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NewsFleet SafetyPipeline and Hazardous Materials Safety Administration (PHMSA), DOTDrug testing - Motor CarrierDrug and Alcohol Testing - DOTOffice of the Secretary of TransportationHazmat SafetyRulemakingFocus AreaProposed RuleEnglishTransportationUSA
89 FR 82957 Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records
2024-10-15T05:00:00Z
DEPARTMENT OF TRANSPORTATION
Office of the Secretary
49 CFR Part 40
Pipeline and Hazardous Materials Safety Administration
49 CFR Part 199
[Docket DOT-OST-2022-0027]
RIN 2105-AF01
Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records
AGENCY: Office of the Secretary, Department of Transportation (DOT).
ACTION: Notice of proposed rulemaking (NPRM).
SUMMARY: The Department of Transportation (DOT or Department) proposes to amend its regulations for conducting workplace drug and alcohol testing for the federally regulated transportation industry to allow, but not require, electronic signatures on documents required to be created and utilized under the regulations, the use of electronic versions of forms, and the electronic storage of forms and data. The regulatory changes would apply to DOT-regulated employers and their contractors (“service agents”) who administer their DOT-regulated drug and alcohol testing programs. Currently, employers and their service agents must use, sign and store paper documents exclusively, unless the employer is utilizing a laboratory's electronic Federal Drug Testing Custody and Control Form (electronic CCF) system that has been approved by the Department of Health and Human Services (HHS). DOT is required by statute to amend its regulations to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms. This rulemaking also responds to an April 2, 2020, petition for rulemaking from DISA Global Solutions, Inc. (DISA), requesting that DOT regulations be amended to allow the use of an electronic version of the alcohol testing form (ATF) for DOT-authorized alcohol testing. The proposed regulatory amendments are expected to provide additional flexibility and reduced costs for the industry while maintaining the integrity and confidentiality requirements of the drug and alcohol testing regulations. In addition, DOT proposes to amend the Pipeline and Hazardous Materials Safety Administration (PHMSA) regulation for conformity and to make other miscellaneous technical changes and corrections.
DATES: Comments on this NPRM must be received on or before December 16, 2024.
ADDRESSES: You may submit comments identified by Docket Number DOT-OST-2022-0027 using any of the following methods:
• Federal eRulemaking Portal: Go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document. Follow the online instructions for submitting comments.
• Mail: Docket Management Facility, U.S. Department of Transportation, 1200 New Jersey Avenue SE, West Building, Ground Floor, Room W12-140, Washington, DC 20590-0001.
• Hand Delivery or Courier: West Building, Ground Floor, Room W12-140, 1200 New Jersey Avenue SE, Washington, DC, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting Dockets Operations.
• Fax: 202-493-2251.
To avoid duplication, please use only one of these methods. See the “Public Participation and Request for Comments” portion of the SUPPLEMENTARY INFORMATION section for instructions on submitting comments, including collection of information comments for the Office of Information and Regulatory Affairs, Office of Management and Budget (OMB).
FOR FURTHER INFORMATION CONTACT:
Mike Huntley, Office of Drug and Alcohol Policy and Compliance, 1200 New Jersey Avenue SE, Washington, DC 20590; telephone number 202-366-3784; ODAPCwebmail@dot.gov. If you have questions on viewing or submitting material to the docket, contact Docket Services, telephone (202) 366-9826.
SUPPLEMENTARY INFORMATION:
This NPRM is organized as follows:
I. Executive Summary
II. Public Participation and Request for Comments
A. Submitting Comments
B. Viewing Comments and Documents
C. Privacy Act
III. Legal Basis for the Rulemaking
IV. Background
V. Advance Notice of Proposed Rulemaking (ANPRM) Overview
VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures
VII. Amending Part 40 To Permit Electronic Documents and Signatures
VIII. Electronic ATF
IX. Section-by-Section Analysis
X. Regulatory Analyses and Notices
I. Executive Summary
Purpose and Summary of the Major Provisions
This proposed rule would establish parity between paper and electronic documents and signatures and expand businesses' and individuals' ability to use electronic methods to comply with the Department's drug and alcohol testing regulation, 49 CFR part 40, “Procedures for Transportation Workplace Drug and Alcohol Testing Programs” (part 40). Businesses and individuals subject to part 40 would continue to have the choice to use paper documents and traditional “wet” signatures. This proposed rule would also modify references to recordkeeping and reporting methods throughout part 40 to make them technologically neutral.
This proposed rulemaking responds to a statutory mandate set forth in section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271 (see 49 U.S.C. 322 note). The proposed rulemaking would take action consistent with the Government Paperwork Elimination Act (GPEA) (division C, title XVII, secs. 1701-1710, Pub. L. 105-277) and the Electronic Signatures in Global and National Commerce Act (E-SIGN) (Pub. L. 106-229) with regard to DOT's part 40 regulations.
II. Public Participation and Request for Comments
A. Submitting Comments
If you submit a comment, please include the docket number for this NPRM (Docket No. DOT-OST-2022-0027), indicate the specific section of this document to which each comment applies, and provide a reason for each suggestion or recommendation. You may submit your comments and material online or by fax, mail, or hand delivery, but please use only one of these means. The Office of the Secretary (OST) recommends that you include your name and a mailing address, an email address, or a phone number in a cover letter or an email so that OST can contact you if there are questions regarding your submission.
To submit your comment online, go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document, click on this NPRM, click “Comment,” and type your comment into the text box on the following screen.
If you submit your comments by mail or hand delivery, submit them in an unbound format, no larger than 8 1/2 by 11 inches, suitable for copying and electronic filing. If you submit comments by mail and would like to know that they reached the facility, please enclose a stamped, self-addressed postcard or envelope.
OST will consider all comments and material received during the comment period in determining how to proceed with any final rule.
B. Viewing Comments and Documents
To view comments, as well as any documents mentioned in this preamble as available in the docket, go to https://www.regulations.gov. Insert the docket number, DOT-OST-2022-0027, in the keyword box, and click “Search.” Next, click the “Open Docket Folder” button and choose the document to review. If you do not have access to the internet, you may view the docket online by visiting the Docket Management Facility in Room W12-140 on the ground floor of the DOT West Building, 1200 New Jersey Avenue SE, Washington, DC 20590-0001, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting the Docket Management Facility.
C. Privacy Act
In accordance with 5 U.S.C. 553(c), DOT solicits comments from the public to better inform its rulemaking process. DOT posts these comments, without edit, including any personal information the commenter provides, to www.regulations.gov, as described in the system of records notice (DOT/ALL-14 FDMS), which can be reviewed at https://www.transportation.gov/individuals/privacy/privacy-act-system-records-notices under the heading of “Department-Wide System of Records Notices”.
III. Legal Basis for the Rulemaking
This rulemaking is promulgated under the authority enacted in the Omnibus Transportation Employee Testing Act of 1991 (OTETA) (Pub. L. 102-143, tit. V, 105 Stat. 952) and codified at 49 U.S.C. 45102 (aviation), 49 U.S.C. 20140 (rail), 49 U.S.C. 31306 (motor carrier), and 49 U.S.C. 5331 (public transportation), as well as the Department's authority in 49 U.S.C. 322 and the PHMSA authorities specified in the proposed regulatory text for this action.
According to Public Law 115-271, the Secretary of Transportation is required to “issue a final rule revising part 40 of title 49, Code of Federal Regulations, to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms.” (49 U.S.C. 322 note) The statute set the deadline for this action as not later than 18 months after HHS establishes a deadline for a certified laboratory to request approval for fully electronic CCFs ( Id. ) On April 7, 2022, HHS set that deadline as August 31, 2023 (87 FR 20528). HHS has extended the deadline to August 31, 2026, to enable sufficient time for all HHS-certified laboratories to identify and contract with an electronic CCF supplier or to develop an electronic CCF. The deadline for DOT's regulatory amendments would therefore be February 29, 2028.
There are two additional Federal statutes relevant to the implementation of electronic document and signature requirements.
The Government Paperwork Elimination Act (GPEA), codified at 44 U.S.C. 3504 note, 1 was enacted to improve customer service and governmental efficiency through the use of information technology. The GPEA defines an electronic signature as a method of signing an electronic communication that: (a) identifies and authenticates a particular person as the source of the electronic communication; and (b) indicates such person's approval of the information contained in the electronic communication. Id. It also requires OMB to ensure Federal agencies provide for: (a) the option of maintaining, submitting; or disclosing information electronically, when practicable; and (b) the use and acceptance of electronic signatures when practicable. The GPEA states that electronic records submitted pursuant to procedures developed under title XVII for the submission of records to Federal agencies and electronic signatures used in accordance with those procedures shall not be denied legal effect, validity, or enforceability merely because they are in electronic form. Id.
1 Division C, title XVII (sec. 1701-1710) of Public Law 105-277, 112 Stat. 2681-749, enacted on October 21, 1998.
The Electronic Signatures in Global and National Commerce Act (E-SIGN), codified at 15 U.S.C. 7001-7031, 2 was designed to promote the use of electronic contract formation, signatures, and recordkeeping in private commerce by establishing legal equivalence between traditional paper-based methods and electronic methods. The E-SIGN Act allows the use of electronic records to satisfy any statute, regulation, or rule of law requiring that such information be provided in writing if the consumer has affirmatively consented to such use and has not withdrawn consent. Specifically, the statute establishes the legal equivalence of the following types of documents with respect to any transaction in or affecting interstate or foreign commerce, whether in traditional paper or electronic form: (a) contracts, (b) signatures, and (c) other records (15 U.S.C. 7001(a)(1)).
2 Public Law 106-229, 114 Stat. 464, enacted on June 30, 2000.
IV. Background
The Department's drug and alcohol testing regulations were promulgated at a time when the ability to sign and retain official records electronically—now commonplace in many business segments—was not available. Over the course of several years, we have adopted measures that have reduced the paper documentation associated with the drug and alcohol testing program without compromising the integrity and confidentiality requirements of the program. In 2003, we standardized the form for employers to report their Management Information System (MIS) aggregate drug and alcohol testing data, as well as the specific data collected. 3 When creating a ONE-DOT MIS Form, we then authorized employers to submit a single standardized form via a web portal. In 2015, we issued a final rule to allow employers, collectors, laboratories, and medical review officers (MROs) to use the electronic version of the Federal Drug Testing CCF in the DOT-regulated drug testing program. 4 That final rule also incorporated into the regulations the requirement to establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons when using the electronic CCF. We also included language protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form when using the electronic CCF.
3 68 FR 43946 (July 25, 2003).
4 80 FR 19551 (Apr. 13, 2015).
Consistent with the statutory mandate in 49 U.S.C. 322 note, we propose amendments to part 40 to permit the use of electronic signatures, forms, and records storage for drug and alcohol testing records throughout the regulation, including the use of an electronic ATF for DOT-authorized alcohol testing. We emphasize that electronic signatures, forms, and records would not be required; we would continue to allow paper, or hard-copy use with traditional “wet signatures.”
These proposed amendments would establish parity between paper and electronic collection and submission of information required under our regulations (and remain compatible with applicable OMB guidance on implementing electronic signatures 5 ) by allowing further use of electronic means and methods to comply with part 40 requirements. Many employers and their service agents have already instituted the use of electronic signatures, forms, and records storage for the non-DOT regulated testing that they conduct. DOT supports this transition to a paperless system and is committed to ensuring that the movement to a partially or fully electronic part 40 is done to maximize program efficiencies and reduce costs, while maintaining the integrity and confidentiality requirements of the program.
5https://www.whitehouse.gov/wp-content/uploads/2017/11/2000-M-00-15-OMB-Guidance-on-Implementing-the-Electronic-Signatures-in-Global-and-National-Commerce-Act.pdf.
Electronic documents would have a high degree of forensic defensibility as long as any changes made to the document are in the document's electronic footprint, which shows when the document or signature, as applicable, was created; when, and if, changes were made; who made the changes; and when, as applicable, a document was transmitted to and received by the receiving entity. The use of electronic forms and signatures in part 40 would help DOT-regulated employers and their service agents improve their workflow efficiency through faster turnaround times for required documents. Cost savings would result through reduced printing and delivery/shipping costs, and expedited transmission of information allowing for more timely decisions. We believe this proposed rule, if adopted, would also mitigate the longstanding problems ( e.g., delays in processing times of test results, cancelling of test results, etc.) associated with illegible and lost copies of paper documents.
V. Advance Notice of Proposed Rulemaking (ANPRM) Overview
On August 5, 2022, we published an ANPRM requesting public comment on how part 40 could be amended, as required by the statute, to allow electronic signatures, forms, and recordkeeping (87 FR 47951). We requested information from DOT-regulated employers and their service agents regarding if and how they are already handling electronic signatures, records transmission, and records storage in their non-DOT testing programs. In addition, we requested comments and information on appropriate performance standards, and on whether particular methods or performance standards have been successful or unsuccessful. We also asked a number of general questions on the potential advantages, risks, ramifications, and required safeguards associated with the use of electronic signatures, forms, and records in the DOT drug and alcohol testing program. We asked questions about specific sections of part 40 that we anticipated would be affected by prospective changes to implement electronic signatures, forms, and records. Finally, we asked a number of questions regarding the use of an electronic ATF for DOT-regulated alcohol tests.
We received 72 comments in response to the ANPRM, including comments from individuals, testing laboratories, MROs, and MRO organizations, substance abuse professionals (SAP) and SAP organizations, and various associations representing DOT-regulated transportation workers subject to mandatory drug and alcohol testing under part 40.
A few individuals expressed opposition to the adoption of electronic signatures, forms, and recordkeeping, citing concerns about the need for the rulemaking, risk to personal information from hackers or mismanaged electronic processes and procedures, and misuse of electronic forms and signatures. To meet our statutory mandate and in consideration of concerns about safeguarding personal information and appropriate use of the information in developing the NPRM, DOT proposes to require security measures for electronic forms and signatures used under part 40 that are the same as those currently in place for the electronic CCF specified in 49 CFR 40.40(c)(5).
Most commenters were supportive of changes to amend part 40 that would permit, but not require, the use of electronic signatures, forms, and recordkeeping. Commenters supporting revisions to part 40 noted that electronic signatures, forms, and recordkeeping are used in virtually every industry today—including but not limited to the banking, insurance, medical, and legal industries. Commenters supported the use of performance standards instead of technology-specific standards to ensure that, once established, standards do not become obsolete given the rapidly evolving nature of information technology standards and practices. Commenters stated that allowing electronic signatures, forms, and recordkeeping would make the drug testing process much more efficient and would result in cost savings. Commenters also stated that it would be safer to store records electronically since records could be backed-up, secured, and protected from tampering and unauthorized access and use.
VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures
In developing this NPRM, we looked to a rule promulgated by DOT's FMCSA that permits the use of electronic methods to generate, certify, sign, maintain, or exchange records so long as the documents accurately reflect the required information and can be used for their intended purpose. (83 FR 16210, Apr. 16, 2018) The rule applies to documents that FMCSA requires entities or individuals to retain. FMCSA permits, but does not require, anyone to satisfy FMCSA requirements by using electronic methods to generate, maintain, or exchange documents. The substance of the document must otherwise comply with applicable Federal laws and FMCSA rules. FMCSA also permits, but does not require, anyone required to sign or certify a document to do so using electronic signatures, defined, as in the GPEA, as a method of signing an electronic communication that: (1) identifies and authenticates a particular person as the source of the electronic communication; and (2) indicates such person's approval of the information contained in the electronic communication. FMCSA allows for the use any available technology for electronic signatures, so long as the signature otherwise complies with FMCSA's requirements.
FMCSA adopted broad performance standards for electronic documents and signatures—as specified in GPEA and E-SIGN—rather than detailed, technology specific standards that would likely become obsolete with inevitable changes in information technology standards and practices. FMCSA's April 2018 rule has been in effect for more than five years, and the definitions and requirements established in that rule have stood the test of time despite the many changes that have occurred with respect to electronic documents and signatures. We are unaware of any FMCSA-regulated entities that have reported issues to FMCSA regarding the use of electronic documents or signatures to meet the requirements of the FMCSRs since the rule became effective in 2018.
VII. Amending Part 40 To Permit Electronic Documents and Signatures
In this NPRM, we propose to permit but not require electronic documents, signatures, and recordkeeping in part 40. Additionally, we propose a performance standard approach as opposed to establishing technology-specific standards. Where it is possible to do so, establishing the same or substantively similar regulatory requirements for common issues across DOT modal agencies—such as the use of electronic documents and signatures—helps the Department maintain a consistent regulatory approach for those common issues.
There are currently more than 60 references to the term “written” in part 40, and more than 20 additional references to the term “in writing.” We propose to add a definition of “written or in writing” in part 40, to eliminate any distinction between paper and electronic documentation and establish technological neutrality throughout the entirety of part 40.
FMCSA's rule does not apply to documents that individuals or entities are required to file directly with FMCSA. In its April 2018 final rule, FMCSA explained that while industry could use electronic signatures and submit information directly to the FMCSA in certain situations, 6 adapting all FMCSA systems to allow for use of electronic signatures and submissions would significantly delay the implementation of the rule for use by third parties as it would require FMCSA to develop and implement technology systems to allow for direct submission to FMCSA from regulated parties. FMCSA noted that development of such systems could take several years, and therefore saw no reason to make private parties' use of electronic signatures and records retention contingent upon FMCSA's ability to receive submissions electronically because doing so would delay potential benefits to be gained by third parties.
6 As an example, Certified Medical Examiners may use electronic signatures, if they choose to do so, to sign medical forms, certificates, and a new driver medication report. If FMCSA requests these forms, they are uploaded in portable document format (PDF) to the Medical Examiner's account associated with the National Registry of Certified Medical Examiners for FMCSA to access.
In contrast to FMCSA's regulations, part 40 does not require entities or individuals to submit documents directly to the Department except for MIS aggregate drug and alcohol testing data that employers subject to DOT or U.S. Coast Guard (USCG) drug and alcohol testing regulations must submit annually. Each of the various documents required and used as part of the DOT drug and alcohol testing program under part 40 ( e.g., employee drug and alcohol testing records, MRO reports and records, SAP reports and records) are documents that are created by, exchanged between, and maintained by a person or entity involved in the testing process—but are not required to be submitted directly to DOT.
As noted earlier, and specifically with respect to the required MIS data, we standardized the form for employers to report their aggregate drug and alcohol testing data, as well as the specific data collected, more than 20 years ago. At that time, we authorized employers to submit the ONE-DOT MIS form via a web portal. Today, the Federal Aviation Administration, FMCSA, Federal Railroad Administration, and Federal Transit Administration permit employers to submit that same drug and alcohol testing data via the internet, and PHMSA requires that the data be submitted electronically. If employers submit the data electronically via the internet, they are not required to submit a hard copy. DOT recommends that employers have a copy of their data available (either hard copy or in electronic format) in the event an auditor or inspector requests a copy.
From the above, and because the only documents that part 40 requires to be submitted directly to the Department are already permitted to be, and in some cases required to be, submitted electronically, there is no need for us to limit the applicability of our proposal as FMCSA did in its 2018 final rule.
Several commenters noted that they already use electronic signatures and documents for their non-DOT drug and alcohol testing program, and in some cases, have done so for many years. In doing so, these commenters have had to establish appropriate confidentiality and security measures to ensure that confidential employee records cannot be accessed by unauthorized persons, including protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The same general requirements were added to the current §40.40(c)(5) when we approved the use of the electronic CCF for use in DOT drug testing in 2015, 7 and we propose the same requirements in this NPRM for the use of electronic signatures, documents, and recordkeeping throughout the entirety of part 40.
7 The 2015 revisions amended then §40.45(c)(5), which was redesignated as §40.40(c)(5) in the May 2023 final rule to include oral fluid testing in the DOT drug testing program (88 FR 27596, May 2, 2023).
Ensuring that confidential employee records are not available to unauthorized persons is an important element of part 40's protections for employees that are subject to DOT's drug and alcohol testing rules. We believe that the failure of a service agent to provide or maintain a secure/confidential electronic system should constitute the basis for the Department to start a public interest exclusion (PIE) proceeding, and propose to add this to the list of examples provided in §40.365(b).
Throughout part 40, information and documents are required to be transmitted and/or communicated between service agents ( e.g., collectors, screening test technicians (STTs) and breath alcohol technicians (BATs), laboratories, MROs, SAPs, and consortium/third party administrators (C/TPAs)), employers, and employees). Although part 40 does not currently require the party receiving these communications and/or documents to affirmatively confirm receipt of such from the sender, in some instances, regardless of whether the document is electronic or a hard copy, we believe that it may be important for the receiving party to verify that those required communications and/or documents were received.
For example, under §40.25, an employer intending to use an employee to perform safety-sensitive functions must, after obtaining an employee's written consent, request information about the employee's drug and alcohol testing record from previous DOT-regulated employers. After receiving a copy of the employee's written consent, the previous employer must immediately provide the requested information to the employer making the inquiry. If an employer is subsequently investigated/audited by the appropriate DOT mode, it may be beneficial for both the gaining employer and the previous employer to be able to affirmatively demonstrate that the employee's written consent and previous testing record were sent and received as required.
Sections 40.191(d) and 40.261(c)(1) require a collector or MRO (for drug tests) or a BAT, STT, or a physician evaluating a “shy lung” situation (for alcohol tests), respectively, to—when an employee refuses to participate in a part of the testing process—terminate the testing process, document the refusal, and immediately and directly notify the employer's designated employer representative (DER) by any means that ensures the refusal notification is immediately received. Because this notification of a refusal to an employer is of an urgent nature, it may be advisable to require the DER to affirmatively confirm receipt of the required notification from the collector, MRO, BAT, STT, or physician. For example, §§40.191(d) and 40.261(c)(1) could be amended to read “. . . immediately notify the DER by any means and ensure that the refusal notification is immediately received”.
While we are not proposing new requirements in this NPRM regarding confirmation of receipt in the sections discussed above (or in other part 40 requirements), we seek comment regarding whether it may be beneficial or advisable to do so, and if so, for which specific sections of part 40.
VIII. Electronic ATF
The ATF has been in use in the DOT alcohol testing program since 1994 (see 59 FR 7349, Feb. 15, 1994). The ATF must be used to document every DOT alcohol test. DOT regulations at 49 CFR 40.225 set forth the requirements for use of the form, and 49 CFR part 40, appendix G, contains a facsimile (reference copy) of the form. The ATF is a three-part carbonless manifold form used by DOT-regulated employers to document the testing event when testing employees subject to DOT alcohol testing. When the employee is tested, both the employee and the STT and/or the BAT will complete the ATF in various sections. The STT/BAT documents the result(s) by either writing in the screening result or attaching the screening and/or confirmation result printed by the evidential breath testing devices (EBT) onto the ATF, and then sends Copy 1 to the employer, provides Copy 2 to the employee, and retains Copy 3 for their records.
On April 2, 2020, DISA petitioned the Department to amend part 40 to allow for the use of an electronic version of the ATF for DOT mandated alcohol testing. In support of its petition, DISA stated that “The requested amendment to 49 CFR part 40 will enable a parallel process for the documentation of DOT-mandated alcohol tests aligned with the similarly situated amendment previously approved for drug testing.” DISA believes that allowing the use of an electronic ATF will result in several benefits to the industry, including “increased efficiency, security and accuracy in documentation of DOT alcohol tests; paperwork reduction; improved process for conducting a DOT alcohol test in conjunction with a DOT drug test when an electronic version of the federal CCF is used for the drug test; reduction of errors and omissions in the completion of the ATF; and improved efficiency and efficacy in the transmission and record retention of alcohol test results.”
DISA noted that non-DOT workplace breath alcohol testing has been conducted using electronic versions of an alcohol testing form that mirrors the DOT ATF for more than five years. Based on experience using those electronic forms for non-DOT testing, DISA cites improved efficiency and accuracy of documentation because: (1) employer and employee information is entered via computer and thus not dependent on reading and deciphering hand-written entries, (2) date time stamps of the testing are automated and not subject to fluctuation or error, (3) transmission of documentation on completed tests is more secure using databases accessed only via protected password and personal identification number (PIN) to authorized employers or their designated agents, and (4) transmission of test result information is faster and more secure than existing transmission options of scanning and emailing attachments or facsimile.
DISA also noted that permitting use of an electronic ATF for DOT-regulated alcohol testing “will substantially reduce cost, by eliminating the requirement for the printing and distribution of carbonless three-ply paper ATFs. The proposed electronic ATF option would still provide for printed paper images to be made available to the employee, the employer, and the alcohol technician, [but] eliminates the requirement for the more expensive carbonless 3 ply paper ATF.”
For the reasons described by DISA in its petition, and recognizing that significant benefits and cost reductions have resulted from use of the electronic CCF for drug testing, we believe that it is likewise appropriate to permit the use of electronic ATFs in part 40 for DOT-regulated testing. Permitting but not requiring the use of an electronic ATF would be consistent with our proposal to permit, but not require, the use of electronic documents and signatures throughout the entirety of part 40 as discussed above. As several commenters noted, the use of an electronic ATF has been used in non-DOT testing for 5-10 years, and the same developers of the electronic CCFs have developed the electronic ATFs. Any electronic ATF used under part 40 for DOT-regulated employees would have to be identical in form and content to the DOT ATF in appendix I to part 40. 8 Just as we imposed general confidentiality and security requirements when electronic CCFs were permitted to be used under part 40, we believe that it is necessary to include the same general requirements relating to the use of electronic ATFs to ensure that confidential employee records cannot be accessed by unauthorized persons.
8 The ATF form was redesignated from appendix G to appendix I as part of the rulemaking process culminating in the May 2023 final rule. During that process, the form was reviewed by the public and DOT received no comment on the form.
Manufacturers of EBTs and alcohol screening devices (ASD) used in DOT alcohol tests must obtain approval from the National Highway Traffic Safety Administration (NHTSA) and then be listed on the Office of Drug and Alcohol Policy and Compliance's (ODAPC) website before those devices may be used in DOT alcohol testing.
IX. PHMSA Proposed Changes
PHMSA is proposing to amend §§199.3, 199.117, and 199.227 and to add §199.4 to conform to the proposed changes in part 40 and to clarify that the proposed changes in part 40 apply to part 199. These changes will help the readers of part 199 find the applicable regulations in part 40 with regards to the definition of terms and record keeping requirements. We also propose to amend §§199.119 and 199.229 by changing the reference of “appendix H” to “appendix J” to conform to the amendment of part 40 published on May 2, 2023.
X. Section-by-Section Analysis
Section 40.3 What do the terms used in this regulation mean?
We propose to add a definition of “electronic signature.” The rule would define an electronic signature as a method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 44 U.S.C. 3504 note, 112 Stat. 2681-749). Including the specific cross reference to GPEA would ensure that regulated entities know that we are using GPEA's performance standard for allowing use of electronic signatures.
We propose to add a definition of “written or in writing.” The rule would define written or in writing as printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of 49 CFR 40.4. This definition would eliminate any distinction between paper and electronic methods of communication/documentation.
Section 40.4 May electronic documents and signatures be used?
We propose to add a new §40.4 that would prescribe the requirements pertaining to electronic documents and signatures throughout part 40.
Paragraph (a) would specify that §40.4 would apply to all documents required by part 40, except for the CCF, as an electronic CCF may only be used when approved by HHS and in compliance with §40.40(c)(5). As background, before an HHS-certified laboratory can use a Federal electronic CCF for regulated specimens, the test facility must submit a detailed plan and proposed standard operating procedures for the electronic CCF system for HHS review and approval through the National Laboratory Certification Program. At the current time, several HHS-certified laboratories have received approval to use a combination electronic/paper CCF, while four laboratories have received approval to use a fully electronic CCF. As noted earlier, and in a separate section of the SUPPORT Act, HHS was required to set a deadline for certified laboratories to request approval for use of fully electronic CCFs. That deadline is now August 31, 2026.
Paragraph (b) would permit, but not require, any person or entity to use electronic methods to comply with any provision in part 40 that requires a document to be signed, certified, generated, maintained, or transmitted between parties. It would apply to all forms of written documentation, including forms, records, notations, and other documents. The substance of the document would otherwise have to comply with part 40 requirements. This would establish parity between paper and electronic documents and signatures, greatly expanding interested parties' ability to use electronic methods to comply with the requirements of part 40.
Paragraph (c) would permit, but not require, any entity required to sign or certify a document to do so using electronic signatures as defined in §40.3. The rule specifies that a person may use any available technology so long as the signature otherwise complies with the requirements of part 40.
Paragraph (d) would establish the minimum requirements for electronic documents and signatures. Any electronic document or signature would be considered the legal equivalent of a paper document or signature if it is the functional equivalent with respect to integrity, accuracy, and accessibility. In other words, the electronic documents or signatures need to accurately and reliably reflect the information in the record. They must remain accessible in a form that could be accurately viewed or reproduced according to Agency rules. As with any documents, paper or electronic, documents that are not legible—for any reason—do not satisfy the Department's requirements.
