Fires. Explosions. Motor vehicle accidents. Leaks. Groundwater contamination.
The potential hazards associated with storing gasoline in underground environments are staggering, and staggeringly vivid. Here on this blog, we’ve written numerous articles about compliance in industries where the risks are largely abstract—that is, financial and litigatory—in nature. By contrast, non-compliance in the world of selling and storing automotive fuel looks like a Michael Bay film.
And yet, despite the perils of storing and managing flammable materials, many employees remain under-informed about their responsibilities under state and federal law. Why?
To find out, we spoke with Ben Thomas, an expert in underground storage tank systems and the president of USTtraining.com, an online training school for Class A, B, and C underground storage tank operators. Compli is proud to offer UST Training courses as part of our suite of workforce compliance products.
We talked to Ben about what led him to develop these courses, as well as how the business challenges and high turnover rate in the petroleum industry necessitate a smarter, employee-focused approach to compliance training.
This interview has been edited.
COMPLI: Can you set the scene for us? Why is underground storage tank training important?
BEN: Think back to 30 years ago. Around 1985, many underground storage tanks around the country were found to be leaking and contaminating the groundwater. It was a tremendous environmental, safety, and legal hazard. And so, many states—California being one of the first—created UST regulations to protect drinking water, and operators began replacing their equipment. Back then, on every corner, you’d see a tank getting torn out of the ground. By 1988, UST rules were in all states and territories and everyone had to comply with the new standards.
These days, the equipment’s been upgraded, but operator training has been slow to catch up. Recently, for instance, there was a gas station explosion in Chicago that prompted neighborhood evacuations and sent a few people to the hospital. Lo and behold, investigators discovered the explosion could have been easily prevented: the station’s records weren’t adding up, and operators had ignored numerous alarms. It’s hard to imagine that training wouldn’t have helped employees take action sooner.
What are the possible hazards of having workers who haven’t been trained on underground tank safety?
Say it’s a busy day. You want that training to kick in when something happens: the tank monitor warning light in the backroom is blinking red, there’s a fire or a spill—accidents are always possible. Training can help employees quickly intervene. It can save lives—and probably has.
Plus, a blinking red light is a violation. It means, willfully or not, you’re ignoring an alarm. At the very least, that can earn you a state inspector citation. But any time you have a violation, it’s likely to be not minor.
On the regulatory side, a state may issue you a warning, or a financial fine of a few hundred dollars. Some states do have the authority to shut down a station. In these states, if an inspector was feeling particularly grouchy one day, they could zip-tie your fuel pipes and put you out of business then and there until the violation is corrected.
From a purely economic perspective, every day a gas station is shut down, it takes 2 days to recover your finances. If you’re shut down for two weeks, you’d need a month of constant business to break even. It’s worth mentioning that gas sales are heavily taxed, and tend to be a loss leader—much like movie theaters, gas stations aren’t making much money on their ‘main’ product—but gas is the primary way to get people through the door.
Why do so many operators remain unaware of their responsibilities? What impedes training?
Gas station storefronts are much busier than those in most industries. In fact, customer rotation at a gas station is kind of hair-raising. Every day, frontline people get hammered with impatient customers: some creating fire hazards, some drivers who aren’t paying attention, and some who may be disorderly at checkout. Plus, there are underage sales of tobacco and alcohol, and even the possibility of getting robbed.
It’s a robust, complex industry, and can be something of a hazardous work environment. The pressure is on for these people to be tracking everything. Accordingly, all gas station employees are required by law to be trained as Class C operators, meaning they need to learn how to respond to emergencies such as spills, fires, someone driving away with the gas pump nozzle attached to their car, a driver colliding with the island—you name it.
And to complicate things, gas stations have an extraordinarily high turnover rate. I’ve read reports of turnover as high as 300%. Many new employees will be gone in less than a month-and-a-half. So, it’s a persistent challenge to get workers up to speed and drive home the importance of a Class C operator’s responsibilities.
Online training covers it all in about 30 minutes. Although companies can train employees live, in a face-to-face setting, many companies rely on third-party software like ours to save time and track compliance across multiple locations.
What safety protocols and technology are in place to ensure explosions, fires, and other hazards don’t happen?
Most gas stations have a tank monitor in the back room that looks for problems and signals with alarms. And most employees see these monitors, but many don’t really know what they mean.
During a recent trip to buy gas, I spoke with an employee at the cash register and pointed out the cutting-edge tank monitor on the wall behind her. She responded with something along the lines of ‘Oh, that? I don’t know what that is.’ I told her that if it started blinking red, it indicated a serious problem. She told me she just figured her manager would know what to do.
There’s also a number of safety devices at the dispenser to keep customers safe, as well as equipment and alarms to keep delivery drivers from accidentally overfilling the underground tanks. That being said, it’s unfortunate that we have this tremendous monitoring technology and many people don’t even realize it. Our training tries to bridge the wealth of knowledge and offer it up to every employee.
How does UST Training cover all these topics? What makes a training course unique?
The feedback we’ve received is that many other courses are not designed or taught by people who know tanks. I have 30-plus years working with underground storage tanks, and it’s important that our knowledge of the subject matter comes across.
Every state has different UST rules and regulations. Our job is not to do a one-size-fits-all, but track the differences and develop robust course content. We’re one of the few companies that only do underground tank training. We have a single package product that works well.
There’s a conversational tone to the training. We’ve strived to make the content extremely engaging. We’re light on words and heavy on visuals. We have real-life gas station photos, 3D graphics, videos, stories, things catching on fire. We’ve worked to make it as visceral as possible.
We also provide advice above and beyond the rules. We’re conveying a risk management mindset rather than just crunching through a bunch of regulations. As much as we take pride in our strong relationships with state regulatory agencies, we go to great lengths to talk about risks and train as if the rules didn’t matter. We try to make it self-evident, using common-sense language and presentation of ideas.
Compli is proud to offer UST Training courses as part of our suite of workforce compliance products. To learn how our automated platform can keep your business cool, calm, and compliant, click here.