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NewsFleet SafetyPipeline and Hazardous Materials Safety Administration (PHMSA), DOTDrug testing - Motor CarrierDrug and Alcohol Testing - DOTOffice of the Secretary of TransportationHazmat SafetyRulemakingFocus AreaProposed RuleEnglishTransportationUSA
89 FR 82957 Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records
2024-10-15T05:00:00Z
DEPARTMENT OF TRANSPORTATION
Office of the Secretary
49 CFR Part 40
Pipeline and Hazardous Materials Safety Administration
49 CFR Part 199
[Docket DOT-OST-2022-0027]
RIN 2105-AF01
Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records
AGENCY: Office of the Secretary, Department of Transportation (DOT).
ACTION: Notice of proposed rulemaking (NPRM).
SUMMARY: The Department of Transportation (DOT or Department) proposes to amend its regulations for conducting workplace drug and alcohol testing for the federally regulated transportation industry to allow, but not require, electronic signatures on documents required to be created and utilized under the regulations, the use of electronic versions of forms, and the electronic storage of forms and data. The regulatory changes would apply to DOT-regulated employers and their contractors (“service agents”) who administer their DOT-regulated drug and alcohol testing programs. Currently, employers and their service agents must use, sign and store paper documents exclusively, unless the employer is utilizing a laboratory's electronic Federal Drug Testing Custody and Control Form (electronic CCF) system that has been approved by the Department of Health and Human Services (HHS). DOT is required by statute to amend its regulations to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms. This rulemaking also responds to an April 2, 2020, petition for rulemaking from DISA Global Solutions, Inc. (DISA), requesting that DOT regulations be amended to allow the use of an electronic version of the alcohol testing form (ATF) for DOT-authorized alcohol testing. The proposed regulatory amendments are expected to provide additional flexibility and reduced costs for the industry while maintaining the integrity and confidentiality requirements of the drug and alcohol testing regulations. In addition, DOT proposes to amend the Pipeline and Hazardous Materials Safety Administration (PHMSA) regulation for conformity and to make other miscellaneous technical changes and corrections.
DATES: Comments on this NPRM must be received on or before December 16, 2024.
ADDRESSES: You may submit comments identified by Docket Number DOT-OST-2022-0027 using any of the following methods:
• Federal eRulemaking Portal: Go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document. Follow the online instructions for submitting comments.
• Mail: Docket Management Facility, U.S. Department of Transportation, 1200 New Jersey Avenue SE, West Building, Ground Floor, Room W12-140, Washington, DC 20590-0001.
• Hand Delivery or Courier: West Building, Ground Floor, Room W12-140, 1200 New Jersey Avenue SE, Washington, DC, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting Dockets Operations.
• Fax: 202-493-2251.
To avoid duplication, please use only one of these methods. See the “Public Participation and Request for Comments” portion of the SUPPLEMENTARY INFORMATION section for instructions on submitting comments, including collection of information comments for the Office of Information and Regulatory Affairs, Office of Management and Budget (OMB).
FOR FURTHER INFORMATION CONTACT:
Mike Huntley, Office of Drug and Alcohol Policy and Compliance, 1200 New Jersey Avenue SE, Washington, DC 20590; telephone number 202-366-3784; ODAPCwebmail@dot.gov. If you have questions on viewing or submitting material to the docket, contact Docket Services, telephone (202) 366-9826.
SUPPLEMENTARY INFORMATION:
This NPRM is organized as follows:
I. Executive Summary
II. Public Participation and Request for Comments
A. Submitting Comments
B. Viewing Comments and Documents
C. Privacy Act
III. Legal Basis for the Rulemaking
IV. Background
V. Advance Notice of Proposed Rulemaking (ANPRM) Overview
VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures
VII. Amending Part 40 To Permit Electronic Documents and Signatures
VIII. Electronic ATF
IX. Section-by-Section Analysis
X. Regulatory Analyses and Notices
I. Executive Summary
Purpose and Summary of the Major Provisions
This proposed rule would establish parity between paper and electronic documents and signatures and expand businesses' and individuals' ability to use electronic methods to comply with the Department's drug and alcohol testing regulation, 49 CFR part 40, “Procedures for Transportation Workplace Drug and Alcohol Testing Programs” (part 40). Businesses and individuals subject to part 40 would continue to have the choice to use paper documents and traditional “wet” signatures. This proposed rule would also modify references to recordkeeping and reporting methods throughout part 40 to make them technologically neutral.
This proposed rulemaking responds to a statutory mandate set forth in section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271 (see 49 U.S.C. 322 note). The proposed rulemaking would take action consistent with the Government Paperwork Elimination Act (GPEA) (division C, title XVII, secs. 1701-1710, Pub. L. 105-277) and the Electronic Signatures in Global and National Commerce Act (E-SIGN) (Pub. L. 106-229) with regard to DOT's part 40 regulations.
II. Public Participation and Request for Comments
A. Submitting Comments
If you submit a comment, please include the docket number for this NPRM (Docket No. DOT-OST-2022-0027), indicate the specific section of this document to which each comment applies, and provide a reason for each suggestion or recommendation. You may submit your comments and material online or by fax, mail, or hand delivery, but please use only one of these means. The Office of the Secretary (OST) recommends that you include your name and a mailing address, an email address, or a phone number in a cover letter or an email so that OST can contact you if there are questions regarding your submission.
To submit your comment online, go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document, click on this NPRM, click “Comment,” and type your comment into the text box on the following screen.
If you submit your comments by mail or hand delivery, submit them in an unbound format, no larger than 8 1/2 by 11 inches, suitable for copying and electronic filing. If you submit comments by mail and would like to know that they reached the facility, please enclose a stamped, self-addressed postcard or envelope.
OST will consider all comments and material received during the comment period in determining how to proceed with any final rule.
B. Viewing Comments and Documents
To view comments, as well as any documents mentioned in this preamble as available in the docket, go to https://www.regulations.gov. Insert the docket number, DOT-OST-2022-0027, in the keyword box, and click “Search.” Next, click the “Open Docket Folder” button and choose the document to review. If you do not have access to the internet, you may view the docket online by visiting the Docket Management Facility in Room W12-140 on the ground floor of the DOT West Building, 1200 New Jersey Avenue SE, Washington, DC 20590-0001, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting the Docket Management Facility.
C. Privacy Act
In accordance with 5 U.S.C. 553(c), DOT solicits comments from the public to better inform its rulemaking process. DOT posts these comments, without edit, including any personal information the commenter provides, to www.regulations.gov, as described in the system of records notice (DOT/ALL-14 FDMS), which can be reviewed at https://www.transportation.gov/individuals/privacy/privacy-act-system-records-notices under the heading of “Department-Wide System of Records Notices”.
III. Legal Basis for the Rulemaking
This rulemaking is promulgated under the authority enacted in the Omnibus Transportation Employee Testing Act of 1991 (OTETA) (Pub. L. 102-143, tit. V, 105 Stat. 952) and codified at 49 U.S.C. 45102 (aviation), 49 U.S.C. 20140 (rail), 49 U.S.C. 31306 (motor carrier), and 49 U.S.C. 5331 (public transportation), as well as the Department's authority in 49 U.S.C. 322 and the PHMSA authorities specified in the proposed regulatory text for this action.
According to Public Law 115-271, the Secretary of Transportation is required to “issue a final rule revising part 40 of title 49, Code of Federal Regulations, to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms.” (49 U.S.C. 322 note) The statute set the deadline for this action as not later than 18 months after HHS establishes a deadline for a certified laboratory to request approval for fully electronic CCFs ( Id. ) On April 7, 2022, HHS set that deadline as August 31, 2023 (87 FR 20528). HHS has extended the deadline to August 31, 2026, to enable sufficient time for all HHS-certified laboratories to identify and contract with an electronic CCF supplier or to develop an electronic CCF. The deadline for DOT's regulatory amendments would therefore be February 29, 2028.
There are two additional Federal statutes relevant to the implementation of electronic document and signature requirements.
The Government Paperwork Elimination Act (GPEA), codified at 44 U.S.C. 3504 note, 1 was enacted to improve customer service and governmental efficiency through the use of information technology. The GPEA defines an electronic signature as a method of signing an electronic communication that: (a) identifies and authenticates a particular person as the source of the electronic communication; and (b) indicates such person's approval of the information contained in the electronic communication. Id. It also requires OMB to ensure Federal agencies provide for: (a) the option of maintaining, submitting; or disclosing information electronically, when practicable; and (b) the use and acceptance of electronic signatures when practicable. The GPEA states that electronic records submitted pursuant to procedures developed under title XVII for the submission of records to Federal agencies and electronic signatures used in accordance with those procedures shall not be denied legal effect, validity, or enforceability merely because they are in electronic form. Id.
1 Division C, title XVII (sec. 1701-1710) of Public Law 105-277, 112 Stat. 2681-749, enacted on October 21, 1998.
The Electronic Signatures in Global and National Commerce Act (E-SIGN), codified at 15 U.S.C. 7001-7031, 2 was designed to promote the use of electronic contract formation, signatures, and recordkeeping in private commerce by establishing legal equivalence between traditional paper-based methods and electronic methods. The E-SIGN Act allows the use of electronic records to satisfy any statute, regulation, or rule of law requiring that such information be provided in writing if the consumer has affirmatively consented to such use and has not withdrawn consent. Specifically, the statute establishes the legal equivalence of the following types of documents with respect to any transaction in or affecting interstate or foreign commerce, whether in traditional paper or electronic form: (a) contracts, (b) signatures, and (c) other records (15 U.S.C. 7001(a)(1)).
2 Public Law 106-229, 114 Stat. 464, enacted on June 30, 2000.
IV. Background
The Department's drug and alcohol testing regulations were promulgated at a time when the ability to sign and retain official records electronically—now commonplace in many business segments—was not available. Over the course of several years, we have adopted measures that have reduced the paper documentation associated with the drug and alcohol testing program without compromising the integrity and confidentiality requirements of the program. In 2003, we standardized the form for employers to report their Management Information System (MIS) aggregate drug and alcohol testing data, as well as the specific data collected. 3 When creating a ONE-DOT MIS Form, we then authorized employers to submit a single standardized form via a web portal. In 2015, we issued a final rule to allow employers, collectors, laboratories, and medical review officers (MROs) to use the electronic version of the Federal Drug Testing CCF in the DOT-regulated drug testing program. 4 That final rule also incorporated into the regulations the requirement to establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons when using the electronic CCF. We also included language protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form when using the electronic CCF.
3 68 FR 43946 (July 25, 2003).
4 80 FR 19551 (Apr. 13, 2015).
Consistent with the statutory mandate in 49 U.S.C. 322 note, we propose amendments to part 40 to permit the use of electronic signatures, forms, and records storage for drug and alcohol testing records throughout the regulation, including the use of an electronic ATF for DOT-authorized alcohol testing. We emphasize that electronic signatures, forms, and records would not be required; we would continue to allow paper, or hard-copy use with traditional “wet signatures.”
These proposed amendments would establish parity between paper and electronic collection and submission of information required under our regulations (and remain compatible with applicable OMB guidance on implementing electronic signatures 5 ) by allowing further use of electronic means and methods to comply with part 40 requirements. Many employers and their service agents have already instituted the use of electronic signatures, forms, and records storage for the non-DOT regulated testing that they conduct. DOT supports this transition to a paperless system and is committed to ensuring that the movement to a partially or fully electronic part 40 is done to maximize program efficiencies and reduce costs, while maintaining the integrity and confidentiality requirements of the program.
5https://www.whitehouse.gov/wp-content/uploads/2017/11/2000-M-00-15-OMB-Guidance-on-Implementing-the-Electronic-Signatures-in-Global-and-National-Commerce-Act.pdf.
Electronic documents would have a high degree of forensic defensibility as long as any changes made to the document are in the document's electronic footprint, which shows when the document or signature, as applicable, was created; when, and if, changes were made; who made the changes; and when, as applicable, a document was transmitted to and received by the receiving entity. The use of electronic forms and signatures in part 40 would help DOT-regulated employers and their service agents improve their workflow efficiency through faster turnaround times for required documents. Cost savings would result through reduced printing and delivery/shipping costs, and expedited transmission of information allowing for more timely decisions. We believe this proposed rule, if adopted, would also mitigate the longstanding problems ( e.g., delays in processing times of test results, cancelling of test results, etc.) associated with illegible and lost copies of paper documents.
V. Advance Notice of Proposed Rulemaking (ANPRM) Overview
On August 5, 2022, we published an ANPRM requesting public comment on how part 40 could be amended, as required by the statute, to allow electronic signatures, forms, and recordkeeping (87 FR 47951). We requested information from DOT-regulated employers and their service agents regarding if and how they are already handling electronic signatures, records transmission, and records storage in their non-DOT testing programs. In addition, we requested comments and information on appropriate performance standards, and on whether particular methods or performance standards have been successful or unsuccessful. We also asked a number of general questions on the potential advantages, risks, ramifications, and required safeguards associated with the use of electronic signatures, forms, and records in the DOT drug and alcohol testing program. We asked questions about specific sections of part 40 that we anticipated would be affected by prospective changes to implement electronic signatures, forms, and records. Finally, we asked a number of questions regarding the use of an electronic ATF for DOT-regulated alcohol tests.
We received 72 comments in response to the ANPRM, including comments from individuals, testing laboratories, MROs, and MRO organizations, substance abuse professionals (SAP) and SAP organizations, and various associations representing DOT-regulated transportation workers subject to mandatory drug and alcohol testing under part 40.
A few individuals expressed opposition to the adoption of electronic signatures, forms, and recordkeeping, citing concerns about the need for the rulemaking, risk to personal information from hackers or mismanaged electronic processes and procedures, and misuse of electronic forms and signatures. To meet our statutory mandate and in consideration of concerns about safeguarding personal information and appropriate use of the information in developing the NPRM, DOT proposes to require security measures for electronic forms and signatures used under part 40 that are the same as those currently in place for the electronic CCF specified in 49 CFR 40.40(c)(5).
Most commenters were supportive of changes to amend part 40 that would permit, but not require, the use of electronic signatures, forms, and recordkeeping. Commenters supporting revisions to part 40 noted that electronic signatures, forms, and recordkeeping are used in virtually every industry today—including but not limited to the banking, insurance, medical, and legal industries. Commenters supported the use of performance standards instead of technology-specific standards to ensure that, once established, standards do not become obsolete given the rapidly evolving nature of information technology standards and practices. Commenters stated that allowing electronic signatures, forms, and recordkeeping would make the drug testing process much more efficient and would result in cost savings. Commenters also stated that it would be safer to store records electronically since records could be backed-up, secured, and protected from tampering and unauthorized access and use.
VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures
In developing this NPRM, we looked to a rule promulgated by DOT's FMCSA that permits the use of electronic methods to generate, certify, sign, maintain, or exchange records so long as the documents accurately reflect the required information and can be used for their intended purpose. (83 FR 16210, Apr. 16, 2018) The rule applies to documents that FMCSA requires entities or individuals to retain. FMCSA permits, but does not require, anyone to satisfy FMCSA requirements by using electronic methods to generate, maintain, or exchange documents. The substance of the document must otherwise comply with applicable Federal laws and FMCSA rules. FMCSA also permits, but does not require, anyone required to sign or certify a document to do so using electronic signatures, defined, as in the GPEA, as a method of signing an electronic communication that: (1) identifies and authenticates a particular person as the source of the electronic communication; and (2) indicates such person's approval of the information contained in the electronic communication. FMCSA allows for the use any available technology for electronic signatures, so long as the signature otherwise complies with FMCSA's requirements.
FMCSA adopted broad performance standards for electronic documents and signatures—as specified in GPEA and E-SIGN—rather than detailed, technology specific standards that would likely become obsolete with inevitable changes in information technology standards and practices. FMCSA's April 2018 rule has been in effect for more than five years, and the definitions and requirements established in that rule have stood the test of time despite the many changes that have occurred with respect to electronic documents and signatures. We are unaware of any FMCSA-regulated entities that have reported issues to FMCSA regarding the use of electronic documents or signatures to meet the requirements of the FMCSRs since the rule became effective in 2018.
VII. Amending Part 40 To Permit Electronic Documents and Signatures
In this NPRM, we propose to permit but not require electronic documents, signatures, and recordkeeping in part 40. Additionally, we propose a performance standard approach as opposed to establishing technology-specific standards. Where it is possible to do so, establishing the same or substantively similar regulatory requirements for common issues across DOT modal agencies—such as the use of electronic documents and signatures—helps the Department maintain a consistent regulatory approach for those common issues.
There are currently more than 60 references to the term “written” in part 40, and more than 20 additional references to the term “in writing.” We propose to add a definition of “written or in writing” in part 40, to eliminate any distinction between paper and electronic documentation and establish technological neutrality throughout the entirety of part 40.
FMCSA's rule does not apply to documents that individuals or entities are required to file directly with FMCSA. In its April 2018 final rule, FMCSA explained that while industry could use electronic signatures and submit information directly to the FMCSA in certain situations, 6 adapting all FMCSA systems to allow for use of electronic signatures and submissions would significantly delay the implementation of the rule for use by third parties as it would require FMCSA to develop and implement technology systems to allow for direct submission to FMCSA from regulated parties. FMCSA noted that development of such systems could take several years, and therefore saw no reason to make private parties' use of electronic signatures and records retention contingent upon FMCSA's ability to receive submissions electronically because doing so would delay potential benefits to be gained by third parties.
6 As an example, Certified Medical Examiners may use electronic signatures, if they choose to do so, to sign medical forms, certificates, and a new driver medication report. If FMCSA requests these forms, they are uploaded in portable document format (PDF) to the Medical Examiner's account associated with the National Registry of Certified Medical Examiners for FMCSA to access.
In contrast to FMCSA's regulations, part 40 does not require entities or individuals to submit documents directly to the Department except for MIS aggregate drug and alcohol testing data that employers subject to DOT or U.S. Coast Guard (USCG) drug and alcohol testing regulations must submit annually. Each of the various documents required and used as part of the DOT drug and alcohol testing program under part 40 ( e.g., employee drug and alcohol testing records, MRO reports and records, SAP reports and records) are documents that are created by, exchanged between, and maintained by a person or entity involved in the testing process—but are not required to be submitted directly to DOT.
As noted earlier, and specifically with respect to the required MIS data, we standardized the form for employers to report their aggregate drug and alcohol testing data, as well as the specific data collected, more than 20 years ago. At that time, we authorized employers to submit the ONE-DOT MIS form via a web portal. Today, the Federal Aviation Administration, FMCSA, Federal Railroad Administration, and Federal Transit Administration permit employers to submit that same drug and alcohol testing data via the internet, and PHMSA requires that the data be submitted electronically. If employers submit the data electronically via the internet, they are not required to submit a hard copy. DOT recommends that employers have a copy of their data available (either hard copy or in electronic format) in the event an auditor or inspector requests a copy.
