PFAS: The Foam the Military Knew Was Toxic

1. What PFAS and AFFF are

PFAS (per- and polyfluoroalkyl substances) are a large family of manufactured chemicals that resist heat, water, and grease. VA notes they are known as "forever chemicals" because they persist in the environment, and some stay in the human body for years.

Aqueous film-forming foam (AFFF) is a firefighting foam made with PFAS that smothers fuel fires. According to the Defense Health Agency, DoD began using AFFF containing PFOS, and in some formulations PFOA, in the 1970s. DoD used it in firefighting and crash-vehicle testing, fire and crash-crew training, hangar systems, fuel spills, and emergency response. Releases also came from spills, leaks, storage, wastewater treatment, and landfills.

The scale of use is large: GAO reported in 2024 that DoD used AFFF in about 1,500 facilities and over 6,800 mobile assets worldwide.

Sources

1. VA News, "VA to review possible service connection between PFAS exposure and kidney cancer": news.va.gov
2. Defense Health Agency, Perfluoroalkyl and Polyfluoroalkyl Substances: health.mil
3. GAO-24-107322, Firefighting Foam: DOD Is Working to Address Challenges to Transitioning to PFAS-Free Alternatives (2024): gao.gov

2. What the services knew, and when

Military research documents, released through records requests and published by the Environmental Working Group (EWG), show the services were testing the foam's environmental effects in the 1970s:

• Air Force, 1972–1974. The Air Force Weapons Laboratory at Kirtland Air Force Base studied the "Treatability of Aqueous Film-Forming Foams Used for Fire Fighting" (report AFWL-TR-73-279, dated February 1974, covering June 1972 to August 1973). In its fish tests, all four rainbow trout placed in treated wastewater effluent containing one 3M foam product (FC-200) died within 24 hours; in a repeat test all four died within 72 hours. All trout exposed to untreated AFFF solutions died within 96 hours (the authors suggested the deaths in distilled-water solutions might partly reflect the change in mineral content).
• Navy, 1978. A Navy candidate environmental impact statement on discharging AFFF into harbor waters during shipboard foam-system testing stated that "certain concentrations of AFFF are toxic to marine organisms," that the foam chemicals' interaction with other contaminants already in the harbor was unknown, and that their chronic effects on marine life were "as yet unknown."

These studies concerned the foam's effects on fish and the environment, not direct human health findings. They show the services had reason for concern decades before the public was told. In 2020, EWG's Scott Faber told reporters that DoD officials "have understood the risks of AFFF since at least the early 1970's, when the Navy and Air Force did their own studies on the toxicity of PFAS in fish, and the early 1980s when the Air Force conducted its own animal studies," as reported by Military Times. That is EWG's characterization; this page relies on the underlying documents above.

The first federal drinking-water benchmark came much later: in 2016 EPA issued a non-enforceable lifetime health advisory of 70 parts per trillion (ppt) for PFOS and PFOA combined, according to DHA. Enforceable limits came in 2024 (see Scale).

Sources

1. Air Force Weapons Laboratory, "Treatability of Aqueous Film-Forming Foams Used for Fire Fighting," AFWL-TR-73-279 (Feb. 1974), as published by EWG: PDF
2. Department of the Navy, Candidate Environmental Impact Statement, AFFF discharges to harbor waters during machinery-space fire-fighting foam system tests (Jan. 1978), as published by EWG: PDF
3. Military Times, "Here's the latest count of suspected bases with toxic 'forever chemicals' in the water" (Apr. 6, 2020): militarytimes.com
4. Defense Health Agency PFAS page (2016 EPA health advisory): health.mil

3. Scale of contamination

DoD's own count. Through June 30, 2026, DoD says 727 active installations, closed (BRAC) bases, National Guard facilities, and Formerly Used Defense Sites require an assessment of PFAS use or potential release. It had finished the first phase (preliminary assessment/site inspection) at 709. It found no further action needed at 119, and 590 are moving to the next phase of the federal cleanup process (remedial investigation/feasibility study). DoD reports finding PFOS and PFOA above 70 ppt in off-base drinking water from its activities at 55 installations, where it says it took immediate action.

EPA drinking-water limits. In April 2024 EPA set the first enforceable national limits: 4.0 ppt each for PFOA and PFOS, 10 ppt each for PFHxS, PFNA, and HFPO-DA ("GenX"), and a Hazard Index for certain mixtures, with compliance due by 2029. As of October 2026:

• The 4.0 ppt limits for PFOA and PFOS remain in force. On May 18, 2026, EPA proposed (not finalized) an optional exemption letting water systems that apply delay PFOA/PFOS compliance from April 26, 2029, to April 26, 2031.
• EPA also proposed in May 2026 to rescind the limits for PFHxS, PFNA, GenX, and the Hazard Index mixture. As of the sources reviewed for this page, that rescission had not been finalized.
• Separately, EPA designated PFOA and PFOS as CERCLA (Superfund) hazardous substances in 2024. CRS reports that on August 18, 2026, the D.C. Circuit unanimously upheld that rule.

