Would you believe lack of proper UST operator training tops the charts of UST violations in the US? A recently published report about the state of national UST compliance shows some curious results, especially about UST operator training violations. The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Tank Subcommittee’s UST Task Force with assistance from the US EPA published the study UST COMMON COMPLIANCE VIOLATIONS REPORT – FY 2014.
According to the study “The intent of this report is to provide a national perspective with regard to which UST violations are discovered in greatest frequency and may require additional attention.”
While much of the report was eye-opening in regards to things like what’s not working with release detection, we focused on the part about UST operator training. The report further states: “The FY 2014 dataset represents the responses of 31 States and one local agency, and accounts for nearly 43,000 UST inspections. For 2014, Operator Training was the top violation category with 81% of the States reporting it in their top eight violations; this is followed by Release Detection Pressure – Piping at 75%, Release Detection – Tank at 69%, Spill Prevention at 63%, Corrosion Protection at 59%, Financial Responsibility at 53%, and Other/State Specific at 50%.”
Here is what the study found and what we think of the results.
“Figure 3 graphs the most frequently occurring violations within the Operator Training category. Over 40% of the violations reported were for failure to meet Class A, B, or C training requirements and an additional 50% was split between failure to conduct periodic inspections and failure to post or provide copies of operator training documents at the site. The remaining violations consist of failing to complete required retraining and State specific operator training violations. Operator Training violations doubled from 2012 to 2014. This follows a large increase in violations from 2010 to 2012. This continues to mirror the States’ efforts to implement and enforce the Operator Training requirements of the Energy Policy Act of 2005.”
So what does this mean? Of the 9,251 training violations noted:
Failure to Complete Retraining is low but retraining is only required in some states. So this number may make sense.
Failure to meet Class A, B or C training requirements make up almost half of the violations. Are there that many folks who did not get trained? Or not trained by a certified trainer? Or could they just not prove it? We will assume this 43% simply didn’t train at all. We’re curious what sectors of the UST world are most commonly not trained…c-stores? Government agencies? Utilities? Shipping?
Failure to conduct periodic inspections is limited to states that require AB’s to inspect sites but is surprisingly high, given that the training should have covered how to inspect. Maybe folks who never trained (see above) would not know to inspect also.
Failure to provide or post training documents could mean the owner had the certificate and failed to post it or didn’t have the correct documents.
Operator training violations doubled between 2012 and 2014. Were operators still getting trained and up to speed? Or were states cracking down harder? Are there that many folks who don’t get it? Historically record keeping violations have been a major problem so this number also make sense.
States NOT reporting UST operator training as a top five violation: CNMI (We trained them), Florida (not sure what their secret is) , Kansas (only free live training allowed), South Carolina (Free online training).
Our two cents:
- There’s lots of operators still not being trained.
- Paperwork violations persist.
- Unclear what will motivate operators to train and reverse trend of increased violations. Public outreach, higher fines, and more qualified trainers can only help.
We at UST Training are always looking for ways to help improve compliance for UST owners and inspectors and see information like this as a great tool to help everyone find and fix the weak spots in the UST program. What do you make of these numbers? We’d love to hear from you. Eial us your thoughts at info@USTtraining.com.
For a copy of the full report, go here http://www.astswmo.org/files/policies/Tanks/2016-09-USTCommonComplianceViolations-FY14Report-FINAL.pdf