From the above, and because the only documents that part 40 requires to be submitted directly to the Department are already permitted to be, and in some cases required to be, submitted electronically, there is no need for us to limit the applicability of our proposal as FMCSA did in its 2018 final rule.
Several commenters noted that they already use electronic signatures and documents for their non-DOT drug and alcohol testing program, and in some cases, have done so for many years. In doing so, these commenters have had to establish appropriate confidentiality and security measures to ensure that confidential employee records cannot be accessed by unauthorized persons, including protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The same general requirements were added to the current §40.40(c)(5) when we approved the use of the electronic CCF for use in DOT drug testing in 2015, 7 and we propose the same requirements in this NPRM for the use of electronic signatures, documents, and recordkeeping throughout the entirety of part 40.
7 The 2015 revisions amended then §40.45(c)(5), which was redesignated as §40.40(c)(5) in the May 2023 final rule to include oral fluid testing in the DOT drug testing program (88 FR 27596, May 2, 2023).
Ensuring that confidential employee records are not available to unauthorized persons is an important element of part 40's protections for employees that are subject to DOT's drug and alcohol testing rules. We believe that the failure of a service agent to provide or maintain a secure/confidential electronic system should constitute the basis for the Department to start a public interest exclusion (PIE) proceeding, and propose to add this to the list of examples provided in §40.365(b).
Throughout part 40, information and documents are required to be transmitted and/or communicated between service agents ( e.g., collectors, screening test technicians (STTs) and breath alcohol technicians (BATs), laboratories, MROs, SAPs, and consortium/third party administrators (C/TPAs)), employers, and employees). Although part 40 does not currently require the party receiving these communications and/or documents to affirmatively confirm receipt of such from the sender, in some instances, regardless of whether the document is electronic or a hard copy, we believe that it may be important for the receiving party to verify that those required communications and/or documents were received.
For example, under §40.25, an employer intending to use an employee to perform safety-sensitive functions must, after obtaining an employee's written consent, request information about the employee's drug and alcohol testing record from previous DOT-regulated employers. After receiving a copy of the employee's written consent, the previous employer must immediately provide the requested information to the employer making the inquiry. If an employer is subsequently investigated/audited by the appropriate DOT mode, it may be beneficial for both the gaining employer and the previous employer to be able to affirmatively demonstrate that the employee's written consent and previous testing record were sent and received as required.
Sections 40.191(d) and 40.261(c)(1) require a collector or MRO (for drug tests) or a BAT, STT, or a physician evaluating a “shy lung” situation (for alcohol tests), respectively, to—when an employee refuses to participate in a part of the testing process—terminate the testing process, document the refusal, and immediately and directly notify the employer's designated employer representative (DER) by any means that ensures the refusal notification is immediately received. Because this notification of a refusal to an employer is of an urgent nature, it may be advisable to require the DER to affirmatively confirm receipt of the required notification from the collector, MRO, BAT, STT, or physician. For example, §§40.191(d) and 40.261(c)(1) could be amended to read “. . . immediately notify the DER by any means and ensure that the refusal notification is immediately received”.
While we are not proposing new requirements in this NPRM regarding confirmation of receipt in the sections discussed above (or in other part 40 requirements), we seek comment regarding whether it may be beneficial or advisable to do so, and if so, for which specific sections of part 40.
VIII. Electronic ATF
The ATF has been in use in the DOT alcohol testing program since 1994 (see 59 FR 7349, Feb. 15, 1994). The ATF must be used to document every DOT alcohol test. DOT regulations at 49 CFR 40.225 set forth the requirements for use of the form, and 49 CFR part 40, appendix G, contains a facsimile (reference copy) of the form. The ATF is a three-part carbonless manifold form used by DOT-regulated employers to document the testing event when testing employees subject to DOT alcohol testing. When the employee is tested, both the employee and the STT and/or the BAT will complete the ATF in various sections. The STT/BAT documents the result(s) by either writing in the screening result or attaching the screening and/or confirmation result printed by the evidential breath testing devices (EBT) onto the ATF, and then sends Copy 1 to the employer, provides Copy 2 to the employee, and retains Copy 3 for their records.
On April 2, 2020, DISA petitioned the Department to amend part 40 to allow for the use of an electronic version of the ATF for DOT mandated alcohol testing. In support of its petition, DISA stated that “The requested amendment to 49 CFR part 40 will enable a parallel process for the documentation of DOT-mandated alcohol tests aligned with the similarly situated amendment previously approved for drug testing.” DISA believes that allowing the use of an electronic ATF will result in several benefits to the industry, including “increased efficiency, security and accuracy in documentation of DOT alcohol tests; paperwork reduction; improved process for conducting a DOT alcohol test in conjunction with a DOT drug test when an electronic version of the federal CCF is used for the drug test; reduction of errors and omissions in the completion of the ATF; and improved efficiency and efficacy in the transmission and record retention of alcohol test results.”
DISA noted that non-DOT workplace breath alcohol testing has been conducted using electronic versions of an alcohol testing form that mirrors the DOT ATF for more than five years. Based on experience using those electronic forms for non-DOT testing, DISA cites improved efficiency and accuracy of documentation because: (1) employer and employee information is entered via computer and thus not dependent on reading and deciphering hand-written entries, (2) date time stamps of the testing are automated and not subject to fluctuation or error, (3) transmission of documentation on completed tests is more secure using databases accessed only via protected password and personal identification number (PIN) to authorized employers or their designated agents, and (4) transmission of test result information is faster and more secure than existing transmission options of scanning and emailing attachments or facsimile.
DISA also noted that permitting use of an electronic ATF for DOT-regulated alcohol testing “will substantially reduce cost, by eliminating the requirement for the printing and distribution of carbonless three-ply paper ATFs. The proposed electronic ATF option would still provide for printed paper images to be made available to the employee, the employer, and the alcohol technician, [but] eliminates the requirement for the more expensive carbonless 3 ply paper ATF.”
For the reasons described by DISA in its petition, and recognizing that significant benefits and cost reductions have resulted from use of the electronic CCF for drug testing, we believe that it is likewise appropriate to permit the use of electronic ATFs in part 40 for DOT-regulated testing. Permitting but not requiring the use of an electronic ATF would be consistent with our proposal to permit, but not require, the use of electronic documents and signatures throughout the entirety of part 40 as discussed above. As several commenters noted, the use of an electronic ATF has been used in non-DOT testing for 5-10 years, and the same developers of the electronic CCFs have developed the electronic ATFs. Any electronic ATF used under part 40 for DOT-regulated employees would have to be identical in form and content to the DOT ATF in appendix I to part 40. 8 Just as we imposed general confidentiality and security requirements when electronic CCFs were permitted to be used under part 40, we believe that it is necessary to include the same general requirements relating to the use of electronic ATFs to ensure that confidential employee records cannot be accessed by unauthorized persons.
8 The ATF form was redesignated from appendix G to appendix I as part of the rulemaking process culminating in the May 2023 final rule. During that process, the form was reviewed by the public and DOT received no comment on the form.
Manufacturers of EBTs and alcohol screening devices (ASD) used in DOT alcohol tests must obtain approval from the National Highway Traffic Safety Administration (NHTSA) and then be listed on the Office of Drug and Alcohol Policy and Compliance's (ODAPC) website before those devices may be used in DOT alcohol testing.
IX. PHMSA Proposed Changes
PHMSA is proposing to amend §§199.3, 199.117, and 199.227 and to add §199.4 to conform to the proposed changes in part 40 and to clarify that the proposed changes in part 40 apply to part 199. These changes will help the readers of part 199 find the applicable regulations in part 40 with regards to the definition of terms and record keeping requirements. We also propose to amend §§199.119 and 199.229 by changing the reference of “appendix H” to “appendix J” to conform to the amendment of part 40 published on May 2, 2023.
X. Section-by-Section Analysis
Section 40.3 What do the terms used in this regulation mean?
We propose to add a definition of “electronic signature.” The rule would define an electronic signature as a method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 44 U.S.C. 3504 note, 112 Stat. 2681-749). Including the specific cross reference to GPEA would ensure that regulated entities know that we are using GPEA's performance standard for allowing use of electronic signatures.
We propose to add a definition of “written or in writing.” The rule would define written or in writing as printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of 49 CFR 40.4. This definition would eliminate any distinction between paper and electronic methods of communication/documentation.
Section 40.4 May electronic documents and signatures be used?
We propose to add a new §40.4 that would prescribe the requirements pertaining to electronic documents and signatures throughout part 40.
Paragraph (a) would specify that §40.4 would apply to all documents required by part 40, except for the CCF, as an electronic CCF may only be used when approved by HHS and in compliance with §40.40(c)(5). As background, before an HHS-certified laboratory can use a Federal electronic CCF for regulated specimens, the test facility must submit a detailed plan and proposed standard operating procedures for the electronic CCF system for HHS review and approval through the National Laboratory Certification Program. At the current time, several HHS-certified laboratories have received approval to use a combination electronic/paper CCF, while four laboratories have received approval to use a fully electronic CCF. As noted earlier, and in a separate section of the SUPPORT Act, HHS was required to set a deadline for certified laboratories to request approval for use of fully electronic CCFs. That deadline is now August 31, 2026.
Paragraph (b) would permit, but not require, any person or entity to use electronic methods to comply with any provision in part 40 that requires a document to be signed, certified, generated, maintained, or transmitted between parties. It would apply to all forms of written documentation, including forms, records, notations, and other documents. The substance of the document would otherwise have to comply with part 40 requirements. This would establish parity between paper and electronic documents and signatures, greatly expanding interested parties' ability to use electronic methods to comply with the requirements of part 40.
Paragraph (c) would permit, but not require, any entity required to sign or certify a document to do so using electronic signatures as defined in §40.3. The rule specifies that a person may use any available technology so long as the signature otherwise complies with the requirements of part 40.
Paragraph (d) would establish the minimum requirements for electronic documents and signatures. Any electronic document or signature would be considered the legal equivalent of a paper document or signature if it is the functional equivalent with respect to integrity, accuracy, and accessibility. In other words, the electronic documents or signatures need to accurately and reliably reflect the information in the record. They must remain accessible in a form that could be accurately viewed or reproduced according to Agency rules. As with any documents, paper or electronic, documents that are not legible—for any reason—do not satisfy the Department's requirements.
Electronic documents are not to be considered the legal equivalent of traditional paper documents if they (1) are not capable of being retained, (2) are not used for the purpose for which they were created, or (3) cannot be accurately reproduced for reference by any entity entitled to access by law, for the period of time required by the Department's recordkeeping requirements.
Paragraph (d) would also require that any electronically signed documents must incorporate or otherwise include evidence that both parties to the document have consented to the use of electronic signatures, as required by the E-SIGN Act (15 U.S.C. 7001(c)).
Paragraph (e) would require that when using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records cannot be accessed by unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The proposed requirements are analogous to those established in the current §40.40(c)(5) when we approved use of the electronic CCF in part 40.
Section 40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?
Currently, paragraph (g) makes it clear that the release of information under this section must be in any written form, and the parenthetical clarifies that this can be paper-based (written, fax) or electronic (email). Under the proposed definition of “written or in writing,” there is no distinction between paper-based and electronic communications. Because “written or in writing” would mean either paper or electronic communications, we propose to remove parenthetical reference to “fax, email, letter” to eliminate redundancy and confusion. All parties can conduct their business using either paper or electronic means of documentation and communication.
Section 40.79 How is the collection process completed?
Currently, paragraph (a)(9) of this section requires the collector to “fax or otherwise transmit” Copy 2 of the CCF to the MRO and Copy 4 to the DER within 24 hours or during the next business day. We propose to amend this section by removing reference to the methods of transmitting receipts, so parties can choose their own medium of communication.
Section 40.97 What do laboratories report and how do they report it?
For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraphs (c)(1) and (2) of this section.
Section 40.111 When and how must a laboratory disclose statistical summaries and other information it maintains?
For the same reasons explained in the discussion of §40.79, we propose to amend paragraph (b) of this section to remove the references to the methods of transmitting the summary or report required by this section. Because the summary or report can be transmitted via hard copy or electronically, there is no need to specify how it must be transmitted. As such, we propose to amend the title of this section accordingly.
Section 40.127 What are the MRO's functions in reviewing negative test results?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (c)(2) of this section.
Section 40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative test results?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (b)(2) of this section.
Section 40.163 How does the MRO report drug test results?
For the same reasons explained in the discussion of §40.25, we propose to remove the reference to a “letter” in paragraph (c) of this section. In paragraph (e) of this section, we propose to replace the term “letter” with “written report” for consistency with paragraph (c).
Section 40.167 How are MRO reports of drug results transmitted to the employer?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (c)(1) of this section.
Section 40.185 Through what methods and to whom must a laboratory report split specimen results?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (b) of this section. In addition, because Copy 1 of the CCF can be transmitted in writing or electronically, there is no need to specify the methods through which it must be transmitted. As such, we propose to amend the title of this section accordingly.
Section 40.187 What does the MRO do with split specimen laboratory results?
For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraph (c)(2)(iv)(C) of this section.
Section 40.191 What is a refusal to take a DOT drug test, and what are the consequences?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (d) of this section as means of transmitting notification that an employee has refused to participate in part of the testing process from the collector or MRO to the DER.
Section 40.193 What happens when an employee does not provide a sufficient amount of urine for a drug test?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “send or fax” as the means for the collector to transmit copies of the CCF to the MRO and the DER in paragraph (b)(3) of this section.
Section 40.205 How are drug test problems corrected?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a collector, laboratory, MRO, employer, or other person to supply signed statements regarding correctable problems in a drug test in paragraphs (b)(1) and (2) of this section.
Section 40.225 What form is used for an alcohol test?
We propose to amend this section to permit, but not require, the use of an electronic version of the DOT ATF that is identical in form and content to the form provided in appendix I to part 40. The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT, and if an EBT provides a separate printout of confirmation test results pursuant to §40.253(g), the electronic ATF must include that separate printout. This section would also be amended to specify the same general confidentiality and security measures in §40.45 relating to electronic CCFs to ensure that confidential employee records cannot be accessed by unauthorized persons.
Section 40.255 What happens next after the alcohol confirmation test result?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (a)(5)(i) of this section as means of transmitting results of the alcohol confirmation test from the BAT to the DER. Similarly, there is no need to specify that Copy 1 of the ATF may be transmitted “in person, by telephone, or by electronic means.”
Section 40.261 What is a refusal to take an alcohol test, and what are the consequences?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (c) of this section as means of transmitting a refusal notification from a BAT, STT, or referral physician to the DER.
Section 40.271 How are alcohol testing problems corrected?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a STT, BAT, employer, or other service agent to supply a signed statement regarding correctable flaws in an alcohol test in paragraph (b)(2) of this section.
Section 40.365 What is the Department's policy concerning starting a PIE proceeding?
We propose to amend this section by adding a new paragraph (b)(15) that would identify the failure of a service agent to provide or maintain a secure/confidential electronic system as appropriate grounds for starting a PIE proceeding.
X. Regulatory Analyses and Notices
Executive Orders 12866, 13563, and 14094 (Regulatory Planning and Review)
The Secretary has examined the impact of the proposed part 40 amendments under Executive Order 12866 (“Regulatory Planning and Review”), as supplemented by Executive Order 13563 (“Improving Regulation and Regulatory Review”) and amended by Executive Order 14094 (“Modernizing Regulatory Review”), which directs Federal agencies to assess all costs and benefits of available regulatory alternatives and, when regulation is necessary, to select regulatory approaches that maximize net benefits (including potential economic, environmental, public health and safety, and other advantages; distributive impacts; and equity).
According to these Executive orders, a regulatory action is “significant” if it meets any one of a number of specified conditions, including having an annual effect on the economy of $200 million or more, as adjusted every three years by the Office of Information and Regulatory Affairs (OIRA); adversely affecting in a material way a sector of the economy, competition, or jobs; or if it raises novel legal or policy issues. The proposed amendments, which would allow the use of electronic documents and signatures, do not meet the Executive order's criteria for being a significant rule. Consequently, OMB has determined that the rulemaking action is not significant under the Executive order.
The proposed rule responds to the statutory mandate set forth in Section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271. The proposed rule would not impose new requirements on the industry; rather, it would simply permit—but not require—regulated entities to use electronic signatures, forms, and recordkeeping, and remove outdated and obsolete references in the regulatory text. The proposed rule would not impose new costs on the industry because regulated entities would be allowed to choose to continue to use paper-based documents as they had before. The benefits of the rule would stem from savings in paper and printing expense and other efficiency gains. Examples of documents affected by this rule include, but are not limited to, records of a prospective employee's drug and alcohol testing history that employers must obtain prior to permitting that employee to perform safety-sensitive duties, MRO records and reports, SAP records and reports, and ATFs. While there is no way to estimate how many entities or individuals would change their practices given the new options, or how many documents would be affected, several commenters to the ANPRM stated that they have been using electronic documents and signatures in their non-DOT drug and alcohol testing programs for many years. While neither the benefits nor the costs of this rule can be reliably estimated, we expect this proposed rule to provide flexibility to the industry. Under this proposed rule, regulated entities would have the flexibility to conduct business using either electronic or traditional paper-based methods. We also expect regulated entities to choose technologies that would maximize benefits in accordance with their individual needs and circumstances.
Regulatory Flexibility Act and Small Business Regulatory Enforcement Fairness Act (SBREFA)
The Regulatory Flexibility Act of 1980 (5 U.S.C. 601 et seq. ) requires Federal agencies to consider the effects of their regulatory actions on small businesses and other small entities and minimize any significant economic impact. The term “small entities” comprises small businesses and not-for-profit organizations that are independently owned and operated and are not dominant in their fields, and governmental jurisdictions with a population of less than 50,000. For this rulemaking, potentially affected small entities include drug testing companies (U.S. Small Business Administration (SBA) North American Industry Classification System (NAICS) Sector 54 (Professional, Scientific and Technical Services), Code 541380 (Testing Laboratories and Services)) as well as DOT-regulated entities (SBA NAICS Sectors 48-49 (Transportation and Warehousing)).
The Department does not expect that the proposed rule would have a significant economic impact on a substantial number of small entities. The proposed rule, if adopted, would increase flexibility for all small-entity transportation employers and their service agents by allowing them to use electronic documents, signatures, and recordkeeping to meet part 40 requirements. Use of electronic documents, electronic signatures, and electronic recordkeeping would be voluntary for affected small entities, which will provide added flexibility to these entities in meeting the part 40 requirements. For these reasons, and as explained in more detail in the preamble to this proposed rule, the Secretary certifies that the proposed rule would not have a significant economic impact on a substantial number of small entities within the meaning of the Regulatory Flexibility Act. Consequently, an initial regulatory flexibility analysis is not required for this proposed rule.
