Erwig Seliaerts, President of EFTCO

Erwig Seliaerts explains why EFTCO was founded and talks about the challenge of reducing risk

How long have you been president of EFTCO (European Federation of Tank Cleaning Associations)? What does the job entail?

I officially became the President of EFTCO on January 1 2013 after being vice-president for several years. EFTCO is the only federation of National Associations that spans 19 countries across Europe. Only the National Association can be a Member of EFTCO and the companies that operate cleaning stations are linked to EFTCO through their national association. There are approximately 430 cleaning stations affiliated to EFTCO in this way.

The structure of EFTCO changed a lot last year when it established a Board of Directors, chaired by the President for the management and operation of EFTCO.Erwig

There are currently six board members from representatives of the following countries: UK, Netherlands, Belgium, France, Germany and Hungary. The board is democratically elected by the EFTCO members during the annual general meeting and, after a two year term of service, the board members are retired but can stand again for re-election.

Key responsibilities are divided among the board members and in addition the wider Membership is involved in Work Groups focused on delivering specific projects such as Budget and Structure, Food Audits and Quality Standards, Shared learning from Incident and Safety studies.

When was the organisation established and what is its purpose?

In 1993 the concept of EFTCO was a spark formed from some national tank cleaning organisations which met to share ideas to promote a wider view within Europe. This took a formal structure in 1999 when EFTCO was established as a legal company with six founding members. (UK, Belgium, Netherlands, France, Italy and Spain).

Since then this has become 19 European countries with more seeking to join when they are able to satisfy the criteria set by EFTCO to maintain standards. EFTCO has had requests for membership from Africa and Asia but, to date, we remain within the geographical area of Europe defined by Turkey in the East, Ireland in the West, Finland in the North and Italy and Spain in the South.

The purpose of EFTCO is to study, protect and develop the professional interests of the federation and its members, to develop and promote the professional image of the sector, to seek and encourage the development of relationships with other organisations having related activities and with regulatory bodies, both nationally and internationally. Good relations are built up with the chemical industry, the food industry and with local authorities in the different countries through national organisations.

What encouraged the formation of EFTCO?

The start point came when the National Associations recognised the tank cleaning sector needed to demonstrate some common standards across frontiers to be accepted as a meaningful partner in discussions with the manufacturing industry and authorities as well as with their direct customers – the tank transport operators. At the time of EFTCO’s foundation European legislators were very active and the national organisations could see it was better to pool resources and where possible deliver multinational solutions to a high standard.

One of the organisation’s major achievements is the publication of the ECD (European cleaning document). Can you please give a brief background on the ECD, its purpose and its acceptance in the cleaning industry?

The development and the success of the European Cleaning Document (ECD) was an important milestone for EFTCO and a good example of a multinational solution.  The ECD was developed in co-operation with Cefic with the purpose of issuing reliable information in a standard format confirming how a tank was cleaned regardless of which station or country it was cleaned in.

[pullquote]The ECD was not made available to just any cleaning station seeking access for it[/pullquote]

The solution was delivered by having all affiliated cleaning stations adopt the standard EFTCO ECD form, and then getting the sites to use a standard numbered key, that we call ‘the codes’ which declares the wash process. The codes are explained in the local language and also other European languages on the reverse of the ECD. Translation of the codes into 18 languages can be downloaded from the EFTCO website:

The ECD was not made available to just any cleaning station seeking access for it. It was also established that every site must first satisfy an independent professional audit process.

EFTCO worked closely with CEFIC to develop a detailed audit to be done under the CEFIC controlled SQAS (Safety and Quality Assessment System). The result is “SQAS Tank Cleaning” and the cleaning station must prove they meet the audit’s requirements before being allowed to use the ECD. The Audit is repeated in full every three years and this assures all that the cleaning station has all necessary permits and can be trusted in their activities.

