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EFTCO Newsflash
EFTCO Council Meeting of 11 March 2010 in Brussels

The major topics dealt with were as follows:
  • The Council has approved unanimously the adherence of the Romanian Tank Cleaning Association “ASCR” formed earlier this year under the presidency of Mr. Lucian Loghin. As from April 1, 2010 the ASCR will be a full member of EFTCO. The desired support will be given to ASCR to make their membership and the tank cleaning development in Romania a success.
  • To fight the ECD falsifications CTC-Belgium is volunteering to utilize the high secured ECD form not different from the existing one but provided with a number of protection features such as micro-text and UV-shades. The next print of ECD’s in Belgium for CTC is planned for the 2nd quarter 2010. Utilizing these ECD’s is expected to start thereafter gradually phasing in the monthes thereafter.
  • The growing demand for complementary services in the tank cleaning sector is particularly taking place in the silo tank cleaning. Therefore EFTCO with representatives of the silo transport sector and the plastics industry are working out better defined tank cleaning order requests. It is expected that a draft agreement will be concluded during the 2nd quarter
  • The FOOD Tank Cleaning project is progressing. The ATCN’s ‘Hygienecode voor Tankauto Reiniging” has been updated to European law. The English translation is in progress. The EFTCO Tank Cleaning Food Assessment procedure is expected to be available as a draft before the next meeting.
  • EFTCO is participating to the SQAS Tank Cleaning revision as planned by the Cefic SQAS T&A Committee. The objective is to further simplify and to better clarify the questions and the guidelines based on the experience of the past years. Also, another attempt is made to improve the consulting of the SQAS Report data base.
  • The next meeting will take place in Hamburg on 10 th June, 2010.
Guidance notice to all EFTCO Members dealing with Tank Cleaning and Complementary Services (6 November 2009)
The EFTCO Council’s meeting of 5 November dealt with the issue of providing cleaning and equipment control services beyond the standard provision of a tank cleaning (tanks and silos) . See definition of ‘clean’ : a tank shall be described as clean when there are no visible traces or odor of the last product or cleaning agent following an inspection via the man-lids. This contractual relation between cleaner and client is meant to be a straight forward operation of cleaning a tank or silo from its last carried product load declared by the client, cleaned with adequate cleaning equipment and managed in accordance with the legal waste disposal requirements of the cleaner’s operating permit. The means to conclude such agreement are sufficiently known by both parties.

This contractual commitment changes when in addition the client asks for complementary or additional cleaning services such as some of the examples below:
  • Cleaning the tank or silo in relation to next particular loading operation (i.e. special cleaning provisions)
  • Cleaning additional equipment of pumps, hoses, gaskets, valves etc.
  • Removing the grease from an air compressor (usually mounted on the truck and not on the silo: note that the silo may be pulled by another truck the next day)
  • Inner inspection (tank entry) of the tank wall and corners not visible from the man-lid, followed by a wall-test
  • Cleaning a tank container and the equipment in an off-hire situation, where the expectation of the hirer/lessor will be greater than just “fit for next load”
  • Operation of manometer and temperature gauge.
Whilst providing these services are a business opportunity in the tank cleaning industry, EFTCO strongly recommends that its members carefully assess the consequences of committing to a performance agreement with quality assurance connotations, because these additional responsibilities may expose the tank cleaner to consequential damage claims in the event of a product quality contamination further down the supply chain line. The standard assurance offered to all customers by the EFTCO “definition of clean” is limited and therefore any action or decision by the cleaning station to extend their potential liability in this way should not be taken without due consideration of the potential consequences. Members may therefore wish to declare the terms and conditions under which the extra services are provided.

EFTCO has been contacted recently by different parties involved: both the transport sector and the chemical industry are very much concerned with the issue since their customer claims are increasing in number and in value. Some insurance companies are covering both parties at the same time: the consequence is they turn the claim towards the cleaner. In some other cases where claims escalate into court, the judge claims “that the cleaner should have known better when accepting the work”.

Considering the above EFTCO distributes this guidance notice for the members and for whom it might concern. At the same time the EFTCO Council has decided to take the initiative to work out a comprehensive guideline with all parties involved including insurance companies and with the support of legal advice.