Sources

1. DoD (Office of the Assistant Secretary for Energy, Installations, and Environment), Cleanup of PFAS, progress as of June 30, 2026: acq.osd.mil
2. EPA, Per- and Polyfluoroalkyl Substances (PFAS) drinking water regulation: epa.gov
3. EPA, Proposed PFOA and PFOS Compliance Extension Rule (May 2026): epa.gov; Federal Register, 91 FR 29425 (May 20, 2026): federalregister.gov
4. EPA, Proposed PFAS Rescission Rule (May 2026): epa.gov
5. Congressional Research Service, R49479, Environmental Remediation of PFAS (Oct. 7, 2026): everycrsreport.com

4. Health effects

National Academies (2022). A National Academies of Sciences, Engineering, and Medicine committee found sufficient evidence of an association between PFAS exposure and:

• decreased antibody response (adults and children);
• dyslipidemia, meaning abnormal cholesterol (adults and children);
• decreased infant and fetal growth; and
• increased risk of kidney cancer (adults).

The committee recommended that clinicians offer PFAS blood testing to people likely to have elevated exposure, including those with occupational exposure, and set three levels for follow-up based on the sum of several PFAS in blood: below 2 ng/mL, usual care; 2 to under 20 ng/mL, reduce exposure and prioritize cholesterol screening; 20 ng/mL or higher, add thyroid testing and checks for signs of kidney cancer (over 45), testicular cancer, and ulcerative colitis (over 15).

ATSDR/CDC. ATSDR lists associations between specific PFAS and higher cholesterol, lower antibody response to some vaccines, changes in liver enzymes, pregnancy-induced hypertension and preeclampsia, small decreases in birth weight, and kidney and testicular cancer (PFOA).

Military communities. ATSDR's exposure assessments in ten communities near sites where AFFF was used (including Lubbock County, Texas) found average blood levels of PFHxS above national levels in all ten, PFOS in eight, and PFOA in seven. ATSDR noted that Air Force and Air National Guard bases used AFFF for firefighter training possibly as early as the 1970s.

Sources

1. National Academies, Guidance on PFAS Exposure, Testing, and Clinical Follow-Up (2022), Summary: NCBI Bookshelf; full text: nationalacademies.org
2. ATSDR, How PFAS Impacts Your Health: atsdr.cdc.gov
3. ATSDR, Final Report: Findings Across Ten Exposure Assessment Sites: atsdr.cdc.gov

5. Firefighters, troops, and families

VA says veterans who were military firefighters may have been exposed when using AFFF on jet fuel fires, and others may have been exposed through base water supplies, "although the duration and intensity of exposure to contaminated water on any military base is unknown."

Under the FY2020 National Defense Authorization Act, DoD began offering PFAS blood testing to its firefighters during annual physicals starting October 1, 2020. Testing is offered to current firefighters at their annual occupational exam, to new hires as a baseline, and to other personnel with firefighting duties; each person may accept or decline. DoD publishes surveillance reports on the results. This testing is for current DoD firefighters. It does not cover veterans.

Sources

1. VA Public Health, PFAS: publichealth.va.gov
2. Defense Health Agency, PFAS page and firefighter testing documents: health.mil; DHA memo (Oct. 23, 2020): health.mil; FY2023 firefighter surveillance report: health.mil

6. VA's position today

• No presumption. Veterans can file disability claims for conditions they believe are related to PFAS. VA decides them case by case, which generally means the veteran needs evidence of in-service exposure and a medical opinion linking the condition to it.
• Kidney cancer review. In September 2024, VA announced a scientific assessment, under the PACT Act's process for new presumptions, of whether PFAS exposure during service is linked to kidney cancer. In December 2025 VA published its responses to public comments, describing an interagency expert panel that will recommend whether the evidence supports a formal evaluation. That process can lead to a presumption, but none has been established.
• No VA blood testing. VA says PFAS blood testing is not currently available at VA medical centers and that it is reevaluating blood testing.