Electronic documents are not to be considered the legal equivalent of traditional paper documents if they (1) are not capable of being retained, (2) are not used for the purpose for which they were created, or (3) cannot be accurately reproduced for reference by any entity entitled to access by law, for the period of time required by the Department's recordkeeping requirements.
Paragraph (d) would also require that any electronically signed documents must incorporate or otherwise include evidence that both parties to the document have consented to the use of electronic signatures, as required by the E-SIGN Act (15 U.S.C. 7001(c)).
Paragraph (e) would require that when using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records cannot be accessed by unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The proposed requirements are analogous to those established in the current §40.40(c)(5) when we approved use of the electronic CCF in part 40.
Section 40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?
Currently, paragraph (g) makes it clear that the release of information under this section must be in any written form, and the parenthetical clarifies that this can be paper-based (written, fax) or electronic (email). Under the proposed definition of “written or in writing,” there is no distinction between paper-based and electronic communications. Because “written or in writing” would mean either paper or electronic communications, we propose to remove parenthetical reference to “fax, email, letter” to eliminate redundancy and confusion. All parties can conduct their business using either paper or electronic means of documentation and communication.
Section 40.79 How is the collection process completed?
Currently, paragraph (a)(9) of this section requires the collector to “fax or otherwise transmit” Copy 2 of the CCF to the MRO and Copy 4 to the DER within 24 hours or during the next business day. We propose to amend this section by removing reference to the methods of transmitting receipts, so parties can choose their own medium of communication.
Section 40.97 What do laboratories report and how do they report it?
For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraphs (c)(1) and (2) of this section.
Section 40.111 When and how must a laboratory disclose statistical summaries and other information it maintains?
For the same reasons explained in the discussion of §40.79, we propose to amend paragraph (b) of this section to remove the references to the methods of transmitting the summary or report required by this section. Because the summary or report can be transmitted via hard copy or electronically, there is no need to specify how it must be transmitted. As such, we propose to amend the title of this section accordingly.
Section 40.127 What are the MRO's functions in reviewing negative test results?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (c)(2) of this section.
Section 40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative test results?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (b)(2) of this section.
Section 40.163 How does the MRO report drug test results?
For the same reasons explained in the discussion of §40.25, we propose to remove the reference to a “letter” in paragraph (c) of this section. In paragraph (e) of this section, we propose to replace the term “letter” with “written report” for consistency with paragraph (c).
Section 40.167 How are MRO reports of drug results transmitted to the employer?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (c)(1) of this section.
Section 40.185 Through what methods and to whom must a laboratory report split specimen results?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (b) of this section. In addition, because Copy 1 of the CCF can be transmitted in writing or electronically, there is no need to specify the methods through which it must be transmitted. As such, we propose to amend the title of this section accordingly.
Section 40.187 What does the MRO do with split specimen laboratory results?
For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraph (c)(2)(iv)(C) of this section.
Section 40.191 What is a refusal to take a DOT drug test, and what are the consequences?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (d) of this section as means of transmitting notification that an employee has refused to participate in part of the testing process from the collector or MRO to the DER.
Section 40.193 What happens when an employee does not provide a sufficient amount of urine for a drug test?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “send or fax” as the means for the collector to transmit copies of the CCF to the MRO and the DER in paragraph (b)(3) of this section.
Section 40.205 How are drug test problems corrected?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a collector, laboratory, MRO, employer, or other person to supply signed statements regarding correctable problems in a drug test in paragraphs (b)(1) and (2) of this section.
Section 40.225 What form is used for an alcohol test?
We propose to amend this section to permit, but not require, the use of an electronic version of the DOT ATF that is identical in form and content to the form provided in appendix I to part 40. The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT, and if an EBT provides a separate printout of confirmation test results pursuant to §40.253(g), the electronic ATF must include that separate printout. This section would also be amended to specify the same general confidentiality and security measures in §40.45 relating to electronic CCFs to ensure that confidential employee records cannot be accessed by unauthorized persons.
Section 40.255 What happens next after the alcohol confirmation test result?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (a)(5)(i) of this section as means of transmitting results of the alcohol confirmation test from the BAT to the DER. Similarly, there is no need to specify that Copy 1 of the ATF may be transmitted “in person, by telephone, or by electronic means.”
Section 40.261 What is a refusal to take an alcohol test, and what are the consequences?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (c) of this section as means of transmitting a refusal notification from a BAT, STT, or referral physician to the DER.
Section 40.271 How are alcohol testing problems corrected?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a STT, BAT, employer, or other service agent to supply a signed statement regarding correctable flaws in an alcohol test in paragraph (b)(2) of this section.
Section 40.365 What is the Department's policy concerning starting a PIE proceeding?
We propose to amend this section by adding a new paragraph (b)(15) that would identify the failure of a service agent to provide or maintain a secure/confidential electronic system as appropriate grounds for starting a PIE proceeding.
X. Regulatory Analyses and Notices
Executive Orders 12866, 13563, and 14094 (Regulatory Planning and Review)
The Secretary has examined the impact of the proposed part 40 amendments under Executive Order 12866 (“Regulatory Planning and Review”), as supplemented by Executive Order 13563 (“Improving Regulation and Regulatory Review”) and amended by Executive Order 14094 (“Modernizing Regulatory Review”), which directs Federal agencies to assess all costs and benefits of available regulatory alternatives and, when regulation is necessary, to select regulatory approaches that maximize net benefits (including potential economic, environmental, public health and safety, and other advantages; distributive impacts; and equity).
According to these Executive orders, a regulatory action is “significant” if it meets any one of a number of specified conditions, including having an annual effect on the economy of $200 million or more, as adjusted every three years by the Office of Information and Regulatory Affairs (OIRA); adversely affecting in a material way a sector of the economy, competition, or jobs; or if it raises novel legal or policy issues. The proposed amendments, which would allow the use of electronic documents and signatures, do not meet the Executive order's criteria for being a significant rule. Consequently, OMB has determined that the rulemaking action is not significant under the Executive order.
The proposed rule responds to the statutory mandate set forth in Section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271. The proposed rule would not impose new requirements on the industry; rather, it would simply permit—but not require—regulated entities to use electronic signatures, forms, and recordkeeping, and remove outdated and obsolete references in the regulatory text. The proposed rule would not impose new costs on the industry because regulated entities would be allowed to choose to continue to use paper-based documents as they had before. The benefits of the rule would stem from savings in paper and printing expense and other efficiency gains. Examples of documents affected by this rule include, but are not limited to, records of a prospective employee's drug and alcohol testing history that employers must obtain prior to permitting that employee to perform safety-sensitive duties, MRO records and reports, SAP records and reports, and ATFs. While there is no way to estimate how many entities or individuals would change their practices given the new options, or how many documents would be affected, several commenters to the ANPRM stated that they have been using electronic documents and signatures in their non-DOT drug and alcohol testing programs for many years. While neither the benefits nor the costs of this rule can be reliably estimated, we expect this proposed rule to provide flexibility to the industry. Under this proposed rule, regulated entities would have the flexibility to conduct business using either electronic or traditional paper-based methods. We also expect regulated entities to choose technologies that would maximize benefits in accordance with their individual needs and circumstances.
Regulatory Flexibility Act and Small Business Regulatory Enforcement Fairness Act (SBREFA)
The Regulatory Flexibility Act of 1980 (5 U.S.C. 601 et seq. ) requires Federal agencies to consider the effects of their regulatory actions on small businesses and other small entities and minimize any significant economic impact. The term “small entities” comprises small businesses and not-for-profit organizations that are independently owned and operated and are not dominant in their fields, and governmental jurisdictions with a population of less than 50,000. For this rulemaking, potentially affected small entities include drug testing companies (U.S. Small Business Administration (SBA) North American Industry Classification System (NAICS) Sector 54 (Professional, Scientific and Technical Services), Code 541380 (Testing Laboratories and Services)) as well as DOT-regulated entities (SBA NAICS Sectors 48-49 (Transportation and Warehousing)).
The Department does not expect that the proposed rule would have a significant economic impact on a substantial number of small entities. The proposed rule, if adopted, would increase flexibility for all small-entity transportation employers and their service agents by allowing them to use electronic documents, signatures, and recordkeeping to meet part 40 requirements. Use of electronic documents, electronic signatures, and electronic recordkeeping would be voluntary for affected small entities, which will provide added flexibility to these entities in meeting the part 40 requirements. For these reasons, and as explained in more detail in the preamble to this proposed rule, the Secretary certifies that the proposed rule would not have a significant economic impact on a substantial number of small entities within the meaning of the Regulatory Flexibility Act. Consequently, an initial regulatory flexibility analysis is not required for this proposed rule.
Unfunded Mandates
The Secretary has examined the impact of the final rule under the Unfunded Mandates Reform Act (UMRA) of 1995 (Pub. L. 104-4). This NPRM does not trigger the requirement for a written statement under sec. 202(a) of the UMRA because this rulemaking does not impose a mandate that results in an expenditure of $100 million (adjusted annually for inflation) or more by either State, local, and tribal governments in the aggregate or by the private sector in any one year. In fact, by providing an alternative to traditional paper-based records, the proposed rule would be expected to reduce costs to regulated parties, including State and local entities ( e.g., public transit authorities, and public works departments) whose employees are subject to testing and that choose to use electronic documents as opposed to paper-based documents.
Environmental Impact
The DOT has analyzed the environmental impacts of this action pursuant to the National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321 et seq. ) and has determined that it is categorically excluded pursuant to DOT Order 5610.1C, “Procedures for Considering Environmental Impacts” (44 FR 56420, October 1, 1979). Categorical exclusions are actions identified in an agency's NEPA implementing procedures that do not normally have a significant impact on the environment and therefore do not require either an environmental assessment (EA) or environmental impact statement (EIS). This proposed rule would amend the transportation industry drug testing program procedures regulation to permit the use of electronic documents, signatures, and recordkeeping. This action is covered by the categorical exclusion listed at 23 CFR 771.118(c)(4), “[p]lanning and administrative activities that do not involve or lead directly to construction, such as: . . . promulgation of rules, regulations, directives . . .” The Department does not anticipate any environmental impacts, and there are no extraordinary circumstances present in connection with this rulemaking.
Executive Order 13132: Federalism
The Secretary has analyzed the final rule in accordance with Executive Order 13132: Federalism. Executive Order 13132 requires Federal agencies to carefully examine actions to determine if they contain policies that have federalism implications or that preempt State law. As defined in the order, “policies that have federalism implications” refer to regulations, legislative comments or proposed legislation, and other policy statements or actions that have substantial direct effects on the States, on the relationship between the National Government and the States, or on the distribution of power and responsibilities among the various levels of government.
Most of the regulated parties under the Department's drug testing program are private entities. Some regulated entities are public entities ( e.g., transit authorities and public works departments); however, as noted above, this proposal would reduce costs of the Department's drug testing program and provide additional flexibility for regulated parties. Accordingly, the Secretary has determined that the proposed rule, which would allow but not require use of electronic signatures and recordkeeping, does not contain policies that have federalism implications.
Executive Order 13175: Consultation and Coordination With Indian Tribal Governments
Executive Order 13175 (65 FR 67249, November 6, 2000) requires Federal agencies to develop an accountable process to ensure “meaningful and timely input by tribal officials in the development of regulatory policies that have tribal implications.” “Policies that have tribal implications” as defined in the Executive order, include regulations that have “substantial direct effects on one or more Indian tribes, on the relationship between the Federal government and the Indian tribes, or on the distribution of power and responsibilities between the Federal government and Indian tribes.” This proposed rule does not have tribal implications. The proposed rule will also not have substantial direct effects on tribal governments, on the relationship between the Federal Government and Indian tribes, or on the distribution of power and responsibilities between the Federal Government and Indian tribes, as specified in Executive Order 13175.
Paperwork Reduction Act
The Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520) (PRA) requires that DOT consider the impact of paperwork and other information collection burdens imposed on the public. This proposed rule would call for no new collection of information under the PRA. Instead, there would likely be a significant reduction in the burden hours required for information collection 2105-0529, Procedures for Transportation Drug and Alcohol Testing Program, due to the ability to use electronic signatures and forms, and largely due to the ability to use an electronic ATF for DOT-regulated alcohol testing under part 40. We request comments on this issue. Notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information subject to the PRA that does not display a currently valid OMB control number.
Privacy Act
Anyone is able to search the electronic form of all comments received in any of our dockets by the name of the individual submitting the comment (or signing the comment, if submitted on behalf of an association, business, labor union, etc.) For information on DOT's compliance with the Privacy Act, please visit https://www.transportation.gov/privacy.
5 U.S.C. 553(b)(4)
As required by 5 U.S.C. 553(b)(4), a summary of this proposed rule can be found at the entry for RIN 2105-AF01 in the Department's Portion of the Unified Agenda of Regulatory and Deregulatory Affairs, available at https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202404&RIN=2105-AF01 .
Pay-As-You-Go Act of 2023
In accordance with Compliance with Pay-As-You-Go Act of 2023 (Fiscal Responsibility Act of 2023, Pub. L. 118-5, div. B, title III) and OMB Memorandum (M-23-21) dated September 1, 2023, the Department has determined that this proposed rule is not subject to the Pay-As-You-Go Act of 2023 because it will not increase direct spending beyond specified thresholds.
List of Subjects
49 CFR Part 40
Administrative practice and procedures, Alcohol abuse, Alcohol testing, Drug abuse, Drug testing, Laboratories, Reporting and recordkeeping requirements, Safety, Transportation.
49 CFR Part 199
Alcohol testing, Drug testing, Pipeline safety, Reporting and recordkeeping requirements, Safety, Transportation.
For the reasons stated in the preamble, the Department proposes to amend 49 CFR parts 40 and 199 as follows:
PART 40—PROCEDURES FOR TRANSPORTATION WORKPLACE DRUG AND ALCOHOL TESTING PROGRAMS
1. The authority for part 40 continues to read as follows:
Authority:
49 U.S.C. 102, 301, 322, 5331, 20140, 31306, and 54101 et seq.
2. In §40.3, add the definitions of “Electronic signature” and “Written or in writing” in alphabetical order to read as follows:
§40.3 What do the terms used in this part mean?
* * * * *
Electronic signature. A method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 112 Stat. 2681-749, 44 U.S.C. 3504 note).
* * * * *
Written or in writing. Printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of §40.4.
3. Add §40.4 to read as follows:
§40.4 May electronic documents and signatures be used?
(a) Applicability. This section applies to all documents required by this part, except for the CCF. An electronic CCF may be used only if it has been approved for use by the Department of Health and Human Services and is used in compliance with §40.40(c)(5).
(b) Electronic records or documents. Any person or entity required to generate, maintain, or exchange and/or transmit documents to satisfy requirements in this part may use electronic methods to satisfy those requirements.
(c) Electronic signatures. (1) Any person or entity required to sign or certify a document to satisfy the requirements of this part may use an electronic signature, as defined in §40.3.
(2) Any available technology may be used that satisfies the requirements of an electronic signature as defined in §40.3.
(d) Electronic document requirements. Any person or entity may use documents signed, certified, generated, maintained, or exchanged using electronic methods, as long as the documents accurately reflect the information otherwise required to be contained in them.
(1) Records, documents, or signatures generated, maintained, or exchanged using electronic methods satisfy the requirements of this section if they are capable of being retained, are used for the purpose for which they were created, and can be accurately reproduced within required timeframes for reference by any party entitled to access.
(2) Records or documents generated electronically satisfy the requirements of this section if they include proof of consent to use electronically generated records or documents, as required by 15 U.S.C. 7001(c).
(e) Confidentiality and security. When using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form to include protecting against destruction, deterioration, and data corruption.
4. In §40.25, revise paragraph (g) to read as follows:
§40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?
* * * * *
(g) The release of information under this section must be in any written form that ensures confidentiality. As the previous employer, you must maintain a written record of the information released, including the date, the party to whom it was released, and a summary of the information provided.
* * * * *
5. In §40.79, revise paragraph (a)(9) to read as follows:
§40.79 How is the collection process completed?
(a) * * *
(9) Send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or during the next business day. Keep Copy 3 for at least 30 days, unless otherwise specified by applicable DOT agency regulations.
* * * * *
6. In §40.97, revise paragraphs (c) introductory text, (c)(1) introductory text, and (c)(2) to read as follows:
§40. 97 What do laboratories report and how do they report it?
* * * * *
(c) As a laboratory, you must report laboratory results directly, and only, to the MRO at his or her place of business. You must not report results to or through the DER or a service agent ( e.g., C/TPA).
(1) Negative results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF which has been signed by the certifying scientist, or you may provide the laboratory results report electronically.
* * * * *
(2) Non-negative and rejected for testing results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF that has been signed by the certifying scientist. In addition, you may provide the laboratory results report following the format and procedures set forth in paragraphs (c)(1)(i) and (ii) of this section.
* * * * *
7. In §40.111, revise the section heading and paragraph (b) to read as follows:
§40.111 When must a laboratory disclose statistical summaries and other information it maintains?
* * * * *
(b) When the employer requests a summary in response to an inspection, audit, or review by a DOT agency, you must provide it unless the employer had fewer than five aggregate test results. In that case, you must send the employer a report indicating that not enough testing was conducted to warrant a summary.
* * * * *
8. In §40.127, revise paragraph (c)(2) to read as follows:
§40.127 What are the MRO's functions in reviewing negative test results?
* * * * *
(c) * * *
(2) A legible copy of Copy 1 of the CCF or the electronic laboratory results report that conveys the negative laboratory test result.
* * * * *
9. In §40.129, revise paragraphs (b) introductory text and (b)(2) to read as follows:
§40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative drug test results?
* * * * *
(b) Before you report a verified negative, positive, test cancelled, refusal to test because of adulteration or substitution, you must have in your possession the following documents:
* * * * *
(2) A legible copy of Copy 1 of the CCF, containing the certifying scientist's signature.
* * * * *
10. In §40.163, revise paragraphs (c) introductory text and (e) to read as follows:
§40.163 How does the MRO report drug test results?
* * * * *
(c) If you do not report test results using Copy 2 of the CCF for the purposes of this section, you must provide a written report for each test result. This report must, as a minimum, include the following information:
* * * * *
(e) You must retain a signed or stamped and dated copy of Copy 2 of the CCF in your records. If you do not use Copy 2 for reporting results, you must maintain a copy of the signed or stamped and dated written report in addition to the signed or stamped and dated Copy 2. If you use the electronic data file to report negatives, you must maintain a retrievable copy of that report in a format suitable for inspection and auditing by a DOT representative.
* * * * *
11. In §40.167, revise paragraph (c)(1) to read as follows:
§40.167 How are MRO reports of drug test results transmitted to the employer?
* * * * *
(c) * * *
(1) You must transmit a legible image or copy of either the signed or stamped and dated Copy 2 or the written report (see §40.163(b) and (c)).
* * * * *
12. In §40.185, revise the section heading and paragraph (b) to read as follows:
§40.185 What and to whom must a laboratory report split specimen results?
* * * * *
(b) You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF, which has been signed by the certifying scientist.
* * * * *
13. In §40.187, revise paragraph (c)(2)(iv)(C) to read as follows:
§40.187 What does the MRO do with split specimen laboratory results?
* * * * *
(c) * * *
(2) * * *
(iv) * * *
(C) As the laboratory that tests the primary specimen to reconfirm the presence of the adulterant found in the split specimen and/or to determine that the primary specimen meets appropriate substitution criteria, report your result to the MRO using a copy of Copy 1 of the CCF.
* * * * *
14. In §40.191, revise paragraph (d) introductory text to read as follows:
§40.191 What is a refusal to take a DOT drug test, and what are the consequences?
* * * * *
(d) As a collector or an MRO, when an employee refuses to participate in the part of the testing process in which you are involved, you must terminate the portion of the testing process in which you are involved, document the refusal on the CCF (including, in the case of the collector, printing the employee's name on Copy 2 of the CCF), immediately notify the DER by any means that ensures that the refusal notification is immediately received. As a referral physician ( e.g., physician evaluating a “shy bladder” condition or a claim of a legitimate medical explanation in a validity testing situation), you must notify the MRO, who in turn will notify the DER.
* * * * *
15. In §40.193, revise paragraph (b)(3) to read as follows:
§40.193 What happens when an employee does not provide a sufficient amount of specimen for a drug test?
* * * * *
(b) * * *
(3) As the collector, you must send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or the next business day.
* * * * *
16. In §40.205, revise paragraphs (b)(1) and (2) to read as follows:
§40.205 How are drug test problems corrected?
* * * * *
(b) * * *
(1) If the problem resulted from the omission of required information, you must, as the person responsible for providing that information, supply in writing the missing information and a statement that it is true and accurate. For example, suppose you are a collector, and you forgot to make a notation on the “Remarks” line of the CCF that the employee did not sign the certification. You would, when the problem is called to your attention, supply a signed statement that the employee failed or refused to sign the certification and that your statement is true and accurate. You must supply this information on the same business day on which you are notified of the problem.
(2) If the problem is the use of a non-Federal form or an expired Federal form, you must provide a signed statement ( i.e., a memorandum for the record). It must state that the incorrect form contains all the information needed for a valid DOT drug test, and that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control. The statement must also list the steps you have taken to prevent future use of non-Federal forms or expired Federal forms for DOT tests. For this flaw to be corrected, the test of the specimen must have occurred at an HHS-certified laboratory where it was tested consistent with the requirements of this part. You must supply this information on the same business day on which you are notified of the problem.
* * * * *
17. In §40.225, revise paragraph (a) and add paragraphs (d) and (e) to read as follows:
§40.225 What form is used for an alcohol test?
(a) The DOT Alcohol Testing Form (ATF) must be used for every DOT alcohol test. The ATF must be a three-part carbonless manifold form or an electronic ATF that meets the requirements of paragraph (d) of this section. The ATF is found in appendix G to this part. You may view this form on the ODAPC website ( https://www.transportation.gov/odapc ).
* * * * *
(d) As an employer, you may use an electronic ATF that meets the following requirements:
(1) The electronic ATF must be identical in form and content to the ATF found in appendix G to this part.
(2) The electronic ATF must meet the requirements of §40.4(d).
(3) The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT.
(4) If an EBT provides a separate printout of confirmation test results (see §40.253(g)), the electronic ATF must include that separate printout.
(e) As an employer, BAT, or STT using an electronic ATF, you must establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form.
18. In §40.255, revise paragraph (a)(5)(i) to read as follows:
§40.255 What happens next after the alcohol confirmation test result?
(a) * * *
(5) * * *
(i) You may transmit the results using Copy 1 of the ATF, in person, by telephone, or by electronic means. In any case, you must immediately notify the DER of any result of 0.02 or greater by any means that ensures the result is immediately received by the DER. You must not transmit these results through C/TPAs or other service agents.
* * * * *
19. In §40.261, revise paragraph (c)(1) to read as follows:
§40.261 What is a refusal to take an alcohol test, and what are the consequences?
* * * * *
(c)(1) As a BAT or an STT, or as the physician evaluating a “shy lung” situation, when an employee refuses to test as provided in paragraph (a) of this section, you must terminate the portion of the testing process in which you are involved, document the refusal on the ATF (or in a separate document which you cause to be attached to the form), immediately notify the DER by any means that ensures the refusal notification is immediately received. You must make this notification directly to the DER (not using a C/TPA as an intermediary).
* * * * *
20. In §40.271, revise paragraph (b)(2) to read as follows:
§40.271 How are alcohol testing problems corrected?
* * * * *
(b) * * *
(2) If the problem is the use of a non-DOT form, you must, as the person responsible for the use of the incorrect form, certify in writing that the incorrect form contains all the information needed for a valid DOT alcohol test. You must also provide a signed statement that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control, and the steps you have taken to prevent future use of non-DOT forms for DOT tests. You must supply this information on the same business day on which you are notified of the problem.
* * * * *
21. In §40.365, revise paragraphs (b)(13) and (14) and add paragraph (b)(15) to read as follows:
§40.365 What is the Department's policy concerning starting a PIE proceeding?
* * * * *
(b) * * *
(13) For any service agent, directing or recommending that an employer fail or refuse to implement any provision of this part;
(14) With respect to noncompliance with a DOT agency regulation, conduct that affects important provisions of Department-wide concern ( e.g., failure to properly conduct the selection process for random testing); or
(15) For a service agent, failing to provide or maintain a secure/confidential electronic system. PART 199—DRUG AND ALCOHOL TESTING
22. The authority citation for part 199 continues to read as follows:
Authority:
49 U.S.C. 5103, 60102, 60104, 60108, 60117, and 60118; 49 CFR 1.53.
23. In §199.3:
a. Designate the introductory text as paragraph (b); and
b. Add paragraph (a).
The addition reads as follows:
§199.3 Definitions.
(a) Terms used in this part have the same meaning as in 49 CFR 40.3.
* * * * *
24. Add §199.4 to read as follows:
§199.4 Electronic documents, records, and signatures.
Electronic documents, records, and signatures may be used to comply with this part provided they meet the requirements specified in 49 CFR part 40.
25. In §199.117, revise paragraph (a) introductory text to read as follows:
§199.117 Recordkeeping.
(a) Each operator shall keep the records in paragraphs (a)(1) through (5) of this section for the periods specified by this section or for the periods specified by 49 CFR part 40, whichever is greater; and will permit access to the records as provided by §190.203.
* * * * *
26. In §199.119, revise paragraph (a) to read as follows:
§199.119 Reporting of anti-drug testing results.
(a) Each large operator (having more than 50 covered employees) must submit an annual Management Information System (MIS) report to PHMSA of its anti-drug testing using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.
* * * * *
27. In §199.227, revise paragraph (b) introductory text to read as follows:
§199.227 Retention of records.
* * * * *
(b) Period of retention. Each operator shall maintain the records in accordance with the following schedule or for the periods specified by 49 CFR part 40, whichever is greater:
* * * * *
28. In §199.229, revise paragraph (a) to read as follows:
§199.229 Reporting of alcohol testing results.
(a) Each large operator (having more than 50 covered employees) must submit an annual MIS report to PHMSA of its alcohol testing results using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.
* * * * *
Signed on: Thursday, October 3, 2024.
Pete Buttigieg,
Secretary of Transportation.
[FR Doc. 2024-23427 Filed 10-11-24; 8:45 am]
BILLING CODE 4910-9X-P
NewsFleet SafetyPipeline and Hazardous Materials Safety Administration (PHMSA), DOTDrug testing - Motor CarrierDrug and Alcohol Testing - DOTOffice of the Secretary of TransportationHazmat SafetyRulemakingFocus AreaProposed RuleEnglishTransportationUSA
89 FR 82957 Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records
2024-10-15T05:00:00Z
DEPARTMENT OF TRANSPORTATION
Office of the Secretary
49 CFR Part 40
Pipeline and Hazardous Materials Safety Administration
49 CFR Part 199
[Docket DOT-OST-2022-0027]
RIN 2105-AF01
Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records
AGENCY: Office of the Secretary, Department of Transportation (DOT).
ACTION: Notice of proposed rulemaking (NPRM).
SUMMARY: The Department of Transportation (DOT or Department) proposes to amend its regulations for conducting workplace drug and alcohol testing for the federally regulated transportation industry to allow, but not require, electronic signatures on documents required to be created and utilized under the regulations, the use of electronic versions of forms, and the electronic storage of forms and data. The regulatory changes would apply to DOT-regulated employers and their contractors (“service agents”) who administer their DOT-regulated drug and alcohol testing programs. Currently, employers and their service agents must use, sign and store paper documents exclusively, unless the employer is utilizing a laboratory's electronic Federal Drug Testing Custody and Control Form (electronic CCF) system that has been approved by the Department of Health and Human Services (HHS). DOT is required by statute to amend its regulations to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms. This rulemaking also responds to an April 2, 2020, petition for rulemaking from DISA Global Solutions, Inc. (DISA), requesting that DOT regulations be amended to allow the use of an electronic version of the alcohol testing form (ATF) for DOT-authorized alcohol testing. The proposed regulatory amendments are expected to provide additional flexibility and reduced costs for the industry while maintaining the integrity and confidentiality requirements of the drug and alcohol testing regulations. In addition, DOT proposes to amend the Pipeline and Hazardous Materials Safety Administration (PHMSA) regulation for conformity and to make other miscellaneous technical changes and corrections.
DATES: Comments on this NPRM must be received on or before December 16, 2024.
ADDRESSES: You may submit comments identified by Docket Number DOT-OST-2022-0027 using any of the following methods:
• Federal eRulemaking Portal: Go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document. Follow the online instructions for submitting comments.
• Mail: Docket Management Facility, U.S. Department of Transportation, 1200 New Jersey Avenue SE, West Building, Ground Floor, Room W12-140, Washington, DC 20590-0001.
