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Written Tests Required for Operators at Underground Storage Tank (“UST”) Facilities.

Pursuant to a federal mandate, Michigan has promulgated requirements that each UST facility have a Class A, Class B, and Class C operator.  Operator candidates will need to pass a written test in order to be certified as either a Class A or Class B operator.  A test is not required for Class C operators, but Class C operators will need to be properly trained.

Class A operators have primary responsibility to operate and maintain the UST, and confirm completion of all maintenance tasks.

Class B operators are generally responsible for the day-to-day operations, including maintenance and record keeping for the UST system.  A Class B operator generally has an in depth understanding of the operation and maintenance aspect of the tank system.

Class C operators are generally on-site daily, and are often the initial responder to emergencies and alarms in the event of spills and releases.  There can be multiple Class C operators at an individual facility.  A at a minimum, there should be at least one Class C operator (or an A or B operator) on-site while the tank system is operating.  Class C operators, while they are not required to pass the aforementioned exam, they must still be trained in appropriate emergency response procedures.

The test and training is to confirm that operators of a UST facility possess the necessary knowledge regarding the proper operation of a UST system.  Michigan, in conjunction with the federal requirement, has an August 8, 2012 deadline for operators to obtain certification.  Beginning August 2012, the Hazardous Materials Storage Tank (“HMST”) inspectors will be checking for compliance with these certification requirements.  Because of the very restrictive time frame, Michigan has indicated that it will not take enforcement actions until after January 2, 2013.

The International Code Council (ICC) is in charge of Michigan-specific testing.  Tank owners and operators can get additional information on the ICC testing program here.

About Susan J. Sadler

Susan J. Sadler is a founding Member of Dawda, Mann, Mulcahy & Sadler, PLC. She is the head of the Environmental, Energy and Sustainability practice group. She concentrates her legal practice on a broad spectrum of environmental issues.

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