Unfunded Mandates
The Secretary has examined the impact of the final rule under the Unfunded Mandates Reform Act (UMRA) of 1995 (Pub. L. 104-4). This NPRM does not trigger the requirement for a written statement under sec. 202(a) of the UMRA because this rulemaking does not impose a mandate that results in an expenditure of $100 million (adjusted annually for inflation) or more by either State, local, and tribal governments in the aggregate or by the private sector in any one year. In fact, by providing an alternative to traditional paper-based records, the proposed rule would be expected to reduce costs to regulated parties, including State and local entities ( e.g., public transit authorities, and public works departments) whose employees are subject to testing and that choose to use electronic documents as opposed to paper-based documents.
Environmental Impact
The DOT has analyzed the environmental impacts of this action pursuant to the National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321 et seq. ) and has determined that it is categorically excluded pursuant to DOT Order 5610.1C, “Procedures for Considering Environmental Impacts” (44 FR 56420, October 1, 1979). Categorical exclusions are actions identified in an agency's NEPA implementing procedures that do not normally have a significant impact on the environment and therefore do not require either an environmental assessment (EA) or environmental impact statement (EIS). This proposed rule would amend the transportation industry drug testing program procedures regulation to permit the use of electronic documents, signatures, and recordkeeping. This action is covered by the categorical exclusion listed at 23 CFR 771.118(c)(4), “[p]lanning and administrative activities that do not involve or lead directly to construction, such as: . . . promulgation of rules, regulations, directives . . .” The Department does not anticipate any environmental impacts, and there are no extraordinary circumstances present in connection with this rulemaking.
Executive Order 13132: Federalism
The Secretary has analyzed the final rule in accordance with Executive Order 13132: Federalism. Executive Order 13132 requires Federal agencies to carefully examine actions to determine if they contain policies that have federalism implications or that preempt State law. As defined in the order, “policies that have federalism implications” refer to regulations, legislative comments or proposed legislation, and other policy statements or actions that have substantial direct effects on the States, on the relationship between the National Government and the States, or on the distribution of power and responsibilities among the various levels of government.
Most of the regulated parties under the Department's drug testing program are private entities. Some regulated entities are public entities ( e.g., transit authorities and public works departments); however, as noted above, this proposal would reduce costs of the Department's drug testing program and provide additional flexibility for regulated parties. Accordingly, the Secretary has determined that the proposed rule, which would allow but not require use of electronic signatures and recordkeeping, does not contain policies that have federalism implications.
Executive Order 13175: Consultation and Coordination With Indian Tribal Governments
Executive Order 13175 (65 FR 67249, November 6, 2000) requires Federal agencies to develop an accountable process to ensure “meaningful and timely input by tribal officials in the development of regulatory policies that have tribal implications.” “Policies that have tribal implications” as defined in the Executive order, include regulations that have “substantial direct effects on one or more Indian tribes, on the relationship between the Federal government and the Indian tribes, or on the distribution of power and responsibilities between the Federal government and Indian tribes.” This proposed rule does not have tribal implications. The proposed rule will also not have substantial direct effects on tribal governments, on the relationship between the Federal Government and Indian tribes, or on the distribution of power and responsibilities between the Federal Government and Indian tribes, as specified in Executive Order 13175.
Paperwork Reduction Act
The Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520) (PRA) requires that DOT consider the impact of paperwork and other information collection burdens imposed on the public. This proposed rule would call for no new collection of information under the PRA. Instead, there would likely be a significant reduction in the burden hours required for information collection 2105-0529, Procedures for Transportation Drug and Alcohol Testing Program, due to the ability to use electronic signatures and forms, and largely due to the ability to use an electronic ATF for DOT-regulated alcohol testing under part 40. We request comments on this issue. Notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information subject to the PRA that does not display a currently valid OMB control number.
Privacy Act
Anyone is able to search the electronic form of all comments received in any of our dockets by the name of the individual submitting the comment (or signing the comment, if submitted on behalf of an association, business, labor union, etc.) For information on DOT's compliance with the Privacy Act, please visit https://www.transportation.gov/privacy.
5 U.S.C. 553(b)(4)
As required by 5 U.S.C. 553(b)(4), a summary of this proposed rule can be found at the entry for RIN 2105-AF01 in the Department's Portion of the Unified Agenda of Regulatory and Deregulatory Affairs, available at https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202404&RIN=2105-AF01 .
Pay-As-You-Go Act of 2023
In accordance with Compliance with Pay-As-You-Go Act of 2023 (Fiscal Responsibility Act of 2023, Pub. L. 118-5, div. B, title III) and OMB Memorandum (M-23-21) dated September 1, 2023, the Department has determined that this proposed rule is not subject to the Pay-As-You-Go Act of 2023 because it will not increase direct spending beyond specified thresholds.
List of Subjects
49 CFR Part 40
Administrative practice and procedures, Alcohol abuse, Alcohol testing, Drug abuse, Drug testing, Laboratories, Reporting and recordkeeping requirements, Safety, Transportation.
49 CFR Part 199
Alcohol testing, Drug testing, Pipeline safety, Reporting and recordkeeping requirements, Safety, Transportation.
For the reasons stated in the preamble, the Department proposes to amend 49 CFR parts 40 and 199 as follows:
PART 40—PROCEDURES FOR TRANSPORTATION WORKPLACE DRUG AND ALCOHOL TESTING PROGRAMS
1. The authority for part 40 continues to read as follows:
Authority:
49 U.S.C. 102, 301, 322, 5331, 20140, 31306, and 54101 et seq.
2. In §40.3, add the definitions of “Electronic signature” and “Written or in writing” in alphabetical order to read as follows:
§40.3 What do the terms used in this part mean?
* * * * *
Electronic signature. A method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 112 Stat. 2681-749, 44 U.S.C. 3504 note).
* * * * *
Written or in writing. Printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of §40.4.
3. Add §40.4 to read as follows:
§40.4 May electronic documents and signatures be used?
(a) Applicability. This section applies to all documents required by this part, except for the CCF. An electronic CCF may be used only if it has been approved for use by the Department of Health and Human Services and is used in compliance with §40.40(c)(5).
(b) Electronic records or documents. Any person or entity required to generate, maintain, or exchange and/or transmit documents to satisfy requirements in this part may use electronic methods to satisfy those requirements.
(c) Electronic signatures. (1) Any person or entity required to sign or certify a document to satisfy the requirements of this part may use an electronic signature, as defined in §40.3.
(2) Any available technology may be used that satisfies the requirements of an electronic signature as defined in §40.3.
(d) Electronic document requirements. Any person or entity may use documents signed, certified, generated, maintained, or exchanged using electronic methods, as long as the documents accurately reflect the information otherwise required to be contained in them.
(1) Records, documents, or signatures generated, maintained, or exchanged using electronic methods satisfy the requirements of this section if they are capable of being retained, are used for the purpose for which they were created, and can be accurately reproduced within required timeframes for reference by any party entitled to access.
(2) Records or documents generated electronically satisfy the requirements of this section if they include proof of consent to use electronically generated records or documents, as required by 15 U.S.C. 7001(c).
(e) Confidentiality and security. When using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form to include protecting against destruction, deterioration, and data corruption.
4. In §40.25, revise paragraph (g) to read as follows:
§40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?
* * * * *
(g) The release of information under this section must be in any written form that ensures confidentiality. As the previous employer, you must maintain a written record of the information released, including the date, the party to whom it was released, and a summary of the information provided.
* * * * *
5. In §40.79, revise paragraph (a)(9) to read as follows:
§40.79 How is the collection process completed?
(a) * * *
(9) Send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or during the next business day. Keep Copy 3 for at least 30 days, unless otherwise specified by applicable DOT agency regulations.
* * * * *
6. In §40.97, revise paragraphs (c) introductory text, (c)(1) introductory text, and (c)(2) to read as follows:
§40. 97 What do laboratories report and how do they report it?
* * * * *
(c) As a laboratory, you must report laboratory results directly, and only, to the MRO at his or her place of business. You must not report results to or through the DER or a service agent ( e.g., C/TPA).
(1) Negative results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF which has been signed by the certifying scientist, or you may provide the laboratory results report electronically.
* * * * *
(2) Non-negative and rejected for testing results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF that has been signed by the certifying scientist. In addition, you may provide the laboratory results report following the format and procedures set forth in paragraphs (c)(1)(i) and (ii) of this section.
* * * * *
7. In §40.111, revise the section heading and paragraph (b) to read as follows:
§40.111 When must a laboratory disclose statistical summaries and other information it maintains?
* * * * *
(b) When the employer requests a summary in response to an inspection, audit, or review by a DOT agency, you must provide it unless the employer had fewer than five aggregate test results. In that case, you must send the employer a report indicating that not enough testing was conducted to warrant a summary.
* * * * *
8. In §40.127, revise paragraph (c)(2) to read as follows:
§40.127 What are the MRO's functions in reviewing negative test results?
* * * * *
(c) * * *
(2) A legible copy of Copy 1 of the CCF or the electronic laboratory results report that conveys the negative laboratory test result.
* * * * *
9. In §40.129, revise paragraphs (b) introductory text and (b)(2) to read as follows:
§40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative drug test results?
* * * * *
(b) Before you report a verified negative, positive, test cancelled, refusal to test because of adulteration or substitution, you must have in your possession the following documents:
* * * * *
(2) A legible copy of Copy 1 of the CCF, containing the certifying scientist's signature.
* * * * *
10. In §40.163, revise paragraphs (c) introductory text and (e) to read as follows:
§40.163 How does the MRO report drug test results?
* * * * *
(c) If you do not report test results using Copy 2 of the CCF for the purposes of this section, you must provide a written report for each test result. This report must, as a minimum, include the following information:
* * * * *
(e) You must retain a signed or stamped and dated copy of Copy 2 of the CCF in your records. If you do not use Copy 2 for reporting results, you must maintain a copy of the signed or stamped and dated written report in addition to the signed or stamped and dated Copy 2. If you use the electronic data file to report negatives, you must maintain a retrievable copy of that report in a format suitable for inspection and auditing by a DOT representative.
* * * * *
11. In §40.167, revise paragraph (c)(1) to read as follows:
§40.167 How are MRO reports of drug test results transmitted to the employer?
* * * * *
(c) * * *
(1) You must transmit a legible image or copy of either the signed or stamped and dated Copy 2 or the written report (see §40.163(b) and (c)).
* * * * *
12. In §40.185, revise the section heading and paragraph (b) to read as follows:
§40.185 What and to whom must a laboratory report split specimen results?
* * * * *
(b) You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF, which has been signed by the certifying scientist.
* * * * *
13. In §40.187, revise paragraph (c)(2)(iv)(C) to read as follows:
§40.187 What does the MRO do with split specimen laboratory results?
* * * * *
(c) * * *
(2) * * *
(iv) * * *
(C) As the laboratory that tests the primary specimen to reconfirm the presence of the adulterant found in the split specimen and/or to determine that the primary specimen meets appropriate substitution criteria, report your result to the MRO using a copy of Copy 1 of the CCF.
* * * * *
14. In §40.191, revise paragraph (d) introductory text to read as follows:
§40.191 What is a refusal to take a DOT drug test, and what are the consequences?
* * * * *
(d) As a collector or an MRO, when an employee refuses to participate in the part of the testing process in which you are involved, you must terminate the portion of the testing process in which you are involved, document the refusal on the CCF (including, in the case of the collector, printing the employee's name on Copy 2 of the CCF), immediately notify the DER by any means that ensures that the refusal notification is immediately received. As a referral physician ( e.g., physician evaluating a “shy bladder” condition or a claim of a legitimate medical explanation in a validity testing situation), you must notify the MRO, who in turn will notify the DER.
* * * * *
15. In §40.193, revise paragraph (b)(3) to read as follows:
§40.193 What happens when an employee does not provide a sufficient amount of specimen for a drug test?
* * * * *
(b) * * *
(3) As the collector, you must send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or the next business day.
* * * * *
16. In §40.205, revise paragraphs (b)(1) and (2) to read as follows:
§40.205 How are drug test problems corrected?
* * * * *
(b) * * *
(1) If the problem resulted from the omission of required information, you must, as the person responsible for providing that information, supply in writing the missing information and a statement that it is true and accurate. For example, suppose you are a collector, and you forgot to make a notation on the “Remarks” line of the CCF that the employee did not sign the certification. You would, when the problem is called to your attention, supply a signed statement that the employee failed or refused to sign the certification and that your statement is true and accurate. You must supply this information on the same business day on which you are notified of the problem.
(2) If the problem is the use of a non-Federal form or an expired Federal form, you must provide a signed statement ( i.e., a memorandum for the record). It must state that the incorrect form contains all the information needed for a valid DOT drug test, and that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control. The statement must also list the steps you have taken to prevent future use of non-Federal forms or expired Federal forms for DOT tests. For this flaw to be corrected, the test of the specimen must have occurred at an HHS-certified laboratory where it was tested consistent with the requirements of this part. You must supply this information on the same business day on which you are notified of the problem.
* * * * *
17. In §40.225, revise paragraph (a) and add paragraphs (d) and (e) to read as follows:
§40.225 What form is used for an alcohol test?
(a) The DOT Alcohol Testing Form (ATF) must be used for every DOT alcohol test. The ATF must be a three-part carbonless manifold form or an electronic ATF that meets the requirements of paragraph (d) of this section. The ATF is found in appendix G to this part. You may view this form on the ODAPC website ( https://www.transportation.gov/odapc ).
* * * * *
(d) As an employer, you may use an electronic ATF that meets the following requirements:
(1) The electronic ATF must be identical in form and content to the ATF found in appendix G to this part.
(2) The electronic ATF must meet the requirements of §40.4(d).
(3) The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT.
(4) If an EBT provides a separate printout of confirmation test results (see §40.253(g)), the electronic ATF must include that separate printout.
(e) As an employer, BAT, or STT using an electronic ATF, you must establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form.
18. In §40.255, revise paragraph (a)(5)(i) to read as follows:
§40.255 What happens next after the alcohol confirmation test result?
(a) * * *
(5) * * *
(i) You may transmit the results using Copy 1 of the ATF, in person, by telephone, or by electronic means. In any case, you must immediately notify the DER of any result of 0.02 or greater by any means that ensures the result is immediately received by the DER. You must not transmit these results through C/TPAs or other service agents.
* * * * *
19. In §40.261, revise paragraph (c)(1) to read as follows:
§40.261 What is a refusal to take an alcohol test, and what are the consequences?
* * * * *
(c)(1) As a BAT or an STT, or as the physician evaluating a “shy lung” situation, when an employee refuses to test as provided in paragraph (a) of this section, you must terminate the portion of the testing process in which you are involved, document the refusal on the ATF (or in a separate document which you cause to be attached to the form), immediately notify the DER by any means that ensures the refusal notification is immediately received. You must make this notification directly to the DER (not using a C/TPA as an intermediary).
* * * * *
20. In §40.271, revise paragraph (b)(2) to read as follows:
§40.271 How are alcohol testing problems corrected?
* * * * *
(b) * * *
(2) If the problem is the use of a non-DOT form, you must, as the person responsible for the use of the incorrect form, certify in writing that the incorrect form contains all the information needed for a valid DOT alcohol test. You must also provide a signed statement that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control, and the steps you have taken to prevent future use of non-DOT forms for DOT tests. You must supply this information on the same business day on which you are notified of the problem.
* * * * *
21. In §40.365, revise paragraphs (b)(13) and (14) and add paragraph (b)(15) to read as follows:
§40.365 What is the Department's policy concerning starting a PIE proceeding?
* * * * *
(b) * * *
(13) For any service agent, directing or recommending that an employer fail or refuse to implement any provision of this part;
(14) With respect to noncompliance with a DOT agency regulation, conduct that affects important provisions of Department-wide concern ( e.g., failure to properly conduct the selection process for random testing); or
(15) For a service agent, failing to provide or maintain a secure/confidential electronic system. PART 199—DRUG AND ALCOHOL TESTING
22. The authority citation for part 199 continues to read as follows:
Authority:
49 U.S.C. 5103, 60102, 60104, 60108, 60117, and 60118; 49 CFR 1.53.
23. In §199.3:
a. Designate the introductory text as paragraph (b); and
b. Add paragraph (a).
The addition reads as follows:
§199.3 Definitions.
(a) Terms used in this part have the same meaning as in 49 CFR 40.3.
* * * * *
24. Add §199.4 to read as follows:
§199.4 Electronic documents, records, and signatures.
Electronic documents, records, and signatures may be used to comply with this part provided they meet the requirements specified in 49 CFR part 40.
25. In §199.117, revise paragraph (a) introductory text to read as follows:
§199.117 Recordkeeping.
(a) Each operator shall keep the records in paragraphs (a)(1) through (5) of this section for the periods specified by this section or for the periods specified by 49 CFR part 40, whichever is greater; and will permit access to the records as provided by §190.203.
* * * * *
26. In §199.119, revise paragraph (a) to read as follows:
§199.119 Reporting of anti-drug testing results.
(a) Each large operator (having more than 50 covered employees) must submit an annual Management Information System (MIS) report to PHMSA of its anti-drug testing using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.
* * * * *
27. In §199.227, revise paragraph (b) introductory text to read as follows:
§199.227 Retention of records.
* * * * *
(b) Period of retention. Each operator shall maintain the records in accordance with the following schedule or for the periods specified by 49 CFR part 40, whichever is greater:
* * * * *
28. In §199.229, revise paragraph (a) to read as follows:
§199.229 Reporting of alcohol testing results.
(a) Each large operator (having more than 50 covered employees) must submit an annual MIS report to PHMSA of its alcohol testing results using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.
* * * * *
Signed on: Thursday, October 3, 2024.
Pete Buttigieg,
Secretary of Transportation.
[FR Doc. 2024-23427 Filed 10-11-24; 8:45 am]
BILLING CODE 4910-9X-P
NewsFleet SafetyPipeline and Hazardous Materials Safety Administration (PHMSA), DOTDrug testing - Motor CarrierDrug and Alcohol Testing - DOTOffice of the Secretary of TransportationHazmat SafetyRulemakingFocus AreaProposed RuleEnglishTransportationUSA
89 FR 82957 Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records
2024-10-15T05:00:00Z
DEPARTMENT OF TRANSPORTATION
Office of the Secretary
49 CFR Part 40
Pipeline and Hazardous Materials Safety Administration
49 CFR Part 199
[Docket DOT-OST-2022-0027]
RIN 2105-AF01
Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records
AGENCY: Office of the Secretary, Department of Transportation (DOT).
ACTION: Notice of proposed rulemaking (NPRM).