• Hand Delivery or Courier: West Building, Ground Floor, Room W12-140, 1200 New Jersey Avenue SE, Washington, DC, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting Dockets Operations.
• Fax: 202-493-2251.
To avoid duplication, please use only one of these methods. See the “Public Participation and Request for Comments” portion of the SUPPLEMENTARY INFORMATION section for instructions on submitting comments, including collection of information comments for the Office of Information and Regulatory Affairs, Office of Management and Budget (OMB).
FOR FURTHER INFORMATION CONTACT:
Mike Huntley, Office of Drug and Alcohol Policy and Compliance, 1200 New Jersey Avenue SE, Washington, DC 20590; telephone number 202-366-3784; ODAPCwebmail@dot.gov. If you have questions on viewing or submitting material to the docket, contact Docket Services, telephone (202) 366-9826.
SUPPLEMENTARY INFORMATION:
This NPRM is organized as follows:
I. Executive Summary
II. Public Participation and Request for Comments
A. Submitting Comments
B. Viewing Comments and Documents
C. Privacy Act
III. Legal Basis for the Rulemaking
IV. Background
V. Advance Notice of Proposed Rulemaking (ANPRM) Overview
VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures
VII. Amending Part 40 To Permit Electronic Documents and Signatures
VIII. Electronic ATF
IX. Section-by-Section Analysis
X. Regulatory Analyses and Notices
I. Executive Summary
Purpose and Summary of the Major Provisions
This proposed rule would establish parity between paper and electronic documents and signatures and expand businesses' and individuals' ability to use electronic methods to comply with the Department's drug and alcohol testing regulation, 49 CFR part 40, “Procedures for Transportation Workplace Drug and Alcohol Testing Programs” (part 40). Businesses and individuals subject to part 40 would continue to have the choice to use paper documents and traditional “wet” signatures. This proposed rule would also modify references to recordkeeping and reporting methods throughout part 40 to make them technologically neutral.
This proposed rulemaking responds to a statutory mandate set forth in section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271 (see 49 U.S.C. 322 note). The proposed rulemaking would take action consistent with the Government Paperwork Elimination Act (GPEA) (division C, title XVII, secs. 1701-1710, Pub. L. 105-277) and the Electronic Signatures in Global and National Commerce Act (E-SIGN) (Pub. L. 106-229) with regard to DOT's part 40 regulations.
II. Public Participation and Request for Comments
A. Submitting Comments
If you submit a comment, please include the docket number for this NPRM (Docket No. DOT-OST-2022-0027), indicate the specific section of this document to which each comment applies, and provide a reason for each suggestion or recommendation. You may submit your comments and material online or by fax, mail, or hand delivery, but please use only one of these means. The Office of the Secretary (OST) recommends that you include your name and a mailing address, an email address, or a phone number in a cover letter or an email so that OST can contact you if there are questions regarding your submission.
To submit your comment online, go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document, click on this NPRM, click “Comment,” and type your comment into the text box on the following screen.
If you submit your comments by mail or hand delivery, submit them in an unbound format, no larger than 8 1/2 by 11 inches, suitable for copying and electronic filing. If you submit comments by mail and would like to know that they reached the facility, please enclose a stamped, self-addressed postcard or envelope.
OST will consider all comments and material received during the comment period in determining how to proceed with any final rule.
B. Viewing Comments and Documents
To view comments, as well as any documents mentioned in this preamble as available in the docket, go to https://www.regulations.gov. Insert the docket number, DOT-OST-2022-0027, in the keyword box, and click “Search.” Next, click the “Open Docket Folder” button and choose the document to review. If you do not have access to the internet, you may view the docket online by visiting the Docket Management Facility in Room W12-140 on the ground floor of the DOT West Building, 1200 New Jersey Avenue SE, Washington, DC 20590-0001, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting the Docket Management Facility.
C. Privacy Act
In accordance with 5 U.S.C. 553(c), DOT solicits comments from the public to better inform its rulemaking process. DOT posts these comments, without edit, including any personal information the commenter provides, to www.regulations.gov, as described in the system of records notice (DOT/ALL-14 FDMS), which can be reviewed at https://www.transportation.gov/individuals/privacy/privacy-act-system-records-notices under the heading of “Department-Wide System of Records Notices”.
III. Legal Basis for the Rulemaking
This rulemaking is promulgated under the authority enacted in the Omnibus Transportation Employee Testing Act of 1991 (OTETA) (Pub. L. 102-143, tit. V, 105 Stat. 952) and codified at 49 U.S.C. 45102 (aviation), 49 U.S.C. 20140 (rail), 49 U.S.C. 31306 (motor carrier), and 49 U.S.C. 5331 (public transportation), as well as the Department's authority in 49 U.S.C. 322 and the PHMSA authorities specified in the proposed regulatory text for this action.
According to Public Law 115-271, the Secretary of Transportation is required to “issue a final rule revising part 40 of title 49, Code of Federal Regulations, to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms.” (49 U.S.C. 322 note) The statute set the deadline for this action as not later than 18 months after HHS establishes a deadline for a certified laboratory to request approval for fully electronic CCFs ( Id. ) On April 7, 2022, HHS set that deadline as August 31, 2023 (87 FR 20528). HHS has extended the deadline to August 31, 2026, to enable sufficient time for all HHS-certified laboratories to identify and contract with an electronic CCF supplier or to develop an electronic CCF. The deadline for DOT's regulatory amendments would therefore be February 29, 2028.
There are two additional Federal statutes relevant to the implementation of electronic document and signature requirements.
The Government Paperwork Elimination Act (GPEA), codified at 44 U.S.C. 3504 note, 1 was enacted to improve customer service and governmental efficiency through the use of information technology. The GPEA defines an electronic signature as a method of signing an electronic communication that: (a) identifies and authenticates a particular person as the source of the electronic communication; and (b) indicates such person's approval of the information contained in the electronic communication. Id. It also requires OMB to ensure Federal agencies provide for: (a) the option of maintaining, submitting; or disclosing information electronically, when practicable; and (b) the use and acceptance of electronic signatures when practicable. The GPEA states that electronic records submitted pursuant to procedures developed under title XVII for the submission of records to Federal agencies and electronic signatures used in accordance with those procedures shall not be denied legal effect, validity, or enforceability merely because they are in electronic form. Id.
1 Division C, title XVII (sec. 1701-1710) of Public Law 105-277, 112 Stat. 2681-749, enacted on October 21, 1998.
The Electronic Signatures in Global and National Commerce Act (E-SIGN), codified at 15 U.S.C. 7001-7031, 2 was designed to promote the use of electronic contract formation, signatures, and recordkeeping in private commerce by establishing legal equivalence between traditional paper-based methods and electronic methods. The E-SIGN Act allows the use of electronic records to satisfy any statute, regulation, or rule of law requiring that such information be provided in writing if the consumer has affirmatively consented to such use and has not withdrawn consent. Specifically, the statute establishes the legal equivalence of the following types of documents with respect to any transaction in or affecting interstate or foreign commerce, whether in traditional paper or electronic form: (a) contracts, (b) signatures, and (c) other records (15 U.S.C. 7001(a)(1)).
2 Public Law 106-229, 114 Stat. 464, enacted on June 30, 2000.
IV. Background
The Department's drug and alcohol testing regulations were promulgated at a time when the ability to sign and retain official records electronically—now commonplace in many business segments—was not available. Over the course of several years, we have adopted measures that have reduced the paper documentation associated with the drug and alcohol testing program without compromising the integrity and confidentiality requirements of the program. In 2003, we standardized the form for employers to report their Management Information System (MIS) aggregate drug and alcohol testing data, as well as the specific data collected. 3 When creating a ONE-DOT MIS Form, we then authorized employers to submit a single standardized form via a web portal. In 2015, we issued a final rule to allow employers, collectors, laboratories, and medical review officers (MROs) to use the electronic version of the Federal Drug Testing CCF in the DOT-regulated drug testing program. 4 That final rule also incorporated into the regulations the requirement to establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons when using the electronic CCF. We also included language protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form when using the electronic CCF.
3 68 FR 43946 (July 25, 2003).
4 80 FR 19551 (Apr. 13, 2015).
Consistent with the statutory mandate in 49 U.S.C. 322 note, we propose amendments to part 40 to permit the use of electronic signatures, forms, and records storage for drug and alcohol testing records throughout the regulation, including the use of an electronic ATF for DOT-authorized alcohol testing. We emphasize that electronic signatures, forms, and records would not be required; we would continue to allow paper, or hard-copy use with traditional “wet signatures.”
These proposed amendments would establish parity between paper and electronic collection and submission of information required under our regulations (and remain compatible with applicable OMB guidance on implementing electronic signatures 5 ) by allowing further use of electronic means and methods to comply with part 40 requirements. Many employers and their service agents have already instituted the use of electronic signatures, forms, and records storage for the non-DOT regulated testing that they conduct. DOT supports this transition to a paperless system and is committed to ensuring that the movement to a partially or fully electronic part 40 is done to maximize program efficiencies and reduce costs, while maintaining the integrity and confidentiality requirements of the program.
5https://www.whitehouse.gov/wp-content/uploads/2017/11/2000-M-00-15-OMB-Guidance-on-Implementing-the-Electronic-Signatures-in-Global-and-National-Commerce-Act.pdf.
Electronic documents would have a high degree of forensic defensibility as long as any changes made to the document are in the document's electronic footprint, which shows when the document or signature, as applicable, was created; when, and if, changes were made; who made the changes; and when, as applicable, a document was transmitted to and received by the receiving entity. The use of electronic forms and signatures in part 40 would help DOT-regulated employers and their service agents improve their workflow efficiency through faster turnaround times for required documents. Cost savings would result through reduced printing and delivery/shipping costs, and expedited transmission of information allowing for more timely decisions. We believe this proposed rule, if adopted, would also mitigate the longstanding problems ( e.g., delays in processing times of test results, cancelling of test results, etc.) associated with illegible and lost copies of paper documents.
V. Advance Notice of Proposed Rulemaking (ANPRM) Overview
On August 5, 2022, we published an ANPRM requesting public comment on how part 40 could be amended, as required by the statute, to allow electronic signatures, forms, and recordkeeping (87 FR 47951). We requested information from DOT-regulated employers and their service agents regarding if and how they are already handling electronic signatures, records transmission, and records storage in their non-DOT testing programs. In addition, we requested comments and information on appropriate performance standards, and on whether particular methods or performance standards have been successful or unsuccessful. We also asked a number of general questions on the potential advantages, risks, ramifications, and required safeguards associated with the use of electronic signatures, forms, and records in the DOT drug and alcohol testing program. We asked questions about specific sections of part 40 that we anticipated would be affected by prospective changes to implement electronic signatures, forms, and records. Finally, we asked a number of questions regarding the use of an electronic ATF for DOT-regulated alcohol tests.
We received 72 comments in response to the ANPRM, including comments from individuals, testing laboratories, MROs, and MRO organizations, substance abuse professionals (SAP) and SAP organizations, and various associations representing DOT-regulated transportation workers subject to mandatory drug and alcohol testing under part 40.
A few individuals expressed opposition to the adoption of electronic signatures, forms, and recordkeeping, citing concerns about the need for the rulemaking, risk to personal information from hackers or mismanaged electronic processes and procedures, and misuse of electronic forms and signatures. To meet our statutory mandate and in consideration of concerns about safeguarding personal information and appropriate use of the information in developing the NPRM, DOT proposes to require security measures for electronic forms and signatures used under part 40 that are the same as those currently in place for the electronic CCF specified in 49 CFR 40.40(c)(5).
Most commenters were supportive of changes to amend part 40 that would permit, but not require, the use of electronic signatures, forms, and recordkeeping. Commenters supporting revisions to part 40 noted that electronic signatures, forms, and recordkeeping are used in virtually every industry today—including but not limited to the banking, insurance, medical, and legal industries. Commenters supported the use of performance standards instead of technology-specific standards to ensure that, once established, standards do not become obsolete given the rapidly evolving nature of information technology standards and practices. Commenters stated that allowing electronic signatures, forms, and recordkeeping would make the drug testing process much more efficient and would result in cost savings. Commenters also stated that it would be safer to store records electronically since records could be backed-up, secured, and protected from tampering and unauthorized access and use.
VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures
In developing this NPRM, we looked to a rule promulgated by DOT's FMCSA that permits the use of electronic methods to generate, certify, sign, maintain, or exchange records so long as the documents accurately reflect the required information and can be used for their intended purpose. (83 FR 16210, Apr. 16, 2018) The rule applies to documents that FMCSA requires entities or individuals to retain. FMCSA permits, but does not require, anyone to satisfy FMCSA requirements by using electronic methods to generate, maintain, or exchange documents. The substance of the document must otherwise comply with applicable Federal laws and FMCSA rules. FMCSA also permits, but does not require, anyone required to sign or certify a document to do so using electronic signatures, defined, as in the GPEA, as a method of signing an electronic communication that: (1) identifies and authenticates a particular person as the source of the electronic communication; and (2) indicates such person's approval of the information contained in the electronic communication. FMCSA allows for the use any available technology for electronic signatures, so long as the signature otherwise complies with FMCSA's requirements.
FMCSA adopted broad performance standards for electronic documents and signatures—as specified in GPEA and E-SIGN—rather than detailed, technology specific standards that would likely become obsolete with inevitable changes in information technology standards and practices. FMCSA's April 2018 rule has been in effect for more than five years, and the definitions and requirements established in that rule have stood the test of time despite the many changes that have occurred with respect to electronic documents and signatures. We are unaware of any FMCSA-regulated entities that have reported issues to FMCSA regarding the use of electronic documents or signatures to meet the requirements of the FMCSRs since the rule became effective in 2018.
VII. Amending Part 40 To Permit Electronic Documents and Signatures
In this NPRM, we propose to permit but not require electronic documents, signatures, and recordkeeping in part 40. Additionally, we propose a performance standard approach as opposed to establishing technology-specific standards. Where it is possible to do so, establishing the same or substantively similar regulatory requirements for common issues across DOT modal agencies—such as the use of electronic documents and signatures—helps the Department maintain a consistent regulatory approach for those common issues.
There are currently more than 60 references to the term “written” in part 40, and more than 20 additional references to the term “in writing.” We propose to add a definition of “written or in writing” in part 40, to eliminate any distinction between paper and electronic documentation and establish technological neutrality throughout the entirety of part 40.
FMCSA's rule does not apply to documents that individuals or entities are required to file directly with FMCSA. In its April 2018 final rule, FMCSA explained that while industry could use electronic signatures and submit information directly to the FMCSA in certain situations, 6 adapting all FMCSA systems to allow for use of electronic signatures and submissions would significantly delay the implementation of the rule for use by third parties as it would require FMCSA to develop and implement technology systems to allow for direct submission to FMCSA from regulated parties. FMCSA noted that development of such systems could take several years, and therefore saw no reason to make private parties' use of electronic signatures and records retention contingent upon FMCSA's ability to receive submissions electronically because doing so would delay potential benefits to be gained by third parties.
6 As an example, Certified Medical Examiners may use electronic signatures, if they choose to do so, to sign medical forms, certificates, and a new driver medication report. If FMCSA requests these forms, they are uploaded in portable document format (PDF) to the Medical Examiner's account associated with the National Registry of Certified Medical Examiners for FMCSA to access.
In contrast to FMCSA's regulations, part 40 does not require entities or individuals to submit documents directly to the Department except for MIS aggregate drug and alcohol testing data that employers subject to DOT or U.S. Coast Guard (USCG) drug and alcohol testing regulations must submit annually. Each of the various documents required and used as part of the DOT drug and alcohol testing program under part 40 ( e.g., employee drug and alcohol testing records, MRO reports and records, SAP reports and records) are documents that are created by, exchanged between, and maintained by a person or entity involved in the testing process—but are not required to be submitted directly to DOT.
As noted earlier, and specifically with respect to the required MIS data, we standardized the form for employers to report their aggregate drug and alcohol testing data, as well as the specific data collected, more than 20 years ago. At that time, we authorized employers to submit the ONE-DOT MIS form via a web portal. Today, the Federal Aviation Administration, FMCSA, Federal Railroad Administration, and Federal Transit Administration permit employers to submit that same drug and alcohol testing data via the internet, and PHMSA requires that the data be submitted electronically. If employers submit the data electronically via the internet, they are not required to submit a hard copy. DOT recommends that employers have a copy of their data available (either hard copy or in electronic format) in the event an auditor or inspector requests a copy.
From the above, and because the only documents that part 40 requires to be submitted directly to the Department are already permitted to be, and in some cases required to be, submitted electronically, there is no need for us to limit the applicability of our proposal as FMCSA did in its 2018 final rule.
Several commenters noted that they already use electronic signatures and documents for their non-DOT drug and alcohol testing program, and in some cases, have done so for many years. In doing so, these commenters have had to establish appropriate confidentiality and security measures to ensure that confidential employee records cannot be accessed by unauthorized persons, including protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The same general requirements were added to the current §40.40(c)(5) when we approved the use of the electronic CCF for use in DOT drug testing in 2015, 7 and we propose the same requirements in this NPRM for the use of electronic signatures, documents, and recordkeeping throughout the entirety of part 40.
7 The 2015 revisions amended then §40.45(c)(5), which was redesignated as §40.40(c)(5) in the May 2023 final rule to include oral fluid testing in the DOT drug testing program (88 FR 27596, May 2, 2023).
Ensuring that confidential employee records are not available to unauthorized persons is an important element of part 40's protections for employees that are subject to DOT's drug and alcohol testing rules. We believe that the failure of a service agent to provide or maintain a secure/confidential electronic system should constitute the basis for the Department to start a public interest exclusion (PIE) proceeding, and propose to add this to the list of examples provided in §40.365(b).
Throughout part 40, information and documents are required to be transmitted and/or communicated between service agents ( e.g., collectors, screening test technicians (STTs) and breath alcohol technicians (BATs), laboratories, MROs, SAPs, and consortium/third party administrators (C/TPAs)), employers, and employees). Although part 40 does not currently require the party receiving these communications and/or documents to affirmatively confirm receipt of such from the sender, in some instances, regardless of whether the document is electronic or a hard copy, we believe that it may be important for the receiving party to verify that those required communications and/or documents were received.
For example, under §40.25, an employer intending to use an employee to perform safety-sensitive functions must, after obtaining an employee's written consent, request information about the employee's drug and alcohol testing record from previous DOT-regulated employers. After receiving a copy of the employee's written consent, the previous employer must immediately provide the requested information to the employer making the inquiry. If an employer is subsequently investigated/audited by the appropriate DOT mode, it may be beneficial for both the gaining employer and the previous employer to be able to affirmatively demonstrate that the employee's written consent and previous testing record were sent and received as required.
Sections 40.191(d) and 40.261(c)(1) require a collector or MRO (for drug tests) or a BAT, STT, or a physician evaluating a “shy lung” situation (for alcohol tests), respectively, to—when an employee refuses to participate in a part of the testing process—terminate the testing process, document the refusal, and immediately and directly notify the employer's designated employer representative (DER) by any means that ensures the refusal notification is immediately received. Because this notification of a refusal to an employer is of an urgent nature, it may be advisable to require the DER to affirmatively confirm receipt of the required notification from the collector, MRO, BAT, STT, or physician. For example, §§40.191(d) and 40.261(c)(1) could be amended to read “. . . immediately notify the DER by any means and ensure that the refusal notification is immediately received”.
While we are not proposing new requirements in this NPRM regarding confirmation of receipt in the sections discussed above (or in other part 40 requirements), we seek comment regarding whether it may be beneficial or advisable to do so, and if so, for which specific sections of part 40.
VIII. Electronic ATF
The ATF has been in use in the DOT alcohol testing program since 1994 (see 59 FR 7349, Feb. 15, 1994). The ATF must be used to document every DOT alcohol test. DOT regulations at 49 CFR 40.225 set forth the requirements for use of the form, and 49 CFR part 40, appendix G, contains a facsimile (reference copy) of the form. The ATF is a three-part carbonless manifold form used by DOT-regulated employers to document the testing event when testing employees subject to DOT alcohol testing. When the employee is tested, both the employee and the STT and/or the BAT will complete the ATF in various sections. The STT/BAT documents the result(s) by either writing in the screening result or attaching the screening and/or confirmation result printed by the evidential breath testing devices (EBT) onto the ATF, and then sends Copy 1 to the employer, provides Copy 2 to the employee, and retains Copy 3 for their records.
On April 2, 2020, DISA petitioned the Department to amend part 40 to allow for the use of an electronic version of the ATF for DOT mandated alcohol testing. In support of its petition, DISA stated that “The requested amendment to 49 CFR part 40 will enable a parallel process for the documentation of DOT-mandated alcohol tests aligned with the similarly situated amendment previously approved for drug testing.” DISA believes that allowing the use of an electronic ATF will result in several benefits to the industry, including “increased efficiency, security and accuracy in documentation of DOT alcohol tests; paperwork reduction; improved process for conducting a DOT alcohol test in conjunction with a DOT drug test when an electronic version of the federal CCF is used for the drug test; reduction of errors and omissions in the completion of the ATF; and improved efficiency and efficacy in the transmission and record retention of alcohol test results.”
DISA noted that non-DOT workplace breath alcohol testing has been conducted using electronic versions of an alcohol testing form that mirrors the DOT ATF for more than five years. Based on experience using those electronic forms for non-DOT testing, DISA cites improved efficiency and accuracy of documentation because: (1) employer and employee information is entered via computer and thus not dependent on reading and deciphering hand-written entries, (2) date time stamps of the testing are automated and not subject to fluctuation or error, (3) transmission of documentation on completed tests is more secure using databases accessed only via protected password and personal identification number (PIN) to authorized employers or their designated agents, and (4) transmission of test result information is faster and more secure than existing transmission options of scanning and emailing attachments or facsimile.
DISA also noted that permitting use of an electronic ATF for DOT-regulated alcohol testing “will substantially reduce cost, by eliminating the requirement for the printing and distribution of carbonless three-ply paper ATFs. The proposed electronic ATF option would still provide for printed paper images to be made available to the employee, the employer, and the alcohol technician, [but] eliminates the requirement for the more expensive carbonless 3 ply paper ATF.”
For the reasons described by DISA in its petition, and recognizing that significant benefits and cost reductions have resulted from use of the electronic CCF for drug testing, we believe that it is likewise appropriate to permit the use of electronic ATFs in part 40 for DOT-regulated testing. Permitting but not requiring the use of an electronic ATF would be consistent with our proposal to permit, but not require, the use of electronic documents and signatures throughout the entirety of part 40 as discussed above. As several commenters noted, the use of an electronic ATF has been used in non-DOT testing for 5-10 years, and the same developers of the electronic CCFs have developed the electronic ATFs. Any electronic ATF used under part 40 for DOT-regulated employees would have to be identical in form and content to the DOT ATF in appendix I to part 40. 8 Just as we imposed general confidentiality and security requirements when electronic CCFs were permitted to be used under part 40, we believe that it is necessary to include the same general requirements relating to the use of electronic ATFs to ensure that confidential employee records cannot be accessed by unauthorized persons.
8 The ATF form was redesignated from appendix G to appendix I as part of the rulemaking process culminating in the May 2023 final rule. During that process, the form was reviewed by the public and DOT received no comment on the form.
Manufacturers of EBTs and alcohol screening devices (ASD) used in DOT alcohol tests must obtain approval from the National Highway Traffic Safety Administration (NHTSA) and then be listed on the Office of Drug and Alcohol Policy and Compliance's (ODAPC) website before those devices may be used in DOT alcohol testing.
IX. PHMSA Proposed Changes
PHMSA is proposing to amend §§199.3, 199.117, and 199.227 and to add §199.4 to conform to the proposed changes in part 40 and to clarify that the proposed changes in part 40 apply to part 199. These changes will help the readers of part 199 find the applicable regulations in part 40 with regards to the definition of terms and record keeping requirements. We also propose to amend §§199.119 and 199.229 by changing the reference of “appendix H” to “appendix J” to conform to the amendment of part 40 published on May 2, 2023.
X. Section-by-Section Analysis
Section 40.3 What do the terms used in this regulation mean?
We propose to add a definition of “electronic signature.” The rule would define an electronic signature as a method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 44 U.S.C. 3504 note, 112 Stat. 2681-749). Including the specific cross reference to GPEA would ensure that regulated entities know that we are using GPEA's performance standard for allowing use of electronic signatures.
We propose to add a definition of “written or in writing.” The rule would define written or in writing as printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of 49 CFR 40.4. This definition would eliminate any distinction between paper and electronic methods of communication/documentation.
Section 40.4 May electronic documents and signatures be used?
We propose to add a new §40.4 that would prescribe the requirements pertaining to electronic documents and signatures throughout part 40.
Paragraph (a) would specify that §40.4 would apply to all documents required by part 40, except for the CCF, as an electronic CCF may only be used when approved by HHS and in compliance with §40.40(c)(5). As background, before an HHS-certified laboratory can use a Federal electronic CCF for regulated specimens, the test facility must submit a detailed plan and proposed standard operating procedures for the electronic CCF system for HHS review and approval through the National Laboratory Certification Program. At the current time, several HHS-certified laboratories have received approval to use a combination electronic/paper CCF, while four laboratories have received approval to use a fully electronic CCF. As noted earlier, and in a separate section of the SUPPORT Act, HHS was required to set a deadline for certified laboratories to request approval for use of fully electronic CCFs. That deadline is now August 31, 2026.
Paragraph (b) would permit, but not require, any person or entity to use electronic methods to comply with any provision in part 40 that requires a document to be signed, certified, generated, maintained, or transmitted between parties. It would apply to all forms of written documentation, including forms, records, notations, and other documents. The substance of the document would otherwise have to comply with part 40 requirements. This would establish parity between paper and electronic documents and signatures, greatly expanding interested parties' ability to use electronic methods to comply with the requirements of part 40.
Paragraph (c) would permit, but not require, any entity required to sign or certify a document to do so using electronic signatures as defined in §40.3. The rule specifies that a person may use any available technology so long as the signature otherwise complies with the requirements of part 40.
Paragraph (d) would establish the minimum requirements for electronic documents and signatures. Any electronic document or signature would be considered the legal equivalent of a paper document or signature if it is the functional equivalent with respect to integrity, accuracy, and accessibility. In other words, the electronic documents or signatures need to accurately and reliably reflect the information in the record. They must remain accessible in a form that could be accurately viewed or reproduced according to Agency rules. As with any documents, paper or electronic, documents that are not legible—for any reason—do not satisfy the Department's requirements.
Electronic documents are not to be considered the legal equivalent of traditional paper documents if they (1) are not capable of being retained, (2) are not used for the purpose for which they were created, or (3) cannot be accurately reproduced for reference by any entity entitled to access by law, for the period of time required by the Department's recordkeeping requirements.
Paragraph (d) would also require that any electronically signed documents must incorporate or otherwise include evidence that both parties to the document have consented to the use of electronic signatures, as required by the E-SIGN Act (15 U.S.C. 7001(c)).
Paragraph (e) would require that when using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records cannot be accessed by unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The proposed requirements are analogous to those established in the current §40.40(c)(5) when we approved use of the electronic CCF in part 40.
Section 40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?
Currently, paragraph (g) makes it clear that the release of information under this section must be in any written form, and the parenthetical clarifies that this can be paper-based (written, fax) or electronic (email). Under the proposed definition of “written or in writing,” there is no distinction between paper-based and electronic communications. Because “written or in writing” would mean either paper or electronic communications, we propose to remove parenthetical reference to “fax, email, letter” to eliminate redundancy and confusion. All parties can conduct their business using either paper or electronic means of documentation and communication.
Section 40.79 How is the collection process completed?
Currently, paragraph (a)(9) of this section requires the collector to “fax or otherwise transmit” Copy 2 of the CCF to the MRO and Copy 4 to the DER within 24 hours or during the next business day. We propose to amend this section by removing reference to the methods of transmitting receipts, so parties can choose their own medium of communication.
Section 40.97 What do laboratories report and how do they report it?
For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraphs (c)(1) and (2) of this section.
Section 40.111 When and how must a laboratory disclose statistical summaries and other information it maintains?
For the same reasons explained in the discussion of §40.79, we propose to amend paragraph (b) of this section to remove the references to the methods of transmitting the summary or report required by this section. Because the summary or report can be transmitted via hard copy or electronically, there is no need to specify how it must be transmitted. As such, we propose to amend the title of this section accordingly.
Section 40.127 What are the MRO's functions in reviewing negative test results?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (c)(2) of this section.
Section 40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative test results?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (b)(2) of this section.
Section 40.163 How does the MRO report drug test results?
For the same reasons explained in the discussion of §40.25, we propose to remove the reference to a “letter” in paragraph (c) of this section. In paragraph (e) of this section, we propose to replace the term “letter” with “written report” for consistency with paragraph (c).
