Operator Classes for USTs in New Jersey: Understanding A, B & C Designations

If you own or operate an underground storage tank (UST) in New Jersey, state law requires you to designate dedicated operators in three classes—Class A, B, or C—and ensure they’re properly trained. These roles are mandated under NJ Administrative Code N.J.A.C. 7:14B‑5.14 and are also federally required under 40 CFR Part 280. Below is a breakdown of each class, including their responsibilities, training requirements, and key compliance deadlines. For professional assistance with registration, training, and ongoing support for UST inspections and reporting, contact Herbert Lutz & Company to access our A/B Operator Services.

Why New Jersey Requires Three Classes

The NJ‑DEP adopted the federal operator classification system to ensure that UST facilities are managed safely and responsibly. This structured approach ensures accountability at different levels—from system-wide oversight to emergency response.

According to N.J.A.C. 7:14B‑5.14, UST owners/operators must:

1. Designate and train at least one operator in each class.
2. Notify NJ‑DEP of the designated Class A and B operators via the UST Facility Certification Questionnaire.
3. Ensure operator presence whenever the facility is in operation.

These rules took effect on October 13, 2018, and mirror federal compliance requirements.

Class A Operator: The Strategic Overseer

A Class A operator holds overall responsibility for the UST system’s compliance and safe operation. This individual typically manages staff, resources, and administrative duties to keep the facility in regulatory alignment.

Key responsibilities include:

• Ensuring staff are trained and UST system procedures (e.g., spill prevention, leak detection, corrosion protection) are followed.
• Responding to emergencies and environmental incidents.
• Maintaining financial responsibility documentation and registration compliance.

Training requirements: Must complete Rutgers-administered NJ‑DEP training for Class A/B and pass the ICC exam.

Class B Operator: The Hands-On Expert

A Class B operator handles the on-the-ground tasks required for UST compliance. Their role is more technical and operational than administrative.

Day-to-day duties encompass:

• Ensuring release detection systems are functioning and reported correctly.
• Overseeing spill/overfill prevention and corrosion inspection.
• Keeping detailed operation and maintenance records.
• Training Class C personnel.

Training requirements: Same as Class A—Rutgers training + ICC exam.

Class C Operator: The Immediate Responder

A Class C operator is the first responder when alarms or emergencies occur. Often stationed at the point of sale or dispensing area, this person acts swiftly to contain potential incidents.

Core responsibilities:

• Responding quickly to alarms, spills, or releases.
• Notifying Class B/A operators and emergency personnel.
• Performing basic immediate actions according to site procedures.

Training requirements: Must complete site-specific emergency response training—usually conducted by Class A/B—before designation.

Training, Designation & Recordkeeping

• New/Replacement operators:
  • Class A/B must be trained within 30 days of assuming duties.
  • Class C must be trained prior to handling emergencies.
• Approval:
  • Class A/B training is only via Rutgers + ICC exam; third-party providers are not recognized.
  • Out-of-state Class A/B credentials may be accepted if NJ‑DEP deems them comparable and in good standing—and documentation is submitted.
• Recordkeeping:
  • Maintain names, training dates, documentation, and signs of retraining if required.
  • Records must be kept on-site and be available during NJ‑DEP inspections.

Retraining and Compliance Enforcement

If a facility is out of compliance—for example, missed alarms or failed leak detection—the NJ‑DEP can require retraining and retesting of Class A/B operators within 30 days.

Operator Presence & Unmanned Facilities

At manned sites, at least one trained operator must be present during UST operations. For unmanned or after-hours delivery sites, operators can be on-call via contracted Class C personnel, or clearly posted signs must guide responders.

How Lutz Helps You Stay Compliant

At Herbert Lutz & Company, our NJ-certified professionals offer full support in:

• Registering Class A/B operators through Rutgers and ICC exams.
• Training Class C personnel to suit your site operations.
• Handling NJ‑DEP filings and Facility Certification submissions.
• Providing on-call support and recordkeeping systems.
• Offering retraining services for compliance incidents.

Compliance with NJ‑DEP’s UST operator designations goes beyond bureaucracy—it ensures clear accountability, strengthens site safety, and helps you avoid fines and facility downtime. Whether you’re designating your own staff or contracting experts, Herbert Lutz & Company provides turnkey solutions so you can assign and train the correct operator classes, file required documentation, maintain on-site presence and readiness, and stay ahead of retraining obligations.

Need help navigating UST operator compliance? Contact Herbert Lutz & Company to ensure your Class A, B, and C operators are trained, designated, and documented—keeping your UST system safe and regulation-ready.