SUMMARY: The Department of Transportation (DOT or Department) proposes to amend its regulations for conducting workplace drug and alcohol testing for the federally regulated transportation industry to allow, but not require, electronic signatures on documents required to be created and utilized under the regulations, the use of electronic versions of forms, and the electronic storage of forms and data. The regulatory changes would apply to DOT-regulated employers and their contractors (“service agents”) who administer their DOT-regulated drug and alcohol testing programs. Currently, employers and their service agents must use, sign and store paper documents exclusively, unless the employer is utilizing a laboratory's electronic Federal Drug Testing Custody and Control Form (electronic CCF) system that has been approved by the Department of Health and Human Services (HHS). DOT is required by statute to amend its regulations to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms. This rulemaking also responds to an April 2, 2020, petition for rulemaking from DISA Global Solutions, Inc. (DISA), requesting that DOT regulations be amended to allow the use of an electronic version of the alcohol testing form (ATF) for DOT-authorized alcohol testing. The proposed regulatory amendments are expected to provide additional flexibility and reduced costs for the industry while maintaining the integrity and confidentiality requirements of the drug and alcohol testing regulations. In addition, DOT proposes to amend the Pipeline and Hazardous Materials Safety Administration (PHMSA) regulation for conformity and to make other miscellaneous technical changes and corrections.
DATES: Comments on this NPRM must be received on or before December 16, 2024.
ADDRESSES: You may submit comments identified by Docket Number DOT-OST-2022-0027 using any of the following methods:
• Federal eRulemaking Portal: Go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document. Follow the online instructions for submitting comments.
• Mail: Docket Management Facility, U.S. Department of Transportation, 1200 New Jersey Avenue SE, West Building, Ground Floor, Room W12-140, Washington, DC 20590-0001.
• Hand Delivery or Courier: West Building, Ground Floor, Room W12-140, 1200 New Jersey Avenue SE, Washington, DC, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting Dockets Operations.
• Fax: 202-493-2251.
To avoid duplication, please use only one of these methods. See the “Public Participation and Request for Comments” portion of the SUPPLEMENTARY INFORMATION section for instructions on submitting comments, including collection of information comments for the Office of Information and Regulatory Affairs, Office of Management and Budget (OMB).
FOR FURTHER INFORMATION CONTACT:
Mike Huntley, Office of Drug and Alcohol Policy and Compliance, 1200 New Jersey Avenue SE, Washington, DC 20590; telephone number 202-366-3784; ODAPCwebmail@dot.gov. If you have questions on viewing or submitting material to the docket, contact Docket Services, telephone (202) 366-9826.
SUPPLEMENTARY INFORMATION:
This NPRM is organized as follows:
I. Executive Summary
II. Public Participation and Request for Comments
A. Submitting Comments
B. Viewing Comments and Documents
C. Privacy Act
III. Legal Basis for the Rulemaking
IV. Background
V. Advance Notice of Proposed Rulemaking (ANPRM) Overview
VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures
VII. Amending Part 40 To Permit Electronic Documents and Signatures
VIII. Electronic ATF
IX. Section-by-Section Analysis
X. Regulatory Analyses and Notices
I. Executive Summary
Purpose and Summary of the Major Provisions
This proposed rule would establish parity between paper and electronic documents and signatures and expand businesses' and individuals' ability to use electronic methods to comply with the Department's drug and alcohol testing regulation, 49 CFR part 40, “Procedures for Transportation Workplace Drug and Alcohol Testing Programs” (part 40). Businesses and individuals subject to part 40 would continue to have the choice to use paper documents and traditional “wet” signatures. This proposed rule would also modify references to recordkeeping and reporting methods throughout part 40 to make them technologically neutral.
This proposed rulemaking responds to a statutory mandate set forth in section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271 (see 49 U.S.C. 322 note). The proposed rulemaking would take action consistent with the Government Paperwork Elimination Act (GPEA) (division C, title XVII, secs. 1701-1710, Pub. L. 105-277) and the Electronic Signatures in Global and National Commerce Act (E-SIGN) (Pub. L. 106-229) with regard to DOT's part 40 regulations.
II. Public Participation and Request for Comments
A. Submitting Comments
If you submit a comment, please include the docket number for this NPRM (Docket No. DOT-OST-2022-0027), indicate the specific section of this document to which each comment applies, and provide a reason for each suggestion or recommendation. You may submit your comments and material online or by fax, mail, or hand delivery, but please use only one of these means. The Office of the Secretary (OST) recommends that you include your name and a mailing address, an email address, or a phone number in a cover letter or an email so that OST can contact you if there are questions regarding your submission.
To submit your comment online, go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document, click on this NPRM, click “Comment,” and type your comment into the text box on the following screen.
If you submit your comments by mail or hand delivery, submit them in an unbound format, no larger than 8 1/2 by 11 inches, suitable for copying and electronic filing. If you submit comments by mail and would like to know that they reached the facility, please enclose a stamped, self-addressed postcard or envelope.
OST will consider all comments and material received during the comment period in determining how to proceed with any final rule.
B. Viewing Comments and Documents
To view comments, as well as any documents mentioned in this preamble as available in the docket, go to https://www.regulations.gov. Insert the docket number, DOT-OST-2022-0027, in the keyword box, and click “Search.” Next, click the “Open Docket Folder” button and choose the document to review. If you do not have access to the internet, you may view the docket online by visiting the Docket Management Facility in Room W12-140 on the ground floor of the DOT West Building, 1200 New Jersey Avenue SE, Washington, DC 20590-0001, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting the Docket Management Facility.
C. Privacy Act
In accordance with 5 U.S.C. 553(c), DOT solicits comments from the public to better inform its rulemaking process. DOT posts these comments, without edit, including any personal information the commenter provides, to www.regulations.gov, as described in the system of records notice (DOT/ALL-14 FDMS), which can be reviewed at https://www.transportation.gov/individuals/privacy/privacy-act-system-records-notices under the heading of “Department-Wide System of Records Notices”.
III. Legal Basis for the Rulemaking
This rulemaking is promulgated under the authority enacted in the Omnibus Transportation Employee Testing Act of 1991 (OTETA) (Pub. L. 102-143, tit. V, 105 Stat. 952) and codified at 49 U.S.C. 45102 (aviation), 49 U.S.C. 20140 (rail), 49 U.S.C. 31306 (motor carrier), and 49 U.S.C. 5331 (public transportation), as well as the Department's authority in 49 U.S.C. 322 and the PHMSA authorities specified in the proposed regulatory text for this action.
According to Public Law 115-271, the Secretary of Transportation is required to “issue a final rule revising part 40 of title 49, Code of Federal Regulations, to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms.” (49 U.S.C. 322 note) The statute set the deadline for this action as not later than 18 months after HHS establishes a deadline for a certified laboratory to request approval for fully electronic CCFs ( Id. ) On April 7, 2022, HHS set that deadline as August 31, 2023 (87 FR 20528). HHS has extended the deadline to August 31, 2026, to enable sufficient time for all HHS-certified laboratories to identify and contract with an electronic CCF supplier or to develop an electronic CCF. The deadline for DOT's regulatory amendments would therefore be February 29, 2028.
There are two additional Federal statutes relevant to the implementation of electronic document and signature requirements.
The Government Paperwork Elimination Act (GPEA), codified at 44 U.S.C. 3504 note, 1 was enacted to improve customer service and governmental efficiency through the use of information technology. The GPEA defines an electronic signature as a method of signing an electronic communication that: (a) identifies and authenticates a particular person as the source of the electronic communication; and (b) indicates such person's approval of the information contained in the electronic communication. Id. It also requires OMB to ensure Federal agencies provide for: (a) the option of maintaining, submitting; or disclosing information electronically, when practicable; and (b) the use and acceptance of electronic signatures when practicable. The GPEA states that electronic records submitted pursuant to procedures developed under title XVII for the submission of records to Federal agencies and electronic signatures used in accordance with those procedures shall not be denied legal effect, validity, or enforceability merely because they are in electronic form. Id.
1 Division C, title XVII (sec. 1701-1710) of Public Law 105-277, 112 Stat. 2681-749, enacted on October 21, 1998.
The Electronic Signatures in Global and National Commerce Act (E-SIGN), codified at 15 U.S.C. 7001-7031, 2 was designed to promote the use of electronic contract formation, signatures, and recordkeeping in private commerce by establishing legal equivalence between traditional paper-based methods and electronic methods. The E-SIGN Act allows the use of electronic records to satisfy any statute, regulation, or rule of law requiring that such information be provided in writing if the consumer has affirmatively consented to such use and has not withdrawn consent. Specifically, the statute establishes the legal equivalence of the following types of documents with respect to any transaction in or affecting interstate or foreign commerce, whether in traditional paper or electronic form: (a) contracts, (b) signatures, and (c) other records (15 U.S.C. 7001(a)(1)).
2 Public Law 106-229, 114 Stat. 464, enacted on June 30, 2000.
IV. Background
The Department's drug and alcohol testing regulations were promulgated at a time when the ability to sign and retain official records electronically—now commonplace in many business segments—was not available. Over the course of several years, we have adopted measures that have reduced the paper documentation associated with the drug and alcohol testing program without compromising the integrity and confidentiality requirements of the program. In 2003, we standardized the form for employers to report their Management Information System (MIS) aggregate drug and alcohol testing data, as well as the specific data collected. 3 When creating a ONE-DOT MIS Form, we then authorized employers to submit a single standardized form via a web portal. In 2015, we issued a final rule to allow employers, collectors, laboratories, and medical review officers (MROs) to use the electronic version of the Federal Drug Testing CCF in the DOT-regulated drug testing program. 4 That final rule also incorporated into the regulations the requirement to establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons when using the electronic CCF. We also included language protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form when using the electronic CCF.
3 68 FR 43946 (July 25, 2003).
4 80 FR 19551 (Apr. 13, 2015).
Consistent with the statutory mandate in 49 U.S.C. 322 note, we propose amendments to part 40 to permit the use of electronic signatures, forms, and records storage for drug and alcohol testing records throughout the regulation, including the use of an electronic ATF for DOT-authorized alcohol testing. We emphasize that electronic signatures, forms, and records would not be required; we would continue to allow paper, or hard-copy use with traditional “wet signatures.”
These proposed amendments would establish parity between paper and electronic collection and submission of information required under our regulations (and remain compatible with applicable OMB guidance on implementing electronic signatures 5 ) by allowing further use of electronic means and methods to comply with part 40 requirements. Many employers and their service agents have already instituted the use of electronic signatures, forms, and records storage for the non-DOT regulated testing that they conduct. DOT supports this transition to a paperless system and is committed to ensuring that the movement to a partially or fully electronic part 40 is done to maximize program efficiencies and reduce costs, while maintaining the integrity and confidentiality requirements of the program.
5https://www.whitehouse.gov/wp-content/uploads/2017/11/2000-M-00-15-OMB-Guidance-on-Implementing-the-Electronic-Signatures-in-Global-and-National-Commerce-Act.pdf.
Electronic documents would have a high degree of forensic defensibility as long as any changes made to the document are in the document's electronic footprint, which shows when the document or signature, as applicable, was created; when, and if, changes were made; who made the changes; and when, as applicable, a document was transmitted to and received by the receiving entity. The use of electronic forms and signatures in part 40 would help DOT-regulated employers and their service agents improve their workflow efficiency through faster turnaround times for required documents. Cost savings would result through reduced printing and delivery/shipping costs, and expedited transmission of information allowing for more timely decisions. We believe this proposed rule, if adopted, would also mitigate the longstanding problems ( e.g., delays in processing times of test results, cancelling of test results, etc.) associated with illegible and lost copies of paper documents.
V. Advance Notice of Proposed Rulemaking (ANPRM) Overview
On August 5, 2022, we published an ANPRM requesting public comment on how part 40 could be amended, as required by the statute, to allow electronic signatures, forms, and recordkeeping (87 FR 47951). We requested information from DOT-regulated employers and their service agents regarding if and how they are already handling electronic signatures, records transmission, and records storage in their non-DOT testing programs. In addition, we requested comments and information on appropriate performance standards, and on whether particular methods or performance standards have been successful or unsuccessful. We also asked a number of general questions on the potential advantages, risks, ramifications, and required safeguards associated with the use of electronic signatures, forms, and records in the DOT drug and alcohol testing program. We asked questions about specific sections of part 40 that we anticipated would be affected by prospective changes to implement electronic signatures, forms, and records. Finally, we asked a number of questions regarding the use of an electronic ATF for DOT-regulated alcohol tests.
We received 72 comments in response to the ANPRM, including comments from individuals, testing laboratories, MROs, and MRO organizations, substance abuse professionals (SAP) and SAP organizations, and various associations representing DOT-regulated transportation workers subject to mandatory drug and alcohol testing under part 40.
A few individuals expressed opposition to the adoption of electronic signatures, forms, and recordkeeping, citing concerns about the need for the rulemaking, risk to personal information from hackers or mismanaged electronic processes and procedures, and misuse of electronic forms and signatures. To meet our statutory mandate and in consideration of concerns about safeguarding personal information and appropriate use of the information in developing the NPRM, DOT proposes to require security measures for electronic forms and signatures used under part 40 that are the same as those currently in place for the electronic CCF specified in 49 CFR 40.40(c)(5).
Most commenters were supportive of changes to amend part 40 that would permit, but not require, the use of electronic signatures, forms, and recordkeeping. Commenters supporting revisions to part 40 noted that electronic signatures, forms, and recordkeeping are used in virtually every industry today—including but not limited to the banking, insurance, medical, and legal industries. Commenters supported the use of performance standards instead of technology-specific standards to ensure that, once established, standards do not become obsolete given the rapidly evolving nature of information technology standards and practices. Commenters stated that allowing electronic signatures, forms, and recordkeeping would make the drug testing process much more efficient and would result in cost savings. Commenters also stated that it would be safer to store records electronically since records could be backed-up, secured, and protected from tampering and unauthorized access and use.
VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures
In developing this NPRM, we looked to a rule promulgated by DOT's FMCSA that permits the use of electronic methods to generate, certify, sign, maintain, or exchange records so long as the documents accurately reflect the required information and can be used for their intended purpose. (83 FR 16210, Apr. 16, 2018) The rule applies to documents that FMCSA requires entities or individuals to retain. FMCSA permits, but does not require, anyone to satisfy FMCSA requirements by using electronic methods to generate, maintain, or exchange documents. The substance of the document must otherwise comply with applicable Federal laws and FMCSA rules. FMCSA also permits, but does not require, anyone required to sign or certify a document to do so using electronic signatures, defined, as in the GPEA, as a method of signing an electronic communication that: (1) identifies and authenticates a particular person as the source of the electronic communication; and (2) indicates such person's approval of the information contained in the electronic communication. FMCSA allows for the use any available technology for electronic signatures, so long as the signature otherwise complies with FMCSA's requirements.
FMCSA adopted broad performance standards for electronic documents and signatures—as specified in GPEA and E-SIGN—rather than detailed, technology specific standards that would likely become obsolete with inevitable changes in information technology standards and practices. FMCSA's April 2018 rule has been in effect for more than five years, and the definitions and requirements established in that rule have stood the test of time despite the many changes that have occurred with respect to electronic documents and signatures. We are unaware of any FMCSA-regulated entities that have reported issues to FMCSA regarding the use of electronic documents or signatures to meet the requirements of the FMCSRs since the rule became effective in 2018.
VII. Amending Part 40 To Permit Electronic Documents and Signatures
In this NPRM, we propose to permit but not require electronic documents, signatures, and recordkeeping in part 40. Additionally, we propose a performance standard approach as opposed to establishing technology-specific standards. Where it is possible to do so, establishing the same or substantively similar regulatory requirements for common issues across DOT modal agencies—such as the use of electronic documents and signatures—helps the Department maintain a consistent regulatory approach for those common issues.
There are currently more than 60 references to the term “written” in part 40, and more than 20 additional references to the term “in writing.” We propose to add a definition of “written or in writing” in part 40, to eliminate any distinction between paper and electronic documentation and establish technological neutrality throughout the entirety of part 40.
FMCSA's rule does not apply to documents that individuals or entities are required to file directly with FMCSA. In its April 2018 final rule, FMCSA explained that while industry could use electronic signatures and submit information directly to the FMCSA in certain situations, 6 adapting all FMCSA systems to allow for use of electronic signatures and submissions would significantly delay the implementation of the rule for use by third parties as it would require FMCSA to develop and implement technology systems to allow for direct submission to FMCSA from regulated parties. FMCSA noted that development of such systems could take several years, and therefore saw no reason to make private parties' use of electronic signatures and records retention contingent upon FMCSA's ability to receive submissions electronically because doing so would delay potential benefits to be gained by third parties.
6 As an example, Certified Medical Examiners may use electronic signatures, if they choose to do so, to sign medical forms, certificates, and a new driver medication report. If FMCSA requests these forms, they are uploaded in portable document format (PDF) to the Medical Examiner's account associated with the National Registry of Certified Medical Examiners for FMCSA to access.
In contrast to FMCSA's regulations, part 40 does not require entities or individuals to submit documents directly to the Department except for MIS aggregate drug and alcohol testing data that employers subject to DOT or U.S. Coast Guard (USCG) drug and alcohol testing regulations must submit annually. Each of the various documents required and used as part of the DOT drug and alcohol testing program under part 40 ( e.g., employee drug and alcohol testing records, MRO reports and records, SAP reports and records) are documents that are created by, exchanged between, and maintained by a person or entity involved in the testing process—but are not required to be submitted directly to DOT.
As noted earlier, and specifically with respect to the required MIS data, we standardized the form for employers to report their aggregate drug and alcohol testing data, as well as the specific data collected, more than 20 years ago. At that time, we authorized employers to submit the ONE-DOT MIS form via a web portal. Today, the Federal Aviation Administration, FMCSA, Federal Railroad Administration, and Federal Transit Administration permit employers to submit that same drug and alcohol testing data via the internet, and PHMSA requires that the data be submitted electronically. If employers submit the data electronically via the internet, they are not required to submit a hard copy. DOT recommends that employers have a copy of their data available (either hard copy or in electronic format) in the event an auditor or inspector requests a copy.
From the above, and because the only documents that part 40 requires to be submitted directly to the Department are already permitted to be, and in some cases required to be, submitted electronically, there is no need for us to limit the applicability of our proposal as FMCSA did in its 2018 final rule.
Several commenters noted that they already use electronic signatures and documents for their non-DOT drug and alcohol testing program, and in some cases, have done so for many years. In doing so, these commenters have had to establish appropriate confidentiality and security measures to ensure that confidential employee records cannot be accessed by unauthorized persons, including protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The same general requirements were added to the current §40.40(c)(5) when we approved the use of the electronic CCF for use in DOT drug testing in 2015, 7 and we propose the same requirements in this NPRM for the use of electronic signatures, documents, and recordkeeping throughout the entirety of part 40.
7 The 2015 revisions amended then §40.45(c)(5), which was redesignated as §40.40(c)(5) in the May 2023 final rule to include oral fluid testing in the DOT drug testing program (88 FR 27596, May 2, 2023).