Section 40.167 How are MRO reports of drug results transmitted to the employer?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (c)(1) of this section.
Section 40.185 Through what methods and to whom must a laboratory report split specimen results?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (b) of this section. In addition, because Copy 1 of the CCF can be transmitted in writing or electronically, there is no need to specify the methods through which it must be transmitted. As such, we propose to amend the title of this section accordingly.
Section 40.187 What does the MRO do with split specimen laboratory results?
For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraph (c)(2)(iv)(C) of this section.
Section 40.191 What is a refusal to take a DOT drug test, and what are the consequences?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (d) of this section as means of transmitting notification that an employee has refused to participate in part of the testing process from the collector or MRO to the DER.
Section 40.193 What happens when an employee does not provide a sufficient amount of urine for a drug test?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “send or fax” as the means for the collector to transmit copies of the CCF to the MRO and the DER in paragraph (b)(3) of this section.
Section 40.205 How are drug test problems corrected?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a collector, laboratory, MRO, employer, or other person to supply signed statements regarding correctable problems in a drug test in paragraphs (b)(1) and (2) of this section.
Section 40.225 What form is used for an alcohol test?
We propose to amend this section to permit, but not require, the use of an electronic version of the DOT ATF that is identical in form and content to the form provided in appendix I to part 40. The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT, and if an EBT provides a separate printout of confirmation test results pursuant to §40.253(g), the electronic ATF must include that separate printout. This section would also be amended to specify the same general confidentiality and security measures in §40.45 relating to electronic CCFs to ensure that confidential employee records cannot be accessed by unauthorized persons.
Section 40.255 What happens next after the alcohol confirmation test result?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (a)(5)(i) of this section as means of transmitting results of the alcohol confirmation test from the BAT to the DER. Similarly, there is no need to specify that Copy 1 of the ATF may be transmitted “in person, by telephone, or by electronic means.”
Section 40.261 What is a refusal to take an alcohol test, and what are the consequences?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (c) of this section as means of transmitting a refusal notification from a BAT, STT, or referral physician to the DER.
Section 40.271 How are alcohol testing problems corrected?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a STT, BAT, employer, or other service agent to supply a signed statement regarding correctable flaws in an alcohol test in paragraph (b)(2) of this section.
Section 40.365 What is the Department's policy concerning starting a PIE proceeding?
We propose to amend this section by adding a new paragraph (b)(15) that would identify the failure of a service agent to provide or maintain a secure/confidential electronic system as appropriate grounds for starting a PIE proceeding.
X. Regulatory Analyses and Notices
Executive Orders 12866, 13563, and 14094 (Regulatory Planning and Review)
The Secretary has examined the impact of the proposed part 40 amendments under Executive Order 12866 (“Regulatory Planning and Review”), as supplemented by Executive Order 13563 (“Improving Regulation and Regulatory Review”) and amended by Executive Order 14094 (“Modernizing Regulatory Review”), which directs Federal agencies to assess all costs and benefits of available regulatory alternatives and, when regulation is necessary, to select regulatory approaches that maximize net benefits (including potential economic, environmental, public health and safety, and other advantages; distributive impacts; and equity).
According to these Executive orders, a regulatory action is “significant” if it meets any one of a number of specified conditions, including having an annual effect on the economy of $200 million or more, as adjusted every three years by the Office of Information and Regulatory Affairs (OIRA); adversely affecting in a material way a sector of the economy, competition, or jobs; or if it raises novel legal or policy issues. The proposed amendments, which would allow the use of electronic documents and signatures, do not meet the Executive order's criteria for being a significant rule. Consequently, OMB has determined that the rulemaking action is not significant under the Executive order.
The proposed rule responds to the statutory mandate set forth in Section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271. The proposed rule would not impose new requirements on the industry; rather, it would simply permit—but not require—regulated entities to use electronic signatures, forms, and recordkeeping, and remove outdated and obsolete references in the regulatory text. The proposed rule would not impose new costs on the industry because regulated entities would be allowed to choose to continue to use paper-based documents as they had before. The benefits of the rule would stem from savings in paper and printing expense and other efficiency gains. Examples of documents affected by this rule include, but are not limited to, records of a prospective employee's drug and alcohol testing history that employers must obtain prior to permitting that employee to perform safety-sensitive duties, MRO records and reports, SAP records and reports, and ATFs. While there is no way to estimate how many entities or individuals would change their practices given the new options, or how many documents would be affected, several commenters to the ANPRM stated that they have been using electronic documents and signatures in their non-DOT drug and alcohol testing programs for many years. While neither the benefits nor the costs of this rule can be reliably estimated, we expect this proposed rule to provide flexibility to the industry. Under this proposed rule, regulated entities would have the flexibility to conduct business using either electronic or traditional paper-based methods. We also expect regulated entities to choose technologies that would maximize benefits in accordance with their individual needs and circumstances.
Regulatory Flexibility Act and Small Business Regulatory Enforcement Fairness Act (SBREFA)
The Regulatory Flexibility Act of 1980 (5 U.S.C. 601 et seq. ) requires Federal agencies to consider the effects of their regulatory actions on small businesses and other small entities and minimize any significant economic impact. The term “small entities” comprises small businesses and not-for-profit organizations that are independently owned and operated and are not dominant in their fields, and governmental jurisdictions with a population of less than 50,000. For this rulemaking, potentially affected small entities include drug testing companies (U.S. Small Business Administration (SBA) North American Industry Classification System (NAICS) Sector 54 (Professional, Scientific and Technical Services), Code 541380 (Testing Laboratories and Services)) as well as DOT-regulated entities (SBA NAICS Sectors 48-49 (Transportation and Warehousing)).
The Department does not expect that the proposed rule would have a significant economic impact on a substantial number of small entities. The proposed rule, if adopted, would increase flexibility for all small-entity transportation employers and their service agents by allowing them to use electronic documents, signatures, and recordkeeping to meet part 40 requirements. Use of electronic documents, electronic signatures, and electronic recordkeeping would be voluntary for affected small entities, which will provide added flexibility to these entities in meeting the part 40 requirements. For these reasons, and as explained in more detail in the preamble to this proposed rule, the Secretary certifies that the proposed rule would not have a significant economic impact on a substantial number of small entities within the meaning of the Regulatory Flexibility Act. Consequently, an initial regulatory flexibility analysis is not required for this proposed rule.
Unfunded Mandates
The Secretary has examined the impact of the final rule under the Unfunded Mandates Reform Act (UMRA) of 1995 (Pub. L. 104-4). This NPRM does not trigger the requirement for a written statement under sec. 202(a) of the UMRA because this rulemaking does not impose a mandate that results in an expenditure of $100 million (adjusted annually for inflation) or more by either State, local, and tribal governments in the aggregate or by the private sector in any one year. In fact, by providing an alternative to traditional paper-based records, the proposed rule would be expected to reduce costs to regulated parties, including State and local entities ( e.g., public transit authorities, and public works departments) whose employees are subject to testing and that choose to use electronic documents as opposed to paper-based documents.
Environmental Impact
The DOT has analyzed the environmental impacts of this action pursuant to the National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321 et seq. ) and has determined that it is categorically excluded pursuant to DOT Order 5610.1C, “Procedures for Considering Environmental Impacts” (44 FR 56420, October 1, 1979). Categorical exclusions are actions identified in an agency's NEPA implementing procedures that do not normally have a significant impact on the environment and therefore do not require either an environmental assessment (EA) or environmental impact statement (EIS). This proposed rule would amend the transportation industry drug testing program procedures regulation to permit the use of electronic documents, signatures, and recordkeeping. This action is covered by the categorical exclusion listed at 23 CFR 771.118(c)(4), “[p]lanning and administrative activities that do not involve or lead directly to construction, such as: . . . promulgation of rules, regulations, directives . . .” The Department does not anticipate any environmental impacts, and there are no extraordinary circumstances present in connection with this rulemaking.
Executive Order 13132: Federalism
The Secretary has analyzed the final rule in accordance with Executive Order 13132: Federalism. Executive Order 13132 requires Federal agencies to carefully examine actions to determine if they contain policies that have federalism implications or that preempt State law. As defined in the order, “policies that have federalism implications” refer to regulations, legislative comments or proposed legislation, and other policy statements or actions that have substantial direct effects on the States, on the relationship between the National Government and the States, or on the distribution of power and responsibilities among the various levels of government.
Most of the regulated parties under the Department's drug testing program are private entities. Some regulated entities are public entities ( e.g., transit authorities and public works departments); however, as noted above, this proposal would reduce costs of the Department's drug testing program and provide additional flexibility for regulated parties. Accordingly, the Secretary has determined that the proposed rule, which would allow but not require use of electronic signatures and recordkeeping, does not contain policies that have federalism implications.
Executive Order 13175: Consultation and Coordination With Indian Tribal Governments
Executive Order 13175 (65 FR 67249, November 6, 2000) requires Federal agencies to develop an accountable process to ensure “meaningful and timely input by tribal officials in the development of regulatory policies that have tribal implications.” “Policies that have tribal implications” as defined in the Executive order, include regulations that have “substantial direct effects on one or more Indian tribes, on the relationship between the Federal government and the Indian tribes, or on the distribution of power and responsibilities between the Federal government and Indian tribes.” This proposed rule does not have tribal implications. The proposed rule will also not have substantial direct effects on tribal governments, on the relationship between the Federal Government and Indian tribes, or on the distribution of power and responsibilities between the Federal Government and Indian tribes, as specified in Executive Order 13175.
Paperwork Reduction Act
The Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520) (PRA) requires that DOT consider the impact of paperwork and other information collection burdens imposed on the public. This proposed rule would call for no new collection of information under the PRA. Instead, there would likely be a significant reduction in the burden hours required for information collection 2105-0529, Procedures for Transportation Drug and Alcohol Testing Program, due to the ability to use electronic signatures and forms, and largely due to the ability to use an electronic ATF for DOT-regulated alcohol testing under part 40. We request comments on this issue. Notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information subject to the PRA that does not display a currently valid OMB control number.
Privacy Act
Anyone is able to search the electronic form of all comments received in any of our dockets by the name of the individual submitting the comment (or signing the comment, if submitted on behalf of an association, business, labor union, etc.) For information on DOT's compliance with the Privacy Act, please visit https://www.transportation.gov/privacy.
5 U.S.C. 553(b)(4)
As required by 5 U.S.C. 553(b)(4), a summary of this proposed rule can be found at the entry for RIN 2105-AF01 in the Department's Portion of the Unified Agenda of Regulatory and Deregulatory Affairs, available at https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202404&RIN=2105-AF01 .
Pay-As-You-Go Act of 2023
In accordance with Compliance with Pay-As-You-Go Act of 2023 (Fiscal Responsibility Act of 2023, Pub. L. 118-5, div. B, title III) and OMB Memorandum (M-23-21) dated September 1, 2023, the Department has determined that this proposed rule is not subject to the Pay-As-You-Go Act of 2023 because it will not increase direct spending beyond specified thresholds.
List of Subjects
49 CFR Part 40
Administrative practice and procedures, Alcohol abuse, Alcohol testing, Drug abuse, Drug testing, Laboratories, Reporting and recordkeeping requirements, Safety, Transportation.
49 CFR Part 199
Alcohol testing, Drug testing, Pipeline safety, Reporting and recordkeeping requirements, Safety, Transportation.
For the reasons stated in the preamble, the Department proposes to amend 49 CFR parts 40 and 199 as follows:
PART 40—PROCEDURES FOR TRANSPORTATION WORKPLACE DRUG AND ALCOHOL TESTING PROGRAMS
1. The authority for part 40 continues to read as follows:
Authority:
49 U.S.C. 102, 301, 322, 5331, 20140, 31306, and 54101 et seq.
2. In §40.3, add the definitions of “Electronic signature” and “Written or in writing” in alphabetical order to read as follows:
§40.3 What do the terms used in this part mean?
* * * * *
Electronic signature. A method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 112 Stat. 2681-749, 44 U.S.C. 3504 note).
* * * * *
Written or in writing. Printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of §40.4.
3. Add §40.4 to read as follows:
§40.4 May electronic documents and signatures be used?
(a) Applicability. This section applies to all documents required by this part, except for the CCF. An electronic CCF may be used only if it has been approved for use by the Department of Health and Human Services and is used in compliance with §40.40(c)(5).
(b) Electronic records or documents. Any person or entity required to generate, maintain, or exchange and/or transmit documents to satisfy requirements in this part may use electronic methods to satisfy those requirements.
(c) Electronic signatures. (1) Any person or entity required to sign or certify a document to satisfy the requirements of this part may use an electronic signature, as defined in §40.3.
(2) Any available technology may be used that satisfies the requirements of an electronic signature as defined in §40.3.
(d) Electronic document requirements. Any person or entity may use documents signed, certified, generated, maintained, or exchanged using electronic methods, as long as the documents accurately reflect the information otherwise required to be contained in them.
(1) Records, documents, or signatures generated, maintained, or exchanged using electronic methods satisfy the requirements of this section if they are capable of being retained, are used for the purpose for which they were created, and can be accurately reproduced within required timeframes for reference by any party entitled to access.
(2) Records or documents generated electronically satisfy the requirements of this section if they include proof of consent to use electronically generated records or documents, as required by 15 U.S.C. 7001(c).
(e) Confidentiality and security. When using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form to include protecting against destruction, deterioration, and data corruption.
4. In §40.25, revise paragraph (g) to read as follows:
§40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?
* * * * *
(g) The release of information under this section must be in any written form that ensures confidentiality. As the previous employer, you must maintain a written record of the information released, including the date, the party to whom it was released, and a summary of the information provided.
* * * * *
5. In §40.79, revise paragraph (a)(9) to read as follows:
§40.79 How is the collection process completed?
(a) * * *
(9) Send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or during the next business day. Keep Copy 3 for at least 30 days, unless otherwise specified by applicable DOT agency regulations.
* * * * *
6. In §40.97, revise paragraphs (c) introductory text, (c)(1) introductory text, and (c)(2) to read as follows:
§40. 97 What do laboratories report and how do they report it?
* * * * *
(c) As a laboratory, you must report laboratory results directly, and only, to the MRO at his or her place of business. You must not report results to or through the DER or a service agent ( e.g., C/TPA).
(1) Negative results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF which has been signed by the certifying scientist, or you may provide the laboratory results report electronically.
* * * * *
(2) Non-negative and rejected for testing results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF that has been signed by the certifying scientist. In addition, you may provide the laboratory results report following the format and procedures set forth in paragraphs (c)(1)(i) and (ii) of this section.
* * * * *
7. In §40.111, revise the section heading and paragraph (b) to read as follows:
§40.111 When must a laboratory disclose statistical summaries and other information it maintains?
* * * * *
(b) When the employer requests a summary in response to an inspection, audit, or review by a DOT agency, you must provide it unless the employer had fewer than five aggregate test results. In that case, you must send the employer a report indicating that not enough testing was conducted to warrant a summary.
* * * * *
8. In §40.127, revise paragraph (c)(2) to read as follows:
§40.127 What are the MRO's functions in reviewing negative test results?
* * * * *
(c) * * *
(2) A legible copy of Copy 1 of the CCF or the electronic laboratory results report that conveys the negative laboratory test result.
* * * * *
9. In §40.129, revise paragraphs (b) introductory text and (b)(2) to read as follows:
§40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative drug test results?
* * * * *
(b) Before you report a verified negative, positive, test cancelled, refusal to test because of adulteration or substitution, you must have in your possession the following documents:
* * * * *
(2) A legible copy of Copy 1 of the CCF, containing the certifying scientist's signature.
* * * * *
10. In §40.163, revise paragraphs (c) introductory text and (e) to read as follows:
§40.163 How does the MRO report drug test results?
* * * * *
(c) If you do not report test results using Copy 2 of the CCF for the purposes of this section, you must provide a written report for each test result. This report must, as a minimum, include the following information:
* * * * *
(e) You must retain a signed or stamped and dated copy of Copy 2 of the CCF in your records. If you do not use Copy 2 for reporting results, you must maintain a copy of the signed or stamped and dated written report in addition to the signed or stamped and dated Copy 2. If you use the electronic data file to report negatives, you must maintain a retrievable copy of that report in a format suitable for inspection and auditing by a DOT representative.
* * * * *
11. In §40.167, revise paragraph (c)(1) to read as follows:
§40.167 How are MRO reports of drug test results transmitted to the employer?
* * * * *
(c) * * *
(1) You must transmit a legible image or copy of either the signed or stamped and dated Copy 2 or the written report (see §40.163(b) and (c)).
* * * * *
12. In §40.185, revise the section heading and paragraph (b) to read as follows:
§40.185 What and to whom must a laboratory report split specimen results?
* * * * *
(b) You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF, which has been signed by the certifying scientist.
* * * * *
13. In §40.187, revise paragraph (c)(2)(iv)(C) to read as follows:
§40.187 What does the MRO do with split specimen laboratory results?
* * * * *
(c) * * *
(2) * * *
(iv) * * *
(C) As the laboratory that tests the primary specimen to reconfirm the presence of the adulterant found in the split specimen and/or to determine that the primary specimen meets appropriate substitution criteria, report your result to the MRO using a copy of Copy 1 of the CCF.
* * * * *
14. In §40.191, revise paragraph (d) introductory text to read as follows:
§40.191 What is a refusal to take a DOT drug test, and what are the consequences?
* * * * *
(d) As a collector or an MRO, when an employee refuses to participate in the part of the testing process in which you are involved, you must terminate the portion of the testing process in which you are involved, document the refusal on the CCF (including, in the case of the collector, printing the employee's name on Copy 2 of the CCF), immediately notify the DER by any means that ensures that the refusal notification is immediately received. As a referral physician ( e.g., physician evaluating a “shy bladder” condition or a claim of a legitimate medical explanation in a validity testing situation), you must notify the MRO, who in turn will notify the DER.
* * * * *
15. In §40.193, revise paragraph (b)(3) to read as follows:
§40.193 What happens when an employee does not provide a sufficient amount of specimen for a drug test?
* * * * *
(b) * * *
(3) As the collector, you must send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or the next business day.
* * * * *
16. In §40.205, revise paragraphs (b)(1) and (2) to read as follows:
§40.205 How are drug test problems corrected?
* * * * *
(b) * * *
(1) If the problem resulted from the omission of required information, you must, as the person responsible for providing that information, supply in writing the missing information and a statement that it is true and accurate. For example, suppose you are a collector, and you forgot to make a notation on the “Remarks” line of the CCF that the employee did not sign the certification. You would, when the problem is called to your attention, supply a signed statement that the employee failed or refused to sign the certification and that your statement is true and accurate. You must supply this information on the same business day on which you are notified of the problem.
(2) If the problem is the use of a non-Federal form or an expired Federal form, you must provide a signed statement ( i.e., a memorandum for the record). It must state that the incorrect form contains all the information needed for a valid DOT drug test, and that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control. The statement must also list the steps you have taken to prevent future use of non-Federal forms or expired Federal forms for DOT tests. For this flaw to be corrected, the test of the specimen must have occurred at an HHS-certified laboratory where it was tested consistent with the requirements of this part. You must supply this information on the same business day on which you are notified of the problem.
* * * * *
17. In §40.225, revise paragraph (a) and add paragraphs (d) and (e) to read as follows:
§40.225 What form is used for an alcohol test?
(a) The DOT Alcohol Testing Form (ATF) must be used for every DOT alcohol test. The ATF must be a three-part carbonless manifold form or an electronic ATF that meets the requirements of paragraph (d) of this section. The ATF is found in appendix G to this part. You may view this form on the ODAPC website ( https://www.transportation.gov/odapc ).
* * * * *
(d) As an employer, you may use an electronic ATF that meets the following requirements:
(1) The electronic ATF must be identical in form and content to the ATF found in appendix G to this part.
(2) The electronic ATF must meet the requirements of §40.4(d).
(3) The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT.
(4) If an EBT provides a separate printout of confirmation test results (see §40.253(g)), the electronic ATF must include that separate printout.
(e) As an employer, BAT, or STT using an electronic ATF, you must establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form.
18. In §40.255, revise paragraph (a)(5)(i) to read as follows:
§40.255 What happens next after the alcohol confirmation test result?
(a) * * *
(5) * * *
(i) You may transmit the results using Copy 1 of the ATF, in person, by telephone, or by electronic means. In any case, you must immediately notify the DER of any result of 0.02 or greater by any means that ensures the result is immediately received by the DER. You must not transmit these results through C/TPAs or other service agents.
* * * * *
19. In §40.261, revise paragraph (c)(1) to read as follows:
§40.261 What is a refusal to take an alcohol test, and what are the consequences?
* * * * *
(c)(1) As a BAT or an STT, or as the physician evaluating a “shy lung” situation, when an employee refuses to test as provided in paragraph (a) of this section, you must terminate the portion of the testing process in which you are involved, document the refusal on the ATF (or in a separate document which you cause to be attached to the form), immediately notify the DER by any means that ensures the refusal notification is immediately received. You must make this notification directly to the DER (not using a C/TPA as an intermediary).
* * * * *
20. In §40.271, revise paragraph (b)(2) to read as follows:
§40.271 How are alcohol testing problems corrected?
* * * * *
(b) * * *
(2) If the problem is the use of a non-DOT form, you must, as the person responsible for the use of the incorrect form, certify in writing that the incorrect form contains all the information needed for a valid DOT alcohol test. You must also provide a signed statement that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control, and the steps you have taken to prevent future use of non-DOT forms for DOT tests. You must supply this information on the same business day on which you are notified of the problem.
* * * * *
21. In §40.365, revise paragraphs (b)(13) and (14) and add paragraph (b)(15) to read as follows:
§40.365 What is the Department's policy concerning starting a PIE proceeding?
* * * * *
(b) * * *
(13) For any service agent, directing or recommending that an employer fail or refuse to implement any provision of this part;
(14) With respect to noncompliance with a DOT agency regulation, conduct that affects important provisions of Department-wide concern ( e.g., failure to properly conduct the selection process for random testing); or
(15) For a service agent, failing to provide or maintain a secure/confidential electronic system. PART 199—DRUG AND ALCOHOL TESTING
22. The authority citation for part 199 continues to read as follows:
Authority:
49 U.S.C. 5103, 60102, 60104, 60108, 60117, and 60118; 49 CFR 1.53.
23. In §199.3:
a. Designate the introductory text as paragraph (b); and
b. Add paragraph (a).
The addition reads as follows:
§199.3 Definitions.
(a) Terms used in this part have the same meaning as in 49 CFR 40.3.
* * * * *
24. Add §199.4 to read as follows:
§199.4 Electronic documents, records, and signatures.
Electronic documents, records, and signatures may be used to comply with this part provided they meet the requirements specified in 49 CFR part 40.
25. In §199.117, revise paragraph (a) introductory text to read as follows:
§199.117 Recordkeeping.
(a) Each operator shall keep the records in paragraphs (a)(1) through (5) of this section for the periods specified by this section or for the periods specified by 49 CFR part 40, whichever is greater; and will permit access to the records as provided by §190.203.
* * * * *
26. In §199.119, revise paragraph (a) to read as follows:
§199.119 Reporting of anti-drug testing results.
(a) Each large operator (having more than 50 covered employees) must submit an annual Management Information System (MIS) report to PHMSA of its anti-drug testing using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.
* * * * *
27. In §199.227, revise paragraph (b) introductory text to read as follows:
§199.227 Retention of records.
* * * * *
(b) Period of retention. Each operator shall maintain the records in accordance with the following schedule or for the periods specified by 49 CFR part 40, whichever is greater:
* * * * *
28. In §199.229, revise paragraph (a) to read as follows:
§199.229 Reporting of alcohol testing results.
(a) Each large operator (having more than 50 covered employees) must submit an annual MIS report to PHMSA of its alcohol testing results using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.
* * * * *
Signed on: Thursday, October 3, 2024.
Pete Buttigieg,
Secretary of Transportation.
[FR Doc. 2024-23427 Filed 10-11-24; 8:45 am]
BILLING CODE 4910-9X-P
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Most Recent Highlights In Environmental
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2026-06-15T05:00:00Z
Hazardous waste manifest S Codes: What storage and transfer facilities need to know
Have you cracked the “S Code” yet? Starting in 2027, facilities that receive regulated waste for temporary storage and disposal must use S Codes on hazardous waste manifests. If your facility hasn’t made the switch, now’s the time!
Under the Resource Conservation and Recovery Act (RCRA), the Environmental Protection Agency (EPA) requires hazardous waste handlers to track shipments of regulated waste from the generating facility to final treatment, recycling, or disposal. Management Method Codes are key to hazardous waste manifests, and they also affect biennial reporting. The codes answer the vital question, “How’s the hazardous waste managed?"
Effective January 1, 2027, “S Codes” will officially replace Management MethodH141 for Storage and Transfer. EPA adopted these codes to improve the accuracy and transparency of waste tracking, specifically for wastes that travel through transfer facilities before final management. Use this overview to help your facility understand how to comply.
What are S Codes?
In January 2025, EPA added S Codes to the list of Management Method Codes, which identify the type of waste management system used to treat, recover, or dispose of a hazardous waste. Management Method Codes are used for:
- The Uniform Hazardous Waste Manifest (EPA Form 8700-22) and Continuation Sheet (EPA Form 8700-22A); and
- The National Biennial RCRA Hazardous Waste Report (EPA Form 8700-13 A/B), known as the Biennial Report.
S Codes apply to receiving facilities (primarily treatment, storage, and disposal facilities (TSDFs)) that temporarily store and then transfer regulated hazardous waste to another receiving facility without treating, recovering, or disposing of the waste. EPA established S Codes to provide more details than code H141 on waste handling activities, improving tracking and transparency. S Codes indicate two things:
- A hazardous waste was received to be stored or transferred; and
- The hazardous waste will be managed later by the final receiving facility using a certain method (i.e., the final management method).
EPA groups S Codes into three categories:
- Transfer off-site for reclamation and recovery,
- Transfer off-site for destruction or treatment prior to disposal, and
- Transfer off-site for disposal.
Each S Code corresponds to a specific final management method. Examples include metals recovery (S010), chemical treatment (S070), and landfilling (S132).
What’s required?
On January 1, 2027, EPA will remove Management Method Code H141 for Storage and Transfer from the e-Manifest and the Biennial Report forms. As a result, hazardous waste handlers must use S Codes instead of code H141 on manifests and the Biennial Report.
S Codes apply to RCRA hazardous waste that’s transferred off-site, impacting:
- Receiving facilities that store and transfer hazardous waste;
- Permitted TSDFs that receive hazardous waste solely for temporary storage and transfer (i.e., it’s the facility’s only management type); and
- Large quantity generators (LQGs) that report wastes shipped to transfer facilities on the Biennial Report.
Hazardous waste manifests
The first receiving TSDF is responsible for choosing and entering the S Codes on manifests. The storage and transfer facility must:
- Identify the S code that best describes how the hazardous waste will be managed by the final receiving facility, and
- Enter the S Code in Item 19 on the manifest and in Item 36 on the continuation sheet (if used).
Generators aren’t responsible for selecting or entering S Codes.
Biennial Reports
LQGs and TSDFs must use S Codes for the Biennial Report on the:
- Waste Generation and Management (GM) Form in Item 3, and
- Waste Received From Off-site (WR) Form in Item F.
LQGs use S Codes on the GM Form for shipments of hazardous waste off-site to a transfer facility for temporary storage and transfer.
TSDFs that receive hazardous waste for temporary storage and transfer off-site use S Codes on the WR Form. These TSDFs must also use Source Code G61 on the GM Form to report shipments of these transferred wastes.
How can facilities prepare?
Help your facility achieve a smooth shift to S Codes by January 1, 2027, with these tips:
- Identify where your facility currently uses code H141.
- Develop a process for transitioning to S Codes exclusively. Consider any changes your facility may need to make to its operations, such as updating software, adjusting procedures, and revising internal guidance documents.
- Train your employees accordingly.
- Set a deadline for making the switch to S Codes. Aim for a date well ahead of January 1, 2027, to give your facility enough time to address any issues that arise.
Key to remember: Starting in 2027, storage and transfer facilities must use S Codes in place of Management Method Code H141 on RCRA hazardous waste manifests and Biennial Reports.
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Hazardous waste manifest S Codes: What storage and transfer facilities need to know
Have you cracked the “S Code” yet? Starting in 2027, facilities that receive regulated waste for temporary storage and disposal must use S Codes on hazardous waste manifests. If your facility hasn’t made the switch, now’s the time!
Under the Resource Conservation and Recovery Act (RCRA), the Environmental Protection Agency (EPA) requires hazardous waste handlers to track shipments of regulated waste from the generating facility to final treatment, recycling, or disposal. Management Method Codes are key to hazardous waste manifests, and they also affect biennial reporting. The codes answer the vital question, “How’s the hazardous waste managed?"
