August marks the one year mark to meet the requirement outlined in the Energy Act of 2005 to have all UST operators trained. As individual states have wrestled to adopt this federal regulation, some have prescribed their own dates ahead of the federal standard. Here is a list of those states—along with some important facts and documents you’ll need to know to be ready to comply with this federal mandate.


First, let’s begin with a refresher of the types of operators defined under this law:

  • Class A Operator -  An individual having primary responsibility for the overall operation and maintenance of an UST System.
  • Class B Operator -   An individual having responsibility and direct control over daily on-site operation and maintenance of an UST System. (Can be same as the A Operator).
  • Class C Operator -   An individual, on-site employee having primary responsibility for addressing emergencies presented by a release from an UST System.

According to the mandate, after August 8, 2012 states MUST require operators to be trained as follows:

  • Class A and B must be trained within 30 days or another reasonable period (specified by the state) after assuming operation and maintenance responsibilities at the UST system
  • Class C operators must be trained before assuming responsibility for responding to emergencies.
State Deadlines

States with deadlines ahead of the federal date of August 8, 2012 are: 

  • California - January 1, 2005 (termed "designated operators")
  • Idaho - April 21, 2008
  • Oregon - August 8, 2009
  • Wyoming - November 10, 2009
  • Colorado - January 1, 2010
  • Louisiana - 2/20/2010 - 11/8/2010 (within 9 months of  inspection if occurring between these dates ; 8/8/2012 if not inspected)
  • New Mexico - July 1, 2010/2011/2012 (phased approach based on number of facilities)
  • Montana - August 8, 2010
  • Oklahoma – July 1, 2011
  • Maine – August 8, 2011 (proposed)
  • South Carolina – August 8, 2011
  • Minnesota – August 8, 2011 (dates vary by region for A&B operators)
  • Iowa - December 31, 2011 (for A&B; April 14, 2011 for Cs)
  • Wisconsin – January 1, 2012
  • Utah - January 1, 2012
  • Kentucky – February 8, 2012 (proposed)
  • Vermont - August 1, 2012

States not on this list can be presumed as having adopted the Federal date of August 8, 2012.


Some states are still determining their adoption of the federal law so look for further changes on the state level during this final 12 month runway period. A few are petitioning for extra time beyond the August 8, 2012 deadline, such as an extension or lengthened grace period, but none have been granted to date.

In addition, many states have special requirements for C operators that exceed the federal guideline. For example, Maryland requires a graded exam of 80% or more and a completed physical walk-through checklist to accompany the training of C operators. Furthermore, quite a few states will be asking for printed reports of trained operators upon inspection, as well as requiring site-specific Emergency Response Plans be produced and posted in a high traffic area at each facility.


For more information about specific operator training requirements by state, ASTSWMO produced an Operator Training Resource Guide in June of this year that is one of the better reference documents available. Click here to download this document.

Online and onsite operator training courses are being planned by a myriad of vendors to fulfill this federal edict, but please check these programs against your state requirements. Also, ensure these programs offer the advanced tracking and reporting that may be required by state regulators at the time of inspection.

Titan Management Group offers its clients an operator training program that is site-specific and integrates advanced tracking and reporting for Class A, B and C operators into its comprehensive EDGE software platform.

Feel free to e-mail Titan today at to learn more about this package.

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