The supply of chemicals for aerial fire suppression across the US has been locked in with the announcement by US Secretary of Agriculture Brooke Rollins that the nation’s Forest Service and Department of Interior’s aerial wildland firefighting force has entered into a new five-year contract.
The new contract is with Perimeter Solutions, a US-based fire supply company, which supplies a range of firefighting chemicals to governments and agencies around the world.
The company, already a long-time supplier of wildfire products to the USDA, CalFire and others, has secured the dominant position as the supplier of fire-retardant in the US for the next five years
Perimeter, according to its website has manufacturing facilities in US, Canada, France, Spain, Germany and Australia. The new contract, however, states that 100 percent of Perimeter’s retardant for federal use will be manufactured in the US.
In a company statement Perimeter claims a “made in America, for America” commitment. “Combined with an increased commitment to sourcing domestic raw materials, the contract reinforces Perimeter’s support for American manufacturing, supply chain diversification, and national resilience. The USDA will receive the lowest pricing Perimeter offers. Together, the benefits of the contract are a result of operational efficiencies and long-term investment in US-based infrastructure by Perimeter Solutions”
In 2024, US federal agencies dropped 48.6 million gallons of fire retardant to fight wildfires. Rollins, in her announcement, boasted that the new contract would save American taxpayers $153 million over the next five years “…including a negotiated direct price reduction and additional cost savings transitioning to full-service bases and powder retardant by 2030.”
“This contract is a tremendous win for America’s taxpayers, our rural communities, and the brave men and women who fight wildfires every day,” Rollins said. “By locking in historic cost savings and bringing every step of the fire-retardant supply chain back to American soil, we are protecting lives, saving communities from destruction, and keeping America safe, strong, and resilient. This agreement proves that when we put America first, we get the best results for our people and our land.”
WildfireToday reached out to the USDA for specifics on where the $153 million in savings comes from, but the agency has not returned our request for comment as of this article’s publication.
A federal judge ruled Friday that the U.S. government can continue using retardant to fight wildfires, despite his finding that it does pollute streams in violation of federal law. Banning retardant could cause greater environmental damage from wildland fires, said U.S. District Judge Dana Christensen in court in Missoula, Montana.
The judge agreed with U.S. Forest Service officials who testified that dropping retardant from aircraft into areas near waterways was sometimes necessary to protect lives and property, according to an AP report posted by KEZI-TV.
2019 retardant drop, photo by Kari Greer
Christensen’s ruling resulted from yet another lawsuit filed last year by an environmentalist group trying to protect fish over people when they learned that the Forest Service had dropped retardant into waterways — what they claim was hundreds of times over the last decade.
Retardant is often crucial in slowing the progression of wildfires, which have grown larger and more destructive and more frequent as climate change and a burgeoning wildland/urban interface advance the danger of fires across the West — and other parts of the world.
Firefighters observe a retardant drop by an RJ85 airtanker. DOI photo.
Though environmental groups claim fire suppression efforts allowed incursions of retardant more than 200 times over the last 10 years, fire officials reply that such situations happened accidentally — and in less than 1 percent of the thousands of retardant drops ordered each year.
During this case — yet another in the decades-long battle by environmental groups against the use of retardant — a coalition including Paradise, California said stopping the use of retardant would risk lives, homes, and forests. (The 2018 Camp Fire killed 85 people and destroyed the town of Paradise.) There’s a good story online about this coalition by AerialFire Magazine.
A neighborhood on Debbie Lane in Paradise, California, before and after the Camp Fire that started November 8, 2018. The homes were 14 to 18 feet apart.
“This case was very personal for us,” said Paradise Mayor Greg Bolin on Friday. “Our brave firefighters need every tool in the toolbox to protect human lives and property against wildfires, and today’s ruling ensures we have a fighting chance this fire season.”
“Retardant lasts and even works if it’s dry,” said Scott Upton, a former region chief and air attack group supervisor for CAL FIRE. “Water is only so good because it dries out. It does very well to suppress fires, but it won’t last.”
