Compliance Just Got Easier: Stay ahead of regulatory changes with instant notifications on updates that matter.
['Drug and Alcohol Testing - DOT']
['Drug testing - Motor Carrier']
2024-10-15T05:00:00Z
JOIN TODAY TO CONTINUE READING THIS ARTICLE & OTHER INDUSTRY NEWS!
You'll also get exclusive access to:
A database of easy-to-understand regulationsAsk unlimited questions to our expertsPre-led discussions forumsAnd more
TRY IT FREE TODAY
Already have an account? Log in now.
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
See More
RELATED NEWS
NewsFleet SafetyFederal Motor Carrier Safety Administration (FMCSA), DOTChange NoticesChange NoticeBusiness planning - Motor CarrierFocus AreaFleet OperationsEnglishTransportationBusiness planning - Motor CarrierUSA
07/21/2026
FMCSA Final Rule: General Technical, Organizational, Conforming, and Correcting Amendments to the Federal Motor Carrier Safety Regulations
NewsDrug and alcohol policy - Motor CarrierDrug testing - Motor CarrierDrug and Alcohol Testing - DOTDrug and alcohol training - Motor CarrierIn-Depth ArticleEnglishIndustry NewsFleet SafetyRandom alcohol and drug testing- Motor CarrierFocus AreaSafety-sensitive function - Motor CarrierAlcohol testing - Motor CarrierDrug and alcohol recordkeeping - Motor CarrierTransportationUSA
11/10/2025
DOT modes & testing: Different inputs, same result

Specialized Industries
Go beyond the regulations! Visit the Institute for in-depth guidance on a wide range of compliance subjects in safety and health, transportation, environment, and human resources.
J. J. Keller® COMPLIANCE NETWORK is a premier online safety and compliance community, offering members exclusive access to timely regulatory content in workplace safety (OSHA), transportation (DOT), environment (EPA), and human resources (DOL).

Interact With Our Compliance Experts
Puzzled by a regulatory question or issue? Let our renowned experts provide the answers and get your business on track to full compliance!

Upcoming Events
Reference the Compliance Network Safety Calendar to keep track of upcoming safety and compliance events. Browse by industry or search by keyword to see relevant dates and observances, including national safety months, compliance deadlines, and more.
SAFETY & COMPLIANCE NEWS
Keep up with the latest regulatory developments from OSHA, DOT, EPA, DOL, and more.
REGSENSE® REGULATORY REFERENCE
Explore a comprehensive database of word-for-word regulations on a wide range of compliance topics, with simplified explanations and best practices advice from our experts.
THE J. J. KELLER INSTITUTE
The Institute is your destination for in-depth content on 120+ compliance subjects. Discover articles, videos, and interactive exercises that will strengthen your understanding of regulatory concepts relevant to your business.
ADD HAZMAT, ENVIRONMENTAL, & HR RESOURCES
Unlock exclusive content offering expert insights into hazmat, environmental, and human resources compliance with a COMPLIANCE NETWORK EDGE membership.
DIRECT ACCESS TO COMPLIANCE EXPERTS
Struggling with a compliance challenge? Get the solution from our in-house team of experts! You can submit a question to our experts by email, set up a phone or video call, or request a detailed research report.
EVENTS
Register to attend live online events hosted by our experts. These webcasts and virtual conferences feature engaging discussions on important compliance topics in a casual, knowledge-sharing environment.
Most Recent Highlights In Environmental
NewsEnforcement and Audits - OSHACERCLA, SARA, EPCRAToxics Release Inventory ReportingVideoMonthly Roundup VideoCAA ComplianceInjury and Illness RecordkeepingEnglishOSHA Violations and PenaltiesAir ProgramsIndustry NewsSafety & HealthGeneral Industry Safety300-A Annual SummaryEnvironmentalFocus AreaAir ProgramsUSA
EHS Monthly Round Up - January 2023
In this monthly roundup video, we’ll review the most impactful environmental, safety, and health news.
Hi everyone! Welcome to the monthly roundup video, where we’ll review the most impactful environmental, safety, and health news. First, let’s take a look at what’s happening in safety and health.
If you haven’t already done so, now is the time to post your OSHA 300A Summary. Employers are required to post the Summary in a conspicuous place from February 1st through April 30th.
As required by law, OSHA increased its penalties for inflation in mid-January. Penalties went up 7.7 percent, effective January 17th.
Also in January, OSHA released its long-awaited Fall 2022 regulatory agenda. Along with numerous proposed rules in the works, three major final rules are slated for 2023 – COVID-19 in healthcare, Injury and Illness tracking, and an update to the hazard communication standard.
OSHA recently released two new letters of interpretation, which address exit signs and lockout/tagout. Specifically, OSHA states that the International Standards Organization emergency exit symbol can be located beside the mandatory EXIT text on an existing sign.
The second letter addresses the applicability of lockout/tagout and the maintenance and operations of cathodic protection rectifiers when working on pipelines.
New York’s Warehouse Worker Protection Act was signed into law in December and takes effect in late February. It protects warehouse distribution workers from undisclosed or unlawful work speed quotas and includes protections for workers who fail to meet these quotas.
In 2021, a worker died every 101 minutes from a work-related injury, according to the Bureau of Labor Statistics. A total of 5,190 fatal work injuries was recorded in the U.S. in 2021, an 8.9 percent increase over 2020.
Turning to environmental news, EPA automatically added nine per- and polyfluoroalkyl substances, or PFAS, to the Toxics Release Inventory, or TRI, list. Four PFAS were added since they are no longer claimed as confidential business information.
EPA released its Fall 2022 regulatory agenda in early January. Included are major regulations impacting the National Ambient Air Quality Standards, waters of the United States, and modifications to the Risk Management Program under the Clean Air Act.
There are also a number of rules related to the National Emission Standards for Hazardous Air Pollutants in various rule stages.
And finally, beginning with model year 2027, heavy-duty trucks will be required to meet clean air standards that are 80 percent more stringent than current requirements.
EPA says this final rule is aimed at reducing smog- and soot-forming emissions, increasing the life of governed vehicles by up to 250 percent, and increasing emissions warranty periods up to 450 percent.
Thanks for tuning in to the monthly news roundup!
NewsWaste GeneratorsWaste ManifestsWasteTennesseeSolid WasteEnglishWaste/HazWasteWaste HandlersChange NoticesChange NoticeWasteWaste TransportersWaste ManagementEnvironmentalWaste Collection CentersFocus Area
2026-11-02T06:00:00Z
Tennessee establishes waste tire hauler registration program
Effective date: January 18, 2027
This applies to: Waste tire generators, commercial waste tire haulers, and permitted waste tire management facilities
Description of change: The Tennessee Underground Storage Tanks and Solid Waste Disposal Control Board approved regulations establishing a waste tire hauler registration program that tracks and regulates the transportation of waste tires from the point of generation to the delivery for permitted storage, processing, or disposal.
The regulations include:
- Administrative requirements for registration;
- Decal requirements for vehicles that commercially haul waste tires;
- An annual registration fee for registered waste tire hauler vehicles;
- Terms and conditions for registered waste tire haulers;
- Manifest requirements for all waste tire generators, transporters, and permitted waste tire management facilities; and
- Financial assurance requirements for registered waste tire haulers.
NewsGreenhouse GasesChange NoticesChange NoticeCaliforniaCAA ComplianceEnvironmentalFocus AreaEnglishAir Programs
2026-11-02T06:00:00Z
California adopts regulations for initial corporate GHG report
Effective date: October 12, 2026
This applies to: U.S.-based companies that do business in California with total annual revenues above $1 billion (reporting entities) and with total annual revenues above $500 million (covered entities)
Description of change: The California Office of Administrative Law (OAL) approved the California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation, which was approved by the California Air Resources Board (CARB) in February 2026.
The adopted regulations help implement the Climate Corporate Data Accountability Act and the Climate-Related Financial Risk Reporting Act, which require U.S.-based companies operating in California to report greenhouse gas (GHG) emissions and climate-related financial risks.
The regulation:
- Establishes annual fee calculations and procedures,
- Specifies definitions to help entities determine applicability (whether the rule applies and if they must comply with both emissions reporting and fee requirements), and
- Sets the first-year reporting deadline of November 10, 2026, for reporting Scope 1 and Scope 2 GHG emissions.
Annual report
CARB has sent a reminder letter to organizations potentially required to sumbit the inital report by November 10, 2026.
Entities that weren’t collecting data or weren’t planning to collect data when CARB issued its December 2024 Enforcement Notice aren’t expected to submit Scope 1 and 2 reporting data for this first reporting cycle in 2026 only.
Starting in 2027, reporting entities must annually disclose Scope 1, Scope 2, and Scope 3 GHG emissions for the previous fiscal year. CARB is developing reporting regulations for 2027 and later.
Annual fee
Reporting entities and covered entities must pay the applicable annual implementation fee within 60 calendar days of receiving a fee determination notice from CARB.
NewsGreenhouse GasesCERCLA, SARA, EPCRA CERCLA, SARA, EPCRAToxics Release Inventory ReportingWater ProgramsEnvironmental Protection Agency (EPA)CAA ComplianceIn-Depth ArticleCWA ComplianceStormwaterWaste/HazWasteEnglishTier II Inventory ReportingIndustry NewsWaste ReportingWasteEnvironmentalFocus AreaSARA ComplianceAir ProgramsUSA
2026-11-02T06:00:00Z
Federal environmental reporting: 5 annual reports due in 2027
With the new year quickly approaching, many businesses take time to reflect on the previous year to evaluate their performance. For numerous facilities subject to federal environmental regulations, this isn’t just a good practice; it’s mandated through annual reporting requirements.
Mark your compliance calendars for these common federal environmental annual reports due in 2027.
Multi-Sector General Permit (MSGP) annual report
Due: January 30, 2027
EPA issues industrial stormwater MSGPs in areas where it serves as the permitting authority. Examples include Massachusetts, New Hampshire, New Mexico, and the District of Columbia.
Facilities with MSGPs must submit the Annual Report for Stormwater Discharges Associated with Industrial Activity Under the NPDES MSGP (NPDES Form 6100-28) electronically via the NPDES Electronic Reporting Tool (NeT). The report covers information from calendar year 2026.
Take note! EPA has administratively continued the 2021 MSGP for facilities covered under the permit before it expired in February 2026.
New facilities must comply with the requirements in EPA’s No Action Assurance for New Industrial Facilities Needing Stormwater Permit Coverage under EPA’s Multi-Sector General Permit memorandum (issued February 27, 2026) until the agency issues a new MSGP. The memorandum mandates that facilities provide the electronically reported information required by the 2021 MSGP (including the annual report) if EPA requests it.
Emergency and Hazardous Chemical Inventory (Tier II Inventory Report)
Due: March 1, 2027
Section 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA) requires covered facilities to submit the Tier II Inventory Report (or a state-equivalent form) to the State Emergency Response Commission, Local Emergency Planning Committee, and local fire department. Reporting applies to facilities:
- That are required by OSHA’s Hazard Communication standard (29 CFR 1910.1200) to prepare or have available Safety Data Sheets (SDSs), and
- That have on-site at any one time emergency hazardous substances (EHSs) or non-EHS hazardous chemicals at or above certain thresholds (40 CFR Part 370 Subpart B).
The report provides information on the covered hazardous chemicals used or stored at the facility in 2026, including locations, amounts, and potential hazards.
Take note! Facilities should check state regulations to:
- Confirm Tier II reporting thresholds, as they may be more stringent;
- Determine whether any additional chemicals are covered; and
- Verify how the report must be submitted, including whether Tier2 Submit files are accepted.
Hazardous Waste Export Annual Report
Due: March 1, 2027
The Resource Conservation and Recovery Act (RCRA) requires exporters of regulated hazardous waste to submit an annual report electronically through the RCRA Information (RCRAInfo) Waste Import and Export Tracking System (WIETS). The report lists the types, quantities, shipment frequency, and ultimate destination of all hazardous waste exported in 2026.
Take note! If an exporter doesn’t ship any hazardous waste after obtaining consent to export certain hazardous wastes, the exporter must still submit an annual report that lists the quantity shipped under the issued consent as 0.
