When an unforeseeable emergency occurs at your retail motor fueling facility, are your employees adequately trained and prepared to respond to the situation? Retail motor fueling facilities, such as gas stations, have underground storage tanks (USTs) containing regulated substances. Unforeseen situations such as fires, spills, or severe-weather-induced power outages can have serious consequences on a facility’s UST system. If the first responder does not know the proper emergency response when an alarm sounds, the chances of human injuries and environmental damages can quickly escalate.

An owner of a UST system is responsible for ensuring that all Class C operators are designated and trained appropriately. The U.S. Environmental Protection Agency (EPA) identifies the Class C operator as the person who typically controls or monitors the dispensing or sale of regulated substances. The EPA further defines a Class C operator as the individual responsible for addressing emergencies presented by a spill or release from a UST system.

The Class C operator is most often the gas station attendant and is usually occupied not only with the sale of gasoline but also with in-store sales and customer interactions. As such, the Class C operator positions are known to have high employment turnover rates. It is not uncommon for regional gas stations to train thousands of Class C operators. Therefore, gas station owners must remain proactive, diligent, and organized in ensuring Class C operators are adequately trained.

Required federal Class C operator training

• Class C operators must be trained by a Class A or Class B operator or must complete a training program or pass a comparable examination.
• Class C operator training must, at a minimum, teach appropriate action in response to an emergency or to alarms caused by spills or releases from the operation of the UST system. This includes notifying the appropriate authorities.
• Class C operators must be evaluated and determined to possess the knowledge and skills to take the appropriate action.
• Training programs must include an evaluation through testing, practical demonstration, or another method accepted by the implementing agency.
• Class C operators must be trained before assuming the duties of a Class C operator (e.g., controlling or monitoring the dispensing or sale of fuel).

But, can most people really be prepared for an unforeseen emergency? Can a Class C operator be prepared if he or she has only participated in a 30-minute computer training course or has never walked through different scenarios under site-specific, emergency-like pressure?

Most Class C operators will never encounter an emergency during their employment, but a facility owner may want to take additional steps above and beyond those of the regulations in order to ensure that its Class C operators perform confidently and without hesitation even in the unlikely event of an emergency.

Additional training steps to consider:

• Walk through the facility one on one with each Class C operator.
• Create a model for Class C operators to interact with real emergency alarms, knobs, and switches.
• Conduct mock emergency scenarios.
• Provide a mechanism for open communication if there is confusion or if there are questions.
• Refresh Class C operator training yearly.

By implementing additional on-site training or guidance, a facility owner can instill self-confidence in its Class C operators. For example, a Class C operator must pull the emergency stop valve to stop the flow of fuel but must also know to push the knob back in. If the Class C operator did not physically try this, it is likely that he or she would not know to do this. The alarms can be loud and startling, too.

Under pressure and possibly panicking, it is fair to assume that a Class C operator may forget his or her basic responsibilities. Class C operators play a vital role in keeping the public safe, keeping the facility’s property safe, and protecting the environment. A gas station accident could lead to the loss of life, civil liabilities, and subsequent regulatory enforcement costs. A facility owner, therefore, has a financial and ethical interest to adequately train Class C operators and make sure each Class C operator knows what to do if an emergency occurs.