KDVR-TV reported that the Oregon-based group Forest Service Employees for Environmental Ethics (FSEEE) argued in its most recent lawsuit that the Forest Service was disregarding the Clean Water Act by continuing to use retardant without taking adequate precautions to protect streams and rivers. Launched by Jeff DeBonis in 1989 in Eugene, Oregon, the group (nationalforestadvocates.org) says it has about 10,000 members; it publishes a quarterly called Forest Magazine and pays its director Andy Stahl over $91K annually. The organization receives a substantial part of its support from a governmental unit and/or the general public.
Andy Stahl
FireRescue1 reported that FSEEE claims wildfire retardant drops are expensive, ineffective, and a growing source of pollution for rivers and streams. “There’s no scientific evidence that it makes any difference in wildfire outcomes,” said Andy Stahl. “This is like dumping cash out of airplanes, except that it’s toxic and you can’t buy anything with it because it doesn’t work.”
The case has been followed closely by officials in California, where an extremely wet winter is likely to stoke the growth of early-season light fuels. “This is going to destroy towns and many communities in California, if they allow this to go through,” said Paradise Mayor Greg Bolin, whose town was razed by the Camp Fire five years ago. “To maybe save a few fish, really?”
The Smokey Wire is a Forest Service and public lands policy blog administered by Sharon Friedman, Ph.D., forest geneticist, Forest Service retiree, and former Chair of both the Forest Policy Committee and Forest Science and Technology Board at the Society of American Foresters. In a recent post about this retardant case, she commented on a piece in the San Joaquin Valley Sun published about a month ago in April, which noted that if the court sided with FSEEE, the USFS would have to obtain a special permit under the Clean Water Act to use retardant from aircraft — a lengthy process that would span multiple years. During the lawsuit, the USFS initiated the process of receiving such a permit from the EPA with the current 300-foot buffer zone for retardant drops from affected waterways.
While following a lead plane, Tanker 118, an HC-130H, begins a retardant drop on the 2018 Ferguson Fire — photo by Kari Greer
In response, FSEEE argued that 300 feet was an arbitrary number. Despite its argument that the USFS had originally created the 300-foot buffer proposal out of thin air, FSEEE then asked the Court for a 600-foot buffer zone.
U.S. District Judge Dana Christensen
Judge Christensen noted then that a ruling was pending, because fire season in the West is pending. He expressed skepticism at the nationwide impact of siding with FSEEE and rejected its push for an extended buffer zone. “The last thing I want to do is start imposing magic numbers in terms of buffer zones,” he said. “I mean, that’s way out of my wheelhouse. But I don’t know what the Forest Service did to come up with a 300-feet buffer, and you’re describing it as being essentially nothing. It’s a magic number. And I will tell you, if this Court imposes a 600-foot buffer, that is truly a magic number. So that’s probably not going to happen.”
USFS attorney Alan Greenberg said the Forest Service uses retardant on about 5 percent of wildfires — and less than 1 percent of those drops end up in contact with water.
Christensen said that stopping the use of retardant could result in greater harm from wildfires — including to human life and property and to the environment. (Note that his ruling was not nationwide — it’s limited to the 10 western states where FSEEE alleged harm from pollution into waterways.)
In the lawsuit (online HERE), FSEEE specifies that “the chemical retardants used by wildland firefighting agencies are tested and approved by the United States Department of Agriculture’s Missoula Technology and Development Center, located in this Division. The Forest Service also has a Fire Sciences Lab and Smokejumper Base in this Division. Plaintiff has members who reside in this Division, and who have been injured by the Forest Service actions and activities complained of in this Complaint. Moreover, the Forest Service has discharged aerial fire retardant into navigable waters in this Division without a National Pollution Discharge Elimination System (NPDES) permit.”