2025 Greenhouse Gas (GHG) Annual Report
Due: March 10, 2027
The GHG Reporting Program (GHGRP) requires large industrial sources of GHG emissions, fuel and industrial gas suppliers, and carbon dioxide injection facilities to report GHG emissions from 2025 for all applicable source categories. Facilities submit reports through EPA’s Greenhouse Gas Reporting Tool (e-GGRT).
Take note! Annual GHG reports for the previous calendar year are usually due by March 31 of the next calendar year. However, EPA issued an interim final rule (effective October 14, 2026) extending the submission deadline for Reporting Year 2025 GHG reports to March 10, 2027.
Toxics Release Inventory (TRI) Report
Due: July 1, 2027
Section 313 of EPCRA requires facilities in specific industry sectors to submit a TRI Form R for each TRI-listed chemical (372.65) manufactured, processed, or otherwise used above threshold levels (listed at 372.25, 372.27, and 372.28) in the previous calendar year. The report, submitted through TRI-MEweb, covers waste management activities and any actions taken to reduce or prevent chemical waste during 2026.
Take note! TRI reports must be submitted to both EPA and the state. If your facility’s state participates in the TRI Data Exchange (TDX), TRI-MEweb will automatically send your report to the state. If your facility’s state doesn’t participate in TRI TDX, check the state’s TRI submission requirements to determine how to submit the required state copy.
Key to remember: The new year is quickly approaching, and the annual reporting compliance deadlines for many federal environmental programs are following closely behind.
NewsGreenhouse GasesIndustry NewsIndustry NewsAir ProgramsEnvironmental Protection Agency (EPA)CAA ComplianceEnvironmentalFocus AreaEnglishVolatile Organic CompoundsAir ProgramsStationary Emission SourcesUSA
2026-10-29T05:00:00Z
EPA proposes major changes to oil, gas emission rules
On October 29, 2026, EPA published a proposed rule to amend certain emission standards that were established by a rule finalized in 2024 (2024 Final Rule) for new and existing crude oil and natural gas facilities
Who’s impacted?
The proposed rule primarily applies to:
- New, modified, and reconstructed crude oil and natural gas facilities subject to the New Source Performance Standards (NSPS) at 40 CFR Part 60 Subpart OOOOb; and
- Existing crude oil and natural gas facilities subject to the emissions guidelines (EGs) at Part 60 Subpart OOOOc.
Collectively, these standards are known as the OOOOb/c rule.
What are the proposed changes?
EPA’s rule proposes revisions to a range of regulations established by the 2024 Final Rule.
Well site categories
The agency co-proposes two options for creating distinct categories of well sites, either:
- By production level as marginal or non-marginal (with reduced requirements for marginal wells), or
- By resource type as conventional or unconventional (with reduced requirements for conventional wells).
EPA also proposes an alternative approach to the marginal or non-marginal option, adding further sub-categories of marginal wells based on production levels.
Covers and closed vent systems (CVSs)
EPA proposes to divide the No Identifiable Emissions (NIE) standard into:
- Design requirements, and
- Operational requirements.
Additionally, the operational requirements would allow for repairs so that emissions that are fixed within a limited timeframe wouldn’t be a deviation.
Associated gas
EPA proposes to modify the best system of emission reduction (BSER) for associated gas from oil wells, including an approach that would allow routing associated gas to a control device or flare meeting specific emission-reduction requirements.
Control devices
The agency proposes to change control device requirements related to:
- Continuous burning pilot flames,
- Flame monitoring data deviations,
- Control device alerts,
- Visible emissions test conditions for fugitive emissions,
- Temporary or backup control devices,
- Temporary process controllers, and
- Control device categories.
Other requirements
EPA addresses other aspects of the 2024 Final Rule, proposing to revise requirements for:
- Liquids unloading,
- Process controllers,
- Pumps,
- Fugitive emissions,
- Storage vessels,
- Covers and CVSs, and
- Equipment leaks at gas plants.
Further, the proposed rule would allow gas processing facilities subject to the NSPS at Part 60 Subparts OOOO, OOOOa, and KKK to conduct optical gas imaging surveys according to Appendix K.
Super Emitter Program
EPA plans to rescind the Super Emitter Program that requires regulated sources to be monitored for methane leaks and releases above a specific threshold by certified third parties using remote-sensing technology. If the threshold is exceeded, it’s known as a “super-emitter event.” The third party notifies EPA, which then notifies a source that a super-emitter event has occurred at its facility. The source must find the leak or release, report its investigation results to EPA, and take corrective action if needed.
Note that the Super Emitter Program isn’t in effect. EPA’s July 2025 interim final rule delayed the program start date to January 22, 2027.
Key to remember: EPA proposes significant changes to emission standards for new and existing oil and natural gas facilities.
Most Recent Highlights In Transportation
NewsStationary Emission SourcesAir EmissionsChange NoticesChange NoticeVirginiaCAA ComplianceEnvironmentalAir PermittingFocus AreaEnglishAir ProgramsAir Programs
2026-10-29T05:00:00Z
Virginia establishes emission limits for data center generators
Effective date: November 4, 2026
This applies to: Data centers that apply for an air permit on or after July 1, 2026
Description of change: The Virginia State Air Pollution Control Board established new emission regulations for engine-generator sets (gen-sets) at data centers. A gen-set refers to an electrical generator and engine mounted together that form one piece of equipment.
The new regulation requires each gen-set covered in the air permit to emit no more than the emissions achieved by a Tier 4 equivalent gen-set. It also grants the Virginia Department of Environmental Quality the authority to require stricter emission limits.
Related state info: Clean air operating permits state comparison
NewsHazardous WasteKansasChange NoticesChange NoticeWasteTSD FacilitiesWaste/HazWasteEnvironmentalWaste PermittingEnglishFocus Area
2026-10-29T05:00:00Z
Kansas adds TSDF permit application review fees
Effective date: October 16, 2026
This applies to: Hazardous waste treatment, storage, and disposal facilities (TSDFs)
Description of change: The Kansas Department of Health and Environment (KDHE) approved a new regulation establishing review fees for new and renewal permit applications from TSDFs. Facility permits must be renewed every 10 years.
The review fee is $20,000 for a permit renewal or an application from a TSDF that has a permit, order, agreement, post-closure plan, or other regulatory mechanism issued or approved by EPA or the KDHE.
The review fee is $50,000 for an application from a TSDF that doesn’t have a permit, order, agreement, post-closure plan, or other regulatory mechanism issued or approved by EPA or the KDHE.
NewsKansasWater PermittingChange NoticesChange NoticeWater ProgramsEnvironmentalWater ProgramsEnglishFocus AreaCWA Compliance
2026-10-29T05:00:00Z
Kansas extends duration of state non-discharging water pollution permit
Effective date: October 30, 2026
This applies to: State-issued non-discharging water pollution control permit holders
Description of change: The Kansas Department of Health and Environment adopted amendments to extend the maximum duration of state-issued non-discharging water pollution control permits from 5 to 10 years.
Related state info: Industrial water permitting state comparison
NewsChange NoticesChange NoticeWater ProgramsWater QualityWyomingEnvironmentalCWA ComplianceEnglishFocus Area
2026-10-29T05:00:00Z
Wyoming updates noncoal surface mining regulations
Effective date: August 21, 2026
This applies to: Noncoal surface mining operations
Description of change: The Wyoming Land Quality Division (LQD) adopted a new chapter and amended three related chapters governing noncoal surface mining operation regulations.
The LQD added Noncoal Chapter 14 to set blasting requirements for noncoal surface mining operations, including requirements for blasting plans for operations that anticipate using explosives.
It also revised Noncoal Chapters 2, 9, and 10 to establish that other types of operations are subject to some or all of the blasting regulations established by Noncoal Chapter 14. For example, the following types of operations must develop blasting plans if the operations are expected to use blasting as part of the mining:
- Regular noncoal mine permit applicants,
- Small mining operations, and
- Limited mining operations on 15 acres or less of affected land.
NewsIndustry NewsIndustry NewsToxic Substances Control Act - EPAToxic Subtances Control Act - EPATSCA ComplianceToxic Substances - EPAEnvironmental Protection Agency (EPA)EnvironmentalEnglishFocus AreaUSA
2026-10-29T05:00:00Z
EPA updates formaldehyde testing standards for composite wood products
EPA published a final rule on October 28, 2026, updating the formaldehyde emission standards for composite wood products under the Toxic Substances Control Act (TSCA). The rule provides a new quality control test method option and updates specific voluntary consensus standards incorporated by reference.
Who’s impacted?
The formaldehyde emission standards apply to entities that manufacture (including import), sell, supply, offer for sale, or certify certain composite wood products that use formaldehyde, including:
- Hardwood plywood,
- Medium-density fiberboard,
- Particleboard, and
- Products containing these composite wood materials.
It may also apply to entities that test these materials or work with certification firms that certify them.
Regulated entities use approved voluntary consensus standards to comply with the formaldehyde emission standards (40 CFR Part 770).
What are the changes?
EPA’s final rule updates six voluntary consensus standards incorporated by reference to the most current standards issued by the American National Standards Institute (ANSI), the American Society for Testing and Materials (ASTM), the International Organization for Standardization (ISO), and the National Institute of Standards and Technology (NIST). Regulated entities must comply with the updated versions of these standards.
The final rule also adds an allowable quality control testing method. ISO 12460-2:2024(en), “Wood-based panels — Determination of Formaldehyde Release — Part 2: Small-scale Chamber Method,” is a small-scale chamber test method for measuring formaldehyde emissions from wood products. The new standard contains a wider range of analytical methods that entities can use (e.g., laser absorption spectroscopy).
Finally, the rule removes the British Standards Institute BS EN ISO 12460-3:2020 standard from the allowable quality control methods since ISO 12460-3:2023(E), one of the existing standards that’s being updated by the final rule, is identical.
The final rule takes effect November 27, 2026.
Key to remember: EPA updated the formaldehyde testing standards for composite wood products, adding a quality control test method and updating multiple voluntary consensus standards.
Most Recent Highlights In Safety & Health
NewsIndustry NewsWater AnalysisToxic Water PollutantsWater ProgramsWater MonitoringEnvironmentalIn-Depth ArticleWater ProgramsUSAEnglishFocus AreaCWA Compliance
2026-10-23T05:00:00Z
Looking beyond PFAS: Emerging contaminants draw EPA's attention
For years, conversations about emerging contaminants have focused on per- and polyfluoroalkyl substances (PFAS). While PFAS remain a major regulatory and public concern, they represent only one part of a much larger picture. Regulators and researchers are increasingly evaluating a broader range of chemicals that may be present in drinking water and the environment.
A recent EPA research initiative highlights this shift. In September 2026, EPA announced a scientific study that will use non-targeted analysis (NTA) to improve the agency's understanding of emerging contaminants in drinking water. Unlike traditional analytical methods that look for a limited list of chemicals, NTA allows researchers to screen for thousands of potential contaminants and identify previously unknown substances.
Emerging contaminants continue to evolve
There's no single regulatory definition of "emerging contaminant." Generally, the term refers to chemicals that have been detected in the environment and may present risks to human health or ecosystems but aren't yet fully understood, routinely monitored, or regulated.
Many emerging contaminants are not new chemicals. In many cases, they've been used for decades. What's changed is the ability to detect them at very low concentrations and to better understand where they occur, how they move through the environment, and what impacts they may have.
PFAS are a prime example. Once largely unknown outside technical circles, they're now the subject of drinking water standards, reporting requirements, cleanup efforts, and litigation. Other contaminant groups may follow a similar path as research continues.
EPA is expanding its view beyond PFAS
As part of its study, EPA developed a screening library containing more than 1,400 emerging contaminants. According to EPA, the library includes more than 1,000 pesticides and pesticide metabolites, more than 250 pharmaceuticals and personal care products, more than 70 PFAS, and other emerging contaminants.
While PFAS remain the most recognized emerging contaminant family, EPA's screening efforts extend far beyond fluorinated chemicals. The pharmaceutical and personal care product category includes compounds such as antibiotics, hormones, and other medicinal ingredients that can enter the environment through wastewater systems and other pathways. The pesticide category encompasses herbicide, insecticide, fungicide, and pesticide degradation products that may persist in soil, groundwater, or surface water.
EPA states that the study will help identify contaminants that may warrant additional investigation in the future.