Sources

1. VA Public Health, PFAS: publichealth.va.gov
2. VA News, PFAS and kidney cancer assessment: news.va.gov
3. Federal Register, VA response to comments on PFAS and kidney cancer assessment (Dec. 18, 2025): federalregister.gov

7. Cleanup: timelines and delays

• Schedules keep slipping. Between September 30, 2025, and June 30, 2026, DoD's estimated end dates for the remedial investigation phase shifted at 243 installations, by an average of 5.1 years and as much as 19 years. DoD cites the need for more testing to meet EPA's 2024 standards (109 installations) and prioritizing higher-risk sites (98 installations).
• No completion dates. CRS reports that DoD has not provided estimated completion dates for remediation at any installation.
• Cost. Through FY2025, DoD obligated about $3.3 billion for PFAS investigation and cleanup and estimated $10.2 billion more would be needed, an estimate DoD expects to rise.
• Costs keep rising. GAO reported in 2025 that DoD's estimated future PFAS investigation and cleanup costs had more than tripled since 2022, that no location had yet entered the long-term cleanup phases (as of June 2024), and that the work could take decades.
• Falling budgets. CRS reports that PFAS funding across DoD's environmental restoration accounts fell from $404 million in FY2023 to $255 million in FY2026, and the FY2027 request would cut it to $142 million.
• Private wells. DoD's policy is to take interim action on private drinking-water wells affected by its PFAS releases at or above three times EPA's limits (12 ppt for PFOA or PFOS). Wells between 4 and 12 ppt go through the full, multi-year cleanup process.

Sources

1. DoD, Cleanup of PFAS (schedule changes as of June 30, 2026): acq.osd.mil
2. CRS, R49479 (Oct. 7, 2026): everycrsreport.com
3. GAO-25-107401, PFAS investigation and cleanup costs at DOD installations (reissued Feb. 25, 2025): gao.gov

8. The AFFF phase-out

• The law. Section 322 of the FY2020 NDAA barred DoD from buying PFAS-containing AFFF after October 1, 2023, and from using it at military installations after October 1, 2024, with up to two one-year waivers (to October 1, 2026). Shipboard use is exempt.
• Waivers used. GAO reported in 2024 that DoD expected to need both waivers, citing the lack of a drop-in replacement, more than $2.1 billion in transition costs, and firefighter training. Trade press reported that in July 2025 the Secretary of Defense certified the second waiver, moving the deadline to October 1, 2026.
• A third delay. InsideEPA reported in August 2026 that, after Congress made further extensions possible in the FY2026 NDAA, DoD notified Congress it had extended the deadline again to October 1, 2027.

Sources

1. GAO-24-107322 (2024): gao.gov
2. Federal Register, DFARS interim rule implementing Section 322 (Sept. 29, 2023): federalregister.gov
3. InsideEPA report on the second waiver, as republished by the Texas Chemistry Council: texaschemistry.org
4. InsideEPA, "Amid Struggles, DOD Postpones AFFF Use, Procurement Ban Until 2027" (Aug. 11, 2026): insideepa.com

9. Texas: Fort Hood / Fort Cavazos

The Army Environmental Command lists Fort Hood, Texas (now Fort Cavazos) as a PFAS investigation site. Its final Preliminary Assessment and Site Inspection was completed in February 2023, and the site is in the remedial investigation phase. The Army notes its drinking water system there is privatized and points to DoD's on-base drinking water database for current sampling results. This page does not report a contamination level for the installation because one was not confirmed in the sources reviewed.

Elsewhere in Texas, ATSDR's exposure assessments included Lubbock County, one of ten communities with PFAS drinking-water contamination from AFFF-type sources.

Sources

1. U.S. Army Environmental Command, PFAS: Fort Hood, TX: aec.army.mil
2. DoD, on-base drinking water PFAS results: acq.osd.mil
3. ATSDR, Final Report, Ten Exposure Assessment Sites: atsdr.cdc.gov

10. The AFFF litigation (facts only)

Lawsuits over AFFF are consolidated as In re: Aqueous Film-Forming Foams Products Liability Litigation, MDL No. 2873, before Judge Richard M. Gergel in the District of South Carolina. The court states that the MDL has had approximately 10,000+ associated cases, comprising tens of thousands of plaintiffs, alleging personal injury, medical monitoring, property damage, and other losses. The court-approved settlements so far, with 3M (final approval March 2024) and with DuPont, Chemours, and Corteva (final approval February 2024), resolve claims by public water systems, not individual personal-injury claims. This is not legal advice. Check the court's MDL page for current status.

Sources

1. U.S. District Court for the District of South Carolina, MDL 2873: scd.uscourts.gov
2. 3M, "Settlement with Public Water Suppliers ... Receives Final Court Approval": investors.3m.com; DuPont entities final approval order: PDF

11. What veterans can do

12. Timeline

About this page

This page reports only what primary documents, government agencies, courts, and established outlets have published, and it attributes characterizations to their sources. Figures from DoD and EPA change often; check the linked pages for the latest. If you find an error, please report it so it can be corrected.

Last reviewed October 8, 2026.