True compliance management means taking ownership of the entire process
By Fernando Crosa
Managing the administrative tasks associated with owning an underground storage tank can be challenging, especially if a marketer has numerous operations across state borders. From permit renewals and waste management tracking to Notice of Violation resolution, the skills required to effectively manage UST compliance need to be specialized and dependable.
One of the biggest challenges that many facility managers or oil marketers face is keeping consistent and up-to-date records. Even today, many marketers’ regulation-tracking systems are unorganized and not trustworthy, leading to inaccurate guesswork and a vague paper trail. These poor documentation habits and unreliable systems have resulted in notices of violations, large fines and station disruption.
Because UST regulations and interpretations vary across state borders and can be changed periodically, having gasoline station employees keeping records is no longer sufficient enough. Many UST oil distributors or gasoline station proprietors have turned to outsourced specialists or compliance-tracking software programs.
Sophisticated databases that streamline compliance testing management are keeping marketers and proprietors on top of compliance regulations and on schedule with periodic tank testing.
For example, US Tank Alliance, Inc., tracks any failures and provides all necessary follow-up to make sure that the system is repaired and retested within the allowable time frame. All marketers should implement a similar database or enlist the expertise of a tank-testing or maintenance contractor to do so.
These sophisticated databases track state regulations, local guidelines, specific equipment details and scheduled tank testing. A profile is set up for each marketer’s tank and a compliance plan is developed, which is regularly updated and easily accessible. Custom reports, released to the marketers, include budget details, upcoming tests, a trend analysis of failed equipment, and will also red-flag equipment failures to facilitate re-tests.
Although these databases are excellent tools, they are only effective when the marketer takes ownership of the tanks and the operation. Anybody can take a spreadsheet, enter test dates into a column and send a tester to execute. It takes commitment and expertise to follow up on re-tests when failures occur. A marketer must research compliance testing contractors to ensure they are being serviced by a reliable system and sound protocols.
Compliance departments for most oil marketers mean that the person responsible for putting Twinkies on the shelves also has to resolve Notices of Violations, which is a written ‘ticket” informing a business that it has failed to comply with a local or a state UST regulation. Because of the magnitude of the task at hand, and the risks of not staying on task, marketers should consider outsourcing the testing management piece and managing from a much higher perspective.
Stage II testing programs, in particular, have a lot of exposure to violations. In some cases, if a Stage II component fails, the regulator may require it to be re-tested within 30 days of the failure. A marketer needs to ask: ‘Who will stay on top of the maintenance contractor to make sure that they understand what is needed and communicate back when they are done?”
If a marketer does not have the knowledgeable and trained staff to effectively manage UST compliance and maintenance, then the UST program needs to be properly outsourced to a contractor with a reliable tracking system. Whether the program is contracted to a specialist that will manage testing vendors or handing the program over to the testing contractor directly, a marketer must demand 100-percent compliance.
A marketer must also demand weekly reports to easily track progress and establish Key Performance Indicators, which will reward a testing vendor for helping to ensure compliance and make them responsible when something was missed.
Sophisticated and reliable database systems can save an operation thousands of dollars in regulation fines, but ultimately the responsibility lies with the marketer. An oil marketer’s job should be to facilitate the process, and work with internal departments and maintenance contractors to ensure speedy repairs and monitor the results. l FON
Fernando Crosa is president and CEO of US Tank Alliance, Inc., a multi-regional environmental services company specializing in tank-cleaning and tank-testing services. US Tank operates from its headquarters in Columbus, Ohio, and covers most of the United States with regional offices in Ohio, Arizona, Massachusetts and Florida. For more information visit, www.ustankalliance.com or call (614) 923-0154.