Why this matters now
Most facilities aren't currently required to monitor for hundreds or thousands of emerging contaminants. However, today's research efforts often become tomorrow's regulatory priorities.
Historically, contaminants often attract scientific attention long before regulatory requirements follow. As occurrence data grows and analytical methods improve, regulators gain a better understanding of where contaminants are found and whether additional action is needed.
Facilities that manufacture, process, use, discharge, or dispose of chemicals should understand which substances are present in their operations and waste streams. This includes evaluating raw materials, wastewater discharges, byproducts, and residual wastes. Facilities may also want to monitor supplier communications and regulatory developments related to chemicals used in their operations.
Organizations with strong chemical inventory management and environmental review processes are often better positioned to adapt when new contaminants attract regulatory attention.
Preparing for what comes next
Organizations don't need to become experts on every emerging contaminant. However, focusing solely on PFAS could cause them to overlook broader trends developing across the environmental landscape.
EPA's latest drinking water study demonstrates that regulators are increasingly using advanced analytical tools to evaluate a much wider universe of chemicals. Whether the next major concern involves pharmaceuticals, pesticide metabolites, or another group of contaminants, facilities that stay informed about emerging issues will be better positioned to anticipate and respond to future compliance challenges.
Key to remember: PFAS may be the most visible emerging contaminant today, but they're unlikely to be the last. EPA's recent drinking water study shows that regulators are evaluating a much broader range of contaminants, making it important for facilities to stay informed about emerging chemical concerns before they become regulatory requirements.
NewsEnglishWasteHawaiiChange NoticesChange NoticeWasteSpecial WasteWaste ManagementEnvironmentalSolid WasteWaste/HazWasteFocus Area
2026-10-20T05:00:00Z
Hawaii overhauls solid waste landfill regulations
Effective date: September 25, 2026
This applies to: Facilities that manage solid waste
Description of change: The State of Hawaii Department of Health made the first major update to the solid waste management control regulations in decades. The amended regulations:
- Increase flexibility for small municipal solid waste landfills (MSWLFs),
- Revise siting restrictions for MSWLFs,
- Add requirements for construction and demolition landfills and special waste landfills,
- Add leachate control and closure requirements for all solid waste management facilities,
- Require auto processing and salvaging on an impervious surface, and
- Update the solid waste permitting program.
Examples of significant changes include:
- Adding requirements for facilities that manage solid waste (except landfills), such as leachate control for all facilities and use of impervious working surfaces for solid waste salvage facilities;
- Updating MSWLF requirements (such as requiring compliance with the federal maximum contaminant level or state level (whichever is lower) for groundwater contaminants); and
- Adding new requirements for construction and demolition landfills.
Related state info: Non-hazardous solid waste and recycling state comparison
NewsChange NoticesChange NoticeWater ProgramsWater QualityEnvironmentalWater ProgramsEnglishNorth DakotaFocus AreaCWA Compliance
2026-10-20T05:00:00Z
North Dakota adopts permanent septic system rules
Effective date: October 1, 2026
This applies to: The licensing, permitting, and installation of on-site wastewater treatment systems (septic systems)
Description of change: The North Dakota Department of Environmental Quality (DEQ) finalized permanent rules for on-site wastewater treatment systems (septic systems). The final rule establishes statewide licensing requirements, a common technical code, and a process for variances from the code.
Senate Bill 2267 shifted responsibility for regulating septic systems to the DEQ. The department issued an emergency rule in 2025 to continue existing licenses. This rulemaking finalizes:
- Licensing requirements for septic system installers,
- Training requirements for licensed septic system installers,
- Permit requirements (permits will continue to be issued by the local permitting authority), and
- Technical requirements (which closely align with the existing voluntary common code previously developed).
NewsEnglishChange NoticesChange NoticeOhioWasteEnvironmentalSolid WasteLand Disposal RestrictionsWaste/HazWasteFocus Area
2026-10-20T05:00:00Z
Ohio establishes CCR regulations
Effective date: October 1, 2026
This applies to: Owners and operators of coal combustion residuals (CCR) landfills and surface impoundments
Description of change: The Ohio Environmental Protection Agency (EPA) adopted regulations for CCR generated by electric utilities and disposed of in dedicated landfills and surface impoundments. The new rules partially implement the federal CCR regulations (40 CFR Part 257 Subpart D). They also contain state-specific provisions (OAC Chapter 3745-525) for requirements related to CCR permits to install and financial assurance for landfills previously regulated by OAC Chapter 3745-30.
The Ohio EPA plans to apply for partial approval to implement the CCR program in place of EPA.
NewsEnglishWasteRecyclingChange NoticesChange NoticeWasteTexasSustainabilityEnvironmentalSolid WasteWaste/HazWasteSustainabilityFocus Area
2026-10-20T05:00:00Z
Texas adopts financial assurance rules for recycling facilities
Effective date: October 1, 2026
This applies to: Recycling facilities that accept, process, and repurpose renewable energy components
Description of change: The Texas Commission on Environmental Quality (TCEQ)’s final rule adds 30 TAC Chapter 376 (and amends Chapter 328 accordingly) to establish new requirements for recycling facilities that accept, process, and repurpose renewable energy components for recovering valuable materials from:
- Wind turbine generators,
- Solar energy devices, and
- Battery energy storage systems.
The new rule adds reporting, financial assurance, and penalty requirements. For example, the regulation requires recycling facilities to submit annual reports by January 15 that include:
- An inventory of unrecycled renewable energy components,
- An estimated timeline to recycle them,
- A cost estimate for recycling or disposing of the materials prepared by a third-party Texas-licensed professional engineer, and
- Evidence of financial assurance for the cost estimate.
Related state info: Non-hazardous solid waste and recycling state comparison
Most Recent Highlights In Human Resources
NewsAir QualityAir EmissionsChange NoticesChange NoticeCaliforniaMobile Emission SourcesCAA ComplianceEnvironmentalFocus AreaEnglishAir ProgramsAir Programs
2026-10-20T05:00:00Z
California amends vehicle regulations
Effective date: September 10, 2026
This applies to: Public agency utilities, high-priority fleets, and drayer trucks subject to the Advanced Clean Fleets (ACF) regulation and hydrogen refueling stations subject to the Low Carbon Fuel Standard (LCFS) regulation
Description of change: The California Air Resources Board (CARB) amended the ACF’s state and local government requirements. CARB’s final rule:
- Extends the 50 percent zero-emission vehicle (ZEV) purchase requirement to January 1, 2030;
- Modifies the Daily Usage Exemption and the ZEV Purchase Exemption to allow all vehicles of all model years to be eligible for consideration;
- Adds an exemption under the ZEV Milestones Option for captive waste and wastewater fleets that produce biomethane on-site;
- Expands the ZEV Purchase Exemption availability criteria to ensure minimum ZEV warranty requirements and manufacturer experience or reliability and streamlines the exemption process;
- Modifies the Fleet Resiliency Exemption by lowering the ZEV penetration threshold from 25 to 5 percent of the fleet where it stays and expands eligibility to all vehicle types; and
- Repeals sections of the ACF regulation for high-priority fleets and drayer trucks (these regulations were never implemented because CARB didn’t have a federal preemption waiver to enforce them).
CARB also amended the LCFS regulation, modifying the derating factors for light- and medium-duty hydrogen refueling infrastructure (LMD-HRI) crediting. CARB reduced the derating factor so that LMD-HRI stations may receive HRI credits for the full nameplate capacity for public stations and 50 percent of the nameplate capacity for private stations.
NewsAir QualityIndustry NewsIndustry NewsEnvironmental Protection Agency (EPA)Renewable and Alternative EnergyBiofuelCAA ComplianceEnvironmentalRenewable and Alternative EnergyFocus AreaEnglishAir ProgramsAir ProgramsUSA
2026-10-20T05:00:00Z
EPA proposes reallocating excess 2025 SREs to 2026, 2027
On October 16, 2026, EPA published a rule proposing to revise the Small Refinery Exemption (SRE) reallocation volumes for compliance years 2026 and 2027 under the Renewable Fuel Standard (RFS) program.
Who’s impacted?
The RFS program applies to obligated parties, including:
- Refiners of gasoline or diesel fuel (i.e., transportation fuel); and
- Importers of transportation fuel.
EPA sets annual renewable fuel volume and percentage standards for each compliance year. Obligated parties must calculate their individual renewable volume obligations (RVOs), measured in Renewable Identification Numbers (RINs), and obtain and retire enough RINs to meet their RVOs for each compliance year.
What’s the issue?
In April 2026, EPA established the annual volume and percentage standards for the 2026 and 2027 compliance years (Set 2 Rule), including reallocating part of the SREs granted and expected to be granted for the 2023–2025 compliance years.
However, EPA granted a higher volume of SREs for the 2025 compliance year than expected, exempting 770 million more RINs than the Set 2 Rule projected for the 2026 and 2027 compliance years. The agency plans to revise the Set 2 Rule to account for the additional SRE reallocation volume.
What’s the proposed solution?
EPA proposes reallocating 100 percent of the additional 770 million RINs by reallocating the additional 2025 exempted RVO either:
- Equally between the 2026 and 2027 compliance years, or
- Fully to the 2027 compliance year.
The proposed rule would adjust the renewable volume and percentage standards for biomass-based diesel, advanced biofuel, and total renewable fuel. The Set 2 Rule didn’t establish SRE reallocation volumes for cellulosic biofuel.
Additionally, the proposed rule may extend the current 2026 compliance reporting deadline of March 31, 2027.
EPA will host a virtual public hearing for the proposed rule on November 4, 2026. Public comments on the rule are due by December 4, 2026 (Docket ID No. EPA-HQ-OAR-2024-0505).
Key to remember: EPA proposes to reallocate the excess 2025 small refinery exemption volumes to the 2026 and 2027 compliance years.
NewsIndustry NewsEnglishEnvironmental Management SystemsEMS PlanningIn-Depth ArticleCAA ComplianceEnvironmentalEnvironmental Management SystemsCWA ComplianceWaste/HazWasteSARA ComplianceFocus AreaUSA
2026-10-16T05:00:00Z
When one activity triggers multiple environmental obligations
Environmental compliance programs are often managed separately. Air permitting, hazardous waste, stormwater, emergency planning, and chemical reporting frequently involve different personnel, regulations, and procedures.
The challenge is that facilities don't operate that way. They operate processes, and those processes rarely fit neatly within a single regulatory category.
A company rarely decides to implement an "air program change" or a "hazardous waste change." Instead, it purchases a new solvent, installs a fuel tank, modifies a manufacturing process, or adds new equipment. A single operational decision can affect multiple environmental compliance programs at the same time. When organizations evaluate changes through only one regulatory lens, they risk overlooking obligations that arise elsewhere.
The following examples illustrate how one product, process, or activity can trigger requirements across several environmental programs.
Switching to a new paint or solvent
A facility may decide to replace an existing paint, coating, or solvent to improve product quality, address supply chain challenges, or reduce costs. Before making the switch, environmental professionals should consider how the change could affect multiple compliance obligations.
A new paint or solvent may contain a different concentration of volatile organic compounds (VOCs), affecting air emission calculations, permit applicability, or recordkeeping requirements. Spent materials, contaminated wipes, absorbents, and cleanup residues may require a new hazardous waste determination. Depending on the chemical composition and quantities involved, the material could also affect Tier II inventory reporting or Toxics Release Inventory (TRI) reporting obligations.
What appears to be a straightforward purchasing decision can ultimately affect air compliance, waste management, and chemical reporting programs.
Installing a diesel fuel storage tank
Organizations often add fuel storage to support emergency generators, fleet operations, or business continuity initiatives. While the project may be viewed primarily as an operational improvement, it can create environmental obligations in several areas.
The tank may count toward Spill Prevention, Control, and Countermeasure (SPCC) applicability thresholds. Fuel storage can also increase stormwater pollution risks, requiring updates to inspection procedures, pollution prevention controls, or employee training. Secondary containment requirements, spill response procedures, and release reporting obligations may also need review.
A project initially viewed as a facilities improvement may affect spill prevention, stormwater management, and emergency preparedness responsibilities.
Managing aerosol cans
Aerosol cans are commonly used throughout facilities for maintenance, cleaning, lubrication, painting, and other routine activities. Their widespread use can cause organizations to overlook their broader compliance implications.