Effective January 1, 2027, “S Codes” will officially replace code H141 for Storage and Transfer. EPA adopted these codes to improve the accuracy and transparency of waste tracking, specifically for wastes that travel through transfer facilities before final management. Use this overview to help your facility understand how to comply.
What are S Codes?
In January 2025, EPA added S Codes to the list of Management Method Codes, which identify the type of waste management system used to treat, recover, or dispose of a hazardous waste. Management Method Codes are used for:
- The Uniform Hazardous Waste Manifest (EPA Form 8700-22) and Continuation Sheet (EPA Form 8700-22A); and
- The National Biennial RCRA Hazardous Waste Report (EPA Form 8700-13 A/B), known as the Biennial Report.
S Codes apply to receiving facilities (primarily treatment, storage, and disposal facilities (TSDFs)) that temporarily store and then transfer regulated hazardous waste to another receiving facility without treating, recovering, or disposing of the waste. EPA established S Codes to provide more details than code H141 on waste handling activities, improving tracking and transparency. S Codes indicate two things:
- A hazardous waste was received to be stored or transferred; and
- The hazardous waste will be managed later by the final receiving facility using a certain method (i.e., the final management method).
EPA groups S Codes into three categories:
- Transfer off-site for reclamation and recovery,
- Transfer off-site for destruction or treatment prior to disposal, and
- Transfer off-site for disposal.
Each S Code corresponds to a specific final management method. Examples of these methods include metals recovery (S010), chemical treatment (S070), and landfilling (S132).
What’s required?
On January 1, 2027, EPA will remove Management Method Code H141 for Storage and Transfer from the e-Manifest and the Biennial Report forms. As a result, hazardous waste handlers must use S Codes instead of code H141 on manifests and the Biennial Report.
S Codes apply to RCRA hazardous waste that’s transferred off-site, impacting:
- Receiving facilities that store and transfer hazardous waste;
- Permitted TSDFs that receive hazardous waste solely for temporary storage and transfer (i.e., it’s the facility’s only management type); and
- Large quantity generators (LQGs) that report wastes shipped to transfer facilities on the Biennial Report.
Hazardous waste manifests
The first receiving TSDF is responsible for choosing and entering the S Codes on manifests. The storage and transfer facility must:
- Identify the S code that best describes how the hazardous waste will be managed by the final receiving facility, and
- Enter the S Code in Item 19 on the manifest and in Item 36 on the continuation sheet (if used).
Generators aren’t responsible for selecting or entering S Codes.
Biennial Reports
LQGs and TSDFs must use S Codes for the Biennial Report on the:
- Waste Generation and Management (GM) Form in Item 3, and
- Waste Received From Off-site (WR) Form in Item F.
LQGs use S Codes on the GM Form for shipments of hazardous waste off-site to a transfer facility for temporary storage and transfer.
TSDFs that receive hazardous waste for temporary storage and transfer off-site use S Codes on the WR Form. These TSDFs must also use Source Code G61 on the GM Form to report shipments of these transferred wastes.
How can facilities prepare?
Help your facility achieve a smooth shift to S Codes by January 1, 2027, with these tips:
- Identify where your facility currently uses code H141.
- Develop a process for transitioning to S Codes exclusively. Consider any changes your facility may need to make to its operations, such as updating software, adjusting procedures, and revising internal guidance documents.
- Train your employees accordingly.
- Set a deadline for making the switch to S Codes. Aim for a date well ahead of January 1, 2027, to give your facility enough time to address any issues that arise.
Key to remember: Starting in 2027, storage and transfer facilities must use S Codes in place of code H141 on RCRA hazardous waste manifests and Biennial Reports.
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EHS Monthly Round Up - May 2026
In this May 2026 roundup video, we’ll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
The first compliance date for the revised HazCom standard took effect May 19. Employers who work with chemical substances that are aerosols, desensitized explosives, or flammable gases should start to see updated safety data sheets and labels. On a related note, OSHA revised its HazCom directive for inspectors. It instructs OSHA officers on how to conduct inspections and issue citations under the standard. However, it also provides chemical manufacturers, importers, distributors, and employers with insight into what officers will be assessing.
OSHA revoked a standard that prohibited open fires and fires in drums or similar containers in marine terminals. The agency stated that since this is no longer typical practice, removing the standard would lessen the compliance burden without compromising worker safety.
OSHA received the backing of an advisory committee as it advances a comprehensive Tree Care Operations proposal. During the Advisory Committee on Construction Safety and Health meeting, the group unanimously voted in favor of moving ahead. This clears the path for OSHA to publish its long-awaited proposal.
Turning to environmental news, EPA extended the submission date for the TSCA Section 8(d) Health and Safety Data Reporting Rule one-time report from May 22, 2026, to May 21, 2027.
EPA published the first round of expiring confidential business information claims for information submitted under TSCA. The list covers claims that expire from June 22 to July 31, 2026. Businesses must submit extension requests to keep the information protected.
EPA postponed the effective compliance date for trichloroethylene users with TSCA Section 6(g) exemptions until pending judicial review is concluded. The agency has yet to establish a new compliance date.
And finally, EPA revised HFC use restrictions for certain subsectors. This applies to entities that are subject to the 2023 Technology Transition Rule requirements. The agency also proposed a rule that would exempt transportation refrigeration units from leak repair requirements regardless of charge size.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
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EHS Monthly Round Up - February 2026
In this Februrary 2026 roundup video, we'll discuss the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
Fatal work injuries fell 4 percent in 2024, largely due to a decline in workplace drug- and alcohol-related overdoses. According to the Bureau of Labor Statistics, overdose fatalities fell from 512 in 2023 to 410 in 2024. Across all types of workplace incidents, there were 5,070 fatal work injuries in 2024, compared to 5,283 in 2023. Transportation incidents continue to be the most frequent type of fatal event, accounting for over 38 percent of all occupational fatalities in 2024.
OSHA is fast-tracking a proposal to remove the 2036 obligation to upgrade fall protection systems on fixed ladders that extend over 24 feet. This follows an industry petition from major chemical and petroleum industry groups, which argue the provision is unjustified, costly, and not supported by the rulemaking record. OSHA frames the upcoming proposed action as deregulatory, allowing employers to update fixed ladders at the end of their service lives. We’ll provide updates as more information becomes available.
As OSHA leans into “deregulatory” actions, lawmakers are moving to pressure the agency to issue “regulatory” rulemaking to protect American workers. The latest legislative wave of bills aims to fill regulatory gaps, tackle emerging hazards, expand OSHA authority, and raise penalties. Topics addressed by these bills include musculoskeletal disorders, heat stress, infectious diseases, wildfire smoke, and workplace violence.
In a recently issued letter of interpretation, OSHA states that a burn injury caused by a personal lithium-ion battery fire is work related if it occurs in the workplace during assigned working hours. The letter details an incident where an employee was burned when their rechargeable lithium-ion batteries for e-cigarettes sparked a fire after coming into contact with a key used for work.
A new report from the Department of Labor Office of Inspector General concludes that OSHA struggles to meet its mission, particularly in high-risk industries like healthcare, construction, and manufacturing. Several pages point to OSHA’s difficulties in effectively enforcing annual injury and illness reporting requirements, reaching the nation’s high-risk worksites for inspection, and addressing workplace violence by regulatory or other action.
Turning to environmental news, EPA extended the deadlines for Facility Evaluation Reports and related requirements for coal combustion residuals facilities. In most instances, the deadlines have been moved one or two years out.
And finally, EPA announced a final rule eliminating the 2009 Endangerment Finding and related greenhouse gas emission requirements for on-highway vehicles and vehicle engines. When the final rule takes effect, manufacturers and importers of new motor vehicles and motor vehicle engines will no longer have to measure, report, certify, or comply with federal greenhouse gas emission standards.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
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EHS Monthly Round Up - March 2026
In this March 2026 roundup video, we'll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
OSHA released an updated Job Safety and Health poster. Employers can use either the revised version or the older one, but the poster must be displayed in a conspicuous place where workers can easily see it.
OSHA recently removed a link from its Data topic webpage that displayed a list of “high-penalty cases” at or over $40,000 since 2015. The agency says it discontinued and removed it in December. The data is frozen and archived elsewhere.
OSHA published two new resources as part of its newly launched Safety Champions Program. The fact sheet provides an overview of how the program works, eligibility criteria, and key benefits. The step-by-step guide helps businesses navigate the core elements of OSHA’s Recommended Practices for Safety and Health Programs.
Several forces are nudging OSHA to address a number of workplace hazards and high-hazard industries. This comes from other agencies, safety organizations, watchdogs, legislative proposals, and persistent injury/fatality data. Among the hazards are combustible dust; first aid; personal protective equipment; and workplace violence. How all this translates into new regulations, guidance, programmed inspections, or other initiatives remains to be seen.
Turning to environmental news, EPA issued a proposed rule to require waste handlers to use electronic manifests to track all RCRA hazardous waste shipments. Stakeholders have until May 4 to comment on the proposal.
On March 10, EPA finalized stronger emission limits for new and existing large municipal waste combustors and made other changes to related standards.
And finally, EPA temporarily extended coverage under the 2021 Multi-Sector General Permit for industrial stormwater discharges until the agency issues a new general permit. The permit expired February 28 and remains in effect for facilities previously covered. EPA won’t take enforcement action against new facilities for unpermitted stormwater discharges if the facilities meet specific conditions.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
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EHS Monthly Round Up - April 2026
In this April 2026 roundup video, we’ll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
OSHA revised its National Emphasis Program on heat-related hazards. Going forward, the agency will prioritize inspections in 55 high-risk industries in indoor and outdoor work settings. The program remains in effect for 5 years from its April 10 effective date.
An OSHA proposed rule seeks to eliminate the November 18, 2036, deadline in the Walking-Working Surfaces standard that would require all fixed ladders extending more than 24 feet above a lower level to be equipped with personal fall arrest systems or ladder safety systems. OSHA also seeks feedback on nine specific questions related to the proposal, with comments due on June 5.
On April 17, OSHA revoked its House Falls in Marine Terminals standard at 1917.41. The agency said that because most cargo has been containerized and is moved by cranes, the standard is no longer necessary to protect employees.
Turning to environmental news, an EPA final rule further delays the submission period for the one-time PFAS report required of manufacturers. It pushes the start of the submission period to either 60 days after the effective date of a future final rule updating the PFAS Reporting Rule or January 31, 2027, whichever comes first.
An EPA final rule makes technical changes to the emission standards established in March 2024 for crude oil and natural gas facilities. The changes take effect June 8.
EPA published the draft 6th Contaminant Candidate List for the next group of contaminants to be considered for regulation under the Safe Drinking Water Act. The proposed list designates microplastics and pharmaceuticals as priority contaminant groups for the first time.
And finally, EPA plans to make significant changes to coal combustion residuals requirements. A proposed rule published April 13 would revise the regulations governing the disposal of coal combustion residuals in landfills and surface impoundments, as well as the beneficial use of coal combustion residuals.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
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EHS Monthly Round Up - January 2026
In this January 2026 roundup video, we'll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
Chemical manufacturers, importers, distributors, and employers will have an extra four months to comply with the provisions of OSHA’s revised Hazard Communication standard. When the rule was revised in 2024, it contained staggered compliance dates for those who classify or use chemical substances and mixtures. The first compliance date is now May 19 rather than January 19 of 2026.
On January 8, OSHA issued further technical corrections to its Hazard Communication final rule. An initial set of corrections was published in October 2024, and OSHA continued to review the standard for errors. The agency said these corrections should reduce confusion during the chemical classification process and prevent errors on labels and safety data sheets.
In 2024, private industry employers reported 2.5 million nonfatal workplace injuries and illnesses, according to the Bureau of Labor Statistics. This is down 3.1 percent from 2023 and largely due to a decrease in respiratory illnesses. The greatest number of cases involving days away from work, job restriction, or transfer were caused by overexertion, repetitive motion, and bodily conditions, followed by contact incidents.
Registration is open for OSHA’s Safety Champions Program, which is designed to help employers develop and implement effective safety and health programs. Participants can work at their own pace through Introductory, Intermediate, and Advanced levels.
Turning to environmental news, on January 9, EPA withdrew its direct final rule on SDS/Tier II reporting tied to OSHA HazCom, before it had a chance to take effect. The direct final rule was published back on November 17, 2025, and was intended to relax the Tier II and safety data sheet reporting requirements and align with OSHA’s HazCom standard. EPA said it plans to write a new rule addressing all public comments.
And finally, EPA published a final rule that changes certain requirements for wastewater discharges from coal-fired steam electric power plants. It applies to the deadlines established by the preceding rule finalized in 2024.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
NewsIndustry NewsIndustry NewsToxic Substances Control Act - EPATSCA ComplianceEnvironmental Protection Agency (EPA)EnvironmentalEnglishPolychlorinated BiphenylsFocus AreaUSA
2026-06-05T05:00:00Z
Agency offers electronic submission of PCB annual reports
The Environmental Protection Agency (EPA) now allows facilities to submit polychlorinated biphenyl (PCB) annual reports electronically through the agency’s Resource Conservation and Recovery Act (RCRA) Info System (RCRAInfo). Facilities may submit reports electronically starting with the upcoming annual report due by July 15, 2026.
Who’s impacted?
EPA’s electronic reporting option applies to PCB commercial storage facilities and PCB disposal facilities (including those that dispose of their own waste and don’t receive or generate manifests) that are:
- Required to submit the PCB Annual Report Form (PCB Annual Report) per 40 CFR 761.180(b)(3), and
- Have a RCRA-issued EPA identification (ID) number.
RCRAInfo doesn’t currently support submissions from PCB facilities with EPA ID numbers issued under the Toxic Substances Control Act (TSCA), but the agency plans to update the system to allow such submissions in the future. Until then, PCB facilities with TSCA-issued EPA IDs must continue submitting the annual report by mail and email.
What are the changes?
Qualifying PCB facilities may now submit the PCB Annual Report (EPA Form 6200-025):
- Electronically through RCRAInfo, or
- By mail and email.
Electronic submissions
Facilities must establish a RCRAInfo Industry Application account to submit PCB Annual Reports electronically. RCRAInfo offers an in-depth user guide for registering as an industry user.
Mail and email
Facilities that submit paper reports must:
- Mail the printed form and any attachments to EPA, and
- Email an electronic copy of the form and any attachments to EPA.
Key to remember: PCB commercial storage and disposal facilities with RCRA-issued EPA ID numbers now have the option to submit the PCB Annual Report electronically.
NewsAir QualityIndustry NewsIndustry NewsAir ProgramsEnvironmental Protection Agency (EPA)Hazardous Air PollutantsCAA ComplianceEnvironmentalFocus AreaEnglishAir ProgramsStationary Emission SourcesUSA
2026-06-03T05:00:00Z
EPA adds new HAPs to hazardous waste combustor requirements
The Environmental Protection Agency (EPA) finalized the residual risk and technology review of the National Emission Standards for Hazardous Air Pollutants (NESHAP) from Hazardous Waste Combustors (HWCs). Most significantly, the final rule:
- Maintains the existing standards;
- Adds requirements for previously unregulated hazardous air pollutants from specific major source HWCs; and
- Establishes work practice standards for periods of startup, shutdown, and malfunction (SSM).
Who’s impacted?
EPA’s final rule applies to major sources subject to the HWC NESHAP at 40 CFR 63 Subpart EEE, including:
- Hazardous waste-burning incinerators,
- Cement kilns,
- Lightweight aggregate kilns,
- Solid fuel-fired boilers,
- Liquid fuel-fired boilers, and
- Hydrochloric acid production furnaces.
What are the changes?
The final rule adds hydrogen fluoride (HF) and hydrogen cyanide (HCN) emission standards for specific sources:
| Major source HWC | New regulation(s) |
|---|---|
| Incinerators |
|
| Cement kilns |
|
| Solid fuel boilers |
|
| Liquid fuel boilers |
|
The final rule also:
- Establishes work practice standards for periods of SSM;
- Requires electronic reporting for specific reports (e.g., compliance progress reports, performance tests, Notifications of Compliance); and
- Makes technical changes.
What’s the compliance timeline?
Existing HWCs must:
- Develop, submit to the regulatory authority for approval, and implement SSM plans and start complying with SSM requirements by November 30, 2026;
- Comply with any applicable HF and HCN emission limits and work practice standards by June 3, 2029; and
- Begin electronic reporting by August 3, 2026.
New HWCs must comply upon startup.
Key to remember: EPA's final rule maintains the existing NESHAP regulations for hazardous waste combustors and establishes emission limits and work practice standards for previously unregulated HAPs.
NewsAir QualityAir ProgramsAir EmissionsChange NoticesChange NoticeColoradoCAA ComplianceEnvironmentalAir PermittingFocus AreaEnglishAir ProgramsStationary Emission Sources
2026-06-03T05:00:00Z
Colorado finalizes emission regulations for priority toxic air contaminants
Effective date: June 14, 2026
This applies to: New, modified, and existing stationary sources of priority toxic air contaminants (PTACs)
Description of change: The Colorado Air Quality Control Commission adopted state-level emission control requirements for PTACs. The rules apply to specific source categories of stationary sources that emit one or more PTAC, including benzene, hexavalent chromium, ethylene oxide (EtO), formaldehyde, and hydrogen sulfide. The commission revised Regulation Numbers 24, 26, and 30.
Regulated sources must reduce emissions by implementing new technologies, adjusting work practices, and using fewer toxic materials. The revisions add regulations for emissions of:
- Benzene from petroleum refineries,
- Formaldehyde from stationary spark-ignition reciprocating internal combustion engines and combustion turbines,
- Hexavalent chromium from decorative and functional chrome plating,
- EtO from sterilization facilities, and
- Hydrogen sulfide from asphalt processing products, roofing products, and manure digesters.
Various requirements for different PTACs and sources start on June 14, 2026.
Related state info: Clean air operating permits state comparison
Most Recent Highlights In Safety & Health
NewsMarylandChange NoticesChange NoticeSustainabilitySustainabilityEnvironmentalProduct StewardshipEnglishSustainabilityFocus Area
2026-06-03T05:00:00Z
Maryland adopts regulations for packaging and paper products
Effective date: May 25, 2026
This applies to: Producers of packaging and paper products (covered materials)
Description of change: Maryland’s Department of the Environment adopted regulations to implement the Packaging and Paper Products — Producer Responsibility Plans Act under the department’s Extended Producer Responsibility program.
The rules establish requirements for producers of covered materials to submit producer responsibility plans and comply with other requirements, such as:
- Annual registration of covered materials,
- Recordkeeping, and
- Reporting.
Producers of covered materials must:
- Pay fees;
- Either:
- Join a Producer Responsibility Organization (PRO) Producer Responsibility Plan;
- Have an approved Individual Producer Responsibility Plan (IPP); or
- Have an approved IPP for a specific covered material and join a PRO plan for other covered materials;
- Register annually with the PRO or department;
- Submit reports to the PRO or department; and
- Comply with recordkeeping requirements.
NewsChange NoticesChange NoticeWater ProgramsIndustrial WastewaterEnvironmentalCWA ComplianceEnglishMichiganFocus Area
2026-06-03T05:00:00Z
Michigan adds requirements to wastewater collection systems
Effective date: April 29, 2026
This applies to: Wastewater collection systems with more than 50 connections and retention treatment basin (RTB) facilities
Description of change: The Michigan Department of Environment, Great Lakes, and Energy amended regulations for wastewater collection systems and RTB facilities by requiring:
- Facility classification, and
- Collection system operators to have system-specific certification (and recertify every 3 years).
The rules also streamline wastewater construction permitting, clarifying requirements for privately owned, publicly used systems when applying for Part 41 Permits.
Related state info: Industrial water permitting — Michigan
NewsWater PermittingChange NoticesChange NoticeWater ProgramsWater QualityIndustrial WastewaterFloridaEnvironmentalWater ProgramsEnglishFocus AreaCWA Compliance
2026-06-03T05:00:00Z
Florida amends on-site sewage treatment and disposal rules
Effective date: June 8, 2026
This applies to: On-site sewage treatment and disposal systems (OSTDS)
Description of change: The Florida Department of Environmental Protection amended the regulatory requirements for OSTDS. In addition to streamlining specific permit application processing procedures, the final rule amends the requirements for:
- Installing and locating OSTDS,
- Abandoning OSTDS,
- Treatment receptacle construction standards,
- Registration requirements for septic tanks and Master Septic Tank Contractors,
- Registration certificate renewals,
- Discipline and penalties for registered persons,
- Certification of partnerships and corporations as septic tank contracting businesses, and
- Service and registration fees.
Related state info: Industrial water permitting — Florida
NewsIndustry NewsIndustry NewsAir ProgramsAir EmissionsEnvironmental Protection Agency (EPA)CAA ComplianceEnvironmentalAir PermittingFocus AreaEnglishAir ProgramsStationary Emission SourcesUSA
2026-06-01T05:00:00Z
EPA restores emergency-related affirmative defense provisions for Title V operating permits
In response to a court mandate, the Environmental Protection Agency (EPA) has rescinded a 2023 final rule that removed emergency-related affirmative defense provisions from the Title V operating permit regulations (the 2023 Affirmative Defense Rule) under the Clean Air Act.
The final rule (published on June 1, 2026) reinstates the emergency-related affirmative defense provisions for state and federal Title V operating permit programs (at 40 CFR 70.6(g) and 71.6(g), respectively).
Who’s impacted?
EPA’s final rule affects stationary sources subject to Title V operating permit requirements.
What does this mean?
The emergency-related affirmative defense provisions establish a framework for regulated facilities to assert an affirmative defense in enforcement proceedings for violations of technology-based emission limits caused by sudden, unavoidable emergencies, provided certain conditions are met.
To rely on the emergency-related affirmative defense, stationary sources must demonstrate that:
- A qualifying emergency occurred,
- The facility was being properly operated,
- The facility took all reasonable actions to limit excess emissions, and
- The facility properly notified the permitting authority.
EPA’s demonstration requirements are listed at 70.6(g)(3)/71.6(g)(3).
What affirmative defense covers
An “emergency,” as defined by 70.6(g)(1)/71.6(g)(1), generally refers to a sudden, unforeseeable event beyond the facility’s control that causes noncompliance with technology-based emission limits established in its Title V operating permit.
What affirmative defense doesn’t cover
The provisions don’t apply to noncompliance due to:
- Improperly designed equipment,
- Lack of preventive maintenance,
- Careless or improper operation, or
- Operator error.
Key to remember: EPA has restored the emergency-related affirmative defense provisions for Title V operating permits, allowing stationary sources to assert a regulatory affirmative defense for certain emission violations caused by events beyond the facility’s control.
NewsIndustry NewsSustainabilityIn-Depth ArticleSustainabilityWaste MinimizationEnvironmentalEnglishSustainabilityFocus AreaUSA
2026-05-29T05:00:00Z
Water reuse: Put your facility’s wastewater to work
Did you know that one entity’s wastewater may be another organization’s treasure? Through water reuse, businesses reclaim municipal and industrial stormwater and wastewater, treat it to make it safe, and repurpose it for beneficial uses.
Reusing water can help companies lower costs, secure a more reliable water supply, and reduce environmental impact. While water reuse is usually voluntary, it must align with federal discharge requirements and state reuse regulations.
The Environmental Protection Agency (EPA) recently launched Water Reuse Action Plan (WRAP) 2.0, an initiative that seeks to advance water reuse in the industrial, technology, and energy sectors. Published in May 2026, Water Reuse Action Plan 2.0: Multiplying Water Benefits, Maximizing American Prosperity provides a comprehensive overview of WRAP 2.0, including specific case studies of how entities have improved operational efficiency by reusing water.
Let’s look at three of these successful water reuse examples and consider factors to help you determine whether water reuse can benefit your business.
Real-world examples of water reuse
Water reuse has been successfully integrated into operations across a range of industries by all types of businesses (from local car washes to national food production companies).
Automobile manufacturing
Painting uses more water than other processes in automobile manufacturing. One major vehicle manufacturer has addressed this through water reuse. At one of its Kentucky assembly plants, the manufacturer started reusing treated wastewater in the paint pretreatment process.
As a result, the assembly plant sends less wastewater to the publicly owned treatment works, uses less freshwater in the manufacturing process, and achieves cost savings by purchasing less water. For instance, during the first year of implementation, the water reuse initiative saved the plant about $50,000.
Stadium operations
A large stadium in Georgia contains a stormwater management system, including a cistern that catches rainwater runoff from the stadium’s roof and plaza structure. The stadium uses this rainwater runoff for exterior landscape irrigation and for make-up water for its cooling towers.
Additionally, nearly all of the plumbing fixtures installed in the stadium are low-flow fixtures, using less water than traditional fixtures.
Similar to the automobile manufacturer, reusing water means that the stadium purchases less water. The stadium’s water reuse efforts have also helped the facility secure a reputation for sustainability.
Refinery processing
A major refinery in California partners with the municipal utility district to reuse recycled water for its boilers.
Boilers require high-purity water, so the utility treats the recycled water with specific technologies (including reverse osmosis) to meet the quality standards. The utility treats the wastewater on-site, supplying the refinery with the recycled water. The refinery then uses the water in its boilers to generate steam needed to manufacture gasoline, diesel, and other products.
By reusing water, the refinery greatly reduces the amount of freshwater it uses (and therefore, reduces the cost of purchasing water). It also allows the refinery to continue operations during drought restrictions, making it more resilient to weather-related changes.
How’s water reuse regulated?
Water reuse is generally voluntary; however, it operates within existing regulatory frameworks that govern wastewater discharges and water quality.
Most states regulate water reuse, although some programs may be implemented at the local level. In California, for instance, the Regional Water Quality Control Boards issue water reuse permits in their respective covered areas, whereas the Texas Commission on Environmental Quality (a state agency) regulates water reuse projects.
Tip: Use EPA’s REUSExplorer tool to find water reuse guidelines or regulations for your facility’s state.
Can water reuse benefit your business?
Each company must evaluate its operational processes to determine whether water reuse can help improve efficiency. Use these tips as a starting point:
- First, assess existing processes to determine whether and how water can be reused.
- Estimate the costs of implementing water reuse projects, such as installing or upgrading the facility’s equipment or infrastructure.
- Compare the potential benefits to the associated costs of reusing water. Consider both the short-term and long-term effects.
- Confirm the compliance requirements for water reuse with the proper regulatory authority (generally, the state environmental agency).
Water reuse may offer your business the opportunity to put its wastewater to work.
Key to remember: Water reuse implemented in compliance with applicable regulations can help facilities improve operational efficiency, lower costs, and reduce environmental impact.
Most Recent Highlights In Human Resources
NewsGreenhouse GasesIndustry NewsIndustry NewsEnvironmental Protection Agency (EPA)CAA ComplianceEnvironmentalFocus AreaEnglishAir ProgramsAir ProgramsUSA
2026-05-27T05:00:00Z
Final rule revises HFC use restrictions and compliance timelines for specific subsectors
On May 26, 2026, the Environmental Protection Agency (EPA) finalized a rule (2026 Final Rule) revising regulations on the use of hydrofluorocarbons (HFCs) in certain subsectors. The final rule specifically amends requirements established by the 2023 Technology Transitions Rule under the American Innovation and Manufacturing Act of 2020 (AIM Act).
EPA also published a proposed rule to exempt road and intermodal container transport refrigeration units (TRUs) from leak repair requirements set by the 2024 Emissions Reduction and Reclamation (ER&R) Rule.
Who’s impacted?
The 2026 Final Rule applies to entities that are subject to the 2023 Technology Transition Rule requirements (40 CFR 84.54) for these subsectors:
- Refrigerated transport — intermodal containers,
- Industrial process refrigeration (IPR) and chillers for IPR used in semiconductor manufacturing,
- Retail food — supermarket systems,
- Retail food — remote condensing units,
- Cold storage warehouses,
- Residential and light commercial air conditioning and heat pumps (RACHP), and
- IPR (not using chillers) — refrigerated laboratory centrifuges and refrigerated laboratory shakers.
The 2026 proposed rule applies to refrigerant-containing road and intermodal container transport refrigeration units (TRUs) regulated by the 2024 ER&R Rule.
What are the changes?
The 2026 Final Rule:
- Adjusts the lower bound temperature and measurement location for refrigerated transport intermodal containers from -50°C to -35°C;
- Extends the compliance dates to January 1, 2030, for restrictions on uses of HFCs and HFC blends by IPR and chillers for IPR in semiconductor manufacturing process equipment (limited to equipment with a charge size of 100 pounds or less);
- Allows retail food supermarket systems to increase the cooling capacity of existing systems by up to 15 percent without triggering new installation requirements;
- Establishes temporary, relaxed interim global warming potential (GWP) limits (implementing stricter GWP limits starting on January 1, 2032) for:
- Retail food supermarket systems,
- Retail food remote condensing unit systems, and
- Cold storage warehouses.
