Here’s what EPA finds as acceptable approaches to meet the training requirements stated in its guidelines:
- An operator training program conducted or developed by the state or by a third party that has received prior state approval. (Note: States might need to establish criteria to determine the suitability of any training provider or curriculum of training courses provided.) The program may include in-class, online, or hands-on training. Such a program must include an evaluation of operator knowledge.
Examples: Testing, practical demonstration, or other tools determined as acceptable by the state.
- An appropriately administered and evaluated verification of operator knowledge (i.e., examination). This determination must be accomplished through an operator examination designed to measure operator knowledge as required in the EPA’s guidelines. The state or a third party acceptable to the state may administer this examination. The examination process must be acceptable to the state and reasonably determine the person tested has the necessary knowledge and skills to be considered competent to operate underground storage tanks.
- For Class C operator training, the state may accept training conducted by a trained Class A or Class B operator.
- To address operators responsible for underground storage tank systems in multiple states, states may develop a program that accepts operator training verification from other states.
- Any combination of the above listed operator training approaches or comparable training approaches recognized by the state.
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Training for Class C Operators
The Class C UST Operator Training available on BLR’s TrainingToday covers the emergency response responsibilities that meet EPA guidelines. Federal law requires that all Class C operators must be trained on or before August 8, 2012 (or sooner in some states). The owner/operator (Class A/B operator) may customize the training to meet state and facility specific requirements. BLR’s Class C UST Operator Training course is acceptable or approved in AL, AR, CO, DC, DE, GA, ID, LA, MA, ME, MI, MN, MT, NC, ND, NV, OH, OK, OR, PA, RI, SC, SD, TN, TX, UT, VA, VT, WI, and WY. And the list is growing!
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Quick Guide to Operator Classes
| Class A Operator | Class B Operator | Class C Operator | |
| Who fits this class of operator? | The individual who generally focuses on the statutory and regulatory requirements related to operating and maintaining the underground storage tank system | The individual who is generally responsible for field implementation of applicable underground storage tank regulatory requirements and implements day-to-day aspects of operating, maintaining, and recordkeeping for USTs at one or more facilities | The individual who is generally the first line of response to events indicating emergency conditions or responding to alarms |
| What is the objective of the training requirements? | Ensure broad knowledge of regulatory requirements | Ensure in-depth knowledge of implementing regulatory requirements | Ensure knowledge of actions to take in the event of a leak or other emergency |
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Minimum training requirements. Nancy Teolis, BLR’s UST legal editor, wrote a pretty in-depth blog post for the Environmental Daily Advisor recently on the minimum requirements for facilities. Remember your state will most likely specific training requirements, so check with them too.
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