Depending on how they're managed, discarded aerosol cans may qualify for the federal universal waste regulations. If cans are punctured and processed for recycling, facilities must also consider hazardous waste management requirements, employee training, and potential air emission concerns associated with puncturing operations. Likewise, storage practices, container management, and recordkeeping procedures should be evaluated.
Because aerosol cans intersect with waste management, recycling, and air concerns, they demonstrate how a routine maintenance activity can involve multiple regulatory programs.
Adding a refrigeration process
Expanding refrigerated storage capacity or installing a new industrial refrigeration process may seem like a project driven by production needs. However, depending on the refrigerant used and the quantity stored on-site, the environmental and safety implications can extend well beyond equipment installation.
Certain refrigerants may be subject to leak management and repair, servicing, recovery, and recordkeeping requirements. Depending on the substance and quantity stored on-site, facilities may also trigger Tier II or TRI reporting obligations.
For facilities using substances such as anhydrous ammonia, increasing refrigerant inventories may have even broader consequences. Exceeding regulatory thresholds could trigger EPA's Risk Management Program (RMP) requirements and OSHA's Process Safety Management (PSM) obligations, adding responsibilities related to process hazard analyses, operating procedures, employee training, emergency planning, mechanical integrity, and management of change.
The project may also require updates to emergency response procedures, hazard communication programs, and chemical inventory management processes. As a result, a decision driven by production or storage needs may affect environmental reporting, accident prevention, emergency preparedness, and process safety requirements across the facility.
Looking beyond program boundaries
Environmental regulations are often organized by media, program, or statute. Facilities, however, operate through products, equipment, and processes. Because of this difference in perspective, a single operational change can have consequences that reach far beyond its original purpose.
Organizations that routinely evaluate projects through multiple compliance lenses are often better positioned to identify environmental obligations before they become compliance issues. Asking how a new product, process, equipment installation, or operational change might affect air, waste, water, chemical reporting, spill prevention, emergency planning, or process safety requirements can help reduce surprises and support more effective compliance management.
Key to remember: Environmental compliance obligations rarely exist in isolation. Before implementing a new product, process, or operational change, consider how it may affect multiple environmental programs, not just the one most directly associated with the project.
NewsIndustry NewsToxic Substances Control Act - EPAToxic Subtances Control Act - EPATSCA ComplianceToxic Substances - EPAEnvironmental Protection Agency (EPA)EnvironmentalIn-Depth ArticleEnglishFocus AreaUSA
2026-10-16T05:00:00Z
Court vacates EPA’s methylene chloride rule: How should facilities respond?
When a court overturns an environmental regulation, it can be tempting to adopt an “all bets are off” approach and stop efforts to comply with the rule. However, facilities that continue to operate as if the rule still applies are better prepared to meet any future rulemaking that’s likely to occur. On September 15, 2026, the U.S. Court of Appeals for the Fifth Circuit vacated EPA’s methylene chloride risk management rule established under the Toxic Substances Control Act (TSCA) and remanded it back to the federal agency for further proceedings. EPA must restart the rulemaking process for methylene chloride.
Here’s what you need to know about the ruling and how your facility can respond to “hedge its bets” against future environmental regulations of methylene chloride.
What regulations and facilities are impacted?
The court’s decision in East Fork Enterprises, Inc. v. EPA (Case No. 24-60227) impacts EPA’s methylene chloride risk management rule finalized in May 2024 (2024 final rule). The rule applied to entities that manufacture (including import), process, distribute in commerce, use, or dispose of methylene chloride or methylene chloride-containing products.
Reasons for overturning the methylene chloride rule
The court listed a range of reasons for vacating the 2024 final rule, including the following significant findings.
Whole-chemical approach
EPA used a “whole chemical” approach in its revised 2022 risk determination for methylene chloride (on which the 2024 final rule is based) instead of making individual risk determinations for each condition of use (COU). As a result, EPA recharacterized six COUs (previously found not to present unreasonable risk) as posing unreasonable risk.
Court’s conclusion: TSCA doesn’t permit EPA to issue a whole-chemical risk determination; it requires EPA to evaluate and issue risk determinations for each COU.
Personal protective equipment (PPE) assumption
In its 2022 risk determination, EPA didn’t assume that exposed employees use PPE. However, TSCA requires the agency to account for PPE use if evidence suggests that it’s commonly used.
Court’s conclusion: There was sufficient evidence for EPA to assume PPE use, especially given that OSHA’s methylene chloride standard generally requires the use of PPE when employee exposure warrants it.
Risk analysis methods
EPA’s approach to “unreasonable risk” went beyond the statutory limits, appearing to attempt to eliminate nearly all risks. Further, EPA’s risk analysis didn’t comply with TSCA’s “best available science” standard (producing exposure limits unsupported by substantial evidence), and the agency overlooked relevant evidence.
Court’s conclusion: TSCA requires EPA to identify only unreasonable risk, which allows for some risk; the act isn’t designed to eliminate all risk. Also, TSCA mandates the agency to base its risk evaluations on all acceptable scientific information, including data contrary to its presuppositions.
Regulating to the extent necessary
EPA exceeded its authority by imposing regulations beyond “the extent necessary.” The court ruled that EPA’s basis for requiring a near-complete ban on methylene chloride use was unauthorized because it was based on the agency’s uncertainty as to whether a risk deemed reasonable will stay reasonable.
Court’s conclusion: TSCA permits EPA to eliminate actual, identified unreasonable risk. The agency can’t ban chemicals based on a reasonable risk that may become unreasonable in the future.
What’s next?
The court vacated with remand EPA’s methylene chloride rule and associated risk determination. As a result, EPA’s risk determination for methylene chloride is invalid, and the methylene chloride risk management rule is no longer in effect. Additionally, EPA must develop a new risk management rule that resolves the issues identified in the court’s opinion.
How should regulated entities respond?
EPA’s methylene chloride risk management rule is legally unenforceable, including its bans on uses and the regulatory requirements (such as the Workplace Chemical Protection Program). However, due to the uncertainty of EPA’s response and future rulemaking, companies should respond thoughtfully. Consider these tips:
- Watch closely for EPA’s response to this litigation.
- Consider maintaining protective measures and compliance programs that were implemented in response to the 2024 final rule, where possible. Continuing these efforts may ease compliance burdens if EPA issues a revised rule in the future. For example:
- Continue conducting exposure monitoring and recording the results,
- Keep searching for possible substitutes, and
- Maintain workplace protections that are already implemented.
- Ensure compliance with existing methylene chloride regulations, including:
- EPA’s March 2019 final rule banning methylene chloride for consumer paint and coating removal, and
- OSHA’s occupational exposure control requirements for methylene chloride (29 CFR 1910.1052).
Key to remember: A U.S. court vacated EPA’s 2024 methylene chloride risk management rule, but facilities that maintain protections and compliance programs developed under the rule may be better prepared for any future regulations of the chemical.
NewsIndustry NewsIndustry NewsToxic Substances Control Act - EPAToxic Subtances Control Act - EPATSCA ComplianceToxic Substances - EPAEnvironmental Protection Agency (EPA)EnvironmentalEnglishFocus AreaUSA
2026-10-14T05:00:00Z
EPA proposes additional TCE compliance delays
On October 14, 2026, EPA published a proposed rule to extend additional compliance dates for the trichloroethylene (TCE) risk management rule finalized in 2024 (2024 TCE final rule) under the Toxic Substances Control Act (TSCA). If finalized, the rule would delay compliance deadlines for certain chemical processors and refrigerant manufacturers.
Who’s impacted?
The 2024 TCE final rule applies to entities that manufacture (including import), process, distribute in commerce, use, or dispose of TCE or TCE-containing products.
The proposed rule specifically affects:
- Chemical processors;
- Manufacturers, processors, and distributors subject to downstream notification requirements; and
- Refrigerant manufacturers that process TCE to make HFC-134a.
What are the proposed changes?
For chemical processors, EPA proposes to move the prohibition compliance dates from December 18, 2026, to December 31, 2027, for:
- Processing TCE as a reactant/intermediate;
- Processing TCE for the industrial and commercial use of TCE as a processing aid in as well as the industrial and commercial use of TCE as a processing aid in:
- Process solvent used in battery manufacturing;
- Process solvent used in polymer fiber spinning, fluoroelastomer manufacturing, and Alcantara manufacturing;
- Extraction solvent used in caprolactam manufacturing; and
- Precipitant used in beta-cyclodextrin manufacturing.
- Disposing of TCE through wastewater from such processing and uses to industrial pretreatment, industrial treatment, or publicly owned treatment works.
For manufacturers, processors, and distributors in commerce, the proposed rule amends the compliance date for downstream notifications and the text required to be in the Safety Data Sheets (SDSs) to reflect the new prohibition compliance dates. EPA would require affected manufacturers, processors, and distributors to update the SDSs with the new text 30 days after the publication date of a final rule.
For refrigerant manufacturers, EPA proposes extending the first phaseout reduction of processing TCE as an intermediate to manufacture HFC-134a. The 2024 TCE final rule requires manufacturers to reduce the annual amount of TCE feedstock they use to no greater than 75 percent of their baseline by June 7, 2027. This proposed rule would push the compliance date to December 31, 2027.
Key to remember: EPA proposes extending the TCE prohibition compliance deadline for certain chemical processors and the TCE feedstock phasedown date for specific refrigerant manufacturers.
New Network Poll
Most Popular Highlights In Environmental
NewsIndustry NewsIndustry NewsWaste/HazWasteWasteEnvironmental Protection Agency (EPA)Waste ManagementEnvironmentalSolid WasteLand Disposal RestrictionsEnglishFocus AreaUSA
2025-09-05T05:00:00Z
Update: EPA withdraws direct rule, keeps proposed rule for alternative CCR reporting option
On September 4, 2025, the Environmental Protection Agency (EPA) withdrew a direct final rule it issued on July 22, 2025, that offered active and inactive coal combustion residuals (CCR) facilities an alternative reporting option and delayed corresponding compliance obligations for CCR management units (CCRMUs). However, the parallel proposed rule that was published with the direct final rule remains in place, and EPA has extended the comment period through September 15, 2025.
Who does this affect?
The direct and proposed rules impact (a) active CCR facilities and (b) inactive CCR facilities with inactive surface impoundments (called legacy CCR surface impoundments) that are regulated by the 2024 Legacy Rule.
What does this mean?
Because the direct rule was withdrawn, the alternative reporting option for the Facility Evaluation Report (FER) Part 1 doesn’t apply, and the compliance deadlines for the related CCRMU requirements revert to the previous timelines.
The parallel proposed rule remains active and contains the same changes as the withdrawn direct final rule, including:
- Adding an alternative option for active CCR facilities and legacy CCR surface impoundments to submit FER Parts 1 and 2 together by February 8, 2027; and
- Extending the related compliance deadlines for facilities with CCRMUs.
Further, the proposed rule seeks public input on potentially delaying both FER reporting deadlines and adjusting the CCRMU compliance timelines accordingly. The proposed additional extension would give CCR facilities the option to:
- Submit FER Part 1 by February 8, 2027, and FER Part 2 by February 8, 2028; or
- Submit FER Parts 1 and 2 together by February 8, 2028.
You can submit comments to Docket ID No. EPA-HQ-OLEM-2020-0107.
Please see the original Industry News article ("EPA offers CCR facilities delayed reporting option and extends compliance deadlines") for more information about the withdrawn direct rule and the active proposed rule.
Key to remember: EPA has withdrawn a direct final rule that offered active and inactive coal combustion facilities an alternative reporting option, but the agency has kept the corresponding proposed rule in place.
NewsWater ProgramsEnvironmental Protection Agency (EPA)Mobile Emission SourcesCAA ComplianceAir PermittingWater ProgramsCWA ComplianceEnglishAir ProgramsIndustry NewsIndustry NewsWater PermittingPoint SourcesCriteria Air PollutantsIndustrial WastewaterEnvironmentalFocus AreaAir ProgramsStationary Emission SourcesUSA
2026-05-19T05:00:00Z
EPA proposes major changes to multiple rules
The Environmental Protection Agency (EPA) has been on a rulemaking roll! In recent weeks, the agency has published significant proposed rules in the Federal Register that affect coal-fired power plant wastewater, pre-construction air permits, and vehicle emission requirements.
