Fire retardants have been produced for almost 60 years by a company whose name and ownership have changed five times since 1997 — starting with Monsanto in 1963, then Solutia, Astaris, ICL, and finally in 2018 Perimeter Solutions. For the last 20 years they have had virtually no competition, but last year a new company emerged seeking a share of the market.
In 2021 Fortress Fire Retardant Systems was able to get a coveted position on the U.S. Forest Service’s Qualified Product list (QPL) for long term retardant. As of May 5, 2021 their Fortress FR-100 was shown as conditionally qualified for use by fixed wing air tankers and in helicopter buckets, meaning that it “complies with all requirements in the specification for laboratory evaluation”. The conditions were that it would be evaluated after loading 200,000 gallons of FR-100 onto air tankers at Missoula, Montana as they departed to wildfires. The ease and effectiveness of mixing, loading onto air tankers, and slowing the spread of wildfires were to be assessed as each of those gallons made their way through the logistics and tactical stages of use. That trial was completed last summer and so far there has been no change in the published status of the retardant on the QPL.
In gathering facts for this article, among other sources I used a July 12, 2021 letter sent to the Chief of the Forest Service signed by Presidents of three air tanker companies, a report by the Forest Service about the Missoula trial of Fortress retardant, and other documents publicly available. In addition, while at the Aerial Firefighting conference in San Diego I separately met with the CEOs of both Perimeter (Edward Goldberg) and Fortress (Robert J. Burnham) who each were accompanied by three to five other executives from their companies while we talked.
In the interest of full disclosure, Perimeter Solutions has in the past placed advertising on Fire Aviation.
Corrosion
The letter from the three air tanker companies about Fortress retardant said that while they support the exploration and consideration of additional fire-retardant technologies, they wrote that they were concerned about “the potential of corrosive impacts from the product on the airtanker asset. It is widely reported that magnesium chloride can cause significant damage to concrete, stainless steel, aluminum, and other metals.”
One of the main components of Fortress FR-100 is a salt, magnesium chloride. Fortress obtains it from an operation that extracts it from Great Salt Lake brine in Utah. It can also be made from the solar evaporation of seawater. There is no doubt that pure magnesium chloride is very corrosive. In our March 22 meeting, Fortress said about the corrosion concerns,
“They single out mag chloride and they start talking about it as if we send it up in airplanes in the raw, it’s like, ‘Hey, we’re gonna put raw salt up there.’… Chloride would be very corrosive. The science of what we do, what we spend our money on, what Joe [McLellan PhD] has an entire team doing all day is figure out how to neutralize corrosion. That’s what [Perimeter] does as well, but not as well as we do. Look at our corrosion numbers. Look at our aquatic toxicity.”
Fortress’ test of corrosion on 2024-T3 Aluminum.Dr. McLellan leads Fortress’ work to mitigate the corrosion caused by the retardant, for example adding corrosion inhibitors to the product. During our meeting in a breakout room at the conference he explained a little about how that is done and the tests the Forest Service and the company conduct to detect and measure corrosion. He then went to his backpack and pulled out handfuls of small plastic bags all containing “coupons” of metal strips — 2024-T3 Aluminum to be precise — saying they ran the same exact tests the Forest Service requires for retardants to be on the QPL. He removed the coupons from the bags and carefully laid them out on the black tablecloth, each approximately an inch or so wide and about four inches long. They were labeled for the type of retardant, Fortress’s FR-100 or Perimeter’s LC95A-Fx. Some were tested with ready to use (RTU) retardant mixed and appropriate for loading onto an air tanker, and others for the concentrate (Conc.) that would need to be mixed with water before being used in an aircraft.
The coupons had been tested by immersion into the retardant for various lengths of time and at different temperatures.
Dr. McLellan held up a couple of the coupons labeled LC95A-Fx that had far more discoloration and pitting than the coupons labeled FR-100, and said, “It’s far more corrosive than our product.”
Red Herrings?