The time when a clean was perhaps done with a brush and a bucket of water disappeared long ago from EFTCO’s domain; modern tank cleaning facilities require large investment in cleaning and environmental technology, a committed culture of safety and training, and considerable operation costs. This is the reason why the sector needs to be protected against less bona fide cleaning stations.

This is also the reason why the layout of the ECD, the codes system and the name European Cleaning Document are registered giving a legal protection to the ECD.  EFTCO gives authorisation for the use of the ECD to the national tank cleaning organisations after they have signed a contract obliging them to set up a traceability system for all ECDs sold. Furthermore EFTCO has made a proposal for a contract between the national organisation and its members for a suitable use of the ECD.

The first ECDs were distributed by the CTC members in June 2005.

In 2012, over 2,000,000 ECDs were printed in the 19 member countries. The fact that the document is sometimes counterfeited, proves the importance of the ECD and that it has reached a certain value in the market. On the other hand, this also meant that EFTCO needed to invest in additional protection measures to make forging as difficult as possible with the new layout introduced in 2011 as result of it.

How do you see the role of EFTCO in advising or interpreting Europe-wide regulations, legislation, etc?

EFTCO has a very wide network of tank cleaning stations and has all expertise concerning tank cleaning in different European countries. For this reason EFTCO or its members are the best partners for authorities when developing new or adopting legislation for the tank cleaning sector. Different aspects of legislation can be involved: water and air emissions, waste disposal, operator safety, food safety, etc.

What further regulation or legislation to do you see on the horizon over the next few years?

We expect that environmental legislation will continue in the direction of improving discharge and disposal standards. Re-use of water and raw materials, energy recuperation, emission of greenhouse gases and a strict separation of waste streams will be imposed in all countries.

The standards for discharge of waste water, vapour emissions and waste disposal will be reduced more and more. EFTCO hopes this will at least be done on a European level, meaning that the standards are the same in all member countries.

Looking ahead, EFTCO wants to support scientific investigation to find acceptable solutions to this problem. In Belgium CTC supports an investigation where scientists are looking for a solution for the concentrate streams produced by membrane filtration. When a solution for these streams is found, the door is open for the re-use of a major part of the cleaning water and even zero-discharge will be a possibility.

How many national associations are now members of EFTCO? What scope is there for widening the membership?

For the moment 19 countries are members of EFTCO. EFTCO does not actively look to seek new members. Because no individual companies can be a member of EFTCO, the tank cleaning stations in a certain country must first be prepared to organise themselves in a national tank cleaning association. Only when this is achieved can membership of EFTCO be possible.

Countries with insufficient tank cleaning stations to form a national organisation can try to be accepted by the national organisation of another country. This was done in the past for Finland, Norway and Sweden, but last year Finland decided to found its own national organisation. Also the cleaning stations of Switzerland are member of the German DVTI.

What are the major risks associated with the process of tank cleaning? How can these risks be minimised?

In the first place major risks associated with the process of tank cleaning are for the cleaning operators. Not only they are confronted with a very wide variety of different chemical products, which have their own properties and risks, but due to their activities they need to enter confined spaces regularly. As we all know this is a risky business which kills people every year. A regrettable accident in a tank cleaning station occurred in Germany recently where two operators lost their lives in a tank. It proved once more that inert gas is a real assassin because you cannot see, feel or smell it.

Each time a tank is cleaned, there must be a tank cleaning procedure in place obliging oxygen and LEL measurements to be taken before tank entry. It is important that each responsible manager ensures this procedure is carried out before each tank entry. The used measurement devices must be kept in perfect condition and functioning must be tested before each use.

EFTCO installed a working group for analyzing the incidents and the accidents occurring in the sector. Each incident will be analyzed with the purpose of making all members aware of certain risks and advice will be given on what can be done to avoid these risks in future, or to reduce them to an acceptable level. If all this can avoid the re-occurrence of just one serious accident, then it is worth doing.

Of course there are also risks associated with the cleaning process.

The broad diversity of cleaned products represent risks in different areas:  toxicity, reactivity, compatibility, chemicals burns. For this reason tank cleaning stations must have a comprehensive product database for managing all these products. All relevant information must be transferred to a cleaning order in order for operators to prescribe all the necessary personal protection.