- Allows RACHP equipment using specific components that were domestically manufactured or imported before January 1, 2025, to continue to be installed; and
- Delays the compliance dates to January 1, 2028, for restrictions on uses of HFCs and HFC blends by refrigerated laboratory centrifuges and refrigerated laboratory shakers.
Please note that the final rule states that EPA maintains existing requirements for new condensing units used as replacements in the RACHP subsector.
What’s the proposed rule?
The 2024 ER&R Rule added leak repair requirements (84.106) for refrigerant-containing appliances with a charge size of 15 pounds or more containing an HFC or a specific HFC substitute, which took effect on January 1, 2026. Examples of the requirements include leak inspections, appliance repairs, and reporting.
EPA proposes to exempt all refrigerant-containing road and intermodal container TRUs from the leak repair provisions (regardless of charge size).
Key to remember: EPA has issued a final rule revising HFC use restrictions for certain subsectors and has proposed a rule exempting transportation refrigeration units from leak repair requirements.
NewsEnforcement and Audits - OSHAPesticidesWorker Protection from PesticidesIn-Depth ArticleHazard CommunicationHR ManagementEnglishUSAIndustry NewsOSHA InspectionsSafety & HealthContingent WorkforceConstruction SafetyGeneral Industry SafetyAgriculture SafetyMaritime SafetyEnvironmentalHazard CommunicationTemporary EmployeesFocus AreaPesticidesHuman Resources
2026-05-26T05:00:00Z
OSHA packs new HazCom directive with enforcement clues
The first compliance date for the amended Hazard Communication (HazCom) standard has arrived, and OSHA finally issued its updated directive. The CPL instructs OSHA officers on how to conduct inspections and issue citations under the standard. However, it also provides chemical manufacturers, importers, distributors, and employers with insight into what officers will be assessing.
In effect, this CPL translates regulatory text into inspector expectations. It shows what adherence to the standard looks like in practice. That makes it a critical resource given recent and upcoming dates at 29 CFR 1910.1200(j).
CPL rewritten for the 2024 standard
On May 19, 2026, OSHA posted a revised CPL 02-02-079, “Inspection Procedures for the Hazard Communication Standard (HCS 2024),” replacing the July 9, 2015, version. The 132-page document reflects the reconfigured HazCom standard published May 20, 2024, effective on July 19, 2024, along with corrections issued through early 2026.
The agency designed this enforcement playbook to maintain uniform inspections during the transition period and after full implementation. Because of the extensive regulatory changes to definitions, hazard classification, labeling, safety data sheets, and trade secrets, the CPL is not a light refresh.
For those familiar with the rulemaking, the new CPL edits will not be surprising. Still, the directive should provide more clarity than the regulatory text.
Front matter and appendices
Updates to Sections I to IX are typical of a CPL, including:
- Cancellation of the 2015 CPL;
- A modified title and references to the 2024 final rule and corrections;
- Alignment with revisions 7 and 8 of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS); and
- A new summary of changes, historical background, and compliance dates.
OSHA also modernized appendices for dates, hazard lists, pictogram hazards, SDS review guidance, chemical resources, and related directives.
Reworked inspection guidelines
Section X outlines inspector instructions for paragraphs (b) through (j) of the standard. The latest modifications impact most sections:
- Scope, applicability, and exemptions — The directive offers new examples and expanded explanations, such as:
- A formaldehyde hazard example for hair smoothing products;
- An overview of pesticide labeling requirements and exemptions;
- Discussion of the EPA Agricultural Worker Protection standard preemption; and
- Greater detail about biological hazards from plants.
- Definitions — The document introduces terms and explains bulk shipment, immediate outer package, physical hazard, released for shipment, and more. It also revisits the terms combustible dust and manufacturer. Lithium-ion batteries are now referenced in the distributor context.
- Hazard classification — The directive instructs OSHA officers to consider the classification of:
- Hazards associated with a chemical’s intrinsic properties, including changes in physical form and reactions from known or reasonably anticipated uses; and
- Impurities, additives, and individual constituents.
- Written plan — The directive clarifies:
- Employers must revise programs by the compliance dates when new information is received from suppliers;
- The use of computers and third-party administrators of safety data sheets (SDSs); and
- The written program must describe how employees will be trained in a language and at a literacy level they understand.
- Labeling — The directive broadens the sections on Department of Transportation labeling, bulk shipments, and small container labeling. It incorporates final rule flexibility too:
- Phased-in compliance dates for labeling;
- Hazards not otherwise classified (HNOCs) and hazards identified and classified under 1910.1200(d)(1)(ii) don’t need to be addressed on the container;
- The exclamation mark pictogram is permitted (but not required) for HNOCs, under certain conditions;
- Minor textual variations for precautionary statements are allowed; and
- OSHA offers alternatives for chemical containers released for shipment.
- Safety data sheets (SDSs) — Amended text focuses on U.S. jurisdiction and technical provisions, such as:
- Phased-in compliance dates for SDSs;
- Importer SDS responsibilities;
- Using a U.S. address and phone number;
- The hazard class and category reflecting intrinsic properties;
- Required Chemical Abstracts Service (CAS) number or other unique identifiers; and
- No need to obtain updated SDSs to replace already received SDSs.
- Employee information/training — The directive references a temporary workers bulletin. It also emphasizes:
- Phased-in compliance dates for necessary training adjustments; and
- Delivering training in a language employees understand.
- Trade secrets — The instruction aligns with the 2024 rule:
- Allows the exact percentage, exact concentration range, or CAS number to be withheld if certain criteria are met; and
- Addresses the use of confidentiality agreements.
- Dates — The directive overhauls compliance timelines and discusses documentation of due diligence and good faith efforts.
In addition, the directive softens citation language with phrases like “should normally cite” instead of “shall cite.” This shift suggests inspectors may have greater discretion based on case-specific circumstances.
Key to remember
While 1910.1200 remains the baseline for employers and chemical manufacturers, importers, and distributors, the revised CPL 02-02-079 provides an enforcement lens. With implementation underway, regulated entities can use the CPL to steer their efforts and conform with how OSHA will inspect them in the field.
NewsIndustry NewsSafety & HealthGeneral Industry SafetyIndoor Air QualityIndustrial HygieneCAA ComplianceEnvironmentalIn-Depth ArticleEnglishFocus AreaUSA
2026-05-22T05:00:00Z
Where workplace exposure meets air permitting: Bridging OSHA industrial hygiene and EPA air programs
Air quality inside a facility and emissions leaving a stack are closely linked. The same chemicals that drive occupational exposure limits under the Occupational Safety and Health Administration (OSHA) often form the basis of regulated air pollutants under the Environmental Protection Agency's (EPA's) programs.
When industrial hygiene (IH) and environmental compliance teams work together, they can spot risks sooner, strengthen controls, and avoid surprises in permits or inspections. The overlap is practical. Worker exposure data can inform stack testing, and permit conditions can signal where IH monitoring should focus.
Shared chemistry, different lenses
Both programs start with the same substances, such as solvents, metals, acids, and combustion byproducts. IH focuses on what workers breathe in the workplace. It uses exposure limits such as OSHA permissible exposure limits or more protective guidelines from the National Institute for Occupational Safety and Health (NIOSH) and the American Conference of Governmental Industrial Hygienists (ACGIH). Environmental air programs focus on what leaves the property. They regulate criteria pollutants, hazardous air pollutants (HAPs), and toxics using emission limits, control requirements, and reporting rules.
The data tools look similar. IH uses personal and area sampling, direct-reading instruments, and task-based assessments. Environmental programs use emission factors, mass balance, continuous monitoring, and periodic stack testing. Both require documentation, quality control, and records.
Key differences that matter
The point of exposure is the biggest difference. IH evaluates the breathing zone of a worker during a task or shift. Environmental programs measure emissions at a release point, such as a stack, or estimate them across the site.
The time frame also differs. IH often looks at short-term peaks and full-shift averages to protect health during work. Air permits may set hourly, daily, or annual limits, and they may cap total emissions per year. Control strategies follow these goals. IH may rely on local exhaust ventilation, enclosure, or work practice changes. Air permits may require add-on controls such as thermal oxidizers, scrubbers, or filters.
Practical crossover: Using IH to inform permitting
IH data can reveal which tasks generate the highest concentrations and which compounds dominate exposure. That insight can refine emission estimates. For example, if wipe cleaning with a solvent produces the highest worker exposure, the same solvent may drive facility-wide volatile organic compound (VOC) emissions. The environmental team can use that knowledge to prioritize accurate emission factors, refine mass balance, or plan stack testing during peak operations.
IH data also helps define realistic operating scenarios for compliance testing. Stack tests that occur only at typical loads may miss worst-case conditions. Pairing test timing with identified peak tasks can provide a more representative test and reduce the risk of later noncompliance.
Practical crossover: Using permits to inform IH
Air permits define regulated compounds, control devices, and operating limits. These details can guide IH planning. If a permit lists specific HAPs or requires a control device for a process, there's a clear signal that exposure to those compounds is possible near the source. IH can target those areas for baseline sampling, validate control performance, and confirm that capture systems are effective where workers are present.
Permit conditions also flag upset and startup modes. These periods can increase emissions. IH can align monitoring during these windows to assess short-term exposures and ensure that work practices and protective measures are adequate.
Aligning controls for dual benefit
Engineering controls can serve both goals when designed as a system. Capture at the source reduces worker exposure and lowers emissions to the stack. Good enclosure and balanced ventilation improve control efficiency and reduce fugitive releases. Preventive maintenance on control devices supports permit limits and keeps workplace air clean.
Administrative controls can align as well. Standard operating procedures can link production rates, control device settings, and ventilation checks. Change management should include both an IH review and an air permitting check to see if a modification triggers a permit update.
Communication and workflows
Successful crossover depends on routine communication. Regular meetings enable safety and environmental staff to share results, plan sampling, and coordinate testing windows. Shared inventories of chemicals and processes reduce duplication and errors. A common data platform, or at least a consistent file structure, makes it easier to compare IH results with emission estimates and permit limits.
Clear triggers help teams act. Examples include a new chemical introduction, a process change, a spike in IH results, or a deviation in control device performance. Each trigger should prompt both an IH review and an environmental compliance check.
Key to remember: When teams connect their data and plans, they gain a clearer picture of risk. The results are stronger compliance, better worker protection, and more efficient operations.
NewsIndustry NewsIndustry NewsToxic Substances Control Act - EPAToxic Subtances Control Act - EPATSCA ComplianceEnvironmental Protection Agency (EPA)EnvironmentalEnglishFocus AreaUSA
2026-05-22T05:00:00Z
Final rule extends TSCA Section 8(d) health and safety reporting deadline
The Environmental Protection Agency (EPA) issued a final rule on May 22, 2026, extending the reporting deadline for the Toxic Substances Control Act (TSCA) Section 8(d) Health and Safety Data Reporting Rule from May 22, 2026, to May 21, 2027.
Who’s impacted?
The TSCA Section 8(d) Health and Safety Data Reporting Rule applies to manufacturers (including importers) of any of the 16 chemical substances listed at 40 CFR 716.120(d), including:
- Entities that currently manufacture (including import) any of the chemicals; and
- Entities that have manufactured (including imported) or have proposed to manufacture (including import) any of the chemicals since January 13, 2015.
What’s required?
The rule requires covered manufacturers (including importers) to submit a one-time report of data on the chemicals from unpublished studies on:
- Health and safety;
- Environmental effects; and
- Occupational, general population, and consumer exposure.
Which chemicals are covered?
The TSCA Section 8(d) Health and Safety Data Reporting Rule applies to:
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Why the delay?
EPA has extended the deadline to allow additional time to reconsider the rule’s scope and possibly propose revisions to the regulations. Once any major changes are finalized, EPA will communicate the updated reporting requirements and timelines accordingly.
Key to remember: EPA has extended the submission date for the TSCA Section 8(d) Health and Safety Data Reporting Rule’s one-time report to May 2027.
NewsIndustry NewsIndustry NewsSafe Drinking WaterWater ProgramsWater QualityEnvironmental Protection Agency (EPA)Maximum Contaminant LevelsEnvironmentalUSAWater ProgramsEnglishFocus AreaCWA Compliance
2026-05-20T05:00:00Z
EPA floats major changes to current PFAS drinking water rules
The Environmental Protection Agency (EPA) has released two proposed rules that, if finalized, would have major impacts on drinking water regulations for per- and polyfluoroalkyl substances (PFAS), specifically, the 2024 National Primary Drinking Water Regulation (NPDWR) for PFAS (2024 PFAS NPDWR).
Proposed rule: MCL compliance extension
The first rule proposes to establish a federal exemption that allows public water systems (PWSs) to request an extension of the deadline to comply with the Maximum Contaminant Levels (MCLs) for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) from April 26, 2029, to April 26, 2031.
The rule would require PWSs that meet the eligibility requirements to submit a request to EPA for the federal exemption within 180 days of the date a final rule is published. PWSs would have to provide specific information in the request (such as recent water sample results and a certified statement that the system can’t comply with the original MCL deadline).
Additionally, EPA’s proposed rule would require:
- All PWSs with the federal exemption to notify customers of the exemption, and
- PWSs with PFOA or PFOS levels at or above 12 parts per trillion to implement two control measures (from six options) during the exemption period.
Who would be impacted?
The proposed federal exemption would apply to PWSs:
- Regulated by the 2024 PFAS NPDWR for PFOA and PFOS;
- In operation on or before June 25, 2024;
- Not under a variance for small systems for the PFOA and PFOS MCLs; and
- In a state that doesn’t have primacy for the 2024 PFAS NPDWR.
PWSs in states with primacy for the 2024 PFAS NPDWR may request an exemption from the primacy agency.
Proposed rule: Rescinding PFAS NPDWRs
The second rule proposes to rescind EPA’s determinations to regulate:
- Perfluorohexane sulfonic acid (PFHxS);
- Perfluorononanoic acid (PFNA);
- Hexafluoropropylene oxide dimer acid and its ammonium salt (HFPO-DA, called GenX chemicals); and
- Perfluorobutane sulfonic acid (PFBS).
It also proposes to remove the related 2024 PFAS NPDWR provisions from 40 CFR Parts 141 and 142, including:
- The MCLs and MCL Goals (MCLGs) for PFHxS, PFNA, and HFPO-DA;
- The MCL and MCLG for mixtures with two or more of PFHxS, PFNA, HFPO-DA, and PFBS (referred to as the Index PFAS); and
- All other compliance requirements.
The proposed rule would maintain the 2024 PFAS NPDWR requirements for PFOA and PFOS.
Who would be impacted?
The rule would impact PWSs, including community water systems (CWSs) and non-transient non-CWSs, subject to the 2024 PFAS NPDWR standards for PFHxS, PFNA, HFPO-DA, or the Index PFAS.
How do I give feedback?
EPA will hold a virtual public hearing for verbal comments on the proposed rules on July 7, 2026. Written comments for the proposed compliance extension rule (Docket ID No. EPA-HQ-OW-2025-1742) and proposed rescission rule (Docket ID No. EPA-HQ-OW-2025-0654) are due by July 20, 2026.
Key to remember: EPA has proposed major changes to the national drinking water regulations for PFAS.
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Most Popular Highlights In Environmental
NewsAir QualityIndustry NewsIndustry NewsAir ProgramsEnvironmental Protection Agency (EPA)Hazardous Air PollutantsCAA ComplianceEnvironmentalFocus AreaEnglishAir ProgramsStationary Emission SourcesUSA
2026-06-03T05:00:00Z
EPA adds new HAPs to hazardous waste combustor requirements
The Environmental Protection Agency (EPA) finalized the residual risk and technology review of the National Emission Standards for Hazardous Air Pollutants (NESHAP) from Hazardous Waste Combustors (HWCs). Most significantly, the final rule:
- Maintains the existing standards;
- Adds requirements for previously unregulated hazardous air pollutants from specific major source HWCs; and
- Establishes work practice standards for periods of startup, shutdown, and malfunction (SSM).
Who’s impacted?
EPA’s final rule applies to major sources subject to the HWC NESHAP at 40 CFR 63 Subpart EEE, including:
- Hazardous waste-burning incinerators,
- Cement kilns,
- Lightweight aggregate kilns,
- Solid fuel-fired boilers,
- Liquid fuel-fired boilers, and
- Hydrochloric acid production furnaces.
What are the changes?
The final rule adds hydrogen fluoride (HF) and hydrogen cyanide (HCN) emission standards for specific sources:
| Major source HWC | New regulation(s) |
|---|---|
| Incinerators |
|
| Cement kilns |
|
| Solid fuel boilers |
|
| Liquid fuel boilers |
|
The final rule also:
- Establishes work practice standards for periods of SSM;
- Requires electronic reporting for specific reports (e.g., compliance progress reports, performance tests, Notifications of Compliance); and
- Makes technical changes.
What’s the compliance timeline?
Existing HWCs must:
- Develop, submit to the regulatory authority for approval, and implement SSM plans and start complying with SSM requirements by November 30, 2026;
- Comply with any applicable HF and HCN emission limits and work practice standards by June 3, 2029; and
- Begin electronic reporting by August 3, 2026.
New HWCs must comply upon startup.
Key to remember: EPA's final rule maintains the existing NESHAP regulations for hazardous waste combustors and establishes emission limits and work practice standards for previously unregulated HAPs.
NewsHazardous WasteIndustry NewsWaste ManifestsWaste/HazWasteWasteEnvironmentalIn-Depth ArticleEnglishFocus AreaUSA
2023-08-30T05:00:00Z
EPA announces new e-manifest fees for FY2024-25
Receiving facilities will experience higher charges for scanned images within the e-Manifest system during fiscal years 2024 and 2025. These updated rates aim to boost a complete transition to electronic submissions. The Environmental Protection Agency (EPA) creates these charges based on the method of manifest submission and the combined processing expenses for each manifest category. It is unsurprising that fully electronic and hybrid manifests come with notably lower costs.
The latest fees For fiscal years 2024 and 2025 (October 1, 2023, through September 30, 2025), the new user fees are as follows:
- $22.00 for uploading scanned images (formerly $20.00)
- $10.00 for uploading data and images (formerly $13.00)
- $6.00 for fully electronic and hybrid submissions (unchanged from $6.00)
The application of user charges also aligns with the broader trend of digitization and modernization in regulatory procedures. By transitioning from paper-based manifest systems to digital platforms, the e-Manifest system trims administrative burdens, reduces the risk of errors, and expedites information flow. These user fees provide the resources to maintain and improve these digital capabilities. It benefits waste management stakeholders by streamlining reporting obligations and enhancing overall efficiency.
More on the user fees for the e-manifest system and amendments to manifest regulations
The Hazardous Waste Electronic Manifest Establishment Act (e-Manifest Act) itself does not determine e-Manifest user fees; rather, it grants EPA the authority to establish user fees through regulations. The Final User Fee rule addresses the following key aspects:
- Which users of manifests or manifest data will be charged user? User fees are not directly charged to generators or transporters. Instead, EPA enforces charges on receiving facilities for each submitted manifest. However, it is likely that increased costs will have a ripple effect across the industry.
- What transactions or services will give rise to fee? The submission of the final copy of each manifest to the system by receiving facilities triggers the user fee requirement. The fee depends on the type of manifest submission. Receiving facilities will also incur charges for manifests involving rejected wastes that are being sent back from the facility to the generator.
- How will users be billed for e-Manifest services and make their fee payments? Receiving facilities will receive a monthly electronic invoice detailing their manifest activity from the previous month. Each facility will be directed to the Treasury’s Pay.gov website to make their payments.
- What model or formula will EPA rely upon for the determination of users’ fees? The final rule’s fee calculation relies heavily on the total program-related costs incurred by EPA and the number of manifests over which these costs are distributed. When adjusting user fee schedules, EPA will reapply its fee formula using the most up-to-date data on program costs and manifest counts. The final rule also incorporates fee adjustment factors to account for inflation and revenue losses resulting from inaccurate estimates of manifests in use.
- How will the rule address fee schedule revisions? Revisions to user fees will not require a new rulemaking. EPA will re-run the fee formula at two-year intervals, with the most recent program cost and manifest usage numbers being used in running the fee formula to calculate the fees for each manifest submission type. The result will be a fee schedule that announces the fees for each of the next two fiscal years.
| For more information see our EzExplanation on Hazardous waste manifests |
Key to remember: Receiving facilities will see increased user fees for scanned images in the e-Manifest system for fiscal years 2024 and 2025. Using fully electronic waste manifests will cost significantly less.
NewsEnforcement and Audits - OSHAPesticidesWorker Protection from PesticidesIn-Depth ArticleHazard CommunicationHR ManagementEnglishUSAIndustry NewsOSHA InspectionsSafety & HealthContingent WorkforceConstruction SafetyGeneral Industry SafetyAgriculture SafetyMaritime SafetyEnvironmentalHazard CommunicationTemporary EmployeesFocus AreaPesticidesHuman Resources
2026-05-26T05:00:00Z
OSHA packs new HazCom directive with enforcement clues
The first compliance date for the amended Hazard Communication (HazCom) standard has arrived, and OSHA finally issued its updated directive. The CPL instructs OSHA officers on how to conduct inspections and issue citations under the standard. However, it also provides chemical manufacturers, importers, distributors, and employers with insight into what officers will be assessing.
In effect, this CPL translates regulatory text into inspector expectations. It shows what adherence to the standard looks like in practice. That makes it a critical resource given recent and upcoming dates at 29 CFR 1910.1200(j).
CPL rewritten for the 2024 standard
On May 19, 2026, OSHA posted a revised CPL 02-02-079, “Inspection Procedures for the Hazard Communication Standard (HCS 2024),” replacing the July 9, 2015, version. The 132-page document reflects the reconfigured HazCom standard published May 20, 2024, effective on July 19, 2024, along with corrections issued through early 2026.
The agency designed this enforcement playbook to maintain uniform inspections during the transition period and after full implementation. Because of the extensive regulatory changes to definitions, hazard classification, labeling, safety data sheets, and trade secrets, the CPL is not a light refresh.
For those familiar with the rulemaking, the new CPL edits will not be surprising. Still, the directive should provide more clarity than the regulatory text.
Front matter and appendices
Updates to Sections I to IX are typical of a CPL, including:
- Cancellation of the 2015 CPL;
- A modified title and references to the 2024 final rule and corrections;
- Alignment with revisions 7 and 8 of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS); and
- A new summary of changes, historical background, and compliance dates.
OSHA also modernized appendices for dates, hazard lists, pictogram hazards, SDS review guidance, chemical resources, and related directives.
Reworked inspection guidelines
Section X outlines inspector instructions for paragraphs (b) through (j) of the standard. The latest modifications impact most sections:
- Scope, applicability, and exemptions — The directive offers new examples and expanded explanations, such as:
- A formaldehyde hazard example for hair smoothing products;
- An overview of pesticide labeling requirements and exemptions;
- Discussion of the EPA Agricultural Worker Protection standard preemption; and
- Greater detail about biological hazards from plants.
- Definitions — The document introduces terms and explains bulk shipment, immediate outer package, physical hazard, released for shipment, and more. It also revisits the terms combustible dust and manufacturer. Lithium-ion batteries are now referenced in the distributor context.
- Hazard classification — The directive instructs OSHA officers to consider the classification of:
- Hazards associated with a chemical’s intrinsic properties, including changes in physical form and reactions from known or reasonably anticipated uses; and
- Impurities, additives, and individual constituents.
- Written plan — The directive clarifies:
- Employers must revise programs by the compliance dates when new information is received from suppliers;
- The use of computers and third-party administrators of safety data sheets (SDSs); and
- The written program must describe how employees will be trained in a language and at a literacy level they understand.
- Labeling — The directive broadens the sections on Department of Transportation labeling, bulk shipments, and small container labeling. It incorporates final rule flexibility too:
- Phased-in compliance dates for labeling;
- Hazards not otherwise classified (HNOCs) and hazards identified and classified under 1910.1200(d)(1)(ii) don’t need to be addressed on the container;
- The exclamation mark pictogram is permitted (but not required) for HNOCs, under certain conditions;
- Minor textual variations for precautionary statements are allowed; and
- OSHA offers alternatives for chemical containers released for shipment.
- Safety data sheets (SDSs) — Amended text focuses on U.S. jurisdiction and technical provisions, such as:
- Phased-in compliance dates for SDSs;
- Importer SDS responsibilities;
- Using a U.S. address and phone number;
- The hazard class and category reflecting intrinsic properties;
- Required Chemical Abstracts Service (CAS) number or other unique identifiers; and
- No need to obtain updated SDSs to replace already received SDSs.
- Employee information/training — The directive references a temporary workers bulletin. It also emphasizes:
- Phased-in compliance dates for necessary training adjustments; and
- Delivering training in a language employees understand.
- Trade secrets — The instruction aligns with the 2024 rule:
- Allows the exact percentage, exact concentration range, or CAS number to be withheld if certain criteria are met; and
- Addresses the use of confidentiality agreements.
- Dates — The directive overhauls compliance timelines and discusses documentation of due diligence and good faith efforts.
In addition, the directive softens citation language with phrases like “should normally cite” instead of “shall cite.” This shift suggests inspectors may have greater discretion based on case-specific circumstances.
Key to remember
While 1910.1200 remains the baseline for employers and chemical manufacturers, importers, and distributors, the revised CPL 02-02-079 provides an enforcement lens. With implementation underway, regulated entities can use the CPL to steer their efforts and conform with how OSHA will inspect them in the field.
NewsIndustry NewsWaste/HazWasteSafety & HealthConstruction SafetyGeneral Industry SafetyWasteEnvironmentalIn-Depth ArticleCWA ComplianceUsed OilEnglishFocus AreaUSA
2025-03-03T06:00:00Z
Used oil disposal: How to stay compliant with EPA, OSHA, and your state
Used oil disposal is a critical issue for safety managers and shop supervisors in industrial settings. Whether your facility generates used oil from machinery, vehicles, or hydraulic systems, you must understand the regulatory requirements to ensure compliance and avoid hefty fines.
Used oil is not always considered hazardous waste, but improper handling, storage, or disposal can lead to regulatory violations and environmental hazards. Understanding how used oil is classified, when it is considered hazardous, and how to manage it in compliance with 40 CFR Part 279 is essential.
Let’s uncover the regulatory framework for used oil disposal, including storage requirements, transportation rules, and best practices to ensure compliance at both the federal and state levels.
What is used oil?
The EPA defines used oil as any petroleum-based or synthetic oil that has been used and is contaminated by physical or chemical impurities. Common sources of used oil in industrial operations include:
- Motor oil and lubricants from vehicle maintenance
- Hydraulic fluids used in heavy machinery
- Metalworking fluids and coolants
- Compressor oils used in air compression systems
According to EPA regulations (40 CFR Part 279), used oil is presumed to be managed under the less stringent used oil management standards unless it meets hazardous waste criteria.
Used oil becomes hazardous waste if:
- It is mixed with hazardous waste (e.g., solvents or heavy metals)
- It contains more than 1,000 parts per million (ppm) of total halogens, unless proven otherwise, or
- It is disposed of improperly, leading to environmental contamination.
If used oil is classified as hazardous waste, it must be managed in accordance with the applicable solid and hazardous waste requirements.
EPA requirements for used oil disposal
The EPA requirements for used oil consist of three different aspects, as outlined below.
1. Storage Requirements
Use leak-proof tanks and containers made of durable, non-earthen materials (e.g., steel, plastic, or concrete). Label all used oil containers with the words "Used Oil" to prevent misidentification. Prevent leaks and spills by using secondary containment systems and regularly inspecting tanks. Never mix used oil with hazardous waste unless authorized.
2. Transportation and Disposal
Used oil generators may transport up to 55 gallons of used oil to a registered collection center without an EPA ID number. If contracting a used oil transporter, ensure they have an EPA Identification Number.
Used oil must be:
- Recycled or re-refined into new oil.
- Burned for energy recovery in approved furnaces or boilers.
- Disposed of at an authorized hazardous waste facility if deemed hazardous.
3. Spill Prevention and Cleanup
Facilities storing large amounts of used oil must have a Spill Prevention, Control, and Countermeasure (SPCC) Plan. SPCC plans establish procedures, methods, and equipment requirements to prevent oil from reaching waterways, and to contain discharges of oil.
Any spills must be cleaned up immediately, and absorbent materials must be disposed of properly. Rags and shop towels contaminated with hazardous materials may be classified as hazardous waste.
OSHA regulations for handling used oil
While the EPA focuses on environmental compliance, OSHA (29 CFR Part 1910) regulates worker safety when handling used oil. Key OSHA requirements include:
1. Personal Protective Equipment (PPE)
Workers handling used oil must wear gloves and protective clothing to prevent skin exposure. Safety goggles or face shields are also important to avoid eye contact.