Airtanker drops retardant
After the lawsuit was filed the Forest Service applied to the EPA for a permit that would allow it to continue using retardant without breaking the law. That process could take years. Christensen ordered federal officials to report every six months on their progress; no word yet on whether the USFS will still pursue that EPA permit or whether they have to continue reporting to Christensen about it.
Fire retardant covers a road sign on Barrett Lake Road in the eastern San Diego town of Dulzura, California, site of the Border 32 Fire that burned 4,456 acres between August 31 and Sept 8, 2022. Photo Credit: Josh Stotler
Health risks to firefighters or other people who come into contact with fire retardant are considered low, according to a 2021 risk assessment. But the chemicals can be harmful to some fish, frogs, crustaceans, and other aquatic species. One government study found misapplied retardant could adversely affect dozens of species including crawfish, spotted owls, and threatened fish such as shiners and suckers. To prevent risk, officials and pilots have avoided drops within 300 feet (92 meters) of waterways. Retardant may be applied inside those zones only when if life or public safety is threatened. Of 213 documented instances of fire retardant contacting water between 2012 and 2019, 190 were accidental and the remainder were necessary to protect lives or property, officials said.
Map showing location of photos of retardant near Sespe Creek at the Howard Fire. The red area is the western side of the fire Oct. 12, 2022. The photo locations were obtained from the metadata in the iPhone photos.
A lawsuit filed Tuesday alleged that the US Forest Service has polluted waterways by firefighting air tankers inadvertently dropping fire retardant in or near waterways in violation of the Clean Water Act and a policy adopted by the Forest Service and other federal agencies in 2011. The policy requires that retardant not be dropped within 300 feet of a waterway on federal land.
Photo 1. Retardant near Sespe Creek at the Howard Fire. Oct. 12, 2022. Peter Deneen.
Fire Aviation has acquired photos and a video that reportedly show signs of retardant being dropped into Sespe Creek on the Los Padres National Forest 8 miles northeast of Ojai, California October 8, 2022. The photos were shot by Pete Deneen on October 12, 2022 at the 85-acre Howard Fire. The creek is designated a “wild and scenic river” and is in a wilderness area.
Photo 2. Retardant near Sespe Creek at the Howard Fire. Oct. 12, 2022. Peter Deneen.
The photos show retardant on rocks and other objects very close to water in Sespe Creek.
Photo 3. Retardant in a dry area of Sespe Creek at the Howard Fire. Oct. 12, 2022. Peter Deneen.
Some organisms, including aquatic threatened and endangered species or their habitats, can be adversely affected by retardants. In addition, retardant in water is a pollutant.
According to US Forest Service data, between 2012 and 2019, the Forest Service discharged retardant on at least 376 occasions totaling 761,282 gallons from aircraft directly into national forest waterways.
In the video below Mr. Deneen explains that there were two locations where retardant was dropped very close to the creek. In one case the aircraft may have turned as it was dropping to follow the creek for several hundred yards, or a second drop accounted for the retardant in the waterway.
The lawsuit was filed Oct. 11 by the Forest Service Employees for Environmental Ethics, FSEEE. In the group’s complaint they are seeking:
A declaration that the Forest Service’s placement of retardant in waterways is a violation of the Clean Water Act.
An injunction “to compel the Forest Service to comply with applicable environmental statutes, prevent irreparable harm, and satisfy the public interest.”
Reimbursement for FSEEE’s costs, expenses, expert witness fees, and attorney fees.
“Such further relief as may be just, proper, and equitable.”
More about FSEEE’s history of protesting retardant, and the federal government’s policy of retardant avoidance areas established in 2011.
Map showing location of photos of retardant near Sespe Creek at the Howard Fire. The red area is the western side of the fire Oct. 12, 2022. The photo locations were obtained from the metadata in the iPhone photos.