Ensuring that confidential employee records are not available to unauthorized persons is an important element of part 40's protections for employees that are subject to DOT's drug and alcohol testing rules. We believe that the failure of a service agent to provide or maintain a secure/confidential electronic system should constitute the basis for the Department to start a public interest exclusion (PIE) proceeding, and propose to add this to the list of examples provided in §40.365(b).
Throughout part 40, information and documents are required to be transmitted and/or communicated between service agents ( e.g., collectors, screening test technicians (STTs) and breath alcohol technicians (BATs), laboratories, MROs, SAPs, and consortium/third party administrators (C/TPAs)), employers, and employees). Although part 40 does not currently require the party receiving these communications and/or documents to affirmatively confirm receipt of such from the sender, in some instances, regardless of whether the document is electronic or a hard copy, we believe that it may be important for the receiving party to verify that those required communications and/or documents were received.
For example, under §40.25, an employer intending to use an employee to perform safety-sensitive functions must, after obtaining an employee's written consent, request information about the employee's drug and alcohol testing record from previous DOT-regulated employers. After receiving a copy of the employee's written consent, the previous employer must immediately provide the requested information to the employer making the inquiry. If an employer is subsequently investigated/audited by the appropriate DOT mode, it may be beneficial for both the gaining employer and the previous employer to be able to affirmatively demonstrate that the employee's written consent and previous testing record were sent and received as required.
Sections 40.191(d) and 40.261(c)(1) require a collector or MRO (for drug tests) or a BAT, STT, or a physician evaluating a “shy lung” situation (for alcohol tests), respectively, to—when an employee refuses to participate in a part of the testing process—terminate the testing process, document the refusal, and immediately and directly notify the employer's designated employer representative (DER) by any means that ensures the refusal notification is immediately received. Because this notification of a refusal to an employer is of an urgent nature, it may be advisable to require the DER to affirmatively confirm receipt of the required notification from the collector, MRO, BAT, STT, or physician. For example, §§40.191(d) and 40.261(c)(1) could be amended to read “. . . immediately notify the DER by any means and ensure that the refusal notification is immediately received”.
While we are not proposing new requirements in this NPRM regarding confirmation of receipt in the sections discussed above (or in other part 40 requirements), we seek comment regarding whether it may be beneficial or advisable to do so, and if so, for which specific sections of part 40.
VIII. Electronic ATF
The ATF has been in use in the DOT alcohol testing program since 1994 (see 59 FR 7349, Feb. 15, 1994). The ATF must be used to document every DOT alcohol test. DOT regulations at 49 CFR 40.225 set forth the requirements for use of the form, and 49 CFR part 40, appendix G, contains a facsimile (reference copy) of the form. The ATF is a three-part carbonless manifold form used by DOT-regulated employers to document the testing event when testing employees subject to DOT alcohol testing. When the employee is tested, both the employee and the STT and/or the BAT will complete the ATF in various sections. The STT/BAT documents the result(s) by either writing in the screening result or attaching the screening and/or confirmation result printed by the evidential breath testing devices (EBT) onto the ATF, and then sends Copy 1 to the employer, provides Copy 2 to the employee, and retains Copy 3 for their records.
On April 2, 2020, DISA petitioned the Department to amend part 40 to allow for the use of an electronic version of the ATF for DOT mandated alcohol testing. In support of its petition, DISA stated that “The requested amendment to 49 CFR part 40 will enable a parallel process for the documentation of DOT-mandated alcohol tests aligned with the similarly situated amendment previously approved for drug testing.” DISA believes that allowing the use of an electronic ATF will result in several benefits to the industry, including “increased efficiency, security and accuracy in documentation of DOT alcohol tests; paperwork reduction; improved process for conducting a DOT alcohol test in conjunction with a DOT drug test when an electronic version of the federal CCF is used for the drug test; reduction of errors and omissions in the completion of the ATF; and improved efficiency and efficacy in the transmission and record retention of alcohol test results.”
DISA noted that non-DOT workplace breath alcohol testing has been conducted using electronic versions of an alcohol testing form that mirrors the DOT ATF for more than five years. Based on experience using those electronic forms for non-DOT testing, DISA cites improved efficiency and accuracy of documentation because: (1) employer and employee information is entered via computer and thus not dependent on reading and deciphering hand-written entries, (2) date time stamps of the testing are automated and not subject to fluctuation or error, (3) transmission of documentation on completed tests is more secure using databases accessed only via protected password and personal identification number (PIN) to authorized employers or their designated agents, and (4) transmission of test result information is faster and more secure than existing transmission options of scanning and emailing attachments or facsimile.
DISA also noted that permitting use of an electronic ATF for DOT-regulated alcohol testing “will substantially reduce cost, by eliminating the requirement for the printing and distribution of carbonless three-ply paper ATFs. The proposed electronic ATF option would still provide for printed paper images to be made available to the employee, the employer, and the alcohol technician, [but] eliminates the requirement for the more expensive carbonless 3 ply paper ATF.”
For the reasons described by DISA in its petition, and recognizing that significant benefits and cost reductions have resulted from use of the electronic CCF for drug testing, we believe that it is likewise appropriate to permit the use of electronic ATFs in part 40 for DOT-regulated testing. Permitting but not requiring the use of an electronic ATF would be consistent with our proposal to permit, but not require, the use of electronic documents and signatures throughout the entirety of part 40 as discussed above. As several commenters noted, the use of an electronic ATF has been used in non-DOT testing for 5-10 years, and the same developers of the electronic CCFs have developed the electronic ATFs. Any electronic ATF used under part 40 for DOT-regulated employees would have to be identical in form and content to the DOT ATF in appendix I to part 40. 8 Just as we imposed general confidentiality and security requirements when electronic CCFs were permitted to be used under part 40, we believe that it is necessary to include the same general requirements relating to the use of electronic ATFs to ensure that confidential employee records cannot be accessed by unauthorized persons.
8 The ATF form was redesignated from appendix G to appendix I as part of the rulemaking process culminating in the May 2023 final rule. During that process, the form was reviewed by the public and DOT received no comment on the form.
Manufacturers of EBTs and alcohol screening devices (ASD) used in DOT alcohol tests must obtain approval from the National Highway Traffic Safety Administration (NHTSA) and then be listed on the Office of Drug and Alcohol Policy and Compliance's (ODAPC) website before those devices may be used in DOT alcohol testing.
IX. PHMSA Proposed Changes
PHMSA is proposing to amend §§199.3, 199.117, and 199.227 and to add §199.4 to conform to the proposed changes in part 40 and to clarify that the proposed changes in part 40 apply to part 199. These changes will help the readers of part 199 find the applicable regulations in part 40 with regards to the definition of terms and record keeping requirements. We also propose to amend §§199.119 and 199.229 by changing the reference of “appendix H” to “appendix J” to conform to the amendment of part 40 published on May 2, 2023.
X. Section-by-Section Analysis
Section 40.3 What do the terms used in this regulation mean?
We propose to add a definition of “electronic signature.” The rule would define an electronic signature as a method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 44 U.S.C. 3504 note, 112 Stat. 2681-749). Including the specific cross reference to GPEA would ensure that regulated entities know that we are using GPEA's performance standard for allowing use of electronic signatures.
We propose to add a definition of “written or in writing.” The rule would define written or in writing as printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of 49 CFR 40.4. This definition would eliminate any distinction between paper and electronic methods of communication/documentation.
Section 40.4 May electronic documents and signatures be used?
We propose to add a new §40.4 that would prescribe the requirements pertaining to electronic documents and signatures throughout part 40.
Paragraph (a) would specify that §40.4 would apply to all documents required by part 40, except for the CCF, as an electronic CCF may only be used when approved by HHS and in compliance with §40.40(c)(5). As background, before an HHS-certified laboratory can use a Federal electronic CCF for regulated specimens, the test facility must submit a detailed plan and proposed standard operating procedures for the electronic CCF system for HHS review and approval through the National Laboratory Certification Program. At the current time, several HHS-certified laboratories have received approval to use a combination electronic/paper CCF, while four laboratories have received approval to use a fully electronic CCF. As noted earlier, and in a separate section of the SUPPORT Act, HHS was required to set a deadline for certified laboratories to request approval for use of fully electronic CCFs. That deadline is now August 31, 2026.
Paragraph (b) would permit, but not require, any person or entity to use electronic methods to comply with any provision in part 40 that requires a document to be signed, certified, generated, maintained, or transmitted between parties. It would apply to all forms of written documentation, including forms, records, notations, and other documents. The substance of the document would otherwise have to comply with part 40 requirements. This would establish parity between paper and electronic documents and signatures, greatly expanding interested parties' ability to use electronic methods to comply with the requirements of part 40.
Paragraph (c) would permit, but not require, any entity required to sign or certify a document to do so using electronic signatures as defined in §40.3. The rule specifies that a person may use any available technology so long as the signature otherwise complies with the requirements of part 40.
Paragraph (d) would establish the minimum requirements for electronic documents and signatures. Any electronic document or signature would be considered the legal equivalent of a paper document or signature if it is the functional equivalent with respect to integrity, accuracy, and accessibility. In other words, the electronic documents or signatures need to accurately and reliably reflect the information in the record. They must remain accessible in a form that could be accurately viewed or reproduced according to Agency rules. As with any documents, paper or electronic, documents that are not legible—for any reason—do not satisfy the Department's requirements.
Electronic documents are not to be considered the legal equivalent of traditional paper documents if they (1) are not capable of being retained, (2) are not used for the purpose for which they were created, or (3) cannot be accurately reproduced for reference by any entity entitled to access by law, for the period of time required by the Department's recordkeeping requirements.
Paragraph (d) would also require that any electronically signed documents must incorporate or otherwise include evidence that both parties to the document have consented to the use of electronic signatures, as required by the E-SIGN Act (15 U.S.C. 7001(c)).
Paragraph (e) would require that when using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records cannot be accessed by unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The proposed requirements are analogous to those established in the current §40.40(c)(5) when we approved use of the electronic CCF in part 40.
Section 40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?
Currently, paragraph (g) makes it clear that the release of information under this section must be in any written form, and the parenthetical clarifies that this can be paper-based (written, fax) or electronic (email). Under the proposed definition of “written or in writing,” there is no distinction between paper-based and electronic communications. Because “written or in writing” would mean either paper or electronic communications, we propose to remove parenthetical reference to “fax, email, letter” to eliminate redundancy and confusion. All parties can conduct their business using either paper or electronic means of documentation and communication.
Section 40.79 How is the collection process completed?
Currently, paragraph (a)(9) of this section requires the collector to “fax or otherwise transmit” Copy 2 of the CCF to the MRO and Copy 4 to the DER within 24 hours or during the next business day. We propose to amend this section by removing reference to the methods of transmitting receipts, so parties can choose their own medium of communication.
Section 40.97 What do laboratories report and how do they report it?
For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraphs (c)(1) and (2) of this section.
Section 40.111 When and how must a laboratory disclose statistical summaries and other information it maintains?
For the same reasons explained in the discussion of §40.79, we propose to amend paragraph (b) of this section to remove the references to the methods of transmitting the summary or report required by this section. Because the summary or report can be transmitted via hard copy or electronically, there is no need to specify how it must be transmitted. As such, we propose to amend the title of this section accordingly.
Section 40.127 What are the MRO's functions in reviewing negative test results?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (c)(2) of this section.
Section 40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative test results?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (b)(2) of this section.
Section 40.163 How does the MRO report drug test results?
For the same reasons explained in the discussion of §40.25, we propose to remove the reference to a “letter” in paragraph (c) of this section. In paragraph (e) of this section, we propose to replace the term “letter” with “written report” for consistency with paragraph (c).
Section 40.167 How are MRO reports of drug results transmitted to the employer?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (c)(1) of this section.
Section 40.185 Through what methods and to whom must a laboratory report split specimen results?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (b) of this section. In addition, because Copy 1 of the CCF can be transmitted in writing or electronically, there is no need to specify the methods through which it must be transmitted. As such, we propose to amend the title of this section accordingly.
Section 40.187 What does the MRO do with split specimen laboratory results?
For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraph (c)(2)(iv)(C) of this section.
Section 40.191 What is a refusal to take a DOT drug test, and what are the consequences?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (d) of this section as means of transmitting notification that an employee has refused to participate in part of the testing process from the collector or MRO to the DER.
Section 40.193 What happens when an employee does not provide a sufficient amount of urine for a drug test?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “send or fax” as the means for the collector to transmit copies of the CCF to the MRO and the DER in paragraph (b)(3) of this section.
Section 40.205 How are drug test problems corrected?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a collector, laboratory, MRO, employer, or other person to supply signed statements regarding correctable problems in a drug test in paragraphs (b)(1) and (2) of this section.
Section 40.225 What form is used for an alcohol test?
We propose to amend this section to permit, but not require, the use of an electronic version of the DOT ATF that is identical in form and content to the form provided in appendix I to part 40. The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT, and if an EBT provides a separate printout of confirmation test results pursuant to §40.253(g), the electronic ATF must include that separate printout. This section would also be amended to specify the same general confidentiality and security measures in §40.45 relating to electronic CCFs to ensure that confidential employee records cannot be accessed by unauthorized persons.
Section 40.255 What happens next after the alcohol confirmation test result?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (a)(5)(i) of this section as means of transmitting results of the alcohol confirmation test from the BAT to the DER. Similarly, there is no need to specify that Copy 1 of the ATF may be transmitted “in person, by telephone, or by electronic means.”
Section 40.261 What is a refusal to take an alcohol test, and what are the consequences?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (c) of this section as means of transmitting a refusal notification from a BAT, STT, or referral physician to the DER.
Section 40.271 How are alcohol testing problems corrected?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a STT, BAT, employer, or other service agent to supply a signed statement regarding correctable flaws in an alcohol test in paragraph (b)(2) of this section.
Section 40.365 What is the Department's policy concerning starting a PIE proceeding?
We propose to amend this section by adding a new paragraph (b)(15) that would identify the failure of a service agent to provide or maintain a secure/confidential electronic system as appropriate grounds for starting a PIE proceeding.
X. Regulatory Analyses and Notices
Executive Orders 12866, 13563, and 14094 (Regulatory Planning and Review)
The Secretary has examined the impact of the proposed part 40 amendments under Executive Order 12866 (“Regulatory Planning and Review”), as supplemented by Executive Order 13563 (“Improving Regulation and Regulatory Review”) and amended by Executive Order 14094 (“Modernizing Regulatory Review”), which directs Federal agencies to assess all costs and benefits of available regulatory alternatives and, when regulation is necessary, to select regulatory approaches that maximize net benefits (including potential economic, environmental, public health and safety, and other advantages; distributive impacts; and equity).
According to these Executive orders, a regulatory action is “significant” if it meets any one of a number of specified conditions, including having an annual effect on the economy of $200 million or more, as adjusted every three years by the Office of Information and Regulatory Affairs (OIRA); adversely affecting in a material way a sector of the economy, competition, or jobs; or if it raises novel legal or policy issues. The proposed amendments, which would allow the use of electronic documents and signatures, do not meet the Executive order's criteria for being a significant rule. Consequently, OMB has determined that the rulemaking action is not significant under the Executive order.
The proposed rule responds to the statutory mandate set forth in Section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271. The proposed rule would not impose new requirements on the industry; rather, it would simply permit—but not require—regulated entities to use electronic signatures, forms, and recordkeeping, and remove outdated and obsolete references in the regulatory text. The proposed rule would not impose new costs on the industry because regulated entities would be allowed to choose to continue to use paper-based documents as they had before. The benefits of the rule would stem from savings in paper and printing expense and other efficiency gains. Examples of documents affected by this rule include, but are not limited to, records of a prospective employee's drug and alcohol testing history that employers must obtain prior to permitting that employee to perform safety-sensitive duties, MRO records and reports, SAP records and reports, and ATFs. While there is no way to estimate how many entities or individuals would change their practices given the new options, or how many documents would be affected, several commenters to the ANPRM stated that they have been using electronic documents and signatures in their non-DOT drug and alcohol testing programs for many years. While neither the benefits nor the costs of this rule can be reliably estimated, we expect this proposed rule to provide flexibility to the industry. Under this proposed rule, regulated entities would have the flexibility to conduct business using either electronic or traditional paper-based methods. We also expect regulated entities to choose technologies that would maximize benefits in accordance with their individual needs and circumstances.
Regulatory Flexibility Act and Small Business Regulatory Enforcement Fairness Act (SBREFA)
The Regulatory Flexibility Act of 1980 (5 U.S.C. 601 et seq. ) requires Federal agencies to consider the effects of their regulatory actions on small businesses and other small entities and minimize any significant economic impact. The term “small entities” comprises small businesses and not-for-profit organizations that are independently owned and operated and are not dominant in their fields, and governmental jurisdictions with a population of less than 50,000. For this rulemaking, potentially affected small entities include drug testing companies (U.S. Small Business Administration (SBA) North American Industry Classification System (NAICS) Sector 54 (Professional, Scientific and Technical Services), Code 541380 (Testing Laboratories and Services)) as well as DOT-regulated entities (SBA NAICS Sectors 48-49 (Transportation and Warehousing)).
The Department does not expect that the proposed rule would have a significant economic impact on a substantial number of small entities. The proposed rule, if adopted, would increase flexibility for all small-entity transportation employers and their service agents by allowing them to use electronic documents, signatures, and recordkeeping to meet part 40 requirements. Use of electronic documents, electronic signatures, and electronic recordkeeping would be voluntary for affected small entities, which will provide added flexibility to these entities in meeting the part 40 requirements. For these reasons, and as explained in more detail in the preamble to this proposed rule, the Secretary certifies that the proposed rule would not have a significant economic impact on a substantial number of small entities within the meaning of the Regulatory Flexibility Act. Consequently, an initial regulatory flexibility analysis is not required for this proposed rule.
Unfunded Mandates
The Secretary has examined the impact of the final rule under the Unfunded Mandates Reform Act (UMRA) of 1995 (Pub. L. 104-4). This NPRM does not trigger the requirement for a written statement under sec. 202(a) of the UMRA because this rulemaking does not impose a mandate that results in an expenditure of $100 million (adjusted annually for inflation) or more by either State, local, and tribal governments in the aggregate or by the private sector in any one year. In fact, by providing an alternative to traditional paper-based records, the proposed rule would be expected to reduce costs to regulated parties, including State and local entities ( e.g., public transit authorities, and public works departments) whose employees are subject to testing and that choose to use electronic documents as opposed to paper-based documents.
Environmental Impact
The DOT has analyzed the environmental impacts of this action pursuant to the National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321 et seq. ) and has determined that it is categorically excluded pursuant to DOT Order 5610.1C, “Procedures for Considering Environmental Impacts” (44 FR 56420, October 1, 1979). Categorical exclusions are actions identified in an agency's NEPA implementing procedures that do not normally have a significant impact on the environment and therefore do not require either an environmental assessment (EA) or environmental impact statement (EIS). This proposed rule would amend the transportation industry drug testing program procedures regulation to permit the use of electronic documents, signatures, and recordkeeping. This action is covered by the categorical exclusion listed at 23 CFR 771.118(c)(4), “[p]lanning and administrative activities that do not involve or lead directly to construction, such as: . . . promulgation of rules, regulations, directives . . .” The Department does not anticipate any environmental impacts, and there are no extraordinary circumstances present in connection with this rulemaking.