Coal-fired power plants: Unmanaged CRL discharges
EPA proposes to revise the wastewater requirements established by a 2024 final rule (2024 Rule) for unmanaged combustion residual leachate (CRL) from coal-fired power plants.
Unmanaged CRL (a type of waste stream) is water that contains coal combustion residuals and leaks from landfills or surface impoundments (i.e., waste management units). Unmanaged CRL includes:
- Pumped unmanaged CRL (leached CRL that’s captured, pumped to the surface, and discharged directly to waters of the United States); and
- The functional equivalent of an unmanaged CRL direct discharge (determined by the permitting authority).
The proposed rule applies to coal-fired power plants with unmanaged CRL that are subject to the 2024 Rule’s technology-based effluent limitations guidelines and standards.
The agency proposes three options to revise the unmanaged CRL requirements:
- Option 1 (preferred by EPA) would maintain the 2024 rule’s mercury and arsenic numeric limits for pumped unmanaged CRL discharges, but it would delay the compliance deadline from December 31, 2029, to December 31, 2034. Additionally, the permitting authorities would determine best available technology economically achievable (BAT) limits for functional equivalents on a case-by-case basis.
- Option 2 would maintain the 2024 rule’s mercury and arsenic numeric limits for pumped unmanaged CRL discharges and functional equivalents. It would also maintain the original compliance timeline of December 31, 2029.
- Option 3 would impose zero-discharge limits for all pollutants in pumped unmanaged CRL discharges and functional equivalents. It would also establish interim BAT limits for mercury and arsenic. Facilities would have to meet the zero-discharge limits by December 31, 2034.
Public comments are due by June 17, 2026 (Docket ID No. EPA–HQ–OW–2009–0819).
Pre-construction air permits: Begin actual construction
EPA proposes to allow construction-related activities on components or structures that don’t emit air pollutants to start before obtaining a New Source Review (NSR) pre-construction permit to build or modify a stationary source. The proposed rule:
- Redefines “begin actual construction," and
- Adds “pollutant-emitting activities” to the regulatory definitions.
Both definitions list equipment, components, and processes that are excluded, meaning that construction on these activities may begin before obtaining an NSR permit. Examples of exempt activities include compacting and stabilizing soil, paving surfaces, and installing concrete pads.
If finalized, the proposed rule will distinguish between construction on stationary sources and construction on non-emitting components (e.g., utility infrastructure, certain building foundations) and codify that on-site construction of non-emitting components or structures can begin before getting an NSR permit.
Public comments are due by June 29, 2026 (Docket ID No. EPA-HQ-OAR-2025-0618).
Light- and medium-duty vehicle regulations: Tier 4 standards
EPA published Part 1 of a two-part rulemaking effort to revise the Tier 4 criteria air pollutant standards set in 2024 (Tier 4 Rule) for light- and medium-duty vehicles (LMDVs), which include:
- Light-duty vehicles and trucks,
- Medium-duty passenger vehicles, and
- Medium-duty vehicles.
In Part 1, EPA proposes to amend the phase-in schedule for Tier 4 criteria air pollutant requirements by:
- Extending the Tier 3 standards set in 2014 (Tier 3 Rule) for LMDVs to model years (MYs) 2027 and 2028,
- Delaying the start of phasing in Tier 4 standards for LMDVs from MY 2027 to MY 2029, and
- Removing the optional early phase-in of Tier 4 standards for LMDVs with a gross vehicle weight rating of more than 6,000 pounds from MYs 2027 and 2028.
The agency also proposes to delay changes to the test protocols for emissions performance certification evaluations to MY 2029.
In Part 2, EPA will reconsider the Tier 4 Rule for LMDVs, which may include changing emission standards, lead time and phase-in schedules, and test procedures.
Public comments are due by July 6, 2026 (Docket ID No. EPA–HQ–OAR–2025–3297).
Key to remember: EPA has issued a series of proposed rules that, if finalized, may have significant regulatory impacts on power plant wastewater, pre-construction air permits, and vehicle emission requirements.
NewsIndustry NewsIndustry NewsToxic Substances Control Act - EPAToxic Subtances Control Act - EPATSCA ComplianceToxic Substances - EPAEnvironmental Protection Agency (EPA)EnvironmentalEnglishFocus AreaUSA
2026-04-13T05:00:00Z
EPA delays TSCA Section 8(a)(7) PFAS reporting timeline again
On April 13, 2026, the Environmental Protection Agency (EPA) published a final rule that further delays the submission period for the one-time report required of manufacturers on per- and polyfluoroalkyl substances (PFAS) by the PFAS Reporting and Recordkeeping Rule (PFAS Reporting Rule).
This final rule pushes the starting 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 is earlier.
Who’s impacted?
Established under Toxic Substances Control Act (TSCA) Section 8(a)(7), the PFAS Reporting Rule (40 CFR Part 705) requires any business that manufactured (including imported) any PFAS or PFAS-containing article between 2011 and 2022 to report. Covered manufacturers and importers must submit information on:
- Chemical identity, uses, and volumes made and processed;
- Byproducts;
- Environmental and health effects;
- Worker exposure; and
- Disposal.
What’s the new timeline?
The opening submission period was moved from April 13, 2026, to either 60 days after the effective date of a future final PFAS Reporting Rule or January 31, 2027, whichever is earlier.
Most manufacturers have 6 months to submit the report. Small manufacturers reporting only as importers of PFAS-containing articles have 1 year.
| TSCA Section 8(a)(7) PFAS Reporting Rule submission period | ||
|---|---|---|
| Start date | End date | |
| Most manufacturers | 60 days from effective date of final PFAS Reporting Rule or January 31, 2027 (whichever is earlier) | 6 months from start date or July 31, 2027 (whichever is earlier) |
| Small manufacturers reporting solely as PFAS article importers | 60 days from effective date of final PFAS Reporting Rule or January 31, 2027 (whichever is earlier) | 1 year from start date or January 31, 2028 (whichever is earlier) |
Why the delay?
In November 2025, the agency proposed updates to the PFAS Reporting Rule. EPA has delayed the reporting period to give the agency time to issue a final rule (expected later this year).
Key to remember: EPA has delayed the starting submission deadline for the TSCA Section 8(a)(7) PFAS Reporting Rule from April 2026 to no later than January 2027.
NewsAir QualityAir EmissionsEnvironmental Protection Agency (EPA)Hazardous Air PollutantsCAA ComplianceAir PermittingEnglishAir ProgramsIndustry NewsIndustry NewsEnvironmentalFocus AreaAir ProgramsStationary Emission SourcesUSA
2026-02-24T06:00:00Z
EPA repeals stricter Mercury and Air Toxics Standards for coal-, oil-fired power plants
On February 24, 2026, the Environmental Protection Agency (EPA) published a final rule repealing the 2024 amendments made to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Coal- and Oil-Fired Electric Utility Steam Generating Units (EGUs). It’s also referred to as the Mercury and Air Toxics Standards (MATS) for power plants.
Effective April 27, 2026, this rule (2026 Final Rule) repeals stricter compliance requirements made to the MATS rule in May 2024 (2024 Final Rule) and reverts them to the less stringent standards established by the 2012 MATS Rule.
Who’s affected?
The rule applies to power plants with coal- and oil-fired EGUs subject to the NESHAP (40 CFR 63 Subpart UUUUU).
What are the changes?
The final rule repeals these 2024 amendments:
- The revised filterable particulate matter (fPM) emission standard and corresponding total and individual non-metal hazardous air pollutant (HAP) metal standards for existing coal-fired EGUs (reverting to the 2012 MATS Rule requirements);
- The revised compliance demonstration requirements for all EGUs to install continuous emission monitoring systems (CEMS) for fPM emissions and the adjusted quality assurance criteria (reverting to the previous standard, allowing EGUs to choose from three compliance demonstration methods); and
- The revised mercury (Hg) emission standard for lignite-fired EGUs (reverting to the 2012 MATS Rule limit).
The 2026 Final Rule also reinstates the low-emitting EGU (LEE) program for fPM and non-Hg HAP metals. The LEE program requires less frequent stack testing for sources with emissions below 50 percent of the corresponding limit for 3 consecutive years.
Further, EPA’s final rule updates the fPM sampling requirements for EGUs that demonstrate compliance with a PM CEMS. These units must collect either a minimum catch of 6.0 milligrams or a minimum sample volume of 4 dry standard cubic meters (dscm) per test run. EGUs demonstrating compliance using other methods must collect a lower minimum sample volume of 1 dscm per PM test run.
| Compliance requirement | 2024 Final Rule | 2026 Final Rule |
|---|---|---|
| fPM emission limit for existing coal-fired EGUs | 0.010 pounds per million British thermal units of heat input (lb/MMBtu) | 0.030 lb/MMBTu |
| fPM emission compliance demonstration for all coal-and oil-fired EGUs | EGUs must use PM CEMS | EGUs may use:
|
| Hg emission limit for existing lignite-fired EGUs | 1.2 pounds per trillion British thermal units of heat input (lb/TBtu) | 4.0 lb/TBtu |
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:
|
|
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 NewsStationary Emission SourcesEnvironmental Protection Agency (EPA)Hazardous Air PollutantsCAA ComplianceEnvironmentalFocus AreaEnglishAir ProgramsAir ProgramsUSA
2026-03-19T05:00:00Z
Final rule adds EtO emission limits to polyether polyol production
The Environmental Protection Agency (EPA) finalized major changes to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Polyether Polyols (PEPO) Production (PEPO NESHAP).
Who’s impacted?
The final rule applies to facilities that produce polyether polyols and are subject to the regulations at 40 CFR 63 Subpart PPP.
What are the changes?
EPA’s final rule establishes ethylene oxide (EtO) standards, updates maximum achievable control technology (MACT) requirements, and revises other provisions for the PEPO NESHAP.
EtO standards
The final rule adds EtO emission standards for:
- Equipment leaks,
- Heat exchange systems,
- Process vents,
- Storage vessels, and
- Wastewater.
The standards set emission limits and add requirements for monitoring and leak repairs.
MACT standards
Further, the final rule:
- Requires heat exchange systems to use the more sensitive Modified El Paso Method (also known as the Air Stripping Method) for quarterly monitoring and a leak definition of 6.2 parts per million by volume of total strippable hydrocarbon concentration (as methane) in the stripping gas,
- Lowers the MACT control thresholds for batch process vents and storage vessels,
- Updates the requirements for internal floating roof storage vessels,
- Lowers the threshold for equipment leaks for valves in gas/vapor service or light liquid service, and
- Requires transfer operations with loading operations that exceed a certain threshold to use a vapor balance system or reduce emissions.
Other standards
EPA’s final rule also:
- Requires 5-year performance testing for process vent control devices;
- Revises flare monitoring and operational requirements to ensure they meet the MACT standards at all times when controlling hazardous air pollutant (HAP) emissions;
- Adds new monitoring requirements for pressure vessels to verify that no detectable emissions exist;
- Clarifies that any bypass of a pollution control device for closed vent systems is a violation;
- Aligns the requirements for surge control vessels and bottoms receivers with the process vent standards;
- Adds butylene oxide to the definition of “epoxide” and the HAPs list;
- Expands “affected source” to cover specific post-reaction processes; and
- Finalizes work practice standards for maintenance vents and equipment openings, storage vessel degassing, and routine storage vessel maintenance.
However, EPA didn’t finalize the 2024 proposed rule’s addition of a fenceline monitoring program for EtO or its changes to the continuous process vent standard.
What’s the compliance timeline?
Facilities subject to the PEPO NESHAP must comply with the changes by March 18, 2029, or upon startup, whichever is later.
Key to remember: EPA’s final rule for polyether polyol emissions makes significant changes, such as establishing EtO limits and revising MACT standards.
Most Popular Highlights In Transportation
NewsIndustry NewsRoad testFleet SafetyFederal Motor Carrier Safety Administration (FMCSA), DOTRisk Management TransportationDriver qualificationsRisk Management - Motor CarrierFocus AreaIn-Depth ArticleEnglishTransportationUSA
2026-10-26T05:00:00Z
Road test requirements: 3 common questions
When hiring commercial motor vehicle (CMV) drivers, motor carriers have limited information to judge how safely an applicant will perform behind the wheel. A driver’s record shows past behavior, but a road test lets the carrier evaluate the driver’s skills firsthand.