One of the Fortress executives said he feels like red herrings are being thrown up to slow the process of their company becoming a competitor in the market. As an example he said said two letters were received by the Forest Service complaining that Fortress was not tested for corrosion stress cracking, a test that is not required to be considered for the QPL. The Forest Service asked Fortress to submit their product for the additional test, and the company said they would, as long as the Perimeter product was also tested. The Forest Service had both retardants tested by an outside laboratory which according to Fortress, found no corrosion stress cracking in either product. Fortress said this set the company back eight months.
The company’s leadership teams
The leadership teams for both companies have personnel with prior wildland firefighting experience. Perimeter has Ron Raley and there may be others. The members of the Fortress leadership team that came from wildland firefighting or land management agencies include CEO Robert Burnham, Director of Base Operations Dennis Hulbert, Contract Specialist Harlan Johnson, and Robert Baird who was listed on the Fortress website as Chief Base Operations Officer days after leaving his Forest Service job as Director of Fire and Aviation for the Forest Service’s Pacific Southwest Region.
Bags of dry mix retardant at the Redding Air Tanker Base, August 7, 2014. Photo by Bill GabbertAvailability of raw materials
In the first few months of 2020, soon after the COVID pandemic began, the Forest Service became so worried that the supply of raw materials would cause a disruption in the supply of Perimeter’s fire retardant that they took the very unusual step of buying 3.8 million gallons of retardant worth $15.6 million long before the busiest part of the fire season began. Normally they pay for it as it is used at air tanker bases. Until then, according to the Forest Service, Perimeter had typically ordered the raw materials on an as needed basis depending on the demand at the time and the rate at which it is used. Caleb Berry, a FS Washington Office Aviation Management Specialist wrote about the issue in an April 29, 2020 internal email:
COVID-19 disrupted international logistics by threatening supply chain continuity and overseas shipping. In order to create a reliable stock pile of retardant for the 2020 fire season, raw materials had to be purchased immediately and moved to the United States. The immediate, large raw materials purchase required a significant funds out lay prior to seasonal fire retardant purchase and commensurate risk assumed by Perimeter Solutions. As a primary consumer of fire retardant, it is in Forest Service best interest to insure availability of retardant products and vendor stability. This dual purpose was achieved by an advance purchase of first tier retardant at all Forest Service full service retardant contract line items.
It was not clear why the Forest Service felt they could not rely on Perimeter to acquire the needed raw materials on their own.
The particular “raw material” that was feared to be in short supply was not identified. But two years later, the pandemic is still affecting supply chains.
Russia’s war with Ukraine has introduced another supply chain issue. The main ingredient in Perimeter’s legacy retardant, LC95A, and their most recent version, LCE20-Fx, is fertilizer. A solution of ammonium polyphosphate comprises 85 percent of the concentrate of Perimeter’s legacy retardant, LC95A. It is also used in their newest retardant, LCE-20-FX.
According to the University of Illinois, Russia is the source for 10 percent of the processed phosphate used in the world today. If that dries up, which may have already happened due to sanctions imposed on Russia by numerous countries, there could be increased competition, difficulty in obtaining it at all, and at higher prices.
Dan Green, who handles public communications for Perimeter, told Fire Aviation, “Perimeter sources key raw materials, including phosphates from multiple sources. We do not anticipate an issue with supply.” And, “Perimeter actually didn’t experience any issues obtaining raw materials in 2020. At the beginning of the pandemic, our supply chain and logistics team had the foresight to anticipate potential issues and proactively took steps that accelerated the purchase of raw materials in order to minimize COVID-related disruptions.”
Royal Australian Air Force hauls retardant to Western Australia. RAAF photo. February, 2021.Co-mingling of retardants
During the 200,000-gallon test of Fortress retardant in 2021 at the Missoula air tanker base a surprising issue was identified by two air tanker companies when their aircraft were loaded with Fortress retardant after carrying Perimeter retardant, or vice versa. In some cases the residuals of the previous retardant when co-mingled with the second product left a sticky substance in the tanks that was visible on interior and exterior surfaces after the tanks were emptied. They also identified increased corrosion on some aircraft components.
The co-mingled product was found to present maintenance challenges related to corrosion, parts replacement, and aircraft cleaning according to a report prepared by a group of five aviation specialists who presumably all worked for the Forest Service.