A lawsuit filed Tuesday alleged that the US Forest Service has polluted waterways by firefighting air tankers inadvertently dropping fire retardant in or near waterways in violation of the Clean Water Act and a policy adopted by the Forest Service and other federal agencies in 2011. The policy requires that retardant not be dropped within 300 feet of a waterway on federal land.
Photo 1. Retardant near Sespe Creek at the Howard Fire. Oct. 12, 2022. Peter Deneen.
Fire Aviation has acquired photos and a video that reportedly show signs of retardant being dropped into Sespe Creek on the Los Padres National Forest 8 miles northeast of Ojai, California October 8, 2022. The photos were shot by Pete Deneen on October 12, 2022 at the 85-acre Howard Fire. The creek is designated a “wild and scenic river” and is in a wilderness area.
Photo 2. Retardant near Sespe Creek at the Howard Fire. Oct. 12, 2022. Peter Deneen.
The photos show retardant on rocks and other objects very close to water in Sespe Creek.
Photo 3. Retardant in a dry area of Sespe Creek at the Howard Fire. Oct. 12, 2022. Peter Deneen.
Some organisms, including aquatic threatened and endangered species or their habitats, can be adversely affected by retardants. In addition, retardant in water is a pollutant.
According to US Forest Service data, between 2012 and 2019, the Forest Service discharged retardant on at least 376 occasions totaling 761,282 gallons from aircraft directly into national forest waterways.
In the video below Mr. Deneen explains that there were two locations where retardant was dropped very close to the creek. In one case the aircraft may have turned as it was dropping to follow the creek for several hundred yards, or a second drop accounted for the retardant in the waterway.
The lawsuit was filed Oct. 11 by the Forest Service Employees for Environmental Ethics, FSEEE. In the group’s complaint they are seeking:
A declaration that the Forest Service’s placement of retardant in waterways is a violation of the Clean Water Act.
An injunction “to compel the Forest Service to comply with applicable environmental statutes, prevent irreparable harm, and satisfy the public interest.”
Reimbursement for FSEEE’s costs, expenses, expert witness fees, and attorney fees.
“Such further relief as may be just, proper, and equitable.”
More about FSEEE’s history of protesting retardant, and the federal government’s policy of retardant avoidance areas established in 2011.
Air Tanker 914, a DC-10, drops retardant on the Central Fire, June 20, 2020. Photo by JDH Images.
This article was first published at Wildfire Today.
An environmental group filed a lawsuit in a Montana federal court Tuesday alleging that the US Forest Service has polluted waterways by inadvertently dropping fire retardant in or near waterways. The retardant was dropped by aircraft under contract with the Forest Service while assisting wildland firefighters on the ground.
The suit says government data released earlier this year showed more than 760,000 gallons of fire retardant was dropped into waterways between 2012 and 2019. The lawsuit alleges the continued use of retardant from aircraft violates the Clean Water Act and requests a judge to declare the pollution illegal.
Example of retardant avoidance areas (red) in Northern California along Hwy. 96 near Klamath River.
The Forest Service has established retardant avoidance areas along waterways where the liquid is not supposed to be applied. This puts buffer zones around waterways and habitat for some threatened, endangered, and sensitive species in order to avoid applying retardant in those areas. When they were first established in 2011 it resulted in approximately 30 percent of USFS lands being off limits for retardant while fighting fire. There is an exception if human life or public safety is threatened. The policy was the result of an Environmental Impact Statement (EIS) that studied the use of retardant and how it affects water resources and certain plant and wildlife species. The EIS was written in response to a July, 2010 decision by U. S. District Court Judge Donald Molloy in a lawsuit filed in 2008 by the Forest Service Employees for Environmental Ethics.
The same organization, FSEEE, filed the new case yesterday. An attorney in Missoula, MT who specializes in environmental law, Tim Bechtold, will be representing FSEEE. Presiding over the case will be District Court Judge Dana Christensen. He joined the court in 2011 after a nomination from President Barack Obama. Before, he was a partner in the firm of Christensen, Moore, Cockrell, Cummings, and Axelberg, in Kalispell, Montana. One of the 15 practice areas the firm deals with today is environment and natural resources.
