Understanding the training ABCs of Underground Storage Tanks

If you work at a facility with one or more underground storage tanks, meaning tanks and piping, storing either petroleum or certain hazardous substances, with at least 10 percent of its volume below ground level, then you must meet federal underground storage tank (UST) regulations. Commonly referred to as a “UST facility,” these requirements apply to a wide range of business types - including universities, hospitals, industrial site, fueling stations, and more. Federal UST regulations identify 3 classes of UST operators: A, B, and C. Understanding what each class requires and what training is required can be confusing, so let’s decode the rules.

Class A operators have day-to-day responsibility for implementing the UST regulations. Often this is the owner, regional manager, of EHS professional. This person must pass an exam covering general knowledge of the UST regulations. Each UST facility must have at least one certified Class A operator and they must be certified within 30 days of assuming responsibilities in the Class A operator role.

Class B operators are individuals who are responsible for daily operations, maintenance, and recordkeeping, commonly the facility manager. The Class B operator exam covers a more in-depth understanding of operation and maintenance aspects of UST systems. Each UST location must have at least one certified Class B operator. Class B operators must be trained within 30 days of assuming responsibilities as Class B operator.

Class C operators are individuals who are first to respond to UST emergencies, spills, or releases. 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 training must be provided by Class A or B operators and must include response procedures to alarms or other indications of an emergency, release, or suspected release. Class C operators must also know procedures for contacting Class A or B operators and any emergency responder when an incident occurs. This group of operators must be trained before beginning work.

If any of your facilities has a UST, make sure:

• Individuals in each role have been identified and required records are kept showing who is in each role.
• When an individual fills the role of more than one operator class, confirm they have been trained to each class.
• Ensure retraining occurs when UST system non-compliances (leaks, missed inspections, etc.) are identified.

In addition, check UST operator requirements for your state, as they may differ from the federal regulations. Many states have annual or 3-year retraining requirements for all Class A and B operators. Also, some states have added topics that must be included in training, beyond those required by the federal EPA.