[pullquote]EFTCO supports the SQAS system to assure at least a certain quality standard[/pullquote]

In the past, explosions have occurred in tank cleaning stations during the cleaning of synthetic resins where inflammable solvents with a low flashpoint and high volatility have been used as a cleaning agent. Only trained operators are allowed to use such products on an explosion proof (ATEX) cleaning bay because the risk for a fire or an explosion is always present. Even the safety equipment of the operators can be important as, according to information we have received, explosions occurring during such cleaning processes were usually caused by the static charge on the high visibility coat of the cleaner. A small spark in the right conditions is enough to blow up a cleaning installation.

For all these reasons efforts are being made to find good alternatives for the solvents involved. Some products are available on the market but they are still too expensive for common use. The pressure of cleaning times does not currently allow for the use of these safer cleaning agents.

Finally there are also risks associated with the cleaning result. When a tank is not sufficiently cleaned, contamination of the next load can have not just big financial consequences, but potential safety problems or even fatalities in cases of contaminated food tankers. The industry puts a lot of pressure on the tank cleaning stations to avoid or at least reduce contamination cases and, according to our information, the number of contaminations is far below 1 percent. Even then, in most cases the contamination has nothing to do with the cleaning of the tanker, but more with the hoses or pumps used for the product transfer.

For this reason EFTCO supports the SQAS system to assure at least a certain quality standard. Based on the same policy, EFTCO’s food work group co-operates with the fruit juice manufacturers to develop a food assessment. In this sector there is a lot to consider about the traceability of procedures carried out during cleaning where temperatures, pressures and concentrations of cleaning agents must be monitored during the whole cleaning process, and the last cleaning water must be tested on several parameters.

The food industry even insists that this traceability is done per spinner and prescribes the cleaning procedures to be carried out – although these can be dependent on the technical installation available in a certain cleaning station. Furthermore, this monitoring checks the process only, but not the quality of the cleaning. Each cleaning procedure can be scrupulously followed but the tank might not be clean due to old residues present in a tank or a procedure which is not adapted to the last load in the tank. Therefore a visual tank inspection by a skilled cleaning operator will be unavoidable. In critical cases even tank entry after cleaning will be necessary.

Can you tell us more about ‘Green Cleaning’?

For the public, tank cleaning is seen as a dangerous, dirty and polluting business, but the sector wants to get rid of this image. Modern tank cleaning facilities are technologically sophisticated installations taking care to reduce their environmental impact as much as possible. Just like you cannot make an omelette without breaking eggs, tank cleaning cannot be done without the use of water. Water is a good solvent for a lot of products. It is cheap and, last but not least, it is non-toxic and safe for use. After the tank cleaning the cleaning water is very dirty and needs to be purified before it is discharged in to the sewer system. Physical, chemical, biological, sand filtration and activated carbon filtration are waste water treatment technologies which are commonly practiced in the tank cleaning sector. The treatment reduces the pollution of waste water by more than 99 percent before discharge.

[pullquote]Modern tank cleaning facilities are technologically sophisticated installations[/pullquote]

Tank cleaning is a necessary part of the supply chain. Can you imagine what would happen on our roads if all solids and liquids were transported in dedicated tanks? Do you see the whole country standing still due to congestion problems? What is the economic impact of that? And what would that mean for our carbon footprint in general?

On the EFTCO website the difference in CO2 emissions is calculated between the energy consumption of normal tank cleaning compared with an empty transport over 250km with a truck consuming 30 litres of fuel / 100 km under normal traffic conditions (no traffic jams are taken into account). When this calculation is done for 2,000,000 tank cleanings per year in Europe only, 285.971.149 kg of CO2 emissions are avoided!

I believe this illustrates that tank cleaning is not only necessary for economic reasons, but also for our environment. A sustainable supply chain cannot ignore this aspect of the tank cleaning business.