2015 was a good year for the clean groundwater and the environment. We trained many thousands of new UST operators in the last 365 days, adding to the growing pool of professionals who manage compliance for USTs nationwide. And near as we can tell, reported leaking USTs were down nationwide. And hopefully, though we cannot confirm, the number of compliance violations have dropped in part due to our training.
So where does that leave operator training in 2016 and beyond? Here’s my observations about what’s working, what’s not, and what we might expect in the near future.
Reciprocity. The term means that certain states allow your operator training certificate in one state to be accepted in another state. Tennessee for instance has a free online program that a number of states recognize as an equivalent, which is odd because the rules in Tennessee may not apply in a number of states. Some New England states are considering not allowing reciprocity in the future. They’ve found that operators with recent violations were trained in another state and have correlated that had they been trained to their state standards and not another, then the violation may not have occurred. After watching this issue sprout and bloom over the last many years, I’ve concluded that UST operator reciprocity is not a good idea for compliance.
Refreshers. Some states require periodic refreshers that range from annually for Class Cs (Hawaii) to 7 years (Georgia) to never (most states). Some states are starting to examine whether a no-refresher rule is a good idea. Refresher are prudent if: there is a lot of learning material; near-complete retention is not possible; the training is not presented in a way to encourage active learning; rule changes since the last class; or the operator is distracted during class, has learning problems or does not agree with the content. However, high industry turnover usually guarantees that the person is no longer employed by the time the refresher comes around. So the best solution? It depends. My perspective is that mandatory retraining is probably a good idea most of the time. If I were king for a day I’d make a Class C refresher every 1-2 years and a Class A/B refresher every 3-4 years.
Testing Versus Training. An unfortunate federal rule that many states adopted allows for testing and training be considered the same thing for operator certification. In other words, a 50-question quiz, testing minimum competency, is just as good as a classroom or online course when people learn things and get tested for minimum competency. Surveys collected our customers from a number of states since 2010 show that roughly one quarter of operators found the information new to them, about half found it somewhat new, and about a quarter found it stuff they already knew. Which could mean that three-quarters of our operators might not be able pass a test (or shouldn’t be expected to). Plus testing is just testing and not a good way to inspire, encourage, support, instruct or correct certain behaviors.
Full, Not Partial Coverage. Some large company operators are happy to have one Class A/B operator to cover an entire region or even an entire state. Some operator have at least one Class A/B per site and some even have multiple A/B operators per site. Guess who gets the least Notice of Violations? I’ve found over the years that the UST owners with the best compliance records always have one or more trained Class A/B operator on-site. Interestingly, some states require a “no more than” rule where any one operator can only represent so many UST sites. Some states base it on the total number of sites under one’s responsibility and some states don’t allow a site to be more than X miles away from their office. Regardless, it stands to reason, if not common sense, that pushing training intelligence down to the site level makes for a great compliance philosophy. The more you train, the less you’re surprised when the inspector shows up.
And FYI: EPA just passed rules that will require ALL designated Class C operators to be trained by or around October 2018, not just one or a few per site. So start thinking about how you will train anyone whose job duty might entail responding to a leak, spill, fire, alarm or other UST incident. We have a lease option that you might find useful for this.
Quality of Training. I’ve written about quality training since I did the nation’s first state-approved Class A/B course in Portland Oregon in 2003. Most states don’t have authority to evaluate quality of the training, qualifications of the trainer, or other intangibles that can make or break a good training experience. The old adage applies here: Good, Quick, Cheap: you can only have three. Or, my favorite: Pay Peanuts, Get Monkeys.
Straggler States. Nebraska is one of the last states to adopt operator training rules and by the deadline of 12/31/15, most of the operators should have been trained. New York just adopted rules and training must be done by October 11, 2016. New Jersey gets the caboose award for being the last state/territory.
Indian Country. USTs in Indian Country are subject to Federal UST rules and since EPA just passed operator training rules, Indian tribes have until October 13, 2018 to get trained. we have a National Class A/B course that’s available to tribes now who want to start getting trained today.
Advanced Training. Some UST operators see the intrinsic value in training and want to go deeper. We provided customized, advanced Class A, B and C training to clients in 2016 are encouraged that some operators hear the call and want to go deeper than what state and federal rules apply. Want to lern more? Give us a call at 866-301-8265 or email us today.
Have a great New Year!