The image below is from the report.
The sticky substance was referred to as “precipitate” in the report. It could not always be removed with water and in some cases had to be physically scraped off. The report’s authors, after talking with two air tanker companies, wrote about maintenance issues on a number of components, including dry bay door actuators, butterfly valves, bolts, flow meters, actuator end cap guides, floats in the quantity indication system, and vent valves. There was also mention of the Gluvit epoxy surface coating dis-bonding inside a tank.
One company submitted an internal safety report documenting an employee injury. One of the company mechanics was washing the inside of a retardant tank and knelt in a puddle of Fortress FR 100 retardant. The employee recognized the product by the purple color of the chemical. In accordance with the Safety Data Sheet for FR-100, the employee immediately flushed and washed the contaminated skin. For the next two days, the employee experienced a very severe burning sensation in the affected area on the skin along with a visible bright red rash. After two days, it diminished, and no further medical attention was required. There were no other examples of this type of reaction in the report.
Excerpts from the report:
“A concern among the company maintenance personnel is that there are likely hidden damages that are not being detected. They are concerned that if the actuators are showing this level of corrosion after hauling only a few loads of FR-100, there are likely unseen corrosion issues to other parts inside the retardant tank or fuselage. Safety of flight becomes important if systems malfunction. For example, if an air tanker loses an engine and isn’t able to release a load because the drop system is disabled, the outcome could be catastrophic.
“Cleaning. One vendor noted that the number of hours required for removal of F-100 from the exterior of the aircraft would increase greatly with more use. This extra time for proper aircraft cleaning would take away from the maintenance staff’s time to make sure the rest of the aircraft is serviceable. Maintenance personnel would require nightly access to water to keep the accumulation under control. Access to water is not guaranteed at every Air Tanker Base, and once the F-100 dries it doesn’t seem to absorb water again allowing for ease of cleaning. Some vendors report spending up to 10 hours trying to clean the aircraft.
“Summary: Fortress FR-100 is an approved product for use, however, due to the lack of data and lack of testing of the substance created when the two products intermingle, it is imperative that these two products do not come in contact with one another.”
Safety
The Safety Data Sheet for Fortress FR-100 does not specify if it is for the concentrate or the final ready to use retardant. It states that if the product gets in eyes, to immediately flush eyes with water for several minutes. If it is on skin, immediately flush skin with plenty of water for at least 15 minutes while removing contaminated clothing and shoes, and get medical aid if the irritation develops or persists.
The Safety Data Sheet for Perimeter’s LC95A-Fx is configured for the concentrate, not the final ready to use retardant. It states that if it gets in eyes, rinse with water for several minutes. For skin contact, if irritation occurs wash skin with plenty of water. Obtain medical attention if irritation persists. The SDS for Perimeter’s new product, LCE20-Fx, is similar.
Whose responsibility is to make the two retardants compatible?
When asked about the co-mingling issue, the Perimeter executives brought up a different firefighting product, foam, saying, “In the Department of Defense qualification process, there is a requirement that any new product being tested must be compatible with any products that are already qualified. They actually test mixtures of any new product with all of the products that are already approved. And that specification has been around for decades.”
The Forest Service’s response to questions
I asked the Forest Service four questions about Fortress’ status on the QPL, possible increased maintenance costs or safety issues if co-mingling occurs, and the effects on firefighters if Fortress is used. We heard back from Fire Communications Specialist Stanton Florea who wrote in an email:
“Several issues related to the co-mingling of aerially delivered fire retardants were identified and documented during the 2021 Fire Year. Our aviation, aviation safety, airworthiness, fire operations, and research and development staffs continue to work through these issues with our airtanker and fire retardant contractors. The safety of all wildland fire personnel, both on the ground and in the air, is our highest priority during firefighting operations.”
Air Tanker 131, a C-130Q (N130FF) on the Karen Fire in San Bernardino County, CA July 26, 2020. Photo credit: CAL FIRE Riverside Co FD.The article was edited at 7 p.m. PDT April 20 to show that the metal coupons that had been tested were 2024-T3 Aluminum, not 4130 steel.