In 2012 FSEEE issued a statement criticizing the use of air tankers on fires, claiming it is “immoral”. The group argued that aerial firefighting is too dangerous and ineffective and that “retardant doesn’t save homes; proper construction and landscaping save homes.”
Air Tanker 41, a BAe-146, drops retardant. BLM photo.
An environmental group filed a lawsuit in a Montana federal court Tuesday alleging that the US Forest Service has polluted waterways by inadvertently dropping fire retardant in or near waterways. The retardant was dropped by aircraft under contract with the Forest Service while assisting wildland firefighters on the ground.
The suit says government data released earlier this year showed more than 760,000 gallons of fire retardant was dropped into waterways between 2012 and 2019. The lawsuit alleges the continued use of retardant from aircraft violates the Clean Water Act and requests a judge to declare the pollution illegal.
Example of retardant avoidance areas (red) in Northern California along Hwy. 96 near Klamath River.
The Forest Service has established retardant avoidance areas along waterways where the liquid is not supposed to be applied. This puts buffer zones around waterways and habitat for some threatened, endangered, and sensitive species in order to avoid applying retardant in those areas. When they were first established in 2011 it resulted in approximately 30 percent of USFS lands being off limits for retardant while fighting fire. There is an exception if human life or public safety is threatened. The policy was the result of an Environmental Impact Statement (EIS) that studied the use of retardant and how it affects water resources and certain plant and wildlife species. The EIS was written in response to a July, 2010 decision by U. S. District Court Judge Donald Molloy in a lawsuit filed in 2008 by the Forest Service Employees for Environmental Ethics.
The same organization, FSEEE, filed the new case yesterday. An attorney in Missoula, MT who specializes in environmental law, Tim Bechtold, will be representing FSEEE. Presiding over the case will be District Court Judge Dana Christensen. He joined the court in 2011 after a nomination from President Barack Obama. Before, he was a partner in the firm of Christensen, Moore, Cockrell, Cummings, and Axelberg, in Kalispell, Montana. One of the 15 practice areas the firm deals with today is environment and natural resources.
In 2012 FSEEE issued a statement criticizing the use of air tankers on fires, claiming it is “immoral”. The group argued that aerial firefighting is too dangerous and ineffective and that “retardant doesn’t save homes; proper construction and landscaping save homes.”
An MD-87 drops on the Oak Fire near Yucaipa, California November 29, 2017. Screen grab from EPN106 OnScene.TV video. Used with permission.
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 Gabbert
Availability 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.
Co-mingling retardants. From a report produced by the U.S. Forest Service.
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.
PHOS-CHEK FORTIFY being applied from an ATV. Perimeter Solutions photo.
The US Forest Service has given approval to a new formulation of fire retardant specifically designed to be applied from the ground. Perimeter Solutions, the maker of PHOS-CHEK long term fire retardant, has added PHOS-CHEK FORTIFY to its inventory of products, saying that “it is the only highly-durable fire retardant that has been approved by USDA Forest Service for preventative application on U.S. federal lands.”
FORTIFY is based on a hydrogel platform and polymer technology to provide enhanced durability to weathering as well as adherence to vegetation. It can be applied on flammable vegetation and cellulosic material early in the fire season before a wildfire approaches and provides ongoing protection, remaining effective until a significant rain event of one inch or more. Unlike retardant dropped from aircraft, which is colored to help pilots track where the retardant is dropped during active wildfires, the durable FORTIFY fire retardant is uncolored and is precision applied from the ground.
Perimeter Solutions says the product was developed in 2018 and over the past three years utilities, railroads, insurance companies, homeowners, and other industries have adopted it as a solution to prevent wildfire ignitions and proactively protect their property from wildfires.
PHOS-CHEK FORTIFY being applied from a water tender. Perimeter Solutions photo.
