory framework and ongoing litigation related to AFFF contamination. Analyzing the arguments for and against shipboard AFFF use, this Note recommends the Navy phase out AFFF on ships.