Executive Order 13132: Federalism
The Secretary has analyzed the final rule in accordance with Executive Order 13132: Federalism. Executive Order 13132 requires Federal agencies to carefully examine actions to determine if they contain policies that have federalism implications or that preempt State law. As defined in the order, “policies that have federalism implications” refer to regulations, legislative comments or proposed legislation, and other policy statements or actions that have substantial direct effects on the States, on the relationship between the National Government and the States, or on the distribution of power and responsibilities among the various levels of government.
Most of the regulated parties under the Department's drug testing program are private entities. Some regulated entities are public entities ( e.g., transit authorities and public works departments); however, as noted above, this proposal would reduce costs of the Department's drug testing program and provide additional flexibility for regulated parties. Accordingly, the Secretary has determined that the proposed rule, which would allow but not require use of electronic signatures and recordkeeping, does not contain policies that have federalism implications.
Executive Order 13175: Consultation and Coordination With Indian Tribal Governments
Executive Order 13175 (65 FR 67249, November 6, 2000) requires Federal agencies to develop an accountable process to ensure “meaningful and timely input by tribal officials in the development of regulatory policies that have tribal implications.” “Policies that have tribal implications” as defined in the Executive order, include regulations that have “substantial direct effects on one or more Indian tribes, on the relationship between the Federal government and the Indian tribes, or on the distribution of power and responsibilities between the Federal government and Indian tribes.” This proposed rule does not have tribal implications. The proposed rule will also not have substantial direct effects on tribal governments, on the relationship between the Federal Government and Indian tribes, or on the distribution of power and responsibilities between the Federal Government and Indian tribes, as specified in Executive Order 13175.
Paperwork Reduction Act
The Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520) (PRA) requires that DOT consider the impact of paperwork and other information collection burdens imposed on the public. This proposed rule would call for no new collection of information under the PRA. Instead, there would likely be a significant reduction in the burden hours required for information collection 2105-0529, Procedures for Transportation Drug and Alcohol Testing Program, due to the ability to use electronic signatures and forms, and largely due to the ability to use an electronic ATF for DOT-regulated alcohol testing under part 40. We request comments on this issue. Notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information subject to the PRA that does not display a currently valid OMB control number.
Privacy Act
Anyone is able to search the electronic form of all comments received in any of our dockets by the name of the individual submitting the comment (or signing the comment, if submitted on behalf of an association, business, labor union, etc.) For information on DOT's compliance with the Privacy Act, please visit https://www.transportation.gov/privacy.
5 U.S.C. 553(b)(4)
As required by 5 U.S.C. 553(b)(4), a summary of this proposed rule can be found at the entry for RIN 2105-AF01 in the Department's Portion of the Unified Agenda of Regulatory and Deregulatory Affairs, available at https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202404&RIN=2105-AF01 .
Pay-As-You-Go Act of 2023
In accordance with Compliance with Pay-As-You-Go Act of 2023 (Fiscal Responsibility Act of 2023, Pub. L. 118-5, div. B, title III) and OMB Memorandum (M-23-21) dated September 1, 2023, the Department has determined that this proposed rule is not subject to the Pay-As-You-Go Act of 2023 because it will not increase direct spending beyond specified thresholds.
List of Subjects
49 CFR Part 40
Administrative practice and procedures, Alcohol abuse, Alcohol testing, Drug abuse, Drug testing, Laboratories, Reporting and recordkeeping requirements, Safety, Transportation.
49 CFR Part 199
Alcohol testing, Drug testing, Pipeline safety, Reporting and recordkeeping requirements, Safety, Transportation.
For the reasons stated in the preamble, the Department proposes to amend 49 CFR parts 40 and 199 as follows:
PART 40—PROCEDURES FOR TRANSPORTATION WORKPLACE DRUG AND ALCOHOL TESTING PROGRAMS
1. The authority for part 40 continues to read as follows:
Authority:
49 U.S.C. 102, 301, 322, 5331, 20140, 31306, and 54101 et seq.
2. In §40.3, add the definitions of “Electronic signature” and “Written or in writing” in alphabetical order to read as follows:
§40.3 What do the terms used in this part mean?
* * * * *
Electronic signature. A method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 112 Stat. 2681-749, 44 U.S.C. 3504 note).
* * * * *
Written or in writing. Printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of §40.4.
3. Add §40.4 to read as follows:
§40.4 May electronic documents and signatures be used?
(a) Applicability. This section applies to all documents required by this part, except for the CCF. An electronic CCF may be used only if it has been approved for use by the Department of Health and Human Services and is used in compliance with §40.40(c)(5).
(b) Electronic records or documents. Any person or entity required to generate, maintain, or exchange and/or transmit documents to satisfy requirements in this part may use electronic methods to satisfy those requirements.
(c) Electronic signatures. (1) Any person or entity required to sign or certify a document to satisfy the requirements of this part may use an electronic signature, as defined in §40.3.
(2) Any available technology may be used that satisfies the requirements of an electronic signature as defined in §40.3.
(d) Electronic document requirements. Any person or entity may use documents signed, certified, generated, maintained, or exchanged using electronic methods, as long as the documents accurately reflect the information otherwise required to be contained in them.
(1) Records, documents, or signatures generated, maintained, or exchanged using electronic methods satisfy the requirements of this section if they are capable of being retained, are used for the purpose for which they were created, and can be accurately reproduced within required timeframes for reference by any party entitled to access.
(2) Records or documents generated electronically satisfy the requirements of this section if they include proof of consent to use electronically generated records or documents, as required by 15 U.S.C. 7001(c).
(e) Confidentiality and security. When using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form to include protecting against destruction, deterioration, and data corruption.
4. In §40.25, revise paragraph (g) to read as follows:
§40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?
* * * * *
(g) The release of information under this section must be in any written form that ensures confidentiality. As the previous employer, you must maintain a written record of the information released, including the date, the party to whom it was released, and a summary of the information provided.
* * * * *
5. In §40.79, revise paragraph (a)(9) to read as follows:
§40.79 How is the collection process completed?
(a) * * *
(9) Send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or during the next business day. Keep Copy 3 for at least 30 days, unless otherwise specified by applicable DOT agency regulations.
* * * * *
6. In §40.97, revise paragraphs (c) introductory text, (c)(1) introductory text, and (c)(2) to read as follows:
§40. 97 What do laboratories report and how do they report it?
* * * * *
(c) As a laboratory, you must report laboratory results directly, and only, to the MRO at his or her place of business. You must not report results to or through the DER or a service agent ( e.g., C/TPA).
(1) Negative results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF which has been signed by the certifying scientist, or you may provide the laboratory results report electronically.
* * * * *
(2) Non-negative and rejected for testing results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF that has been signed by the certifying scientist. In addition, you may provide the laboratory results report following the format and procedures set forth in paragraphs (c)(1)(i) and (ii) of this section.
* * * * *
7. In §40.111, revise the section heading and paragraph (b) to read as follows:
§40.111 When must a laboratory disclose statistical summaries and other information it maintains?
* * * * *
(b) When the employer requests a summary in response to an inspection, audit, or review by a DOT agency, you must provide it unless the employer had fewer than five aggregate test results. In that case, you must send the employer a report indicating that not enough testing was conducted to warrant a summary.
* * * * *
8. In §40.127, revise paragraph (c)(2) to read as follows:
§40.127 What are the MRO's functions in reviewing negative test results?
* * * * *
(c) * * *
(2) A legible copy of Copy 1 of the CCF or the electronic laboratory results report that conveys the negative laboratory test result.
* * * * *
9. In §40.129, revise paragraphs (b) introductory text and (b)(2) to read as follows:
§40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative drug test results?
* * * * *
(b) Before you report a verified negative, positive, test cancelled, refusal to test because of adulteration or substitution, you must have in your possession the following documents:
* * * * *
(2) A legible copy of Copy 1 of the CCF, containing the certifying scientist's signature.
* * * * *
10. In §40.163, revise paragraphs (c) introductory text and (e) to read as follows:
§40.163 How does the MRO report drug test results?
* * * * *
(c) If you do not report test results using Copy 2 of the CCF for the purposes of this section, you must provide a written report for each test result. This report must, as a minimum, include the following information:
* * * * *
(e) You must retain a signed or stamped and dated copy of Copy 2 of the CCF in your records. If you do not use Copy 2 for reporting results, you must maintain a copy of the signed or stamped and dated written report in addition to the signed or stamped and dated Copy 2. If you use the electronic data file to report negatives, you must maintain a retrievable copy of that report in a format suitable for inspection and auditing by a DOT representative.
* * * * *
11. In §40.167, revise paragraph (c)(1) to read as follows:
§40.167 How are MRO reports of drug test results transmitted to the employer?
* * * * *
(c) * * *
(1) You must transmit a legible image or copy of either the signed or stamped and dated Copy 2 or the written report (see §40.163(b) and (c)).
* * * * *
12. In §40.185, revise the section heading and paragraph (b) to read as follows:
§40.185 What and to whom must a laboratory report split specimen results?
* * * * *
(b) You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF, which has been signed by the certifying scientist.
* * * * *
13. In §40.187, revise paragraph (c)(2)(iv)(C) to read as follows:
§40.187 What does the MRO do with split specimen laboratory results?
* * * * *
(c) * * *
(2) * * *
(iv) * * *
(C) As the laboratory that tests the primary specimen to reconfirm the presence of the adulterant found in the split specimen and/or to determine that the primary specimen meets appropriate substitution criteria, report your result to the MRO using a copy of Copy 1 of the CCF.
* * * * *
14. In §40.191, revise paragraph (d) introductory text to read as follows:
§40.191 What is a refusal to take a DOT drug test, and what are the consequences?
* * * * *
(d) As a collector or an MRO, when an employee refuses to participate in the part of the testing process in which you are involved, you must terminate the portion of the testing process in which you are involved, document the refusal on the CCF (including, in the case of the collector, printing the employee's name on Copy 2 of the CCF), immediately notify the DER by any means that ensures that the refusal notification is immediately received. As a referral physician ( e.g., physician evaluating a “shy bladder” condition or a claim of a legitimate medical explanation in a validity testing situation), you must notify the MRO, who in turn will notify the DER.
* * * * *
15. In §40.193, revise paragraph (b)(3) to read as follows:
§40.193 What happens when an employee does not provide a sufficient amount of specimen for a drug test?
* * * * *
(b) * * *
(3) As the collector, you must send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or the next business day.
* * * * *
16. In §40.205, revise paragraphs (b)(1) and (2) to read as follows:
§40.205 How are drug test problems corrected?
* * * * *
(b) * * *
(1) If the problem resulted from the omission of required information, you must, as the person responsible for providing that information, supply in writing the missing information and a statement that it is true and accurate. For example, suppose you are a collector, and you forgot to make a notation on the “Remarks” line of the CCF that the employee did not sign the certification. You would, when the problem is called to your attention, supply a signed statement that the employee failed or refused to sign the certification and that your statement is true and accurate. You must supply this information on the same business day on which you are notified of the problem.
(2) If the problem is the use of a non-Federal form or an expired Federal form, you must provide a signed statement ( i.e., a memorandum for the record). It must state that the incorrect form contains all the information needed for a valid DOT drug test, and that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control. The statement must also list the steps you have taken to prevent future use of non-Federal forms or expired Federal forms for DOT tests. For this flaw to be corrected, the test of the specimen must have occurred at an HHS-certified laboratory where it was tested consistent with the requirements of this part. You must supply this information on the same business day on which you are notified of the problem.
* * * * *
17. In §40.225, revise paragraph (a) and add paragraphs (d) and (e) to read as follows:
§40.225 What form is used for an alcohol test?
(a) The DOT Alcohol Testing Form (ATF) must be used for every DOT alcohol test. The ATF must be a three-part carbonless manifold form or an electronic ATF that meets the requirements of paragraph (d) of this section. The ATF is found in appendix G to this part. You may view this form on the ODAPC website ( https://www.transportation.gov/odapc ).
* * * * *
(d) As an employer, you may use an electronic ATF that meets the following requirements:
(1) The electronic ATF must be identical in form and content to the ATF found in appendix G to this part.
(2) The electronic ATF must meet the requirements of §40.4(d).
(3) The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT.
(4) If an EBT provides a separate printout of confirmation test results (see §40.253(g)), the electronic ATF must include that separate printout.
(e) As an employer, BAT, or STT using an electronic ATF, you must establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form.
18. In §40.255, revise paragraph (a)(5)(i) to read as follows:
§40.255 What happens next after the alcohol confirmation test result?
(a) * * *
(5) * * *
(i) You may transmit the results using Copy 1 of the ATF, in person, by telephone, or by electronic means. In any case, you must immediately notify the DER of any result of 0.02 or greater by any means that ensures the result is immediately received by the DER. You must not transmit these results through C/TPAs or other service agents.
* * * * *
19. In §40.261, revise paragraph (c)(1) to read as follows:
§40.261 What is a refusal to take an alcohol test, and what are the consequences?
* * * * *
(c)(1) As a BAT or an STT, or as the physician evaluating a “shy lung” situation, when an employee refuses to test as provided in paragraph (a) of this section, you must terminate the portion of the testing process in which you are involved, document the refusal on the ATF (or in a separate document which you cause to be attached to the form), immediately notify the DER by any means that ensures the refusal notification is immediately received. You must make this notification directly to the DER (not using a C/TPA as an intermediary).
* * * * *
20. In §40.271, revise paragraph (b)(2) to read as follows:
§40.271 How are alcohol testing problems corrected?
* * * * *
(b) * * *
(2) If the problem is the use of a non-DOT form, you must, as the person responsible for the use of the incorrect form, certify in writing that the incorrect form contains all the information needed for a valid DOT alcohol test. You must also provide a signed statement that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control, and the steps you have taken to prevent future use of non-DOT forms for DOT tests. You must supply this information on the same business day on which you are notified of the problem.
* * * * *
21. In §40.365, revise paragraphs (b)(13) and (14) and add paragraph (b)(15) to read as follows:
§40.365 What is the Department's policy concerning starting a PIE proceeding?
* * * * *
(b) * * *
(13) For any service agent, directing or recommending that an employer fail or refuse to implement any provision of this part;
(14) With respect to noncompliance with a DOT agency regulation, conduct that affects important provisions of Department-wide concern ( e.g., failure to properly conduct the selection process for random testing); or
(15) For a service agent, failing to provide or maintain a secure/confidential electronic system. PART 199—DRUG AND ALCOHOL TESTING
22. The authority citation for part 199 continues to read as follows:
Authority:
49 U.S.C. 5103, 60102, 60104, 60108, 60117, and 60118; 49 CFR 1.53.
23. In §199.3:
a. Designate the introductory text as paragraph (b); and
b. Add paragraph (a).
The addition reads as follows:
§199.3 Definitions.
(a) Terms used in this part have the same meaning as in 49 CFR 40.3.
* * * * *
24. Add §199.4 to read as follows:
§199.4 Electronic documents, records, and signatures.
Electronic documents, records, and signatures may be used to comply with this part provided they meet the requirements specified in 49 CFR part 40.
25. In §199.117, revise paragraph (a) introductory text to read as follows:
§199.117 Recordkeeping.
(a) Each operator shall keep the records in paragraphs (a)(1) through (5) of this section for the periods specified by this section or for the periods specified by 49 CFR part 40, whichever is greater; and will permit access to the records as provided by §190.203.
* * * * *
26. In §199.119, revise paragraph (a) to read as follows:
§199.119 Reporting of anti-drug testing results.
(a) Each large operator (having more than 50 covered employees) must submit an annual Management Information System (MIS) report to PHMSA of its anti-drug testing using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.
* * * * *
27. In §199.227, revise paragraph (b) introductory text to read as follows:
§199.227 Retention of records.
* * * * *
(b) Period of retention. Each operator shall maintain the records in accordance with the following schedule or for the periods specified by 49 CFR part 40, whichever is greater:
* * * * *
28. In §199.229, revise paragraph (a) to read as follows:
§199.229 Reporting of alcohol testing results.
(a) Each large operator (having more than 50 covered employees) must submit an annual MIS report to PHMSA of its alcohol testing results using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.
* * * * *
Signed on: Thursday, October 3, 2024.
Pete Buttigieg,
Secretary of Transportation.
[FR Doc. 2024-23427 Filed 10-11-24; 8:45 am]
BILLING CODE 4910-9X-P
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DOT modes & testing: Different inputs, same result

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Most Recent Highlights In Environmental
NewsIndustry NewsCriteria Air PollutantsEnvironmental Protection Agency (EPA)CAA ComplianceEnvironmentalIn-Depth ArticleFocus AreaEnglishAir PermittingAir ProgramsStationary Emission SourcesUSA
2026-07-29T05:00:00Z
EPA updates preconstruction permitting guidance: What are the impacts on major sources?
Where there’s construction, there are permits, and where there are permits, there are usually delays. For major construction projects in areas with poor air quality, the delay could be due to emission credits. New federal guidance, however, may help reduce those delays.
The Environmental Protection Agency (EPA) recently released guidance clarifying that Nonattainment New Source Review (NNSR) preconstruction permits may be issued to applicants before they obtain the required offsetting emission reduction credits (ERCs) if certain conditions are met.
The new guidance for permitting authorities (usually state or local air agencies) is a change in the agency’s recommended approach, designed to help prevent preconstruction permitting delays for applicants that haven’t yet formally secured ERCs. So, what does this mean for facilities? Let’s take a look!
Which construction projects could be affected?
EPA’s new guidance impacts construction projects in nonattainment areas. These are areas where emissions exceed the National Ambient Air Quality Standards (NAAQS) for any of the six regulated criteria air pollutants.
You need an NNSR permit to build a new major stationary source or make major modifications to an existing major stationary source if:
- The new or modified source is located in a nonattainment area, and
- The new or modified source emits or has the potential to emit a regulated pollutant in amounts that meet the applicable major source or major modification thresholds.
You must obtain an NNSR permit before construction begins. NNSR permits can be issued only if the applicant meets certain conditions, one of which is meeting emission offset requirements.
What are emission offsets?
Emission offsets are reductions in emissions from existing sources that can be used to compensate for emissions from a new or modified source. The Clean Air Act requires new and modified major sources to offset emissions by obtaining sufficient ERCs from existing sources located in the same nonattainment area.
In other words, a new or modified major source must get enough credits from existing nearby sources to cover the total amount of emissions that the facility will add to the area.
How does the guidance impact permitting?
