The Best Number in EPA’s FY2026 Report Has a Blind Spot

When EPA’s Mid-Year FY2026 UST performance measures landed, most of the attention went to the number that slipped: the national Technical Compliance Rate fell two points to 60.9%. But look one row down and you’ll find the brightest spot in the entire report — operator training compliance climbed to 89.7%, up from 88.6% at the end of FY2025. It’s the measure closest to what we do, it moved in the right direction, and it’s one of the most fixable levers a facility controls.

So why isn’t it 100%? And more importantly — what is that 89.7% actually measuring?

Read the fine print on the training number

EPA’s training measure tracks “the percentage of inspected facilities in compliance with Class A and B operator training requirements.” Read that again: Class A and B. The number that looks healthiest in the whole report is built entirely on your designated and primary operators — the people responsible for the system and its day-to-day operation. Class C operators aren’t in it at all.

That’s not a flaw in EPA’s reporting; it’s just how the federal performance measure is scoped. But it means the cleanest number in the FY2026 report has a blind spot exactly where compliance tends to break down in the real world.

Class C is where the gap actually lives

Class C operators are the people working the counter — the first to respond when an alarm sounds or a spill happens. Under 40 CFR Part 280 Subpart J, they have to be trained before they assume their duties. Not within 30 days, not by the next inspection. Before.

In practice, this is the hardest piece of operator training to keep clean, and it has nothing to do with the quality of the training and everything to do with the rhythm of the business. Turnover at the store level is constant. Every new hire who touches fuel dispensing is a new Class C operator who needs documented training on day one. Miss the documentation on a handful of them across a few sites, and you’ve got a gap that an inspector can find — even though your Class A and B numbers, the ones EPA publishes, look pristine.

So the 89.7% is real and it’s good news. It just isn’t the whole story. The frontline layer that turns over fastest is the layer the headline number never sees.

Why the timing matters

Training is getting more regulatory attention, not less. EPA tracks it as a dedicated performance measure, and states that receive federal UST grant funding are expected to show progress on it. That means inspectors are looking at training records more carefully, and facilities without clean documentation are more likely to get flagged — regardless of how well the equipment is running.

It also means the gap between states is wide. The same FY2026 report that put national training at 89.7% shows technical compliance ranging from Missouri’s 96% down to Indiana’s 19%. Training requirements vary just as much underneath the national average: retraining cycles, approved course lists, Class C sign-off rules, and documentation expectations differ from one state to the next. A multi-state operator isn’t managing one training requirement — they’re managing dozens.

Closing the part of the gap the number doesn’t show

This is exactly the layer PASS Training was built for. We deliver state-approved UST operator training in all 50 states, DC, and U.S. territories — and we maintain more state-approved courses than any other provider, including dedicated Class C training for the frontline employees the headline measure leaves out, with Spanish-language versions in the states that need them most.

The courses run on our own learning management system: self-paced, available 24/7 from any computer, tablet, or phone, with no time limit on completion. A new hire can be trained and documented before their first shift, and on PASS Opus that certification is tracked by individual, by facility, and by state — so expirations get flagged before they become violations, and Class C training is captured every time someone new comes on board.

Bottom line

The FY2026 training number is the good-news line in a report full of harder ones — and it deserves the credit. But 89.7% measures your Class A and B operators, not the Class C employees turning over at the counter every month. The most fixable lever in the data is even more fixable than the headline suggests, as long as you’re closing the part of the gap EPA doesn’t publish.

See where your states stand in our EPA comparison tool, then explore state-approved Class A, B, and C training in the PASS Training Marketplace — or contact us to schedule a demo.