Introduction

This Fact File gives a detailed look at the underground storage tank (UST) Class C operator training requirements. The Class C operator training is unique in that it is provided at a facility level and by the Class A or B operator for the facility. Because of this nuance Class C operator training tends to be less defined in regulation and can be an area of confusion for UST facilities. Presented here are Class C operator training requirements, what records must be kept for the training and what information it is important that Class C operators know.

Background

Initially taking effect in 2018, EPA established minimum training requirements for three designated “classes” of UST operators. The training requirements are intended to make sure that everyone directly involved in UST operations knows what their role is in prevention of and response to leaks, overfills, emergencies, and negative environmental impacts. UST operators are required at every “UST facility,” meaning a location with one or more underground storage tanks or tank piping with at least 10 percent of its volume below ground level and storing either petroleum or certain hazardous substances. UST facilities can be a wide range of business types - including universities, hospitals, industrial site, fueling stations, and more.

Federal regulation established the three classes as Class A, Class B, and Class C operators. Classes A and B have more responsibility and formal certification requirements and are typically in a more authoritative role such as manager or Environment, Safety, and Health professional. The Class A or B operator then provides training or testing of all Class C operators at each UST facility. Class C operators are individuals are typically first to respond to UST emergencies, spills, or releases and therefore training focuses on these areas.

Class C operator training requirements

Each designated Class C operator must be trained by a Class A or Class B operator; complete a training program; or pass a comparable examination. No matter what training option is used, the material must cover appropriate actions for a Class C operator to take in response to emergencies and alarms related to the facility UST system. Emergencies and alarms can include visible spills, alarms from rapid tank level drops, leaks, and alarms from material in secondary containment and under-dispenser containment, and much more. Class C operators must also be knowledgeable required notification to appropriate authorities, including when and how to contact emergency responders and Class A and B operators.

Anyone who meets the definition of a Class C operator must be designated as one, including fuel station attendants or fleet office personnel. Class C operators must be trained before beginning work.

Class C operator training records

There are two types of records that UST facilities must maintain regarding operator training – a record of who is trained in each role and then training specific records for each operator. The first is a list that is kept up to date, which identifies all Class A, Class B, and Class C operators for the location. The list must include the name of each operator, the class each operator is trained to, date the operator’s duties began, date each operator completed initial training, and dates of any retraining. The second type of record - those documenting training for each operator - at a minimum, must identify name of trainee, date trained, operator training class completed, and list the name of the trainer or examiner and the training company name, address, and telephone number. Owners and operators must maintain these records for as long as the operator is designated for that UST facility

Class C operator — What to know

The following is a list of things that a Class C operator should be familiar with and should be included in the training provided:

• Understand how the UST system(s) at your facility operate.
• Be familiar with the location of the parts of your UST system(s):
  • Dispenser,
  • Hoses,
  • Nozzles,
  • Breakaway couplings,
  • Emergency shut-off switch, and
  • Alarm panel.
• Be familiar with all the alarms, messages, and lights on the alarm panel. Label the lights, switches, and alarms to eliminate confusion.
• Know where to find the list of company people who should be notified in an emergency.
• Be familiar with the number to call the fire department for this facility and know the address of the facility, so it can be given to any emergency responders.
• If applicable, know the difference between the emergency stop switch (shuts off power to all the dispensers and fuel pumps) and the “Stop” or “All Stop” button on the point-of-sale (POS) console.

Applicable laws & regulations

40 CFR 280 Subpart J — Operator Training

Related definitions

Class A operator: The individual who has primary responsibility to operate and maintain the UST system in accordance with applicable requirements established by the implementing agency. The Class A operator typically manages resources and personnel, such as establishing work assignments, to achieve and maintain compliance with regulatory requirements.

Class B operator: The individual who has day-to-day responsibility for implementing applicable regulatory requirements established by the implementing agency. The Class B operator typically implements in-field aspects of operation, maintenance, and associated recordkeeping for the UST system. “Class C operator” means the individual responsible for initially addressing emergencies presented by a spill or release from an UST system. The Class C operator typically controls or monitors the dispensing or sale of regulated substances.

Key to remember

Anyone who meets the definition of a Class C operator must be designated as one, including fuel station attendants or fleet office personnel. Regulations do not set a specific number of people at a UST facility, but rather leaves it open to include whatever number is appropriate for each facility based on the operation.

Always check UST operator requirements for the state in which a UST Facility is located. Many states have UST operator requirements that differ the federal regulations. For example, some states have added topics, beyond those required by the federal EPA, that must be included in training.

Real world example

A commercial gas station that also operates a 24-hour a day convenience store at the location had trained all day-sift store attendants with a very thorough hands-on training class. Since most of the inspections, fuel deliveries, system maintenance, and other tasks they considered to be a high risk of causing a release or spill, occurred during the day the company thought they were complying with the regulation. When the state environmental department conducted an annual inspection, the company was caught very off-guard when they were cited for lacking Class C trainings. What the station management had failed to recognize was the need for all the attendants, including night-shift employees, to be trained. These “off-shift” attendees are still acting in a position that meets the Class C operator role and must also know how to 1. respond to alarms, releases, and spills and 2. what notifications must be made when these occur.