EPA’s previous guidance recommended that NNSR permits generally shouldn’t be issued until ERCs are actually secured. As a result, permitting agencies require applicants to obtain ERCs before issuing an NNSR permit to start construction on a facility, even if the facility won’t immediately begin operations.
Guidance on Clean Air Act Nonattainment New Source Review Emissions Offsets (ERC guidance), issued by EPA on July 1, 2026, changes the agency’s recommended approach. It clarifies that permitting authorities may issue NNSR permits before applicants specifically secure the required ERCs if the permit contains:
- A federally enforceable commitment by the permit applicant to obtain the needed ERCs before starting operations, and
- An express ban on starting operations until the required ERCs are obtained with appropriate permit restrictions on the sources providing the ERCs.
What’s the possible impact on facilities?
Permitting authorities that apply ERC guidance to permitting decisions can issue NNSR permits to qualifying sources before they secure ERCs. This would allow applicants to start construction on or modifications to a major source without delay, provided the enforceable permit conditions are met.
Here's an example:
A business is ready to build a manufacturing plant in a nonattainment area, but operations at the new facility won’t begin until a year after construction is complete.
Under previous guidance, the business couldn’t begin construction on the manufacturing plant until it formally secured the required ERCs upfront for operations that won’t start until a year after the facility is complete.
EPA’s ERC guidance would allow the permitting authority to issue the business an NNSR permit before it obtains the ERCs. That means the business could build the manufacturing plant right away and then secure the ERCs later, closer to the time the facility starts operating.
Keep these points in mind!
Consider the following when determining how EPA’s updated NNSR policy may impact your construction project:
- The ERC guidance is nonbinding, meaning that permitting authorities aren’t required to implement the guidance. Permitting authorities can still require applicants to secure ERCs before issuing NNSR permits.
- Facilities may be able to start construction without first securing ERCs, but facilities can’t begin operating until they secure the required ERCs.
- Most NNSR permits are issued on a state or local level. Confirm the specific requirements that apply to your major source construction project with the relevant state or local permitting authority.
Key to remember: EPA’s guidance allows permitting authorities to issue preconstruction permits for new major sources and major modifications in nonattainment areas before the sources secure emission reduction credits.
NewsIndustry NewsIndustry NewsToxic Substances Control Act - EPAToxic Subtances Control Act - EPATSCA ComplianceToxic Substances - EPAEnvironmental Protection Agency (EPA)EnvironmentalEnglishFocus AreaUSA
2026-07-28T05:00:00Z
EPA extends PCE and CTC compliance deadlines
The Environmental Protection Agency (EPA) has extended the compliance dates of certain Workplace Chemical Protection Program (WCPP) requirements for perchloroethylene (PCE) and carbon tetrachloride (CTC) established under the Toxic Substances Control Act (TSCA).
Published on July 28, 2026, EPA’s final rule changes specific compliance dates but doesn’t alter the underlying WCPP requirements or the agency’s determination that PCE and CTC present unreasonable risks.
Who’s impacted?
The revised deadlines affect facilities subject to the TSCA PCE and CTC risk management rules finalized in 2024. These include entities that manufacture (including import), process, distribute in commerce, use, or dispose of:
- PCE,
- CTC, or
- Products containing PCE or CTC.
What are the new PCE and CTC compliance dates?
EPA’s final rule extends compliance deadlines for various WCPP requirements, including:
- Conducting initial monitoring,
- Meeting the existing chemical exposure limit (ECEL),
- Establishing a regulated area,
- Providing any required respiratory personal protective equipment (PPE) and establishing a respiratory PPE program,
- Implementing a workplace information and training program, and
- Establishing and implementing an exposure control plan (ECP).
Below is a summary of the new compliance deadlines.
| WCPP requirement | New compliance deadline | PCE applicability | CTC applicability |
|---|---|---|---|
| June 21, 2027 | Non-federal facilities | Non-federal facilities |
| September 20, 2027 | Non-federal facilities | Non-federal facilities |
| September 20, 2027 | Federal and non-federal facilities | Non-federal facilities |
| December 20, 2027 | Non-federal facilities | — |
* EPA maintains the CTC rule’s WCPP compliance date of December 3, 2027, for federal and non-federal facilities to establish and implement an ECP.
Key to remember: EPA has extended compliance dates for certain PCE and CTC Workplace Chemical Protection Program requirements into 2027.
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2026-07-24T05:00:00Z
New Mexico classifies AFFF as hazardous waste
Effective date: August 1, 2026
This applies to: Entities regulated by the New Mexico hazardous waste regulations
Description of change: The New Mexico Hazardous Waste Bureau adopted amendments and a new rule to regulate aqueous film-forming foam (AFFF) containing intentionally added per- and polyfluoroalkyl substances (PFAS).
Changes include:
- Classifying AFFF with intentionally added PFAS as a hazardous waste (subject to New Mexico’s hazardous waste regulations); and
- Establishing regulations for AFFF with intentionally added PFAS, including:
- A periodic inventory of the substance,
- Restricting the use of AFFF to emergency purposes only, and
- Requiring cleanup of discarded AFFF according to the New Mexico Hazardous Waste Act regulations.
Note that the operational restrictions (20.13.3 NMAC) take effect on August 1, 2026, and the disposal and cleanup rules (20.4.1) take effect on December 1, 2026.
Related state info: Hazardous waste generators — New Mexico
NewsGreenhouse GasesAir EmissionsChange NoticesChange NoticeColoradoCAA ComplianceEnvironmentalFocus AreaEnglishAir ProgramsAir Programs
2026-07-24T05:00:00Z
Colorado revises annual emissions reporting requirements
Effective date: July 15, 2026
This applies to: Sources subject to Regulations 3 and 7 annual reporting requirements
Description of change: The Colorado Air Quality Control Commission amended Regulation Numbers 3 and 7. The revisions:
- Remove the duplicate greenhouse gas (GHG) air pollutant emission notice (APEN) reporting requirement for sources required by Regulation Number 22 to report GHG emissions annually;
- Streamline reporting requirements for annual estimated emissions reports required by Regulation Numbers 3 and 7 (for certain non-oil and gas sector sources and for upstream and midstream oil and gas sector sources, respectively) by specifying that their Emissions Reporting Notices (ERNs) will satisfy the requirements to submit revised APENs due to a change in actual emissions or solely before expiration;
- Increase existing fees for APEN submissions, annual emissions, and application processing required by Regulation Number 3; and
- Add a fee for filing ERNs required by Regulation 7 on a per-emission-point basis (with plans to require fees from all annual reporters eventually).
Streamlined reporting begins in 2027 for Regulation Number 7 annual emissions reports for calendar year 2026 emissions. The ERN filing fee for Regulation Number 7 reporters starts with the ERN filed in 2027 for calendar year 2026 emissions.
Related state info: Clean air operating permits state comparison
NewsHazardous WasteWaste HandlersChange NoticesChange NoticeWasteWaste/HazWasteWaste ManagementEnvironmentalNevadaEnglishFocus Area
2026-07-24T05:00:00Z
Nevada revises hazardous waste recycling rules
Effective date: July 1, 2026
This applies to: Facilities and mobile units that manage recyclable materials classified as hazardous waste or hazardous secondary materials
Description of change: The Nevada State Environmental Commission adopted amendments to the hazardous waste recycling program regulations. Changes include:
- Establishing one regulatory regime for facilities managing recyclable materials classified as either hazardous waste or hazardous secondary materials;
- Exempting certain facilities or mobile units from the requirement to obtain a written determination from the Department of Conservation and Natural Resources before construction and providing that such facilities must comply with certain federal requirements, local zoning requirements if applicable, reporting and notification requirements, and other regulations;
- Exempting certain facilities (if they’re subject to local zoning requirements) from prohibitions on the locations where new or expanding stationary facilities that manage hazardous waste may be built; and
- Establishing an annual $5,000 fee for:
- A written determination issued to new facilities or mobile units that the facilities or units will operate for recycling hazardous waste; and
- Existing facilities that recycle certain hazardous waste and are subject to specific federal recycling requirements.
Most Recent Highlights In Transportation
NewsPesticidesPesticidesChange NoticesChange NoticeEnvironmentalPesticide ManagementEnglishMichiganFocus AreaPesticides
2026-07-24T05:00:00Z
Michigan updates fertilizer bulk storage requirements
Effective date: July 2, 2026
This applies to: Commercial bulk fertilizer storage facilities
Description of change: The amendments increase requirements related to physical and structural redundancy, maintenance, and recordkeeping. The rules align with the standards of the Association of American Plant Food Control Officials (AAPFCO) and the regulations established by similarly situated states. Some of the changes include:
- Requiring every storage container to have a liquid level gauging device;
- Requiring storage containers and appurtenances to be fenced, locked, or otherwise secured to protect against vandalism or unauthorized access that could result in a discharge; and
- Allowing alternative diking for large storage tanks that use double steel wall systems.
Further, the rules require the Michigan Department of Agriculture and Rural Development to preapprove the construction of new or the modification of existing containment systems and operational areas.
NewsIndustry NewsEnglishEnvironmental Management SystemsISO 14001Environmental Management SystemsEnvironmentalIn-Depth ArticleLifecycle AnalysisEnvironmental Management SystemsFocus AreaUSA
2026-07-14T05:00:00Z
ISO 14001:2026 arrives: Key changes for environmental management systems
Environmental management has changed significantly since ISO 14001 was last revised in 2015. Climate-related risks, resource constraints, supply chain challenges, and stakeholder expectations have reshaped how organizations manage environmental issues. In response, the International Organization for Standardization (ISO) released ISO 14001:2026, the first major update to the environmental management system (EMS) standard in over a decade.
The revised standard doesn't change the purpose of ISO 14001. Organizations will continue to use an EMS to identify environmental aspects, meet compliance obligations, manage environmental risks, and improve environmental performance. However, the new edition clarifies requirements and places greater emphasis on measurable environmental results. ISO says the revision is intended to better align EMS programs with today's environmental challenges. Organizations certified to ISO 14001 may need to update procedures, documentation, audits, and management reviews.
Why was the standard updated?
When ISO published ISO 14001:2015, many organizations focused primarily on regulatory compliance. While compliance remains a core component of an EMS, environmental managers today face a broader range of issues. Climate impacts, resource availability, supply chain disruptions, and stakeholder expectations can all affect environmental planning and performance. Rather than creating an entirely new framework, the 2026 version largely builds on concepts that already existed in the 2015 edition while expanding and clarifying expectations.
Environmental context receives greater attention
A major theme of the revision is a stronger focus on organizational context. Organizations are expected to look beyond day-to-day compliance activities when identifying environmental risks and opportunities.
The revised standard emphasizes consideration of environmental conditions that may affect the EMS, including climate-related concerns, biodiversity, ecosystem impacts, and natural resource availability. Organizations are expected to evaluate how external issues and stakeholder expectations may influence environmental objectives and planning.
For environmental managers, this may mean expanding annual EMS reviews to evaluate emerging environmental issues that could affect operations, compliance obligations, permit conditions, or environmental objectives.
Change management moves into the spotlight
The revised standard also introduces a more structured approach to managing change. Many organizations already evaluate environmental impacts when making operational changes, but those reviews are often informal.
ISO 14001:2026 expects organizations to plan, manage, and evaluate changes that may affect environmental performance. Examples include:
- Installing new equipment,
- Expanding production capacity,
- Changing raw materials,
- Modifying waste management practices,
- Switching suppliers, and
- Adding new products or processes.
This requirement should sound familiar to many environmental professionals. Operational changes can affect air emissions, waste generation, wastewater discharges, stormwater exposure, and permit applicability. A structured review process can help identify environmental impacts before changes are implemented.
Lifecycle thinking and supply chains gain importance
Lifecycle thinking was already part of ISO 14001:2015, but the revised standard places greater emphasis on it. Organizations are expected to consider environmental impacts throughout the lifecycle of products and services, including activities involving suppliers, contractors, and externally provided products and services.
This requirement doesn't mean organizations are responsible for every environmental impact within their supply chain. Rather, it encourages organizations to understand how purchasing decisions, outsourced activities, and supplier relationships may affect environmental performance.
For some organizations, this could mean greater emphasis on supplier evaluations, procurement procedures, contractor oversight, or product stewardship initiatives.
Leadership involvement becomes more visible
ISO 14001:2026 also strengthens expectations related to leadership accountability. Environmental management is no longer viewed solely as the responsibility of the environmental department.
The revised standard emphasizes visible leadership involvement and broader organizational participation. Environmental responsibilities may extend beyond EHS personnel to departments such as operations, purchasing, engineering, and management. Organizations will need to demonstrate that leadership is actively engaged in environmental planning, resource allocation, and performance evaluation activities.
What should organizations do now?
Although organizations have time to prepare for the transition, environmental managers may want to begin evaluating their programs now. Early reviews can help identify gaps and reduce the likelihood of surprises during future audits.
Questions organizations may want to consider include:
- Does the EMS adequately address climate, resources, and other emerging environmental issues?
- Is there a documented process for evaluating environmental impacts before operational changes are made?
- Are lifecycle considerations incorporated into purchasing and contractor management activities?
- Can leadership involvement be demonstrated through documented actions and decisions?
- Do environmental objectives show measurable performance improvements?
While ISO 14001:2026 is an evolution of the existing standard rather than a complete overhaul, organizations shouldn't assume existing EMS procedures will meet the revised expectations. Environmental managers may want to review how their systems address organizational context, change management, lifecycle considerations, and leadership involvement before their next audit.
Key to remember: For environmental professionals, the revised standard provides an opportunity to strengthen that connection and demonstrate the value that effective environmental management brings to the organization.
NewsWasteTSCA ComplianceWater ProgramsEnvironmental Protection Agency (EPA)CAA ComplianceWater ProgramsCWA ComplianceWaste/HazWasteEnglishAir ProgramsIndustry NewsIndustry NewsWasteEnvironmentalFocus AreaSARA ComplianceAir ProgramsUSA
2026-07-09T05:00:00Z
EPA releases 2026 regulatory agenda
The Environmental Protection Agency (EPA) published the 2026 Agenda of Regulatory and Deregulatory Actions on July 3, 2026. The agenda outlines the agency’s upcoming regulatory actions and their status in the rulemaking process. Many of the proposed and final rules support EPA’s continued deregulatory efforts.
Significant rulemaking on EPA’s docket includes the following:
- Proposing risk management regulations under the Toxic Substances Control Act (TSCA) for various chemical substances, such as formaldehyde, diisodecyl phthalate (DIDP), and diisononyl phthalate (DINP);
- Aligning the definition of “waters of the United States” with the Supreme Court’s Sackett v. Environmental Protection Agency (2023) decision, which narrowed the definition under the Clean Water Act;
- Finalizing the part 2 risk management regulations for asbestos, including use and associated disposal requirements for legacy asbestos, asbestos-containing talc, and asbestos fibers other than chrysotile;
- Repealing the Carbon Pollution Standards (CPS) that limit greenhouse gas emissions from fossil fuel-fired plants (or repealing a narrower set of requirements under the CPS); and
- Establishing a federal permitting program under the Resource Conservation and Recovery Act (RCRA) for the disposal of coal combustion residuals (CCR).
Additionally, EPA continues to conduct rulemaking related to per- and polyfluoroalkyl substances (PFAS), such as:
- Revising existing effluent limitations guidelines and standards (ELGs) to address PFAS discharges from PFAS manufacturing facilities and chromium electroplating facilities;
- Extending the compliance deadlines for Maximum Contaminant Levels established by the National Primary Drinking Water Regulations (NPDWRs) for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS); and
- Rescinding the NPDWRs for four PFAS.
This article highlights some of the major rules we’re monitoring closely. You can review the entire agenda to learn about all the rulemakings EPA plans to review, propose, and finalize. Please note that the agenda dates are tentative, indicating when the agency seeks to publish the rulemakings in the Federal Register.
| Final Rule Stage | |
| Projected publication date | Title |
| July 2026 | Reconsideration of the Greenhouse Gas Reporting Program |
| August 2026 | 1-Bromopropane (1-BP); Regulation Under the Toxic Substances Control Act (TSCA) |
| October 2026 | Revisions to Standards for the Open Burning/Open Detonation of Waste Explosives |
| October 2026 | Secondary Lead Smelting: National Emissions Standard for Hazardous Air Pollutants (NESHAP) Technology Review and Reconsideration |
| January 2027 | Listing of Specific PFAS as Hazardous Constituents |
| Proposed Rule Stage | |
| Projected publication date of notice of proposed rulemaking | |
| August 2026 | Improving Recycling and Management of Renewable Energy Wastes: Universal Waste Regulations for Solar Panels and Lithium Batteries |
| September 2026 | Effluent Limitations Guidelines and Standards for the Oil and Gas Extraction Category (40 CFR 435 Subpart E) |
| October 2026 | Effluent Limitations Guidelines and Standards for the Centralized Waste Treatment Category (40 CFR 437) |
| December 2026 | Clean Water Act Hazardous Substance Facility Response Plans; Amendment Reconsideration |
| December 2026 | National Emission Standards for Hazardous Air Pollutants: Stationary Combustion Turbines; Amendments |
| Pre-Rule Stage | |
| Projected publication date or other action | Title |
| January 2027 (final rule) | Risk Management Program, CAA Section 112(r)(7) (Section 610 Review) |
| August 2026 (begin review) | Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources (Section 610 Review) |
NewsAir QualityStationary Emission SourcesEnforcement and Audits - OSHAToxic Substances Control Act - EPAAir EmissionsSafe Drinking WaterTSCA ComplianceWater ProgramsWater QualityMonthly Roundup VideoCAA ComplianceAir PermittingHazard CommunicationUSAEnglishHeat StressOSHA Violations and PenaltiesIndustry NewsHeat and Cold ExposureSafety & HealthToxic Substances - EPAGeneral Industry SafetyEnvironmentalFocus AreaWater MonitoringHazard CommunicationAir ProgramsExtreme Temperature PreparationVideo
EHS Monthly Round Up - June 2026
In this June 2026 roundup video, we'll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
OSHA 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 data released by the Bureau of Labor Statistics. 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.
OSHA updated its inspection guidance for the Hazard Communication standard. While the document is geared towards OSHA inspectors, it provides insights for chemical manufacturers, importers, distributors, and employers as to what the agency will look for during an inspection.
OSHA will hold a series of informal, virtual hearings on multiple proposed rules beginning August 19th. The majority relate to respiratory protection requirements for different chemical substances. All of the proposed rules were originally published in the Federal Register on July 1, 2025.
Nevada OSHA published a list of frequently asked questions related to its recently adopted heat illness rule. The state’s rule took effect April 29.
Turning to environmental news, EPA restored emergency-related affirmative defense provisions for Title V operating permits. This allows stationary sources to assert a regulatory affirmative defense for certain air emission violations caused by events beyond their control.
EPA released two proposed rules that would have major impacts on drinking water regulations for PFAS. The agency will accept comments on the proposals until July 20.
