Safety and Regulatory Compliance – JFC Poland’s Priorities
Safety and compliance with regulations are the key pillars guiding our decisions at JFC Poland. Recently, we received numerous expert opinions in the field of fire protection (including an Opinion dated July 14, 2021), analyses from the Office of Technical Inspection, and statements from experts and firefighters highlighting significant risks when using double-walled tanks without an external distribution box, where the pump and dispensing system are mounted directly on the inner tank. Additionally, fuel distribution equipment manufacturers (e.g., Piusi) clearly state in their instructions that their pumps “are not explosion-proof and should not be installed in locations where flammable vapors may be present” (Opinion 14.07.2021, p. 4).
Below we present the key reasons why we decided not to introduce such constructions to the market.
1. Hazard According to § 64 Section 1 of the Regulation from September 18, 2001
As stated in § 64 Section 1 of the Regulation of the Minister of Economy dated September 18, 2001, regarding technical supervision conditions:
“No residues of the working substance should be present on the external surfaces of the tank.”
However, in tanks without a separated (external) distribution box, the dispensing system (pump, filter, filler, meter, or hose reel) is installed directly on the inner tank, which is accessed via a door on the external tank. Experts point out that in such a solution:
“fuel leakage (e.g., when setting down the filler) or ingress of rainwater (when doors are open) may lead to liquid accumulation in the interstitial space” (Opinion 14.07.2021).
Thus, fuel residues appear on the outer surfaces of the inner tank (which is formally part of the double-walled structure), contradicting the above-mentioned regulation.
2. False Alarms and Risk of Overlooking Real Leaks
According to fire protection opinions:
“Installing the dispensing system on the inner tank allows easy access of various liquids [...] to the interstitial space, which may disturb the correct operation of the leak sensor” (Opinion 14.07.2021).
This means that any accumulation of rainwater or diesel droplets between the tank walls can trigger leak alarms, disrupting user operation and potentially causing real leaks to be overlooked if liquid was previously collected in the interstitial space.
3. Temperature Rise, Vapors, and Lack of Explosion-Proof Design
The interstitial space may heat up to temperatures exceeding 70°C on hot days. Experts state:
“The pump installed in the interstitial space is not explosion-proof and may generate sparks directly contacting fuel vapors in that space.” (Opinion 14.07.2021)
At the same time, pump manufacturers (including Piusi) explicitly state that “motors are not explosion-proof and must not be installed where flammable vapors may be present.” If the inner tank leaks (even slightly), diesel vapors may accumulate where sparks are generated, increasing the risk of ignition.
Moreover, some designs without an external box install a vent valve directly on the inner tank. According to the opinion:
“Vapors released from the valve may accumulate in the interstitial space where the dispensing system is installed – exposing the tank user to vapors.” (Opinion 14.07.2021)
This practically means higher vapor concentration on hot days and increased ignition risk during refueling and nozzle operation.
4. Direct Exposure to Pump Vibrations and Risk of Spontaneous Combustion
The same expert opinion notes:
“The pump generates heat and vibrations during operation, which may adversely affect the inner tank’s condition […]. The temperature generated by the pump may cause spontaneous ignition of diesel vapors.” (Opinion 14.07.2021)
For tanks without an external box, the pump is mounted directly on the inner tank containing fuel. Vibrations and high engine temperature may accelerate material aging and trigger dangerous thermal reactions.
Why Doesn’t JFC Poland Introduce Such Tanks to the Market?
Considering expert opinions on fire protection, the UDT’s position, the Regulation of the Minister of Economy dated September 18, 2001, and ATEX Directives (1999/92/EC, 2014/34/EU), JFC Poland consciously decided not to sell double-walled tanks without a separated external distribution box.
It should be noted that – as clearly stated in point 4 of the UDT letter (TC.40.27.2018/JK2-2) – the tank manufacturer is responsible for identifying hazards related to tank operation. Therefore, all production decisions must be preceded by thorough analysis of potential risks and legal compliance.
Conclusions from Analyses:
- Fire and explosion risk: contact of non-Ex pumps with diesel vapors in heated space.
- False alarms and lack of reliable leak monitoring: misleading leak sensor indications when contacting water or fuel droplets.
- Non-compliance with regulations: exposing users to consequences of § 64 Section 1 Regulation from 18.09.2001 (fuel residues on tank surface) and explosion hazard equipment regulations.
- Increased temperature: high temperatures favor accumulation of flammable vapors, which manufacturers must consider during design.
As an experienced manufacturer, we always prioritize safety and customer care. Based on analyses of specialist fire protection expert opinions, UDT recommendations, and pump manufacturers’ guidelines, we have decided to completely withdraw double-walled tanks without an external distribution box from our offer.
We believe that full separation of pump and filter systems from the interstitial space is the only way to ensure maximum user protection and reliable sensor operation. We continually improve our solutions to meet legal requirements and actual operating conditions.
Thanks to this, JFC Poland customers can be confident they invest in products free from unnecessary risks, designed for long-lasting and safe use. We care not only about legal compliance but also about the full satisfaction of every customer who trusts us.
