Thank you for your request for information, please accept my apologies for the delay issuign this response. Some of the information you have requested constitutes environmental information within the meaning of regulation 2(1) of the Environmental Information Regulations 2004 (EIR), and those elements of your request have therefore been handled under the EIR. Other elements of your request do not constitute environmental information and have been handled under the Freedom of Information Act 2000 (FOIA).
Where different access regimes apply, we have applied each regime to the relevant parts of your request in accordance with ICO guidance.
Please refer below for our responses in bold text.
- PFAS-containing firefighting foams
Please provide details of firefighting foams containing PFAS used by your Service, including:
Not applicable – no PFAS containing foams are currently held in stock or storage.
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Dates when PFAS-containing foams were phased out (if applicable)
They were phased out in 2021-2022 when the Service moved from Solberg to Moussol.
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Details of replacement foams, including manufacturer name(s) and approximate dates of introduction (where applicable)
Dr. Sthamer Moussol FXS FF 3/6 was introduced into the Service during 2021-2022
- Using already collected data and records relating to major incidents involving high foam usage (such as trainings, medium to large-scale fire incidents e.g. industrial, petrochemical, airport, landfill fires etc.). Where available, please provide:
- Location and month/year of the incident/training(s)
- Approximate quantity, manufacturer of PFAS-containing foam used
We have considered this under the Environmental Information Regulations 2004 (EIR).
We hold some information that may indicate whether firefighting foam was used during incidents (for example within incident recording system/ call logs). However, we do not routinely record the quantity of foam used or the manufacturer of the foam within these records. Where such details are not recorded, we are unable to provide them.
In addition, your request seeks information about “major incidents involving high foam usage” between 2016 and 2026. Our systems do not include a structured field that identifies “high foam usage” incidents. Identifying the information in scope would require a manual review of a large volume of unstructured incident records across the period.
We therefore consider that complying with the request as framed would be manifestly unreasonable under regulation 12(4)(b) of the EIR.
Regulation 12(2) provides a presumption in favour of disclosure. We have therefore considered whether, in all the circumstances of the case, the public interest in maintaining the exception outweighs the public interest in disclosure. We recognise the public interest in transparency about the use of PFAS‑containing foam. However, we consider that this is outweighed by the significant burden that would be imposed by manually reviewing and extracting information from over 6 years of records, particularly where key elements of the requested information are not routinely recorded. This would involve a substantial amount of officer time to:
• locate potentially relevant records across multiple years and storage locations;
• review each record to determine whether it contains information within scope;
• extract and quality-check information that is not routinely recorded as discrete fields; and
• collate the information into a usable format.
This would necessitate a substantial diversion of staff time away from core duties, (including operational response), for a disproportionate level of work relative to the nature of the information requested. Given the scale of manual review and the fact that the requested information would require significant reconstruction from unstructured records, we consider the request to be manifestly unreasonable for the purposes of regulation 12(4)(b).
On balance, the public interest in maintaining the exception at regulation 12(4)(b) outweighs the public interest in disclosure.
The authority has considered whether the request could be refined or narrowed. Due to the way records are held, even a reduced timeframe would still involve a degree of manual review.
While we are unable to comply with your request as per the reasons set out above, we can provide the following high-level contextual information for assistance.
Prior to the phasing out of Solberg Foam, Appliances had 100l capacity, the Foam Unit carried 2 No. 1000l IBCs and some was stored at Service Head Quarters in Shrewsbury in 25l drums.
This information is provided for general context only and has not been compiled through a review of historical records. Providing further detail or confirmation over extended time periods would require the extensive manual review described above.
2. Firefighter personal protective equipment (PPE)
For the last decade, please provide:
The Service’s cleaning provider uses a Christeyns product, Aquablock Triple, in their business. Details of the product are attached. Our cleaning provider has confirmed that this product has not been applied to PPE cleaned under their contract with the Service.