2. Hazard communication (HazCom) program
Employers must label all used oil containers with appropriate hazard information and train employees on safe handling procedures and emergency response.
3. Fire and Explosion Safety
Always store used oil away from ignition sources to prevent fire hazards. Ensure storage areas are ventilated to avoid vapor buildup.
State-Specific used oil disposal regulations
Many states have stricter used oil regulations than federal laws. For example:
- California classifies used oil as hazardous waste unless it meets specific recycling criteria.
- Texas requires additional storage permits for large generators.
- New York mandates annual reporting on used oil disposal activities.
To ensure compliance, check with your state’s environmental agency for state-specific used oil disposal rules and whether used oil is considered hazardous. Additional permits for transporting or processing used oil may be necessary.
Staying compliant with used oil disposal requirements
Ensuring compliance with EPA, OSHA, and state laws is essential for safety managers and shop supervisors handling used oil. By following proper storage, transportation, and disposal practices, businesses can reduce environmental risks, improve workplace safety, and avoid costly fines.
Key to remember: By staying informed and proactive, your facility can maintain safe, sustainable, and compliant used oil management practices.
NewsHazardous WasteWaste GeneratorsWaste ManifestsWaste/HazWasteWasteEnvironmental Protection Agency (EPA)In-Depth ArticleEnglishIndustry NewsWaste ReportingWasteTSD FacilitiesWaste ManagementEnvironmentalFocus AreaUSA
2026-06-15T05:00:00Z
Hazardous waste manifest S Codes: What storage and transfer facilities need to know
Have you cracked the “S Code” yet? Starting in 2027, facilities that receive regulated waste for temporary storage and disposal must use S Codes on hazardous waste manifests. If your facility hasn’t made the switch, now’s the time!
Under the Resource Conservation and Recovery Act (RCRA), the Environmental Protection Agency (EPA) requires hazardous waste handlers to track shipments of regulated waste from the generating facility to final treatment, recycling, or disposal. Management Method Codes are key to hazardous waste manifests, and they also affect biennial reporting. The codes answer the vital question, “How’s the hazardous waste managed?"
Effective January 1, 2027, “S Codes” will officially replace code H141 for Storage and Transfer. EPA adopted these codes to improve the accuracy and transparency of waste tracking, specifically for wastes that travel through transfer facilities before final management. Use this overview to help your facility understand how to comply.
What are S Codes?
In January 2025, EPA added S Codes to the list of Management Method Codes, which identify the type of waste management system used to treat, recover, or dispose of a hazardous waste. Management Method Codes are used for:
- The Uniform Hazardous Waste Manifest (EPA Form 8700-22) and Continuation Sheet (EPA Form 8700-22A); and
- The National Biennial RCRA Hazardous Waste Report (EPA Form 8700-13 A/B), known as the Biennial Report.
S Codes apply to receiving facilities (primarily treatment, storage, and disposal facilities (TSDFs)) that temporarily store and then transfer regulated hazardous waste to another receiving facility without treating, recovering, or disposing of the waste. EPA established S Codes to provide more details than code H141 on waste handling activities, improving tracking and transparency. S Codes indicate two things:
- A hazardous waste was received to be stored or transferred; and
- The hazardous waste will be managed later by the final receiving facility using a certain method (i.e., the final management method).
EPA groups S Codes into three categories:
- Transfer off-site for reclamation and recovery,
- Transfer off-site for destruction or treatment prior to disposal, and
- Transfer off-site for disposal.
Each S Code corresponds to a specific final management method. Examples of these methods include metals recovery (S010), chemical treatment (S070), and landfilling (S132).
What’s required?
On January 1, 2027, EPA will remove Management Method Code H141 for Storage and Transfer from the e-Manifest and the Biennial Report forms. As a result, hazardous waste handlers must use S Codes instead of code H141 on manifests and the Biennial Report.
S Codes apply to RCRA hazardous waste that’s transferred off-site, impacting:
- Receiving facilities that store and transfer hazardous waste;
- Permitted TSDFs that receive hazardous waste solely for temporary storage and transfer (i.e., it’s the facility’s only management type); and
- Large quantity generators (LQGs) that report wastes shipped to transfer facilities on the Biennial Report.
Hazardous waste manifests
The first receiving TSDF is responsible for choosing and entering the S Codes on manifests. The storage and transfer facility must:
- Identify the S code that best describes how the hazardous waste will be managed by the final receiving facility, and
- Enter the S Code in Item 19 on the manifest and in Item 36 on the continuation sheet (if used).
Generators aren’t responsible for selecting or entering S Codes.
Biennial Reports
LQGs and TSDFs must use S Codes for the Biennial Report on the:
- Waste Generation and Management (GM) Form in Item 3, and
- Waste Received From Off-site (WR) Form in Item F.
LQGs use S Codes on the GM Form for shipments of hazardous waste off-site to a transfer facility for temporary storage and transfer.
TSDFs that receive hazardous waste for temporary storage and transfer off-site use S Codes on the WR Form. These TSDFs must also use Source Code G61 on the GM Form to report shipments of these transferred wastes.
How can facilities prepare?
Help your facility achieve a smooth shift to S Codes by January 1, 2027, with these tips:
- Identify where your facility currently uses code H141.
- Develop a process for transitioning to S Codes exclusively. Consider any changes your facility may need to make to its operations, such as updating software, adjusting procedures, and revising internal guidance documents.
- Train your employees accordingly.
- Set a deadline for making the switch to S Codes. Aim for a date well ahead of January 1, 2027, to give your facility enough time to address any issues that arise.
Key to remember: Starting in 2027, storage and transfer facilities must use S Codes in place of code H141 on RCRA hazardous waste manifests and Biennial Reports.
NewsGreenhouse GasesToxic Substances Control Act - EPAToxic Subtances Control Act - EPATSCA ComplianceMonthly Roundup VideoCAA ComplianceUSAHazard CommunicationEnglishIndustry NewsSafety & HealthConstruction SafetyGeneral Industry SafetyMaritime SafetyEnvironmentalFocus AreaHazard CommunicationAir ProgramsVideo
EHS Monthly Round Up - May 2026
In this May 2026 roundup video, we’ll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
The first compliance date for the revised HazCom standard took effect May 19. Employers who work with chemical substances that are aerosols, desensitized explosives, or flammable gases should start to see updated safety data sheets and labels. On a related note, OSHA revised its HazCom directive for inspectors. It instructs OSHA officers on how to conduct inspections and issue citations under the standard. However, it also provides chemical manufacturers, importers, distributors, and employers with insight into what officers will be assessing.
OSHA revoked a standard that prohibited open fires and fires in drums or similar containers in marine terminals. The agency stated that since this is no longer typical practice, removing the standard would lessen the compliance burden without compromising worker safety.
OSHA received the backing of an advisory committee as it advances a comprehensive Tree Care Operations proposal. During the Advisory Committee on Construction Safety and Health meeting, the group unanimously voted in favor of moving ahead. This clears the path for OSHA to publish its long-awaited proposal.
Turning to environmental news, EPA extended the submission date for the TSCA Section 8(d) Health and Safety Data Reporting Rule one-time report from May 22, 2026, to May 21, 2027.
EPA published the first round of expiring confidential business information claims for information submitted under TSCA. The list covers claims that expire from June 22 to July 31, 2026. Businesses must submit extension requests to keep the information protected.
EPA postponed the effective compliance date for trichloroethylene users with TSCA Section 6(g) exemptions until pending judicial review is concluded. The agency has yet to establish a new compliance date.
And finally, EPA revised HFC use restrictions for certain subsectors. This applies to entities that are subject to the 2023 Technology Transition Rule requirements. The agency also proposed a rule that would exempt transportation refrigeration units from leak repair requirements regardless of charge size.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
Most Popular Highlights In Transportation
NewsIndustry NewsIndustry NewsElectronic logging device (ELD)Electronic logging device (ELD)Focus AreaFleet OperationsEnglishTransportationUSA
2026-06-11T05:00:00Z
Last chance to replace your ELDs: 12 total removed from FMCSA’s list
A total of 12 devices were recently removed from the FMCSA’s list of registered electronic logging devices (ELDs).
On May 20, 2026, the following ELDs were removed for not meeting the minimum requirements in 49 CFR 395, Subpart B, Appendix A:
- 888 ELD
- DRAGON E
- ACTION ELD
- Mondo ELD HOS
- FIRST ELD
- FIRST ELD V2.0
- MTL ELD
- USPower ELD
- Sam Freight ELD
- DSGELOGS
- COBRA ELD
- GT USA ELOGS
The Federal Motor Carrier Safety Administration (FMCSA) has moved these devices to its “revoked devices” list.
Carriers and drivers have until toward the end of next month on July 20, 2026, to replace them with compliant ELDs.
Many ELD providers remove their devices from the list voluntarily, but the FMCSA has the authority to remove any ELD that does not comply with regulations.
Next steps for commercial carriers
Commercial carriers and drivers who use the above-listed devices must stop using the devices and switch to paper logs or logging software to record their hours of service.
In addition, they must replace the devices with ELDs listed on the FMCSA’s ELD registry and begin using those compliant devices before the posted dates.
ELD providers who correct device deficiencies can be placed back on the list of registered devices. The FMCSA will inform the industry when revoked devices are compliant again.
ELD compliance standards
During the 60-day replacement period, the FMCSA has instructed safety officials to review affected drivers’ hours-of-service data using logging software, paper logs, or the ELD display.
After July 20, respectively, any motor carrier that continues to use the revoked devices will be considered operating without an ELD. Drivers will be placed out of service and cited for “No record of duty status” (395.8(a)(1)).
Review the full list of registered devices at https://eld.fmcsa.dot.gov/List.
NewsIndustry NewsFleet SafetyDriver qualificationsDrivers qualification (DQ file)Driver qualification and hiringFocus AreaIn-Depth ArticleEnglishTransportationUSA
2026-06-01T05:00:00Z
Driver qualification FAQs: Avoiding common compliance pitfalls
Managing driver qualification (DQ) files is a critical part of any motor carrier’s compliance program. While most trucking professionals understand the core requirements of maintaining DQ files, there are other safety aspects that come into play. Applying DQ file rules inconsistently in day-to-day operations can raise questions and open the door for an audit. When real-world situations don’t fit neatly into the regulations, carriers increase risk exposure.
Across the transport industry, a few questions consistently rise to the top. Here are some of the most common carrier questions, along with practical answers.
What is a commercial motor vehicle (CMV)?
The definition of a CMV comes straight from 49 CFR 390.5. At a high level, a CMV is a vehicle used in interstate commerce that:
- Has a gross vehicle weight rating (GVWR) or gross combination weight rating (GCWR), or gross vehicle weight (GVW) or gross combination weight (GCW) of 10,001 pounds or more, whichever is greater;
- Transports passengers above specific thresholds; or
- Requires placarding for hazardous materials.
Motor carriers often run into trouble with the weight threshold, especially when trailers are involved.
For example, a pickup with a GVWR – and actual weight – of 7,500 pounds isn’t a CMV on its own. But if a driver attaches a trailer with a GVWR of 3,000 pounds, the combined weight rating exceeds 10,001 pounds. At that point, the vehicle meets the CMV definition, and a driver becomes subject to the Federal Motor Carrier Safety Regulations.
What if a commercial driver only operates in intrastate transport?
Intrastate transportation requirements are set at the state level. Definitions of a CMV can vary, adding to the complexity. Some states follow the 10,001-pound federal threshold, while others align more closely with the 26,001-pound commercial driver’s license (CDL) standard — or fall somewhere in between.
Because of that, there’s no one-size-fits-all answer.
From a practical standpoint, many carriers adopt a consistent approach and qualify all drivers at the 10,001-pound threshold. That approach creates uniformity and helps prevent compliance gaps as operations evolve or expand across state lines.
What if a CDL driver’s medical card doesn’t appear on the motor vehicle record (MVR)?
The Federal Motor Carrier Safety Administration currently allows CDL drivers to carry a medical certificate for up to 60 days via an exemption issued through October 11, 2026. Carriers should still verify that certification appears on the MVR promptly.
In most cases, it shows up within a few days. If it doesn’t appear within about 5 days, motor carriers should:
- Check with the medical examiner for validation errors (often caused by mismatched driver data);
- If necessary, have the examiner resubmit the results to the National Registry; or
- Contact the state licensing agency to locate the record. When calling the state, carriers should ask to speak with someone in the CDL department directly.
Most issues should be resolved when taking these steps.
Must a carrier give a CDL driver a road test?
Not always. A valid CDL can be accepted in place of a road test.
However, if the driver will operate equipment requiring a tanker, double, or triple endorsement, a road test will be required.
Even when not mandated, many carriers conduct road tests as a risk-management practice. It’s one of the few opportunities to confirm a driver can safely operate the specific equipment they’ll be assigned.
Must a driver be re-examined after an injury or illness?
Under 49 CFR 391.45(b), if a driver’s ability to perform normal duties is impaired by a medical condition, they must be re-evaluated and medically certified before returning to duty.
This includes conditions like heart attacks, seizures, or anything else that could affect safe operation.
If a carrier is aware of a potential issue, they have an obligation to act. Allowing a driver to continue operating without re-evaluation creates significant risk exposure.
Key to remember: Consistency in how you apply DQ requirements day to day is what ultimately keeps your program compliant and your risk in check.
NewsIndustry NewsEnglishFleet SafetyDrug and Alcohol Testing - DOTDrug testing - Motor CarrierFocus AreaIn-Depth ArticleUSAAlcohol testing - Motor CarrierTransportationReasonable suspicion drug and alcohol testing - Motor Carrier
2023-01-11T06:00:00Z
Video can be used for alcohol and drug observations, FMCSA says
With the world becoming more and more virtual, it’s no surprise that trained supervisors can now order reasonable-suspicion drug or alcohol tests based on video observations, according to the Federal Motor Carrier Safety Administration (FMCSA).
In response to a recent J. J. Keller inquiry, the agency’s Drug and Alcohol Programs Division wrote that the reasonable-suspicion testing rules in 49 CFR 382.307 do not prohibit video-based observations to determine that a driver is under the influence.
The new guidance means in-person observations are not necessarily required before sending a driver for a “reasonable suspicion” drug or alcohol test.
However, with video, supervisors must still make “specific, contemporaneous, articulable observations” concerning the driver’s appearance, behavior, or speech before a test may be authorized.
“If, during a video chat, the supervisor can assess and document the observations as set forth in 382.307, the employer can require the driver to test,” the FMCSA wrote.
All supervisors of drivers subject to DOT-mandated testing must receive at least two hours of training, per 382.603, before they can order a reasonable-suspicion test.
Timing is critical
For reasonable suspicion of alcohol, keep in mind the timing requirements for both the observation (whether on video or in person) and the testing, as described in 382.307:
- The observation must be made just before, during, or just after the driver performs safety-sensitive functions; and
- The alcohol test must be performed within no more than 2 to 8 hours of the observation.
Finally, whether the observations are made in-person or over video, the observations must be documented within 24 hours or before the test results are released, whichever is earlier.
Third-party observations
The new guidance means motor carriers can make remote video observations that can lead to a reasonable-suspicion test. Keep in mind, however, that motor carriers still cannot rely on third parties to make such observations.
For example, if a third-party shipper or receiver’s trained supervisor observes that another employer’s driver appears to be in violation of the drug/alcohol prohibitions, that supervisor has no authority to order a drug or alcohol test. A trained supervisor working for the driver’s employer must make the observation. If a video-based or in-person observation is not possible, then the third party or employing motor carrier could:
- Advise the driver not to perform safety-sensitive work; and/or
- Contact the police to request appropriate action.
Key to remember: The FMCSA now allows video-based observations to lead to reasonable-suspicion drug and alcohol tests.
NewsIndustry NewsHazmat SafetyHazmat: HighwayFocus AreaIn-Depth ArticleHazmat EnforcementEnglishTransportationUSA
2022-12-27T06:00:00Z
Placarding responsibility – Whose is it?
Many shippers are unaware of their responsibility to provide placards to drivers, but the responsibility shifts as soon as the driver hits the road.
Check the regulations
According to Section 172.506 of the Hazardous Materials Regulations (HMR), a shipper offering a hazardous material for transportation by highway must provide the motor carrier with the required placards for the material being offered. The shipper must offer the placards to the carrier prior to, or at the same time as, the material is offered for transportation — unless the vehicle is already placarded for the hazmat.
Section 172.506 also states that no motor carrier may transport a hazardous material in a motor vehicle unless the required placards for the hazmat are affixed to the vehicle. Before transport, the driver is responsible for displaying the required placards for all the hazmat that is on the vehicle.
Avoid issues with shippers
Many trailers are equipped with flip placards that represent most classes of hazardous materials but without adequate training, shippers may not understand their responsibility to provide the driver with the required placards. If a driver arrives and the shipper fails to provide placards, the driver should contact dispatch for additional instructions or drive to a truck stop to secure the necessary placards. The driver becomes responsible for placards as soon as the trailer enters a public highway, so train your drivers to temporarily refuse the shipment until the proper placards can be obtained. If necessary, the driver must bobtail or leave empty before driving to pick up placards.
Another common placarding question with shippers involves combination loads. If a driver arrives at a shipper’s location and is already transporting a hazardous material below the placarding threshold, is the shipper required to provide placards for the combination load on the trailer? In this scenario, the driver already has 600 pounds of a Class 8 corrosive material on the trailer, and the shipper is offering an additional 500 pounds of the same commodity. The regulations state that the shipper is only required to provide placards for the commodity that is being offered, not for the aggregate weight of both shipments. In this scenario, the driver is responsible for providing placards since it involves a combination load.
The Hazardous Materials Regulations are complex, especially for newer employees. Drivers that can speak “hazmat” to shippers often secure additional business, so be sure to train your drivers and give them the confidence to have impactful conversations with shippers.
Key to remember: Carry extra placards in case a shipper is unable to supply the required placards or a combination of hazmat on the vehicle requires different placards.
NewsIndustry NewsHazmat PlacardingHazmat SafetyFocus AreaIn-Depth ArticleHazmat markings, Placards, and LabelsEnglishTransportationUSA
2025-03-20T05:00:00Z
Knowing the ins and outs when transporting diesel
If you work with heavy equipment or vehicles, it's likely they run on diesel fuel. You probably already know that driving these machines to the nearest gas station isn't practical. So, what's the solution? The simplest approach is to bring the diesel fuel directly to your equipment.
Transporting diesel fuel raises a lot of questions about it being regulated as hazmat and the requirements for placarding. This guide provides an overview of what to look out for when transporting diesel fuel, ensuring compliance with the Hazardous Materials Regulations (HMR). Let’s take a closer look at what you need to look for.
Bulk and non-bulk packaging
Understanding the difference between bulk and non-bulk packaging is important when you are transporting diesel fuel because it can determine if the HMR applies or not.
Bulk packaging: This type of packaging does not have an intermediate form of containment and has a capacity greater than 119 gallons for a liquid hazardous material (hazmat). Bulk packages are easily recognizable because of their size and include IBCs, cargo tanks, and portable tanks.
Non-bulk packaging: This type of package has a maximum capacity of 119 gallons or less. Non-bulk packages are smaller and can easily fit into other packages or vehicles and include bottles, buckets, and drums.
The key here is the CAPACITY of the packaging, not how much liquid is in the packaging. For example, if you have a 250-gallon IBC but only have 20 gallons of liquid inside the IBC, it’s still a bulk packaging and you need to follow the requirements for bulk packages regardless of how much liquid is inside.
Reclassifying diesel
Diesel fuel is normally classified as a Class 3 flammable liquid in the HMR. However, diesel fuel can also be reclassified as a combustible liquid. According to 49 CFR 173.150(f), a flammable liquid with a flash point at or above 100º F (38º C) that does not meet the definition of any other hazard class may be reclassified as a combustible liquid.
Reclassifying diesel fuel as a combustible liquid does offer some advantages:
- Non-bulk packaging: 49 CFR 173.150(f)(2) says that “the requirements of this subchapter do not apply to combustible liquids in non-bulk packaging.” That means diesel fuel in non-bulk packaging is not regulated by the HMR and is essentially considered general cargo. Meaning the following are not required: specification packaging, markings, labels, placards, or hazmat shipping papers.
- Bulk packaging: Unfortunately, bulk packages of combustible liquids don’t have the same exemptions as non-bulk combustible liquids. However, bulk packages of combustible liquids are exempt from the security plan requirements of the HMR.
When to placard
Placarding requirements can depend on several factors such as hazard classification, package size, and total quantity.
For non-bulk packages of diesel fuel that haven’t been reclassified to a combustible liquid, placarding is required when the total weight of diesel fuel in non-bulk packages meets or exceeds 1,001 pounds. If your diesel fuel in non-bulk packages has been reclassified to a combustible liquid, then placards are not required because combustible liquids in non-bulk packages are not subject to the HMR, 173.150(f)(2).
Placards are always required for diesel fuel in bulk packages. With that said, if your diesel fuel has been reclassified to a combustible liquid, you have the option to use the all-red placard or the red placard with a white bottom. If you are transporting combustible liquids by rail, you must use the red placard with the white bottom. If your diesel fuel has not been reclassified, then you must use the all-red placard.
Need additional information on the combustible placard? Check out this FAQ.
Key to remember: Ensure you understand the difference between bulk and non-bulk packages of diesel fuel. Reclassifying your non-bulk packages of diesel fuel to a combustible liquid exempts you from the requirements of the HMR.
NewsClassification - HazmatPipeline and Hazardous Materials Safety Administration (PHMSA), DOTChange NoticesChange NoticeHazmat SafetyHazmatFocus AreaEnglishTransportationUSA
2026-06-02T05:00:00Z
PHMSA Final Rule: Hazardous Materials: Streamlining Requirements for the Approval of Certain Energetic Materials
PHMSA is amending the Hazardous Materials Regulations (HMR) by streamlining the classification and approval process for transporting certain low-hazard fireworks, revising the criteria for small arms cartridges to include tracer ammunition as eligible for self-classification, designating the PHMSA portal as the sole method to submit applications for all explosives approvals, and authorizing voluntary termination of an explosive approval by the approval holder.
DATES:
Effective Date: This final rule is effective on July 2, 2026. The incorporation by reference of certain material listed in this rule was approved by the Director of the Federal Register as of December 28, 2020. Voluntary Compliance Date: June 2, 2026. Delayed Compliance Date: August 31, 2026.
Published in the Federal Register June 2, 2026, page 32889.
View final rule.
| §107.705 Registrations, reports, and applications for approval. | ||
| (a)(1) | Revised | View text |
| §107.713 Approval modification, suspension or termination. | ||
| (c) introductory text | Revised | View text |
| (e) | Added | View text |
| §171.8 Definitions and abbreviations. | ||
| Definition for ”FW number” | Added | View text |
| §173.56 New explosives—definition and procedures for classification and approval. | ||
| (h)(3) | Revised | View text |
| §173.59 Description of terms for explosives. | ||
| Description for ”Low hazard fireworks” | Added | View text |
| §173.63 Packaging exceptions. | ||
| (b)(1)(ii) | Revised | View text |
| §173.64 Exceptions for Division 1.3 and 1.4 fireworks. | ||
| Entire section | Revised | View text |
Previous Text
§107.705 Registrations, reports, and applications for approval.
* * * *
(a)(1) File the registration, report, or application with the Associate Administrator for Hazardous Materials Safety (Attention: Approvals, PHH–32), Pipeline and Hazardous Materials Safety Administration, U.S. Department of Transportation, East Building, 2nd Floor, E23–406, 1200 New Jersey Avenue, SE., Washington, DC 20590– 0001. Alternatively, the document with any attached supporting documentation in an appropriate format may be filed by facsimile (fax) to: (202) 366–3753 or (202) 366–3308 or by electronic mail (e-mail) to: approvals@dot.gov
§107.713 Approval modification, suspension or termination.
* * * *
(c) Except as provided in paragraph (d) of this section, before an approval is modified, suspended or terminated, the Associate Administrator notifies the holder in writing of the proposed action and the reasons for it, and provides an opportunity to show cause why the proposed action should not be taken.
§173.56 New explosives—definition and procedures for classification and approval.
* * * *
(h)(3) Ammunition with inert projectile or blank ammunition; and
§173.63 Packaging exceptions.
* * * *
(b)(1)(ii) Cartridges, small arms, Cartridges, power device (used to project fastening devices), Cartridges for tools, blank, and Cases, cartridge empty with primer that may be shipped as a limited quantity are as follows:
(A) Ammunition for rifle, pistol or shotgun;
(B) Ammunition with inert projectiles or blank ammunition;
(C) Ammunition having no tear gas, incendiary, or detonating explosive projectiles;
(D) Ammunition not exceeding 12.7 mm (50 caliber or 0.5 inch) for rifle or pistol, cartridges or 8 gauge for shotshells;
(E) Cartridges for tools, blank; and
(F) Cases, cartridge, empty with primer.
(G) Cartridges, power device (used to project fastening devices).
§173.64 Exceptions for Division 1.3 and 1.4 fireworks.
(a) Notwithstanding the requirements of §173.56(b), Division 1.3 and 1.4 fireworks (see §173.65 for Division 1.4G consumer fireworks) may be classed and approved by the Associate Administrator without prior examination and offered for transportation if the following conditions are met:
(1) The fireworks are manufactured in accordance with the applicable requirements in APA 87-1A, 87-1B, and 87-1C (IBR, see §171.7 of this subchapter);
(2) The device must pass a thermal stability test conducted by a third-party laboratory, or the manufacturer. The test must be performed by maintaining the device, or a representative prototype of a large device such as a display shell, at a temperature of 75°C (167°F) for 48 consecutive hours. When a device contains more than one component, those components that could be in physical contact with each other in the finished device must be placed in contact with each other during the thermal stability test;
(3) The manufacturer applies in writing to the Associate Administrator following the applicable requirements in APA 87-1A, 87-1B, and 87-1C and is notified in writing by the Associate Administrator that the fireworks have been classed, approved, and assigned an EX number. Each application must be complete and include all relevant background data and copies of all applicable drawings, test results, and any other pertinent information on each device for which approval is being requested. The manufacturer must sign the application and certify that the device for which approval is requested conforms to the appropriate APA Standard, that the descriptions and technical information contained in the application are complete and accurate, and with respect to APA 87-1A that no duplicate application has been submitted to a fireworks certification agency. If the application is denied, the manufacturer will be notified in writing of the reasons for the denial. The Associate Administrator may require that the fireworks be examined by an agency listed in §173.56(b)(1) of this part.
(b) [Reserved]
Most Popular Highlights In Human Resources
NewsIndustry NewsRecruiting and hiringHR GeneralistBackground ChecksIn-Depth ArticleFair Credit Reporting Act (FCRA)Associate RelationsEnglishUSAHR ManagementFocus AreaTalent Management & RecruitingHuman Resources
2026-06-10T05:00:00Z
Applicant says trucking company’s background check forms were too confusing and files class action
An applicant for a trucking job alleged that the company violated the Fair Credit Reporting Act (FCRA) by making background check disclosure forms too complicated. He filed a class action on behalf of applicants and employees who had received the forms.
In Askins v. CRST Expedited, Inc., a California appellate court addressed whether workers or job applicants must show actual harm in order to sue under the federal FCRA for improper background check disclosures.
Background
The complainant had applied for a job with a trucking company. During the hiring process and employment, the company conducted background checks and provided disclosure and authorization forms related to those checks.
The FCRA requires background check forms to be stand-alone documents. It states that before a background check, called a consumer report, can be ordered for employment purposes, a document that “consists solely of the disclosure that a consumer report may be obtained for employment purposes” must be provided to the applicant or employee.
The complainant alleged, however, that the forms provided by the trucking company violated the FCRA because they:
- Were confusing,
- Contained extraneous information, and
- Didn’t comply with the law’s standalone disclosure requirements.
He filed a class action on behalf of applicants and employees who allegedly received noncompliant disclosure and authorization forms before background checks were obtained. A trial court initially certified the class, but later, relying on another California case, Limon v. Circle K Stores Inc., the employer argued the class should be decertified because the driver couldn’t show a “concrete injury” or actual harm from the alleged FCRA violations. The trial court agreed and decertified the class. An appeal was filed.
Appellate court’s decision
The California Court of Appeal reversed the decertification order and held that:
- The FCRA allows recovery of statutory damages for willful violations even when no actual harm or concrete injury can be proven; and
- A violation of the employee’s statutory rights under the FCRA is enough to establish standing in California state court.
The court emphasized that Congress intentionally created statutory damages under the FCRA to allow claims even where measurable harm couldn’t be shown. It also rejected the reasoning from Limon, concluding that the earlier case interpreted the statute too narrowly.
The appeals court sent the case back to the trial court for further proceedings.