Members will be informed soon of the outcome of the first step of the initiative.
EFTCO Councils Meeting of 5 November 2009 in Amsterdam-Schiphol
The major topics dealt with were as follows:
  • The increasing number of ECD falsifications is the adverse effect of the ECD success and its’ standardization of tank cleaning operations. Therefore an improvement action plan was agreed to protect better and to identify faster this counterfeiting, an act of false competition in the transport supply chain and often a criminal offense towards the environment.
  • As a consequence of the growing demand for complementary services in the tank cleaning sector, the Council decided to draft a guidance notice for its members. In the meantime the text is made available – see also this website.
  • The FOOD Tank Cleaning project is progressing. The ATCN’s ‘Hygienecode voor Tankauto Reiniging” (updated to European law and in English) together with independent expert advice from Précon-Food is complementing the project regarding the assessment procedures in FOOD TC. A first draft is expected to be available before the next EFTCO meeting.
  • The application and the participation from the Romanian Tank Cleaning Association “ASCR” formed earlier this year, is welcomed at this meeting of 5 November. The ASCR delegation is requested to further pursue the conditions of adherence so as to allow the voting for membership at the next EFTCO meeting planned on March 11, 2010 in Brussels.
DRAMATIC IMPACT OF THE ECONOMIC CRISIS ON TANK CLEANING
On top of the substantial decline of the number of cleanings (e.g. up to 40 % in silo cleaning) and the depressed tariffs the tank cleaning industry faces a dramatic increase of fraudulent ECD use and of illegal cleanings. It looks like the clock is set back some 15 years.
  1. Read hereafter the WORMS press article of 14 Aug about the illegal tank cleaning prosecuted by the Kriminal Polizei.
  2. NIENBURG case of 7 Aug : the driver of a tank truck company in Oldenburg wanting to clean his tank himself entering the tank. Seriously hurt his life was saved at the very last second by the city emergency team.
  3. The subcontractor of a well known respected haulier (without his knowledge) carefully duplicating ECD’s in a systematic way (2 drivers involved) over a long period applying the system in Holland, Germany, Belgium. The system was intercepted thanks to the control at the loading point of a major chemical production site.
  4. A similar case in Holland by an individual truck driver: in June he was caught for the second time in a year repeating of what he did before.
  5. Several cases of duplication in Spain.
  6. Dramatic situations in Italy are reported: substandard tank cleaning operations by owners not even knowing what SQAS or ISO certification means resulted in casualties a few of which fatal. Tank cleaning operations are performed at tariffs that do not even cover the energy cost.
Todays situation in the tank cleaning amongst a larger part of non-EFTCO members is unsafe, dangerous to the environment and illegal.
EFTCO has made an appeal to Cefic and to ECTA to discuss how to correct this situation which on top is unfair and false competition to the reputed hauliers who are our customers.
On September 15 a work meeting will be held to that effect.

Click here to download the EFTCO Newsletter of 18 August 2009 (935 Kb)
EFTCO meeting,29 January 2009
At the EFTCO meeting of 29 January 2009 in Brussels the Council has agreed and voted the new organization to be as follows:
  • Karl-Josef Schürmann president of and representing DVTI Germany as President of EFTCO
  • Erwig Seliaerts chairman of and representing CTC Belgium as Vice-president of EFTCO
  • John Wilson representing NRTCA England to continue the function as Treasurer
  • Hugo Kerkhofs for CLM bvba Belgium to continue the function as Secretary General

At the same meeting the progress about the following topics was discussed:
  • SQAS Tank Cleaning last major revision in 2008 with Cefic valid until the next revision planned for 2010.
  • ECD – the European Cleaning Document guidelines revision published on this site under ‘Download’ and concerning amongst others the period of validity issue of the document.
  • ECD – progress reporting about the development of an electronic version: a test is running in the version of an ‘electronic order confirmation’ procedure under supervision of DVTI. Conclusions are expected to be drawn in the course of 2009.
  • The Council agreed to continue the development of an SQAS F (Food / Feed) while keeping the ECD form as is: the EFTCO Work Group Food is conducting this study and will develop a proposal in the months ahead prior to the next meeting.
The Council decided as well that the next meeting will take place in Prague on 28-29 May 2009 combined with the celebration of EFTCO’s 10th year of association.