Below are three common road test questions, along with the basic requirements and some best practices to help you go beyond the minimum.
1. Does every driver have to take a road test?
Not necessarily. A motor carrier generally cannot allow a driver to operate a CMV until the driver successfully completes a road test and receives a certificate of the driver's road test.
However, the Federal Motor Carrier Safety Regulations (FMCSRs) allow a carrier to accept certain documents as the equivalent of a road test. The most common document is a valid commercial driver’s license (CDL). Keep in mind, if the driver will operate a vehicle that requires a double/triple or tank endorsement, a road test must be performed in that type of vehicle.
Just because the FMCSRs allow an exception doesn’t mean carriers must use it. A road test is your opportunity to verify that a driver can safely operate the assigned vehicle. Skipping the road test can also weaken your defense in post-accident litigation if you could have identified a risk but chose not to. As a best practice, many carriers road test all drivers, regardless of exceptions.
2. Who can administer the road test?
The road test must be given by the motor carrier or a person the carrier designates. That person must be competent enough to evaluate whether the driver can safely operate the type of CMV the driver will be assigned.
Don’t assume anyone with CMV-driving experience is automatically qualified to administer the test. The carrier is responsible for selecting the right person to evaluate the driver’s performance. You should be able to explain why that person is a competent examiner.
Training examiners and setting clear expectations are just as important. A consistent testing process across all examiners is key to a successful road test program, and examiners should be evaluated periodically to make sure they remain effective.
3. What must the road test cover?
Section 391.31 of the FMCSRs identifies specific areas that must be evaluated. Depending on the vehicle, these include:
- Performing a pre-trip inspection required by 392.7;
- Coupling and uncoupling combination units, when applicable;
- Placing the vehicle in operation;
- Using the vehicle's controls and emergency equipment;
- Operating safely in traffic;
- Turning and other vehicle movements;
- Braking and slowing the vehicle; and
- Backing and parking.
As a best practice, your evaluation criteria should expand on each required area and include common scenarios drivers face during a typical day. You must also have a system to rate the driver’s performance in each operation tested.
Document any areas that need improvement, along with any additional training or corrective action taken after the test. This shows effective safety management controls are in place. If a road test shows a driver needed improvement in an area and no action was taken, that might be tough to explain in post-accident litigation.
Key to remember: Don’t treat the road test as just another document for the driver qualifications file. It’s one of the few chances you’ll have to verify that a driver can safely operate the assigned vehicle.
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 SafetyHazmatIn-Depth ArticleFocus AreaUSAEnglishTransportationHazmat Rulemaking procedures
2023-12-22T06:00:00Z
Navigating change: Key updates to 2024 IATA DGR take effect
Every year the International Air Transport Association (IATA) updates its Dangerous Goods Regulations (DGR) to ensure the safe and secure handling of dangerous goods that are shipped or transported by air. While changes to the 2024 IATA DGR (65th edition) are not as plentiful as they were in previous years, they are no less important.
Mandatory compliance with the 2024 IATA DGR begins on January 1, 2024, and will be valid until the 2025 IATA DGR comes into effect. Let’s look at the key updates, listed by Section, for the 65th edition of the IATA DGR:
Need additional information for IATA? Check out this ezExplanation.
Limitations
- Dangerous Goods Carried by Passengers or Crew (2.3)— Provisions for battery-powered mobility aids have been revised to include reference to the guidance on the end-to-end processes associated with the carriage of mobility aids.
Packing
The following packing instructions have been updated:
- 5.2.0.9 - Added a water capacity limit for non-refillable cylinders containing a flammable gas, limited to a water capacity not exceeding 1.25 L.
- PI 952 - Revised to include reference to "equipment."
- PI 954 - Clarified the rules for marking overpacks containing dry ice. The total net quantity of dry ice in the overpack must be marked on the outside of the overpack.
Packaging specifications and performance tests
- 6.0.3 - Clarified the requirements and formatting for UN specification marks on packages.
Documentation
- 8.1.6.9.2, Step 6 – Added a note to "reinforce that there is no requirement for the type, number and net quantity in inner packagings within the outer packaging of a combination packaging to be shown" on the shipping papers (Shippers Declaration for Dangerous Goods).
Radioactive materials
- 10.8.3.9.1—Added an additional example of the description for the first sequence of information on the Shipper's Declaration to address where a radioactive material has a subsidiary hazard, and the proper shipping name must be supplemented by the technical or chemical name.
- 10.8.6—Added two examples to show how radioactive materials with a subsidiary hazard should be described and how packages in an overpack should be shown.
Appendices
IATA has added a new appendix to the list of appendices in the DGR. Appendix H includes a list of changes IATA will make to the 2025 IATA DGR. IATA added Appendix H so that shippers and carriers have time to prepare for the substantial updates that are coming for 2025. Some of the changes include:
- Adding an exception for data loggers and cargo trackers with installed lithium batteries.
- Modifying the exception for COVID-19 vaccines to now apply to all pharmaceutical products.
- Adding a new classification for sodium ion batteries.
- Updating the list of dangerous goods and special provisions.
- Amending and adding several packing instructions.
- Revising the "lithium battery mark", which will be known as the "battery mark" in the future.
Making sure you are keeping up with these regulatory changes and preparing for future updates is extremely important if you want to avoid costly delays, fines, and lost revenue. Keep your hazmat employees up to speed and inform them of any changes they need to be aware of.
Key to Remember: IATA updates their DGR every year and changes to the 2024 IATA DGR become effective on January 1, 2024.
NewsIndustry NewsFleet SafetyFocus AreaIn-Depth ArticleUSAEnglishRoadside InspectionsTransportationEnforcement - DOT
2022-07-01T05:00:00Z
Answers to common questions about annual inspections
The basic requirement for the periodic (normally annual) inspection required in 396.17 is, “Every commercial motor vehicle must be inspected as required by this section. The inspection must include, at a minimum, the parts and accessories set forth in appendix A to this part.”
Here are some common questions when it comes to this requirement and the answers to these questions.
Question: What vehicles are covered by this regulation?
Answer: All commercial vehicles meeting the definition of a commercial vehicle in 390.5 must be periodically inspected. This includes vehicles that:
- Are used in interstate commerce with an actual or rated weight of 10,001 pounds or more,
- Seat more than 8 or 15 (depending on compensation), or
- Are placarded for hazardous materials.
Also, all vehicles that make up a combination commercial vehicle (power unit and any trailing units) must be inspected (see 396.17(a)). This includes a pickup truck and trailer if the combination meets the definition of a CMV.
Question: What if my vehicle must be inspected under a state-mandatory inspection program?
Answer: If the vehicle must be inspected under a state-mandatory vehicle inspection program, and FMCSA has determined the inspection is the equivalent of the FMCSA annual inspection, the inspections done under the state-mandatory inspection program can be used to satisfy the FMCSA requirement (see 396.23).
Question: Who can do annual inspections?
Answer: In general, the person doing the inspection must be qualified under 396.19. If the person meets the requirements in this section, the employer documents the person’s qualifications and keeps the qualification documents on file for the entire time the person is doing the inspections, and then for one year thereafter. However, some of the state-mandatory programs require that the vehicle be inspected by state-licensed inspectors and/or at facilities that have been certified by the state. In some of these states, a carrier can have their personnel and/or facilities certified to conduct the inspections.
Question: What is acceptable proof of inspection?
Answer: Once the inspection is passed, a periodic inspection report is completed (see 396.21(a)). If the carrier is investigated or audited, the report must be provided to an investigator or auditor by the carrier. Proof of passing the inspection must also be on the vehicle. The proof can be EITHER a decal containing the information listed in 396.17(c) indicating when the inspection was done and where the report is located, OR a copy of the report (paper or electronic). The vehicle is not required to have both.
Question: Can I have an outside shop (or the dealer in the case of a new vehicle) do the inspection and keep the records for me?
Answer: Yes, see 396.21(b). However, if you are audited or investigated, you will be responsible for securing the report and presenting it, if you don’t have a copy on file in your office.
Key to remember: There are a lot of questions when it comes to annual inspections. However, the answers can generally be found in the Part 396 regulations.
NewsIndustry NewsIndustry NewsSpeed limitsAnnual inspections - Motor CarrierCMV drivingFocus AreaUSAFleet OperationsEnglishTransportationCMV Inspections
2026-10-15T05:00:00Z
Safe driving habits are on cruise control: Tickets/warnings issued to over half of drivers
Of the 8,083 commercial motor vehicle and passenger vehicle drivers tested across North American roadways during the 2026 Operation Safe Driver Week initiative, 3,968 warnings and 2,604 tickets were issued for unsafe driving behaviors.
Speeding, distracted driving, and aggressive driving were among the leading causes of roadway crashes cited, according to the Commercial Vehicle Safety Alliance’s (CVSA’s) 2026 North America safety event findings from July 12–18.
The top unsafe behaviors of 2026 include:
- Reckless, careless, and dangerous driving, which was the focus of this year’s Operation Safe Driver Week: 83 warnings and 33 citations were issued. Broken down by driver type, 50 warnings and 22 citations were issued to commercial motor vehicle drivers, and 33 warnings and 11 citations were issued to passenger vehicle drivers.
- Speeding, which was the most cited behavior: 1,003 warnings and 691 citations were issued. Broken down by driver type, 772 warnings and 342 citations were issued to commercial motor vehicle drivers, and 231 warnings and 349 citations were issued to passenger vehicle drivers.
- Failure to wear a seat belt: 292 warnings and 311 citations were issued. Broken down by driver type, 267 warnings and 270 citations were issued to commercial motor vehicle drivers, and 25 warnings and 41 citations were issued to passenger vehicle drivers.
- Possession, use or impairment of drugs or alcohol: 17 warnings and 26 citations were issued. Broken down by type, 12 warnings and 22 citations were issued to commercial motor vehicle drivers, and 5 warnings and 4 citations were issued to passenger vehicle drivers.
| Other Top Warnings, Citations, and Tickets Issued to CMV Drivers | ||
| Offense | Total # Warnings | Total # Citations |
| Failure to obey traffic control device | 652 | 319 |
| Improper lane change | 76 | 23 |
| Following too closely | 48 | 23 |
| Improper passing | 29 | 10 |
| Improper turn | 12 | 3 |
NewsIndustry NewsFleet SafetyDriver qualificationsDriving RecordsEnforcement - DOTFocus AreaIn-Depth ArticleEnglishRoadside InspectionsTransportationUSA
2024-01-12T06:00:00Z
Answers to 3 key questions to keep commercial drivers compliant after vision surgery
Options for corrective vision surgery have significantly increased over the past 25 years. Commercial drivers who meet vision standards post-surgery must update their licensing and medical certifications. They must also understand the consequences of inaction.
During a roadside inspection after vision surgery, if the driver's license or medical card states that corrective lenses are required, the driver must prove they are wearing them. If the driver is not wearing glasses or contacts, but the driver's license or medical card still lists them as required, the driver will be cited and placed out of service.
Three key questions
Below are three questions and the answers to which can help avoid citations and out-of-service orders relating to vision requirements.
1. What must a driver do after vision surgery if they no longer require corrective lenses?
Answer: The driver must:
- Take a vision test at the motor vehicle department to have the corrective lenses restriction removed from their license, and
- Contact a certified medical examiner (CME) from the National Registry for an exam to remove the corrective lenses requirement from their medical certification.
The driver may also need to undergo an eye exam from an optometrist or ophthalmologist if requested by the CME.
2. If a medical certification says corrective lenses are required, but the license does not, or vice versa, is this a violation in a roadside inspection?
Answer: Yes. If the driver is not wearing corrective lenses, it is a medical qualification violation per Federal Motor Carrier Safety Administration Regulations (FMCSRs) §391.11(b)(4), and the driver must be placed out of service.
Alternatively, if the license says corrective lenses are required, and the driver is not wearing them, then the citation is written as a licensing violation (§391.11(b)(5) or §383.21(a)(2)), and the driver must also be placed out of service.
3. Is the discrepancy a violation if the driver wears corrective lenses as specified by their medical certification but not on their license?
