Managing Risk, Regulation and Performance in a Rapidly Evolving Market
PFAS have historically played an important role in firefighting turnout gear materials and components because of their exceptional physical and chemical properties. The carbon–fluorine bond is among the strongest in organic chemistry, giving certain fluorinated materials outstanding thermal stability, chemical resistance and durability under extreme conditions.
In turnout gear, PFAS-based finishes and membranes help repel water, fuels and other hazardous liquids, reducing saturation of the outer shell and limiting penetration of contaminants. These properties support acute safety by maintaining barrier integrity during fireground operations, as well as by providing long-term durability under repeated exposure to heat, moisture and chemical and mechanical stress.
Federal testing and published research have documented the presence of various PFAS in turnout gear textiles, particularly in moisture barriers and outer shell treatments. These materials are incorporated into a three-layer protective system governed by National Fire Protection Association (NFPA) performance standards, consisting of a flame-resistant outer shell, a waterproof and breathable moisture barrier and an insulating thermal liner. Together, these layers are engineered to balance thermal protection, breathability, liquid resistance and mechanical strength.
Shifting Standards and the Push Toward “PFAS-Free” Gear
Turnout gear in the United States is primarily regulated through consensus performance standards rather than direct federal product regulations. NFPA standards exist to establish mandatory performance requirements related to flame resistance, heat stress, liquid penetration resistance, tensile strength, contamination removal efficiency and surface wetting.
More recently, these standards and procurement expectations have begun to shift. NFPA 1970, which consolidates several protective equipment standards, introduces a Restricted Substances List (RSL) that limits PFAS and other chemicals of concern. In parallel, several states and local jurisdictions have enacted or proposed restrictions on intentionally added PFAS in firefighter protective equipment.
In addition, beginning in 2023, firefighters and firefighter organizations began filing lawsuits against turnout-gear and chemical manufacturers alleging that PFAS in protective gear contributed to cancer and other health harms, further increasing liability and reputational risk for manufacturers navigating material transitions.
In response, many manufacturers and departments are accelerating transitions toward turnout gear marketed as “PFAS-free.” While these efforts reflect growing concern for firefighter health, they also introduce new technical and risk management challenges that cannot be addressed through categorical substitution alone.
Performance Tradeoffs and Firefighter Safety
Removing fluorinated chemistries from turnout gear can affect performance in ways that matter under real-world firefighting conditions. Comparative research has identified reductions in oil and diesel repellency for some non-PFAS outer shell treatments compared to fluorinated finishes. Reduced repellency increases the likelihood that fuels or oily substances persist on turnout gear surfaces unless promptly removed through cleaning or turnout gear exchange.
This matters because turnout gear routinely encounters complex mixtures of hazardous combustion byproducts, including polycyclic aromatic hydrocarbons (PAHs) and other known carcinogens present in fireground smoke and soot. Increased saturation and contaminant retention can create additional opportunities for secondary exposure during doffing, handling, storage, transport and laundering.
As manufacturers redesign gear to meet evolving standards, it is essential to consider how material changes affect not only chemical hazard profiles but also protective performance and contaminant behavior over the full lifecycle of the product.
PFAS Are Not All the Same and Substitution Is Complicated
One of the challenges in current PFAS discussions is the tendency to treat all PFAS as though they share a uniform hazard and exposure profile. In practice, PFAS encompass a wide range of chemistries with very different physical properties, mobility and potential exposure pathways.
For example, fluoropolymer membranes such as polytetrafluoroethylene (PTFE) and expanded PTFE (ePTFE), which are commonly used in turnout gear moisture barriers, are high-molecular-weight, inert materials that remain encapsulated within the barrier layer until temperatures exceed approximately 630°F. At temperatures above this threshold, PTFE may begin to degrade into a coalescible gel. However, characterizations of firefighters’ typical thermal exposures report temperature ranges of approximately 302-392 °F during severe training scenarios and 212-532°F during pre-flashover real-world fires.
Thus, these materials are not bioavailable, are insoluble and do not present plausible exposure pathways under expected conditions of use. Their risk profile is fundamentally different from that of more mobile, lower-molecular-weight PFAS that have driven much of the regulatory and public concern.
At the same time, rapid substitution driven solely by “PFAS-free” labeling can introduce the risk of regrettable substitution when PFAS are not the only chemicals of concern. For example, recent research has reported elevated concentrations of certain brominated flame retardants in some turnout gear marketed as “PFAS-free,” including decabromodiphenyl ethane (DBDPE)—a chemical addressed in the NFPA 1970 RSL. These findings highlight the potential for substitution pressures to shift chemical concerns rather than eliminate them.
PFAS management in turnout gear must occur through an application-specific, risk-based framework that evaluates chemical hazard, exposure potential and protective performance together. Effective PFAS policy and product stewardship should therefore prioritize substitutions based on realistic exposure pathways, the hazard profile of specific chemistries, the likelihood of environmental release and the ability to meet performance requirements. This approach supports replacing materials where exposure potential and hazard are higher, while avoiding unnecessary replacement of contained, low-mobility materials used in critical barrier applications when substitution may compromise protection or introduce new risks.
Moving Forward
As standards evolve and scrutiny intensifies, turnout gear manufacturers must navigate a challenging landscape where chemical risk, firefighter safety and product performance are tightly intertwined. A science-based, risk-informed approach ensures that decisions are defensible, transparent and centered on protecting those who rely on this equipment every day.
How TRC Can Help
TRC supports turnout gear manufacturers through both product stewardship and litigation-focused services grounded in exposure science, toxicology and risk assessment.
Product stewardship support includes alternatives assessment and exposure-informed testing to evaluate how PFAS-containing and PFAS-free material systems absorb, retain and release contaminants under realistic conditions. TRC helps manufacturers validate supplier disclosures, assess reformulation risks and develop transparent, defensible approaches to material choices. Our team also supports firefighter-facing communication and stewardship strategies that align with operational realities and evidence-based cleaning and decontamination practices.
Litigation support focuses on developing clear, scientifically grounded perspectives that clarify exposure pathways, distinguish among PFAS subclasses and contextualize firefighter risk in a defensible manner. TRC supports data review, expert testimony preparation and coordinated scientific positioning in complex litigation environments, helping manufacturers communicate sound, evidence-based decisions.
Manufacturers navigating PFAS-related regulatory change, product redesign or litigation are encouraged to contact TRC to discuss how a science-based, risk-informed strategy can support defensible decisions and long-term product stewardship.