The Federal Aviation Administration has required Part 139 certified airports to utilize AFFF for fire suppression since the 1970s, creating a legacy of environmental exposure. Testing often confirms what the historical record suggests: the chemicals are present in the soil and water on airport grounds. For operators, the financial burden includes far more than foam replacement; it encompasses infrastructure flushing, equipment upgrades, firefighter retraining, and extensive environmental remediation efforts.

Tristan Duarte, an associate attorney at Milberg, noted that many facilities are already moving toward litigation. For those still on the sidelines, the window to preserve legal rights is narrowing. Senior partner Vicki Maniatis emphasized that the debate has shifted from confirming contamination to determining financial liability. With 3M, DuPont, Tyco, and BASF having already reached multi-billion dollar settlements, the focus is now on the remaining eight primary manufacturers named in the ongoing AFFF Products Liability Litigation, MDL No. 2873, currently pending in the U.S. District Court for the District of South Carolina.