Answer: No. The violation only exists if the license or the medical certification requires corrective lenses and the driver is not wearing them.
Some states do not use the same criteria for requiring corrective lenses as are specified in the FMCSRs vision standard in §391.41(b)(10), so there's a difference it's not a violation. In many states, it is possible to have a license without the corrective lens restriction and not be able to pass the federal vision standard.
Drivers are usually licensed for more than five years. Vision can change during periods far longer than the maximum two-year medical certification.
Keep in mind, a medical qualification violation cannot be challenged in the FMCSA's DataQs system because "the driver didn't need corrective lenses anymore." Post-surgery, the medical certification, and license must reflect that no corrective lenses are needed, or the driver will face consequences.
Key to remember: Educate drivers on the requirement to update their license and medical certification after corrective vision surgery to keep them compliant.
Most Popular Highlights In Human Resources
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.
NewsChange NoticesWage and HourChange NoticeAssociate Benefits & CompensationCaliforniaAssociate RelationsHR GeneralistMinimum WageHR ManagementEnglishFocus AreaHuman Resources
2026-11-04T06:00:00Z
California (Novato) to increase minimum wage
Effective date: January 1, 2027
This applies to: Employers with employees who perform more than 2 hours of work in a particular week within city limits
Description of change: Effective January 1, 2027, the Novato, California minimum wage increases as follows:
- Very large businesses (100+ employees): from $17.73 to $18.25 per hour
- Large businesses (26-99 employees): from $17.46 to $17.97 per hour
- Small businesses (1 – 25 employees): from $16.90 to $17.40 per hour
NewsChange NoticesWage and HourChange NoticeAssociate Benefits & CompensationCaliforniaAssociate RelationsHR GeneralistMinimum WageHR ManagementEnglishFocus AreaHuman Resources
2026-11-04T06:00:00Z
California (Daly City) to increase minimum wage
Effective date: January 1, 2027
This applies to: Employers with employees working within the geographic boundaries of Daly City, California, and any employee working at least 2 or more hours per week
Description of change: Effective January 1, 2027, Daly City, California’s minimum wage increases from $17.50 to $18.10 per hour.
Employers may not use tips or fringe benefits such as health insurance, vacation, sick leave, or other benefits to offset or use as a credit towards the employer's obligation to pay the Daly City's minimum wage.
NewsIndustry NewsSexual HarassmentSexual HarassmentTraining & DevelopmentHR GeneralistIn-Depth ArticleUSAHR ManagementEnglishFocus AreaHuman Resources
2026-10-28T05:00:00Z
Chicago requires bystander training. Should you?
If you’re an employer whose company is in Chicago or New York City, you’re required to provide bystander intervention training in addition to sexual harassment prevention training. In other locations, bystander training isn’t legally required, but it’s still considered a best practice.
One reason bystander training makes sense for all workplaces is that it can help show that an employer took reasonable steps to prevent harassment, which might be relevant in a legal defense, should an incident ever become a court case.
What is bystander training?
Bystander intervention training is being used in organizations to prevent violence and sexual harassment. As the name implies, bystander intervention training encourages people who witness potentially harassing situations to step in to diffuse them.
Bystander training is effective because without it, employees who see inappropriate workplace behavior may want to help but hesitate because they don’t know what to say or do. This type of training gives employees practical options for responding to a situation without expecting them to confront someone or put themselves at risk.
The goal isn’t to turn employees into investigators or ask them to decide whether conduct violates the law. It’s to help them recognize concerning behavior, support coworkers, and know when and how to raise concerns. Employers can reinforce that message by explaining how reports are handled and assure employees that they won’t face retaliation for speaking up.
What to include in bystander training
Give employees realistic examples so they can practice choosing how to respond. Training should cover:
- Recognizing concerning conduct. Use scenarios involving inappropriate jokes, repeated put-downs, bullying, or other behavior that conflicts with workplace policies.
- Choosing a safe response. Options could include briefly speaking up, interrupting or redirecting a conversation, or seeking help from a supervisor or HR. Emphasize that direct confrontation isn’t always appropriate.
- Supporting the person affected. Show employees how to check in privately and offer support without pressuring the person to share details. Explain what the available reporting options are and where to go for help.
- Reporting concerns. Identify reporting channels, explain what information is helpful, and distinguish employees’ options from supervisors’ responsibilities under company policy.
- Avoiding retaliation. Explain the company’s prohibition against retaliation and how employees can report concerns about it without fear of losing their job.
Keep examples relevant to your workplace, including remote meetings, group chats, customer interactions, and situations involving someone in a position of authority.
End ‘normalizing’
One goal of bystander training is to put an end to “normalizing” bad workplace behaviors. Normalizing occurs when a person dismisses or overlooks misconduct for so long that it begins to feel acceptable or expected. Typically, this occurs because an employee or supervisor believes the behavior is unavoidable or easier to ignore than to address.
There’s no environment where people should continue to dismiss acts of harassment because “that’s just the way it is here.” Sexual harassment is pervasive in some workplaces, but that doesn’t mean it’s acceptable or something to tolerate.
Key to remember: Bystander training should give employees safe options, clear reporting channels, and opportunities to practice ways to respond. Reinforce the training with consistent follow-through, so employees know they’ll be supported if they speak up.
NewsIndustry NewsIndustry NewsAssociate Benefits & CompensationHR GeneralistFamily and Medical Leave Act (FMLA)Family and Medical Leave Act (FMLA)Associate RelationsEnglishHR ManagementFocus AreaHuman ResourcesUSA
2026-10-14T05:00:00Z
HR manager didn’t follow company policy for his own FMLA leave, and got terminated for it
In early 2023, Frank, an HR manager, suffered from severe right shoulder arthritis. Starting on February 21, he decided to take leave under the federal Family and Medical Leave Act (FMLA) to manage his health issues, eventually opting for surgery.
The employer’s policy indicated that requests for FMLA leave be made through the HR Department on the forms provided. The forms required employees to provide a medical certification to support the absence.
When Frank first asked for leave, he didn’t submit a medical certification. He argued that delayed submission of such paperwork was, nonetheless, consistent with the employer’s customary practice. During his tenure as HR manager, he would also retroactively approve FMLA leave for employees who began their leave before filling out the required paperwork.
On March 9, Debra, a company director, sent Frank a letter reminding him to submit the medical certification by March 17. When Frank failed to do so, Debra sent him a second, third, and fourth reminder, extending the deadline each time. In the last two letters, she warned Frank that failure to comply with the company leave policies could result in his termination.
Frank didn’t submit a certification until May 4. It excused his absence beginning May 2, but didn’t address his absences from February 21 to May 1. He never provided documentation covering the prior absences or a reason for them.
On July 7, before he could return to work, the employer informed Frank that his employment was terminated. The termination letter cited his “failure to provide the healthcare certifications required” by company policies, which resulted in his incurring “multiple unexcused absences in violation of the” company’s personnel code.
Frank sued, but the court sided with the employer, despite the suspicious timing of the termination. It first noted that when an employee takes leave without complying with the employer’s internal leave policies, they haven’t “engaged in any activity protected by the FMLA.” Also, since Frank failed to provide a certification supporting his leave from February 21 to May 1, the FMLA didn’t cover his time off, and he didn’t engage in FMLA-protected activity.
Bergman v. St. Clair County, Southern District of Illinois, No. 3:24-CV-02374, September 23, 2026.
Key to remember: If an employee fails to provide a requested FMLA certification without justification, employers may deny FMLA protections.
Court decisions are based on the specific facts presented and each court’s interpretation of the law. Because courts may reach different conclusions, similar situations can lead to different outcomes. Employers should avoid relying on a single case as definitive guidance and instead assess each situation carefully, considering applicable laws, and seeking advice when needed.
NewsIndustry NewsAssociate Benefits & CompensationHR GeneralistFamily and Medical Leave Act (FMLA)In-Depth ArticleFamily and Medical Leave Act (FMLA)Associate RelationsEnglishHR ManagementFocus AreaHuman ResourcesUSA
2025-03-27T05:00:00Z
Who can fill out FMLA forms? The answer might surprise you
One of the most common questions involving the federal Family and Medical Leave Act (FMLA) that we see is: “Can ________ fill out the medical certification?”
This question stumps a lot of HR people and can be a little confusing.
It might be easier to start with who CAN’T fill out an FMLA certification. That includes your coworker, best friend, neighbor, or pet.
Jokes aside, often (but not always) a doctor fills out the FMLA certification, and since March 30 is “Doctors’ Day,” this is a great time to discuss this topic.
FMLA certification basics
Employers aren’t required to use certifications, but if they do, the U.S. Department of Labor (DOL) has five different certification forms to use for various FMLA leave situations.
The forms are as follows:
- Certification of Health Care Provider for Employee's Serious Health Condition,
- Certification of Health Care Provider for Family Member's Serious Health Condition,
- Certification of Qualifying Exigency for Military Family Leave,
- Certification for Serious Injury or Illness of a Current Servicemember for Military Family Leave, and
- Certification for Serious Injury or Illness of a Veteran for Military Family Leave.
Let’s focus on the first two, as these are the most common ones HR administrators use.
Who can fill out an FMLA certification?
The FMLA regulations describe the person who has the authority to fill out a certification as a “health care provider.” The good news is, the regulations include a lengthy list of medical professionals who fit this role.
Under the FMLA, a health care provider includes:
- A doctor of medicine or osteopathy,
- A podiatrist,
- A dentist,
- A clinical psychologist,
- An optometrist,
- A chiropractor (limited to manual manipulation of the spine as demonstrated by X-ray),
- A nurse practitioner,
- A nurse midwife,
- A clinical social worker,
- A physician assistant,
- A Christian Science practitioner, and
- Any health care provider from whom the employer or the employer's group health plan's benefits manager will accept a medical certification to substantiate a claim for benefits.
To be qualified to fill out FMLA forms, medical professionals must be authorized to practice in the state and perform within the scope of their practice. This means that the provider must be authorized to diagnose and treat physical or mental health conditions.
What about doctors in a foreign country?
If an employee or an employee's family member is visiting another country, or a family member resides in another country, and a serious health condition develops, the employer must accept a medical certification from a health care provider who practices in that country. This includes second and third opinions.
If a medical certification from a foreign health care provider is not in English, the employee may be required to provide a written translation of the certification.
Key to remember: The FMLA regulations spell out which medical professionals can fill out certification forms.
Most Popular Highlights In Safety & Health
NewsIndustry NewsSafety and Health Programs and TrainingSafety & HealthBehavior Based SafetyConstruction SafetyGeneral Industry SafetyIn-Depth ArticleEnglishFocus AreaUSA
2026-10-29T05:00:00Z
Fatigue doesn't always look like fatigue
When people think about fatigue, they may picture someone struggling to stay awake. However, the signs of fatigue can be much less obvious. An employee may appear alert, continue working normally, and still experience subtle changes in focus, awareness, reaction time, and decision-making.
This time of year can create additional challenges. As we approach the holiday season, employees may face increased production demands, year-end projects, inventory activities, or other operational pressures. Combined with seasonal weather conditions, these factors can make fatigue more likely to affect workplace performance.
Workplace demands
Physical demands, sustained concentration, environmental conditions, and the length or pace of the workday add up over time. An employee may handle one of these demands without difficulty, but several occurring together can make it harder to maintain focus and respond safely as the day goes on. Contributing factors can include:
- Repetitive tasks,
- Physically demanding work,
- Extended periods of concentration,
- Environmental conditions such as heat or cold,
- Long or consecutive workdays, and
- High-production periods.
When hazards become easier to miss
Fatigue doesn't introduce a new physical hazard. Instead, it can affect how employees recognize and respond to hazards already present in the workplace. A condition that would normally catch an employee’s attention may be overlooked when concentration, judgment, or reaction time declines.
These can become more of a concern during longer workdays, demanding production periods, or work performed in cold conditions. Employees may miss details during inspections, overlook a procedural step, or react more slowly when equipment, traffic, or job conditions change.
The effects can show up across the workplace
Any task that requires sustained attention, sound judgment, or physical coordination may become more difficult to perform safely as alertness declines.
For example, an employee operating a forklift may be slower to recognize a pedestrian entering the travel path. A maintenance employee may overlook a step in a procedure. An inspector may have missed a condition that would have been noticed earlier in the shift. Small mistakes don't always lead to incidents, but they can increase the likelihood that something goes wrong.
