The analysis of processes taking place in a steady pneumatic (dynamic) foam shows the possibility of different modes of surfactant accumulation within the top layers of bubbles due to rupture of external foam films. An increasing surfactant concentration within the top layers promotes the stabilisation of bubbles and the foam as a whole. Considering the balance of surfactant and water during the bursting of films it is possible to estimate the accumulated surfactant loss caused by a downwards flow through the Plateau borders of the subsurface bubble layer. This effect depends on the particular conditions, especially on the surfactant activity and concentration of the surfactant, water volume fraction in the foam and size of foam bubbles. The process of surfactant accumulation in the top foam bubble layer can be complicated due to the removal of part of the accumulated surfactant through transport with droplets spread out during bubble bursting.