whatbindsCheck your order

Clauses · DFARS · Environment and safety

DFARS 252.223-7009 Prohibition of Procurement of Fluorinated Fire-Fighting Agent for Use on Military Installations

Does the regulation require it to flow down?

Yes

Paragraph (c): all subcontracts, including subcontracts for commercial products and commercial services, relating to fire-fighting on a military installation. No dollar threshold, and — unusually for a 2024-vintage DFARS flow-down — no COTS exclusion.

Form
substance, including paragraph (c) itself — self-perpetuating
Reaches
all tiers

Checked against acquisition.gov on 2026-08-05 · edition MAR 2024 (codified DFARS); Class Deviation 2026-O0018 prints it as FEB 2024 with a narrower prohibition — see changes2025_26 · base v0.9.3 Read the text ↗

What it makes you produce

One item for your checklist.

  1. Nothing to send, ever

    There is no paperwork here. It is a rule you follow while you perform the work.

    • Nothing to send — the clause bars providing or using any fire-fighting agent carrying more than one part per billion of perfluoroalkyl or polyfluoroalkyl substances

      DFARS 252.223-7009(b)

When it is used

Solicitations and contracts, including those using FAR part 12 procedures for commercial products and commercial services, RELATING TO FIRE-FIGHTING ON MILITARY INSTALLATIONS (DFARS 223.7404). No dollar threshold, no COTS exception. The subpart implements section 322(b), (c) and (d) of the FY 2020 NDAA (Pub. L. 116-92): DoD may not procure any fire-fighting agent containing more than one part per billion of perfluoroalkyl or polyfluoroalkyl substances (223.7402). One exemption exists — fire-fighting agent for use solely onboard ocean-going vessels, meaning a vessel over 59 feet owned or operated by DoD or the U.S. Coast Guard other than time- or voyage-chartered vessels (223.7401, 223.7402) — and it is documented by the requiring activity in the contract file, not claimed by the contractor (223.7403).

Read closely

The clause has three paragraphs and none of them asks for a certificate, a test report or any other submission — it states a composition limit and stops. One part per billion is effectively a no-detect line, so what answers it is the analysis behind the agent rather than a statement written for this order. How wide the limit reaches is genuinely unsettled, and the codified clause is split against itself: the heading printed above it on acquisition.gov reads FLUORINATED AQUEOUS FILM-FORMING FOAM FIRE-FIGHTING AGENT (MAR 2024) while its own (b) reads on any fire-fighting agent. The text a DoD contracting officer applies instead — Class Deviation 2026-O0018, Attachment A1, page 17, FEB 2024 — carries the narrower reading in both places, its (b) reaching an aqueous film-forming foam agent only. Both were read on 2026-08-08. A non-foam fluorinated agent is inside the codified (b) and outside the deviated one.

The 7 templates that name it, with the line
233RTX Flowdown of U.S. Government Contract Clauses Under U.S. Government ContractsRTXline 713166Northrop Grumman CTM-P-ST-001 — U.S. Government Firm Fixed Price Order (Not for Commercial Products and Services)Northrop Grummanline 245169Northrop Grumman CTM-P-ST-002 — U.S. Government FFP or T&M Order for Commercial Products and ServicesNorthrop Grummanline 2414166Northrop Grumman CTM-P-ST-003 — U.S. Government T&M Order (Not for Commercial Products and Services)Northrop Grummanline 2390168Northrop Grumman CTM-P-ST-004 — U.S. Government Cost Reimbursement Order (Not for Commercial Products and Services)Northrop Grummanline 2488107Honeywell — Supplemental Provisions Under Fixed Price U.S. Government Contracts for Commercial ItemsHoneywellline 66389AAR Government Services — C40 Purchase Order General Provisions, Non-Commercial Firm Fixed Price Items or ServicesAAR Corpline 3140

Source: acquisition.gov, DFARS 252.223-7009, DFARS subpart 223.74 (223.7400 through 223.7404) and DFARS 212.301(f) (verified 2026-08-05); DoD Class Deviation 2026-O0018, DFARS Part 223, 2025-12-18, Attachment A1, 223.7402/223.7404 and 252.223-7009; Class Deviation 2026-O0028, Table 212.4

This is research, not legal advice. It states what the regulation says about this clause and cites the paragraph behind it. It does not rule on your order, and it does not rule on whether a prime's markings are correct.