Employer takeaways
Despite this ruling coming from a California appeals court, the FCRA is a federal law, so employers nationwide should view this case as a reminder that FCRA compliance matters.
The case shows that:
- Employers may face FCRA class actions even when applicants or employees can’t show actual harm or financial loss.
- Background check disclosure and authorization forms should be reviewed carefully for strict compliance with the FCRA’s standalone disclosure requirements.
- Forms should be clear, concise, and free from unrelated or extraneous information.
- Employers using background checks should audit onboarding packets and vendor-provided forms regularly.
Key to remember: A ruling from a California appeals court should serve as a reminder to employers nationwide that FCRA forms must be clear and concise.
NewsFamily and Medical Leave Act (FMLA)New JerseyLeaveTime offHR ManagementEnglishLeaveFamily and Medical Leave Act (FMLA)Associate Benefits & CompensationDisability BenefitsChange NoticesChange NoticeHR GeneralistAssociate RelationsFocus AreaHuman Resources
2026-06-11T05:00:00Z
New Jersey Family Leave Act expanded
Effective date: July 17, 2026
This applies to: Employers with 15 or more employees in New Jersey as of July 17, 2026.
Description of change: More employers will be covered by the law, and more employees will be eligible to take New Jersey Family Leave Act (NJFLA) leave.
On July 17, 2026, employers with 15 or more employees are covered by the law.
Currently, for employees to be eligible for NJFLA job-protected leave, they must have:
- Worked for the employer for at least 12 months, and
- Performed at least 1,000 hours of work in the last 12 months.
The law is changed such that for employees to be eligible for NJFLA, they must have:
- Worked for the employer for at least 3 months, and
- Performed at least 250 hours of work in the preceding 3 months.
Employees who utilize New Jersey Temporary Disability Insurance benefits (TDI) for their own medical needs have additional protections. Employers must restore employees to their position or a position of equivalent seniority, pay, and benefits upon their return.
Employees control the sequence of what form of leave to use, whether TDI, NJFLA, or earned sick leave; thereby allowing stacking of leave. Employers may not dictate the sequence.
View related state info: FMLA – New Jersey
NewsIndustry NewsIndustry NewsHR GeneralistFamily and Medical Leave Act (FMLA)Family and Medical Leave Act (FMLA)USAHR ManagementEnglishFocus AreaHuman Resources
2023-09-06T05:00:00Z
Appellate court sided with employee's (almost) 3-year-delayed FMLA claim
Back in October 2018, Laffon had a medical emergency and needed some time off under the federal Family and Medical Leave Act (FMLA).
Her leave lasted until November 15. Ten days after she returned to work, on November 26, her employer terminated her.
She sued, arguing that the employer retaliated against her because of her FMLA leave.
The catch? She didn't bring the suit until almost three years later.
No link between leave and termination
In court, the employer argued that there was no causal link between Laffon taking FMLA leave and her termination. Although the court documents aren't robust, they do reveal that the employer indicated that Laffon's allegations didn't show that her taking FMLA leave was a factor in the decision to terminate her. The documents showed only that the termination chronologically followed her leave.
The court agreed with the employer. It also agreed that Laffon failed to allege a willful violation of the FMLA, which would allow her to benefit from the FMLA's three-year statute of limitations.
Laffon appealed the case to the Ninth Circuit.
Statute of limitations
Under the FMLA, employees have two years from the date of the last event constituting the alleged violation for which they can bring a claim.
Those two years are extended to three years if the employer's actions were "willful." This means that an employee must show that the employer either knew or showed reckless disregard for whether its conduct violated the FMLA.
Ruling overturned
Fast forward to August 2023, when the Ninth Circuit reversed the lower court's decision. It indicated that, based on Laffon's amended complaint and liberally construing the law, her allegations establish that her leave was causally connected to her termination and that the employer's action (her termination) was willful.
Glymph v. CT Corporation Systems, No. 22-35735, Ninth Circuit Court of Appeals, August 22, 2023.
Key to remember: Terminating an employee soon after returning from FMLA leave is risky, unless there is a clear, well-documented, non-leave-related reason. Case documents did not show such a clear reason, which can also increase the risk of a willful finding. Employees have time to file claims, even years.
NewsEnglishChange NoticesChange NoticeColoradoAssociate RelationsAssociate Benefits & CompensationHR GeneralistLeaveTime offHR ManagementLeaveFocus AreaHuman Resources
2026-06-16T05:00:00Z
Colorado employee voting leave law expands
Effective date: June 1, 2026
This applies to: Employers with employees in Colorado
Description of change: Effective June 1, 2026, employees may take up to 2 hours of job-protected, paid time off any day when voter service and polling centers are open.
Previously, voting leave was only required on the day of the election.
Because polling centers are open well before Election Day, employees now have a bigger window during which they may request this leave.
Employees must apply for the voting absence before the day of the election for which leave is requested.
The change also specifies that employers may deny an employee's request for voting leave if the employee has 3 or more consecutive hours off while the polls are open.
View related state info: Leave - Colorado
NewsIndustry NewsAssociate RelationsHR GeneralistIn-Depth ArticleLabor Law PostersHR ManagementEnglishLabor Law PostersUSAFocus AreaHuman Resources
2026-06-01T05:00:00Z
Be ready for summertime workplace posting updates
Summer brings vacations, sunshine, and relaxation as well as some mid-year workplace posting updates. Before hitting beach or jumping in the pool this year, be aware that these posting changes are on deck:
Alaska: The minimum wage increases to $14 per hour on July 1, and an updated Minimum Wage poster is needed. In addition, an updated Safety and Health Protection on the Job posting is also required, as the state has updated information about how to file a discrimination complaint. Employers can also display an updated Child Labor posting, as it includes new address information.
District of Columbia: The district’s minimum wage will increase to $18.40 per hour on July 1, bringing mandatory changes to the Minimum Wage and Universal Wage Law postings. In addition, the district’s Time Off to Vote posting has been revised with information about fall elections and the updated version needs to be posted.
Nevada: Although the state’s minimum wage will remain at $12 per hour, the state releases new Minimum Wage and Overtime Bulletins each year. Employers will need to display the annual bulletins showing the minimum wage and overtime rates in effect as of July 1.
Nebraska: Amendments to the state’s Wage and Hour Act bring changes to the youth minimum wage for workers ages 14 and 15 and the training wage, with both set at $13.50 per hour as of July 17. This is likely to bring a mandatory posting change to the state’s Minimum Wage poster.
Oregon: The minimum wage will increase on July 1, bringing a mandatory change to the state’s Minimum Wage poster. The new standard rate will be $15.05 per hour. The rate will be $14.05 per hour in nonurban counties and $16.30 per hour in the Portland Metro area.
New Jersey: The state’s Family Leave Act will apply to more employers as of July 17 and will be coordinated with other state leave laws. This may bring changes to the Temporary Disability Insurance, Family Leave Insurance, and Earned Sick Leave Laws postings, as will the Family Leave Act posting.
Virginia: The state’s Covenants Not to Compete law, which currently covers low wage workers, will be revised on July 1 to cover more employees. The revised law will need to be posted, as the law requires employers to post a copy of that section of the state code.
Local minimum wage changes
Some cities and counties raise their minimum wage on July 1. Employers in these communities should be ready to display updated posters:
California
- Alameda
- Berkeley
- Emeryville
- Fremont
- Los Angeles
- Los Angeles County
- Malibu
- Milpitas
- Pasadena
- San Francisco
- Santa Monica
- Santa Rosa
- West Hollywood
Illinois
- Chicago
- Cook County
Maryland
- Howard County
- Montgomery County
Minnesota
- St. Paul
Key to remember: Some states, cities, and counties make mandatory mid-year posting changes. Employers should be ready to display the updated posters.
NewsTime ClocksBefore and After Work ActivitiesUSAHR ManagementEnglishAssociate Benefits & CompensationIndustry NewsIndustry NewsWage and HourEmployee BenefitsWage and HourPreparatory and Concluding Activities/Time CardsBreaks and Meal PeriodsEmployee BenefitsHours WorkedHR GeneralistFair Labor Standards Act (FLSA)Focus AreaHuman Resources
2026-06-05T05:00:00Z
DOL answers FLSA questions with 4 opinion letters
On May 28, the U.S. Department of Labor (DOL) issued four new opinion letters that answer questions about complying with the federal Fair Labor Standards Act (FLSA).
The agency provided insight into these issues:
Can an exempt employee also do non-exempt work and be paid hourly for it?
Yes, under the federal FLSA. An exempt employee can take on extra non-exempt work in a second role and be paid an hourly rate for that work without losing exempt status, as long as the employee’s main duty is still exempt work and the salary basis requirements are still met. In that case, the arrangement doesn’t automatically create overtime obligations.
In the example described by the DOL, an exempt employee worked additional non-exempt weekend shifts. The employer paid an hourly rate for those extra shifts, but the employee still received their full salary each week, no matter how many extra shifts they worked.
Can a quarterly bonus be paid without recomputing the regular rate and still comply with the FLSA?
Yes. A quarterly bonus can comply with the FLSA if it is calculated using a percentage of total earnings. In using that method, using both straight and overtime earnings, the bonus includes payment of the overtime premium that is due, and the employer doesn’t need to go back and recalculate the employee’s regular rate or pay extra overtime.
Do employers have to pay employees for time spent leaving the worksite during a meal break?
No. If the employer provides a true 30-minute meal period and the employees are fully relieved of duties during that time, the employer doesn’t have to pay employees for time spent voluntarily leaving the worksite to get or eat a meal.
The employer also doesn’t have to extend the meal period to cover the time employees spend leaving and returning to the work area before and after the meal.
Can employers avoid paying for pre-shift activities and waiting time, and round to the scheduled start time?
It depends on what the employee is doing before the shift begins. If the pre-shift activity is an integral part of the employee’s main job duties, that time must be paid. But employers generally don’t have to pay for time spent on activities such as waiting in line to clock in or out, as long as those activities happen before the employee begins principal work or after that work has ended.
The DOL warned, however, that rounding practices can violate minimum wage or overtime rules if employees are already doing compensable work before their scheduled shift starts.
In the example described, a company allowed employees to clock in up to 7 minutes early to reduce lines at time clocks. The system rounded those times to the scheduled shift start. But because some employees began working right after clocking in, the employer had to pay them for that time. The DOL noted that rounding to the shift’s start time, especially across a large workforce, could be seen as consistently favoring the employer.
Employers should be mindful of state or local requirements, as they might differ from federal requirements.
Key to remember: FLSA compliance depends on the specific facts and circumstances of each situation, but recent opinion letters from the DOL provide insight into how it looks at certain issues relating to bonuses, mealtimes, time clock rounding, and exempt employees doing nonexempt work.
Most Popular Highlights In Safety & Health
NewsIndustry NewsSafety and Health Programs and TrainingSafety & HealthConstruction SafetyGeneral Industry SafetyExpert InsightsSafety and Health Programs and TrainingEnglishFocus AreaUSA
2026-06-12T05:00:00Z
Expert Insights: Coaching safety on the front line
Frontline managers play one of the most critical roles in workplace safety, yet they often face the greatest challenges. Positioned between senior leadership expectations and frontline realities, they are responsible for translating and coordinating safety from a written policy into everyday practice.
Whether safety becomes proactive and sustainable or reactive and compliance driven often depends on how well these leaders are supported and equipped to lead.
Reactive or proactive…that is the question
A key shift many organizations must make is moving from a “safety cop” mindset to a “safety coach” approach. Reactive leadership tends to emerge only after an incident occurs, focusing on enforcement and documentation. Proactive leadership intervenes before someone gets hurt by asking questions, listening to employees, identifying hazards early, and working together to fix issues. When safety happens with employees instead of to them, engagement and accountability increase.
That shift begins with upper management who sets the tone, provides resources, and signals what truly matters. True commitment is demonstrated by where leaders focus their time, how visible they are, and how they behave day to day. When safety is linked to business goals such as productivity, quality, and cost control, it becomes part of how decisions are made rather than a competing priority.
Actionable goals for upper management include:
- Link safety to business performance by tying injury trends, near miss data, and hazard correction rates to cost savings and productivity.
- Include safety in leadership key performance indicators and reviews, so leaders are held accountable for participation and results.
- Be visibly involved in safety walks, toolbox talks, audits, and frontline conversations.
- Shift focus to leading indicators such as training participation, near miss reporting, and corrective action closure.
- Recognize proactive safety success, not just react to incidents after they occur.
When senior leaders consistently show these behaviors, they give frontline managers the confidence and support to focus on preventing problems instead of reacting to them.
Safety culture improves when employees help shape it
Safety culture is realized at the employee level. Frontline managers are the bridge between leadership intent and workforce action. Employees are far more likely to engage when they see leaders listen, follow through, and set clear expectations.
Actionable goals for engaging employees include:
- Lead by example every day by consistently following safety rules, procedures, and PPE requirements.
- Involve employees early in hazard assessments, process changes, equipment trials, and pilot programs.
- Define specific, observable safe behaviors for each role instead of using blanket safe work practices and vague messages like “be careful.” •Integrate safety into daily routines such as shift huddles, job planning, and production meetings.
- Make reporting easy and safe with simple tools, anonymous options if needed, and zero tolerance for retaliation.
- Recognize and reinforce safe behaviors through immediate verbal feedback and formal recognition programs.
- Empower stop work authority and openly support employees who speak up when something isn’t safe.
Training reinforces these efforts when it is practical, hands on, and continuous. Adults learn best through real world application, discussion, and reinforcement, not annual check the box training alone. Short toolbox talks, demonstrations, and regular reminders keep safety relevant and actionable.
As you consider your organization’s safety leadership, remember that when leaders support frontline managers who stay connected to their teams, safety is built into how work gets done.
NewsIndustry NewsEnglishSafety & HealthConstruction SafetyGeneral Industry SafetyIn-Depth ArticleHazard CommunicationHazard CommunicationHazcom LabelingUSAFocus AreaHazCom Written ProgramHazCom Information and Training
2026-05-28T05:00:00Z
November's HazCom GHS 7 Deadline: What employers need to know
OSHA’s updated Hazard Communication Standard, now aligned with the 7th revised edition of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS 7), is being rolled out in phases. One deadline passed in May, and the next arrives in November. For employers, this means now is the time to start making updates. This revision introduces enough meaningful changes that relying on an old hazard communication checklist will not be enough.
First, a Quick Refresher on What HazCom Actually Is
At its core, OSHA’s Hazard Communication Standard is designed to make sure workers know what chemicals they are working with and what hazards those chemicals present. It covers the labels on chemical containers, the Safety Data Sheets (SDSs) that provide detailed hazard information, and the training employees need so they can understand and use that information effectively.
HazCom is tied to the Globally Harmonized System, or GHS, an international framework developed by the United Nations to create a more consistent approach to classifying and communicating chemical hazards. When the UN updates the GHS, OSHA eventually updates HazCom to better align with it. That is what is happening now with GHS 7, and those updates are beginning to work their way into supplier documents and workplace compliance expectations.
What’s Actually Changing in GHS 7
So what is different this time? GHS 7 includes several substantive changes that affect how chemicals are classified, how SDSs are written, and how labels are presented. These are not just wording updates. In some cases, they can change how hazards are described and how information is communicated to workers. The changes are:
- New and Revised Hazard Categories: GHS 7 expands classification for certain health and physical hazards. Desensitized explosives, for example, now have their own hazard class. Some existing categories have been refined with new subcategories that require different labeling and SDS language.
- Updated SDS Requirements: Section formatting and content requirements are being revised in several areas. Employers and chemical manufacturers will need to review existing SDS documents to ensure they reflect the updated classification criteria and language. If you’re an employer who receives SDS from suppliers, you’ll need to verify that incoming documents meet the new standard.
- Label Changes: Some products will require updated pictograms, signal words, or hazard statements based on reclassification under GHS 7. That means physical labels on containers may need to be reprinted and replaced.
- Exposure Limits and Inhalation Hazards: GHS 7 brings more specificity to how inhalation hazards are communicated, particularly for aerosols and mixtures.
What the May Deadline Covered
OSHA’s GHS 7 update was not designed as a single cutoff date. Instead, it was rolled out in phases, with different obligations applying at different points in time. The May 2026 deadline primarily affected chemical manufacturers, importers, and distributors. By then, those upstream parties were expected to update chemical classifications and begin issuing labels and SDSs that align with the revised standard.
For employers, that phase matters because it marks the point when updated information should begin flowing into the workplace. If you receive hazardous chemicals from suppliers, the SDSs and shipped labels you get should increasingly reflect the new classification language and formatting requirements.
That does not mean employers can treat compliance as only a supplier issue. You are still responsible for making sure the SDSs in your workplace are current, your labels reflect the hazards of the chemicals in use, and employees are trained on the information they rely on. If a supplier is slow to update documentation, that gap can quickly become your problem during an inspection.
That is why now is the time to start reaching out to chemical vendors and reviewing your own program. Ask suppliers whether their SDSs have been updated to GHS 7 standards, track what you receive, and follow up on anything that is missing or unclear. November will arrive quickly, and employers that wait too long may find themselves rushing through updates that should have been planned in advance.
Roadmap for November Update
The best way to approach the November deadline is as a practical compliance project rather than a last-minute document review.
- Chemical inventory audit: You cannot update what you have not identified, so pull together a complete inventory of every chemical in the workplace, including cleaning products, maintenance supplies, and production materials. That inventory becomes the baseline for everything that follows.
- Review and update your SDS library: Contact suppliers and request GHS 7-compliant SDSs for each product on your inventory. Do not assume existing files are already current. Create a simple tracking system so you know which documents have been updated, which are still pending, and where follow-up is needed.
- Audit your physical labels: Walk the facility and compare container labels to the updated hazard information you are receiving. If products have been reclassified or now use different pictograms, signal words, or hazard statements, your in-house labels may also need to change. Starting early is important, especially for larger facilities where relabeling can take time.
- Revise your written HazCom program: This should be treated as a living document that reflects current practice. Review it carefully and update language, procedures, and responsibilities so they align with the revised standard and with the way your facility actually manages chemical hazards.
- Retrain your workforce and brief supervisors: Employees need to understand what changed, what updated labels and SDSs mean, and how those changes affect handling, storage, and response expectations. Supervisors should receive deeper guidance so they can answer questions, recognize compliance gaps, and reinforce the updated program in day-to-day operations.
Key to remember: Now is the time to prepare for November's Hazard Communication Standard deadline.
NewsFire Protection and PreventionIn-Depth ArticleEnglishEmergency Planning - OSHAIndustry NewsSafety & HealthEmergency PreparednessEmergency Planning (OSHA)Emergency ExitsExit RoutesConstruction SafetyGeneral Industry SafetyAgriculture SafetyMaritime SafetyFire Protection and PreventionMine SafetyFocus AreaUSA
2023-12-28T06:00:00Z
Does my office need an exit sign?
One of the most common questions inspectors get when evaluating workplace emergency safeguards is, “Does my office need an exit sign?” Section 29 CFR 1910.37 requires employers to provide specific safeguards and operational features for exit routes. OSHA’s intent is to minimize danger to employees and requiring proper exit route marking is one way to do so.
In short, smaller rooms or offices with only one door don’t necessarily need an exit sign. OSHA standards for exit signage are based on NFPA 101, Life Safety Code, which OSHA incorporated by reference. OSHA 1910.37(b)(4) states, “If the direction of travel to the exit or exit discharge is not immediately apparent, signs must be posted along the exit access indicating the direction of travel to the nearest exit and exit discharge. Additionally, the line-of-sight to an exit sign must clearly be visible at all times.”
Other exit signage requirements to consider
The International Fire Code (IFC) was not adopted by OSHA; however, it’s likely to be referenced by local fire marshals. The IFC states, “Exit signs are not required in rooms or areas that require only one exit or exit access.” Generally, a room or area that holds fewer than 50 people is permitted to have only one exit. These rooms are typically smaller with an exit that is close and obvious, so an exit sign shouldn’t be needed inside the room. For example, individual offices, small conference rooms, storage rooms, and bathrooms usually don’t have exit signs because the way out is obvious.
Additional requirements for office exits require they:
- Are free of obstructions. No materials or equipment may be placed, either permanently or temporarily, within the exit route.
- Are arranged so that employees aren’t required to travel toward a high hazard area unless the path of travel is effectively shielded from the high hazard area by suitable partitions or other physical barriers.
- Don’t pass through a room that can be locked, such as a bathroom, to reach an exit or exit discharge, or lead into a dead-end corridor.
- Are adequately lighted so that an employee with normal vision can see along the exit route.
- Have each exit route door be free of decorations or signs that obscure the visibility of the exit route door.
Key to remember
When considering exit signs for smaller offices, employers must determine the size of the room, path of travel to an exit, and how obvious the exit would be based on room size. Generally, a room intended to hold fewer than 50 people is permitted to have only one exit and would not require an exit sign.
NewsIndustry NewsAt-Will EmploymentSafety & HealthGeneral Industry SafetyTerminationHR GeneralistIn-Depth ArticleUSAHR ManagementEnglishTerminationFocus AreaHuman Resources
2024-08-28T05:00:00Z
When to skip a PIP and move to terminate an employee
The U.S. Bureau of Labor statistics reported in July 2024 that there are 8.2 million job openings in the U.S., but only 7.2 million unemployed workers.
With that in mind, employers might choose to hang onto employees even if they’re under performing. But what about when complaints are rolling in from different angles? Take, for example, a lackluster supervisor who’s annoying employees and disappointing customers.
An employer could be hesitant to let the supervisor go, especially if there’s no documentation backing up claims of misconduct. The employer must weigh their options to decide if putting the supervisor on a performance improvement plan (PIP) or moving right to termination is the ideal choice.
At-will employment
For starters, in most states employers may terminate an employee at-will, meaning they can fire employees for pretty much any reason as long as it doesn’t discriminate against someone in a protected class based on sex, age, race, religion, etc. Employers also cannot terminate in retaliation for an employee making a claim of harassment, discrimination, or safety concerns.
Aside from these limits, employers can terminate employees for good cause, bad cause, or no cause at all.
PIP or terminate
Deciding whether to put an employee on a PIP or terminate must be decided on a case-by-case basis.
A PIP is usually for job performance issues (hence, performance improvement plan). This could mean anything from not making enough sales to being inept at the job’s essential functions. If job performance doesn’t improve under the PIP, termination may be the end result depending on company policies and practices.
Even if an employee has job performance issues, the employer can terminate without going through the PIP process first, unless the usual process is to implement a PIP with employees who have had similar problems. In that case, not doing a PIP could be seen as discrimination against an employee, especially if the person falls into a protected class.
Workplace misconduct, however, is another situation altogether. This could be anything from a one-off poor joke to pervasive harassment. Snapping at customers or coworkers (or worse), for example, is a conduct issue. An employer could issue a warning or move right to termination if the behavior is clearly illegal or a serious threat to workplace safety.
| Read more: ezExplanation on discharging employees |
Termination tips
If an employer decides to terminate, they should treat the employee as respectfully as possible during the termination process. Also, an employer should carefully and clearly communicate the job-related reasons for the termination to avoid any hint of discrimination. Lastly, an employer should document the reasons and reiterate the steps taken leading up to the termination and keep those records handy in case the employee files a wrongful termination lawsuit.
Key to remember: Employers sometimes struggle when making termination decisions. Having a process in place and documenting steps along the way can help if a case lands in court.
NewsIndustry NewsSafety & HealthHand and Other Portable Powered ToolsGeneral Industry SafetyTool SafetyAir Compressor SystemsIn-Depth ArticleTool SafetyEnglishFocus AreaUSA
2022-06-13T05:00:00Z
Cleaning with compressed air: Making sense of the OSHA regulation
It is a common sight in many workplaces to see employees using compressed air to clean parts, equipment, and even clothing. What many workers and some employers do not realize is that compressed air can be deadly. That is why OSHA has a regulation prohibiting the use of compressed air for cleaning unless the dead-end pressure is reduced to below 30 psi, and then only with effective chip guarding and PPE.
The regulation Federal OSHA’s requirement for cleaning with compressed air is in 1910.242(b):
- “Compressed air used for cleaning. Compressed air shall not be used for cleaning purposes except where reduced to less than 30 psi and then only with effective chip guarding and personal protective equipment.” Because the regulation is short and somewhat vague, OSHA has clarified the issue in a compliance directive and letters of interpretation.
What is “chip guarding”?
“Effective chip guarding” means any method or equipment which will prevent a chip or particle (of whatever size) from being blown into the eyes or unbroken skin of the operator or other workers.
Effective chip guarding may be separate from the air nozzle as in the case where screens or barriers are used. The use of protective cone air nozzles are acceptable in general for protection of the operator, but barriers, baffles or screens may be required to protect other workers if they are exposed to flying chips or particles.
What about the psi requirement?
The regulation requires the psi at the nozzle to be less than 30 when using compressed air for cleaning.
However, OSHA has said in interpretive guidance that the use of compressed air for cleaning purposes at pressures at or greater than 30 psi is permissible if the outlet or source is fitted with a relief device or air ports that drop the pressure to less than 30 psi if the flow is dead-ended.
What about cleaning clothing/bodies?
While the regulation does not specifically address the issue, in a letter of interpretation OSHA said that employers should not allow employees to use compressed air for cleaning themselves or their clothing in general industry situations. The eyes and other body parts, such as the respiratory system, may be damaged as the result of inadequate personal protective equipment, lack of chip guards, and/or uncontrolled release of compressed air.
The dangers
There are numerous dangers of improperly using compressed air:
- Embolism: If compressed air enters the bloodstream through a body opening or skin break, it can create an embolism (air bubble) that can be life threatening.
- Eye damage: Particles that are being blown can “blow back” and strike the eyes. The air itself can also cause injury if it is pointed toward the eyes.
- Hearing loss: Some compressed air equipment can be loud enough to damage hearing. Always wear proper PPE.
- Combustible dust: If compressed air is used to blow certain dusts, it can create a suspension in the air that could ignite if there is an ignition source.
- Respiratory: Particles or air can enter the respiratory system, posing deadly hazards.
- Whips: If not properly secured, hoses can whip and cause severe injury.
Workers must be trained that even extremely low pressures, such as 5 or 10 psi, can still cause severe damage if pointed toward the body, particularly the mouth, eyes, ears, or open areas in the skin.
Employers should train employees on the dangers of compressed air, and ensure the equipment is equipped with the necessary safety features and is properly maintained.
Supervisors should watch for improper use, particularly horseplay, and initiate corrective action. In addition, for many applications, a broom or shop vacuum may be just as effective at cleaning, and much safer. Compressed air may seem harmless, but if strict safeguards and practices are not utilized it can be deadly.
NewsPersonal Protective EquipmentBenzeneFormaldehydeMethylene ChlorideWalking Working SurfacesWalking Working SurfacesCarcinogensEnglishAsbestosCadmiumIndustry NewsIndustry NewsLeadSafety & HealthConstruction SafetyGeneral Industry SafetyMaritime SafetyAcrylonitrileSafety Color CodingCotton DustEthylene OxideRespiratory ProtectionSigns and MarkingsCoke Oven EmissionsFocus AreaToxic and Hazardous Substances - OSHAUSA
2026-06-03T05:00:00Z
OSHA to hold public hearings on multiple proposed rules
OSHA will hold a series of informal, virtual public hearings on multiple proposed rules beginning on August 19, 2026. The majority relate to respiratory protection requirements for different chemical substances. All of the proposed rules were published in the Federal Register on July 1, 2025, except for the Walking-Working Surfaces proposal, which was published on April 6, 2026.
| Standards Impacted 29 CFR | Standard Name |
| 1910.1044 | 1,2-dibromo-3-chloropropane |
| 1910.1051 | 1, 3- Butadiene |
| 1910.1003 | 13 Carcinogens (4- Nitrobiphenyl, etc.) |
| 1910.1045 | Acrylonitrile |
| 1910.1001 | Asbestos |
| 1910.1028 | Benzene |
| 1910.1027 and 1926.1127 | Cadmium |
| 1910.1029 | Coke Oven Emissions |
| 1910.1043 | Cotton Dust |
| 1910.1047 | Ethylene Oxide |
| 1910.1048 | Formaldehyde |
| 1910.1018 | Inorganic Arsenic |
| 1910.1025 and 1926.62 | Lead |
| 1910.1052 | Methylene Chloride |
| 1910.1050 and 1926.60 | Methylenedianiline |
| 1910.1017 | Vinyl Chloride |
| 1910.134 | Respiratory Protection |
| 1910.144, 1910.262, 1910.265, and 1915.90 | Safety Color Code for Marking Physical Hazards |
| 1910.28 | Walking-Working Surfaces |
The hearings are open to the public, but only individuals who file a Notice of Intention to Appear (NOITA) may testify, provide documentary evidence, or ask questions. For more information, see www.osha.gov/deregulatory-rulemaking.
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