Warning signs often appear before an injury occurs
Fatigue-related concerns may be present long before an injury or property damage event. The first signs may be subtle and may not immediately raise a safety concern. Potential warning signs include:
- Increased errors,
- Missed procedural steps,
- Reduced attention to detail,
- Frequent near misses,
- Slower response times, and
- Difficulty maintaining concentration.
Recognizing these warning signs can help make fatigue part of the broader conversation about workplace hazards. Employers can help by encouraging employees to speak up when alertness declines and by considering fatigue when workplace conditions or job demands change.
Key to remember: Fatigue can affect performance long before an employee appears tired. Understanding how fatigue influences workplace safety can help employers identify risks before they contribute to an incident.
NewsIndustry NewsSafety and Health Programs and TrainingSafety & HealthConstruction SafetyGeneral Industry SafetyOSHA Outreach TrainingMaritime SafetyIn-Depth ArticleEnglishFocus AreaUSA
2026-10-29T05:00:00Z
OSHA 10- and 30-hour training: Common questions answered
Is an OSHA 10 or 30 card a certification? Who’s required to take the training? Does completing a course mean an employee is qualified to perform specific tasks? Can employers use the training as proof they’ve met all OSHA training requirements? Let’s dive into these and other common questions surrounding OSHA 10- and 30-hour courses.
Is an OSHA 10 or 30 card a certification?
No, the card isn’t a certification and completing a course doesn’t mean an employee is qualified to perform specific tasks. The courses are a foundation for hazard awareness and emphasize hazard identification, avoidance, control, and prevention, rather than OSHA standards. Employers must ensure employees receive job-specific training on the hazards they may encounter in the workplace.
Who’s required to take the training?
OSHA’s 10- and 30-hour Outreach Training Program is a voluntary program for workers in general industry, construction, maritime, and disaster site work. No OSHA standard requires employees to take the 10- or 30-hour outreach courses. Some states and municipalities, however, have enacted laws mandating the training, particularly for certain construction projects. It’s also not uncommon for private construction or service contracts to include requirements that only workers who have completed a 10- or 30-hour OSHA outreach course be allowed to work on the site.
10 vs. 30: What’s the difference?
Both courses provide basic awareness training on the recognition, avoidance, abatement, and prevention of workplace hazards. They also provide information regarding workers’ rights, employer responsibilities, and filing a complaint with OSHA.
The 10-hour training program is primarily intended for entry level workers while the 30-hour training program is more appropriate for supervisors or workers with some safety responsibility. It provides a greater depth and variety of training on an expanded list of topics associated with workplace hazards in each industry.
When the 10- or 30-hour courses are taught by OSHA authorized trainers, trainees will receive course completion cards from OSHA. As mentioned, these cards are not certifications, but they do acknowledge that the person has taken either a 10-hour or 30-hour OSHA outreach training course that was taught by an authorized trainer.
At the federal level, student course completion cards don’t have an expiration date. However, some states and municipalities do have further training requirements, such as refresher training every five years, so it’s important to be aware of such requirements.
How do you become an authorized trainer?
To become an authorized trainer to conduct 10- and 30-hour general industry outreach courses, you must complete OSHA’s Course #501, Trainer Course in Occupational Safety and Health Standards for General Industry. For construction courses, you must complete OSHA’s Course #500, Trainer Course in Occupational Safety and Health Standards for the Construction Industry. The trainer course is mandatory for those trainers who conduct 10- and 30-hour courses and issue OSHA course completion cards to the students.
Only the OSHA Training Institute (OTI) and OTI Education Centers can offer OSHA courses. The #500 and #501 courses are offered at OTI Education Centers around the country.
Trainers are independent service providers and their schedules and fees may vary. All trainers should possess a trainer card which includes an expiration date along with the name of the authorizing OTI Education Center.
Key to remember: No OSHA standard requires employees to take 10- or 30-hour outreach courses. However, some states, municipalities, and private employers may have such requirements. Even if employees take OSHA 10 or 30 courses, employers must ensure they receive job-specific training on the hazards they may encounter in the workplace.
True
NewsHazard ClassificationsIn-Depth ArticleHazard CommunicationHazCom Written ProgramHazcom LabelingEnglishHazCom Information and TrainingIndustry NewsSafety & HealthConstruction SafetyGeneral Industry SafetyHazard CommunicationFocus AreaUSA
2026-10-21T05:00:00Z
November 20 Is Coming: Is Your HazCom Program Ready?
Every October, OSHA hands employers its cheat sheet. The preliminary fiscal year 2026 numbers came out this month, and Hazard Communication (29 CFR 1910.1200) ranked second overall and first in general industry, with 1,961 citations.
That's down 23% from the year before, and it would probably be pretty easy to just assume the sharp decline as progress. However, it's more likely a lull. For all of FY2026, employers were operating inside a transition window that allowed compliance with the 2012 standard, the 2024 standard, or both. That window closes for employers on November 20, 2026. Every HazCom citation written in FY2027 will be measured against the new rule.
How we got to this point
OSHA published its updated HazCom final rule on May 20, 2024 (89 FR 44144), aligning the standard with Revision 7 of the UN's Globally Harmonized System plus selected Revision 8 elements. In January 2026, with the first deadline days away and its own guidance documents unfinished, OSHA pushed every compliance date back four months (91 FR 1695). The schedule under 1910.1200(j) now reads:
- May 19, 2026: Manufacturers, importers and distributors: substances (passed)
- November 20, 2026: Employers: substances
- November 19, 2027: Manufacturers, importers and distributors: mixtures
- May 19, 2028: Employers: mixtures
The upcoming November date requires employers to update alternative workplace labeling, revise their written hazard communication programs, and train workers on newly identified hazards for substances whose classifications changed.
The manufacturer deadline for substances passed in May, which means reclassified safety data sheets have been arriving. Some products picked up new hazard classes, such as the new Category 3 for non-flammable aerosols or the subdivided flammable gas categories. Others shifted or changed hazard statements or precautionary language.
Each of those revised SDSs will need to be studied by employers because they could contain triggers. Under 1910.1200(h)(1), employers must train workers whenever a new chemical hazard is introduced into the work area. That includes a reclassified product. If your workplace labels, inventory and training still reflect the old SDS, you are out of step with the first document an inspector will ask for.
The cost of falling behind
Federal OSHA's maximum penalty is $16,550 per serious violation and $165,514 per willful or repeat violation. Those figures didn't rise this year and OSHA skipped the 2026 inflation adjustment because the fall 2025 government shutdown delayed the CPI data it relies on. Expect an adjustment in 2027.
Individual HazCom citations rarely make headlines. The real exposure is cumulative. HazCom violations often pop up alongside respiratory protection and PPE citations, and a HazCom citation today becomes the possibility for a repeat classification tomorrow, at ten times the price.
A 30-day action plan
With about a month left to prepare, focus on what an inspector will actually ask for.
- Audit your SDS library: Request current SDSs from every supplier and compare Section 2 against the versions on file. Flag every changed classification.
- True up the chemical inventory: The list required by 1910.1200(e)(1)(i) must use product identifiers that match the current SDS.
- Audit workplace labels: Secondary containers and alternative systems such as HMIS or NFPA must convey hazard information consistent with the updated SDS. Reclassified products need relabeling.
- Revise the written program: Document how you receive, review and distribute updated SDSs, and reference the 2024 standard. Inspectors usually start here.
- Retrain, and document it: Target training to the products that changed rather than running a generic refresher. Record dates, attendees and content.
- Prepare for 2028: The mixtures deadline is a pretty big wave, because most workplace chemicals are mixtures. The SDS review process you build this month is the one you'll lean on through May 2028.
Keys to remember: November 20, 2026, is the employer HazCom deadline for substances. Employers must be ready to address updated hazard classifications flowing downstream from manufacturers and importers.
NewsIndustry NewsIndustry NewsSafety & HealthConstruction SafetyLockout/TagoutGeneral Industry SafetyFire Protection and PreventionFire ExtinguishersEnglishFocus AreaUSA
2026-10-20T05:00:00Z
NIOSH publishes toolbox talks on fire safety, LOTO
The National Institute for Occupational Safety and Health (NIOSH) recently published two toolbox talk documents, one addressing workplace fire hazards and the other focusing on lockout/tagout (LOTO).
The fire safety toolbox talk describes a fatal incident involving a worker who was unable to detect smoke due to a lack of functioning smoke alarms. The document highlights the importance of fire protection programs, hazard identification, fire extinguishers, and proper ventilation to remove flammable and combustible fumes and vapors.
The LOTO toolbox talk explains how to safely shut off or isolate power to a machine. Steps include:
- Applying a hasp to lock the energy source in the off position,
- Tagging the equipment,
- Releasing or blocking any stored energy, and
- Ensuring the machine is off before servicing it.
Both documents are available on NIOSH’s website.
NewsExcavation Hazard IdentificationIndustry NewsExcavationsSafety & HealthConstruction SafetyExcavationsExpert InsightsEnglishFocus AreaUSA
2026-10-15T05:00:00Z
Expert Insights: Trench Safety by the Numbers
When I started working in construction safety, my colleague and I loved to challenge each other with safety questions to keep on top of our game amidst a dynamic construction world. Remembering safety rules is critical, but can be overwhelming, when it comes to excavation and trenches for example. Things such as when a protection system is required, when an egress method is necessary, or at what point a professional engineer needs to get involved come to mind. So, we came up with a little quiz called Excavation Safety by the Numbers to help refresh the what, where, and when of excavations. Here are some common numbers by the foot: 2, 4, 5, 6, 20, and 25.
2 Feet
There are two circumstances where the number 2 comes into play.
- Spoil piles must be at least 2 feet from the edge of an excavation or trench provided the surface is able to support such a load.
- If using a trench box or other engineered protection system, the bottom of the protection system cannot be more than 2 feet above the bottom of the trench or excavation.
4 Feet with 25 feet
Four feet is the trench or excavation depth that triggers the requirement to have a means of egress such as a ladder. Depending on the length of the trench/excavation, the maximum travel distance to or between egress points is 25 feet.
5 Feet
A protective system is required for trenches and excavations 5 feet deep or deeper unless a competent person determines the excavation is entirely in stable rock.
6 Feet
If employees are working near the edge of a trench/excavation with a depth of 6 feet or more, then fall protection/prevention is required.
20 Feet
If the depth of a trench/excavation is greater than 20 feet, then the protective system must be designed and approved by a professional engineer. While this number quiz does not encompass every aspect of trench/excavation safety, it may help reinforce key concepts before the first scoop of soil is moved. Remember to follow specific jobsite requirements for each trench and excavation.
NewsIndustry NewsIndustry NewsEnforcement and Audits - OSHASafety & HealthConstruction SafetyGeneral Industry SafetyAgriculture SafetyMaritime SafetyFocus AreaEnglishOSHA Violations and PenaltiesUSA
2026-05-28T05:00:00Z
OSHA penalty amounts won’t increase in 2026
OSHA won’t increase its penalty amounts in 2026. The agency is required to annually adjust its penalties for inflation, based specifically on the October Consumer Price Index for All Urban Consumers (CPI-U) data released by the Bureau of Labor Statistics (BLS). Due to a lapse in funding, BLS did not release the October 2025 data. Because no alternative calculation is allowed, OSHA penalties will remain at the 2025 amounts.
| Type of violation | Penalty |
| Serious Other-than-serious Posting requirements | $16,550 per violation |
| Failure to abate | $16,550 per day beyond the abatement date |
| Willful or repeated | $165,514 per violation |
Saved to my EVENT CALENDAR!
View your saved links by clicking the arrow next to your profile picture located in the header. Then, click “My Activity” to view the Event Calendar on your Activity page.
OK
J. J. Keller is the trusted source for DOT / Transportation, OSHA / Workplace Safety, Human Resources, Construction Safety and Hazmat / Hazardous Materials regulation compliance products and services. J. J. Keller helps you increase safety awareness, reduce risk, follow best practices, improve safety training, and stay current with changing regulations.
Copyright 2026 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.


















