And finally, EPA now allows facilities to submit PCB annual reports electronically. Facilities can start with the upcoming report that’s due July 15.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
NewsIndustry NewsIndustry NewsPesticidesPesticide Registration and LabelingEnvironmental Protection Agency (EPA)EnvironmentalEnglishFocus AreaPesticidesUSA
2026-07-01T05:00:00Z
EPA sets MyPeST compliance reporting deadlines for bilingual pesticide labeling requirements
The Environmental Protection Agency (EPA) published instructions and deadlines for pesticide registrants to report compliance with bilingual labeling requirements in the MyPeST application. The first compliance reporting deadline is July 31, 2026, for pesticide products with the highest toxicity.
Who’s impacted?
Compliance reporting applies to registrants of pesticide products subject to the bilingual labeling requirements established by the Pesticide Registration Improvement Act of 2022 (PRIA 5) amendments to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
PRIA 5 requires all end-use pesticide product labels to provide Spanish translations of the human health and safety sections by including the translated sections directly on the label or providing a link via scannable technology or other readily accessible electronic methods to the translated sections. EPA allows certain antimicrobial and non-agricultural pesticide products to comply by providing access to Spanish-language Safety Data Sheets instead of direct label translations.
Compliance timelines are based on the type of pesticide and its toxicity category.
What’s required?
Pesticide registrants must report compliance with the PRIA 5 bilingual labeling requirements using EPA’s MyPeST app. The agency recently published detailed reporting instructions in the MyPeST Application User Guide (accessible in the MyPeST app).
EPA also established the following deadlines for reporting compliance in MyPeST:
| Pesticide product type | Bilingual labeling deadline | Compliance reporting deadline |
|---|---|---|
| Restricted use pesticides (RUPs) | December 29, 2025 | July 31, 2026 |
| Non-RUP agricultural products | ||
| Acute Toxicity Category I | December 29, 2025 | July 31, 2026 |
| Acute Toxicity Category II | December 29, 2027 | January 28, 2028 |
| Antimicrobials and non-agricultural products | ||
| Acute Toxicity Category I | December 29, 2026 | January 28, 2027 |
| Acute Toxicity Category II | December 29, 2028 | January 28, 2029 |
| All other pesticide products | December 29, 2030 | January 28, 2031 |
Most Recent Highlights In Safety & Health
NewsIndustry NewsEnvironmental Protection Agency (EPA)Oil Spill PreventionOil Spill PreventionEnvironmentalIn-Depth ArticleCWA ComplianceEnglishFocus AreaUSA
2026-06-30T05:00:00Z
Secondary containment alternative: Does your oil-filled operational equipment qualify?
Facilities that run like a well-oiled machine often rely on just that — operational equipment that stores and uses oil to function (like hydraulic systems). But wherever oil is stored, there’s always the possibility of a leak, and spilled oil can do serious harm, especially if it reaches water.
That’s where the Environmental Protection Agency’s (EPA’s) Spill Prevention, Control, and Countermeasure (SPCC) rule comes in. Usually, regulated facilities must equip oil-filled operational equipment with general secondary containment, which is designed to temporarily hold discharged oil until it can be properly cleaned up. However, some facilities may have another compliance option available.
EPA offers an alternative to secondary containment for qualified oil-filled operational equipment. Let’s take a look at the eligibility criteria and what the other method of compliance requires.
What’s oil-filled operational equipment?
EPA defines “oil-filled operational equipment” at 40 CFR 112.2. Generally, it refers to equipment that has one or more oil storage containers with oil that’s used solely to operate the equipment. Common examples are lubrication systems for pumps and compressors, machining coolant systems, circuit breakers, and electrical switches.
Does your facility have qualified equipment?
Only qualified oil-filled operational equipment is eligible for the alternative requirements to general secondary containment.
The SPCC rule considers oil-filled operational equipment to be qualified if it hasn’t had one discharge of oil exceeding 1,000 gallons or two discharges of oil exceeding 42 gallons each over the following time periods:
- If the facility has operated for at least 3 years, within any 12-month period in the 3 years before the SPCC Plan’s certification date; or
- If the facility has operated for less than 3 years, since becoming subject to the SPCC regulations.
Take note! When determining whether your facility’s oil-filled operational equipment is eligible under federal standards:
- Don’t count oil discharges caused by natural disasters, acts of war, or terrorism; and
- Don’t count the total amount of oil spilled, only the amount that reaches navigable waters or adjoining shorelines.
What about oil-filled manufacturing equipment?
The SPCC rule distinguishes between oil-filled manufacturing equipment and oil-filled operational equipment. Oil-filled manufacturing equipment stores oil only as a supporting element for conducting a mechanical or chemical operation to create or modify a product. It typically involves a flow-through process in which oil continuously moves through the equipment. Examples of this type of equipment include reaction vessels, mixing tanks, and distillation columns.
Because it’s defined independently under the SPCC rule, oil-filled manufacturing equipment isn’t eligible for the alternative compliance option available to qualified oil-filled operational equipment.
What are the alternative measures?
Instead of providing secondary containment for qualified oil-filled operational equipment, facilities may choose to comply with the alternative requirements at 112.7(k), which include:
- Establishing and documenting an inspection or a monitoring program to detect equipment failures and discharges; and
- Adding to the SPCC Plan:
- An oil spill contingency plan according to the requirements of Part 109; and
- A written commitment of the resources (manpower, equipment, and materials) needed to quickly control and remove any potentially harmful quantities of discharged oil.
Take note! If your business must submit a facility response plan (FRP) under 112.20, the oil spill contingency plan and written commitment requirements don’t apply since your FRP already contains these elements.
Why should my facility consider the alternative compliance option?
The alternative requirements to general secondary containment don’t require facilities to prepare an impracticability determination for qualified oil-filled operational equipment.
The impracticability determination provisions at 112.7(d) impose more requirements for facilities that use alternative measures to secondary containment for unqualified equipment. In addition to meeting the same requirements for qualified oil-filled operational equipment, facilities must have the oil spill contingency plan certified by a Professional Engineer (unless self-certifying as a qualified facility). They also must:
- Describe in the SPCC Plan the reasons such measures aren’t practicable, and
- Conduct periodic integrity tests of bulk storage containers and periodic integrity and leak tests of valves and piping.
Key to remember: The SPCC rule offers an alternative to general secondary containment requirements for qualified oil-filled operational equipment.
NewsGreenhouse GasesAir QualityExcavationsToxic Substances Control Act - EPAToxic Subtances Control Act - EPAPersonal Protective EquipmentAir EmissionsTSCA ComplianceExcavationsMonthly Roundup VideoMiningCAA ComplianceUSAEnglishIndustry NewsSafety & HealthConstruction SafetyInfectious DiseasesCOVID-19General Industry SafetyGeneral Duty ClauseSpecialized IndustriesEnvironmentalFocus AreaRespiratory ProtectionMine SafetyGeneral Duty ClauseAir ProgramsVideo
EHS Monthly Round Up - August 2025
In this August 2025 roundup video, we'll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what’s happened over the past month!
OSHA extended the comment period for multiple proposed rules it published on July 1. Stakeholders now have an extra 60 days, until November 1, to comment. Impacted rules include those for respiratory protection, construction illumination, COVID-19, and the General Duty Clause.
OSHA is expanding its Voluntary Protection Programs to help employers develop strong safety programs and lower injury rates. To participate, employers must submit an application to OSHA and undergo an onsite evaluation by a team of safety and health professionals.
Following a series of recent trench collapses, OSHA urges employers to take steps to protect workers. Trench collapses can be prevented by sloping or benching trench walls at an angle, shoring trench walls with supports, and shielding walls with trench boxes. More information can be found on OSHA’s website.
The Mine Safety and Health Administration launched a webpage for its new Compliance Assistance in Safety and Health, or CASH, program. The agency anticipates a surge in domestic mining productivity and seeks to proactively provide miners and mine operators with compliance assistance materials.
Turning to environmental news, EPA proposes challenges to California’s Clean Truck Check program. The program aims to reduce emissions of nitrogen oxides and particulate matter for heavy-duty vehicles. EPA supports the regulation as it applies to California-registered vehicles but disapproves the regulation as it applies to out of state and out of country vehicles. Stakeholders have until September 25 to comment on the proposal.
On August 14, EPA released the July 2025 nonconfidential TSCA Inventory of chemical substances manufactured, processed, or imported in the U.S. The Inventory contains over 86 thousand chemicals, nearly half of which are in active use. The next inventory update is planned for late 2026.
And finally, EPA proposes to rescind the 2009 Endangerment Finding and repeal greenhouse gas emissions for new motor vehicles and vehicle engines. The agency will accept comments on the proposal through September 15.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
NewsHazardous WasteGreenhouse GasesWaste ManifestsWater ProgramsFall ProtectionMonthly Roundup VideoFall Protection for ConstructionCAA ComplianceUSAWater ProgramsWaste/HazWasteEnglishIndustry NewsSafety & HealthConstruction SafetyGeneral Industry SafetyWasteEnvironmentalFocus AreaAir ProgramsVideo
EHS Monthly Round Up - September 2025
In this September 2025 roundup video, we'll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what’s happened over the past month.
OSHA released its Spring 2025 regulatory agenda on September 4. Many rulemakings have been pushed into the fourth quarter of 2025 and the first half of 2026, while a few have been removed from the agenda altogether. These include Infectious Diseases, Blood Lead Level for Medical Removal, and the Musculoskeletal Disorders Column on the OSHA 300 log.
Three rules moved into the long-term actions category – Workplace Violence in Health Care and Social Assistance, Cranes and Derricks in Construction, and Process Safety Management and Prevention of Major Chemical Accidents. The proposed rule stage saw an influx of new entries, most of which were published in the July 1 Federal Register.
The Standards Improvement Project, slated for proposal in May 2026, intends to “remove, modernize, or narrow duplicative, unnecessary, or overly burdensome regulatory provisions.”
OSHA renewed its alliance with the National Waste and Recycling Association and the Solid Waste Association of North America. The partnership will focus on safety issues such as transportation hazards; slips, trips, and falls; needlestick and musculoskeletal injuries; and health issues associated with lithium battery hazards in waste/recycling collection and processing.
For the 15th year in a row, fall protection for construction topped OSHA’s list of top 10 violations. In fiscal year 2024, there were 5,914 recorded fall protection violations, down from 7,271 in fiscal year 2023. The standards that round out the top 10 remain unchanged, with a shift in some of the rankings.
Turning to environmental news, EPA proposes to eliminate the Greenhouse Gas Reporting Program requirements for all source categories except the petroleum and natural gas systems category. The agency also proposes to suspend compliance obligations for covered facilities until 2034. A public hearing was held October 1 and stakeholders have until November 3 to comment on the proposal.
Hazardous waste handlers may continue to use 5-paper copy manifest forms. EPA announced it will accept these forms from entities regulated by the Resource Conservation and Recovery Act, or RCRA, until further notice. The agency will give a 90-day notice before it plans to stop accepting the 5-copy forms.
And finally, EPA published its Spring 2025 regulatory agenda on September 4. The agenda outlines the agency’s upcoming regulatory actions and their status in the rulemaking process. Major updates on the docket include those for greenhouse gases, risk management rules, and the Renewable Fuel Standards for 2026 and 2027.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
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EHS Monthly Round Up - January 2025
In this January 2025 monthly roundup video, we'll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. There’s a lot going on, so let’s get started!
As happens at the start of most incoming presidential administrations, a freeze has been placed on all regulatory activity at the federal level, giving the new administration time to review agencies’ plans. The Office of Management and Budget, which must approve most rulemaking activities, has sent numerous pending rules back to the agencies for review. In addition, OSHA withdrew its infectious diseases proposed rule and its COVID-19 in healthcare rule prior to the inauguration.
OSHA’s penalties increased on January 15. The maximum penalty amounts for serious and other-than-serious violations increased to $16,550. For willful or repeated violations, the maximum penalty increased to $165,514 per violation.
OSHA updated its directive on injury and illness recordkeeping policies and procedures. While it’s intended for OSHA compliance officers, employers can use the information to help with recordkeeping compliance.
Fewer workers died on the job in 2023, as fatal work injuries decreased 3.7 percent from 2022. Transportation incidents remained the most frequent type of fatal event, accounting for over 36 percent of all occupational fatalities.
California’s Occupational Safety and Health Standards Board voted to adopt a permanent silica standard. If approved, it would extend and strengthen the state’s emergency temporary standard, which was put in place in December 2023.
The National Institute for Occupational Safety and Health updated its List of Hazardous Drugs in Healthcare Settings. This is a resource for employers and employees in identifying drugs that are hazardous to the health and safety of those who handle them.
Turning to environmental news, EPA released the biannual update of the nonconfidential TSCA inventory. The inventory helps facilities determine their regulatory requirements for the chemicals they use or plan to use.
And finally, EPA added new Management Method Codes to describe how hazardous waste will be managed after temporary storage and transfer. As of January 1st, hazardous waste handlers must use the codes on the Biennial Report Waste Generation and Management forms.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
NewsProcess Safety ManagementEnforcement and Audits - OSHAToxic Substances Control Act - EPAWasteErgonomicsMonthly Roundup VideoUSAWaste/HazWasteEnglishErgonomicsIndustry NewsEnforcement and Audits - OSHASafety & HealthToxic Substances - EPAGeneral Industry SafetyWasteEnvironmentalHazardous Materials Safety - OSHAFocus AreaVideo
EHS Monthly Round-Up - August 2024
In this August 2024 roundup, we'll review the most impactful environmental, health, and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental, health, and safety news. Please view the content links in the transcript for more information about the topics I’ll be covering today. Let’s get started!
Two State Plan agencies allegedly provided advance notice of workplace inspections to employers, a practice that’s prohibited under the Occupational Safety and Health Act. Now, lawmakers have requested that the Department of Labor’s acting secretary address the allegations and explain what challenges OSHA faces when monitoring and enforcing State Plan compliance.
A recent study shows jobs in agriculture, forestry, fishing, and hunting are among California’s most dangerous, accounting for the highest number of fatalities among full-time workers. Transportation and utilities jobs ranked second and construction was third.
Remote isolation of process equipment can quickly stop the release of hazardous materials, which can help prevent fatalities and injuries, limit facility damage, and better protect communities and the environment. A U.S. Chemical Safety Board study explores their use and makes recommendations for their utilization in chemical facilities.
A National Safety Council report explores the role of diversity, equity, and inclusion on work-related musculoskeletal disorders, or MSDs. MSDs are the most common workplace injury and often lead to worker disability, early retirement, and employment limitations.
And finally, turning to environmental news, EPA published a final rule that revises its hazardous waste export manifest regulations. All hazardous waste shipments and manifest-related reports will be managed electronically through the agency’s e-Manifest program.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
Most Recent Highlights In Human Resources
NewsIndustry NewsEnglishIn-Depth ArticleCAA ComplianceSustainabilityEnvironmental Management SystemsCWA ComplianceEnvironmentalWaste/HazWasteSustainabilityESG (Environmental, Social, and Governance)Focus AreaUSA
2026-06-26T05:00:00Z
Multimedia inspections are back: How to prepare for comprehensive EPA and state audits
Regulators have returned to routine, in-person inspections, and many are no longer limited to a single program. The Environmental Protection Agency (EPA) and state agencies are again conducting multimedia inspections that review air, water, and hazardous waste compliance in one visit. For facilities, this shift raises the stakes. An issue in one program can quickly lead inspectors into others, especially when records or operations don't align.
Most inspectors now arrive with background data already reviewed. Electronic submissions, air reports, discharge monitoring reports, and hazardous waste filings are compared against what they see on-site. When numbers, dates, or practices don't match, the scope of the inspection often expands.
What inspectors are really evaluating
While documents are important, inspectors focus on whether procedures match actual operations. They will often start with a walk-through of the facility, tracing how materials move through production and become emissions, discharges, or wastes.
For example:
- Air compliance may be checked by reviewing fuel use, hours of operation, or control device logs;
- Stormwater compliance often involves visual checks for exposed materials and conditions of controls; and
- Hazardous waste inspections typically focus on labeling, container condition, and accumulation practices.
The common thread is consistency. If a plan says one thing but operators do another, it's likely to result in a finding.
Common gaps seen during multimedia inspections
Across industries, several issues appear repeatedly:
- Records that don't match across programs (e.g., waste logs versus manifests);
- Missing or incomplete inspection logs for air or stormwater systems;
- Assumptions about exemptions without supporting documentation;
- Satellite accumulation areas managed informally outside environmental oversight; and
- Housekeeping issues that create unintended stormwater exposure.
Many of these aren't complex violations. They're breakdowns in communication, training, or follow-through.
A practical way to prepare
Facilities can improve readiness by conducting an internal, cross-media review that mirrors an actual inspection. This is more effective than reviewing each program in isolation.
Start with a process-based walk-through:
- Identify where raw materials enter the facility.
- Follow how they're used, stored, and handled.
- Note where wastes, emissions, or discharges are generated.
- Confirm how each is managed and documented.
At each step, ask two questions:
- Is this activity reflected accurately in our records and plans?
- Would an operator explain it the same way it's written?
This approach often reveals gaps that aren't obvious during a desk review.
A recent case: How one issue expands the scope
At a mid-sized manufacturing facility, inspectors began with a routine hazardous waste review. They noticed that waste logs showed periodic disposal of solvent residues, but there were no related air records for emissions tied to cleaning operations.
This led inspectors to review the facility’s air permit assumptions. They found that solvent use had increased over time, but the facility hadn't updated its potential-to-emit calculations. What started as a simple waste review expanded into an air applicability concern.
The facility ultimately faced findings in both programs, not because of a single major violation, but because information didn't align across systems.
Strengthening compliance across programs
Preparation doesn't require building new systems. It requires making sure existing ones are aligned and consistently followed.
Focus on:
- Clear ownership of compliance tasks across departments;
- Regular cross-checks between records (air, water, waste);
- Training staff on how their daily tasks affect compliance; and
- Maintaining documentation that supports assumptions, exemptions, and limits.
Facilities that treat compliance as a connected system, not separate programs, are better positioned during inspections.
Key to remember: A multimedia inspection looks for consistency across air, water, and waste programs, not just isolated compliance. If your records and operations tell the same story, you're far less likely to face expanded scrutiny.
NewsHazardous WasteIndustry NewsWaste GeneratorsEnglishWasteEnvironmentalIn-Depth ArticleWaste/HazWasteFocus AreaUSA
2026-06-25T05:00:00Z
Hazardous waste episodic events: What to do when a bad month happens
Every generator has that month. A tank clean-out gets scheduled; a forklift punctures a tote, and suddenly you've generated way more hazardous waste than you normally would. If you're a Very Small Quantity Generator (VSQG) or Small Quantity Generator (SQG), that one bad month could technically bump you into Large Quantity Generator (LQG) status, potentially subjecting the facility to LQG requirements such as contingency planning, personnel training, and biennial reporting.
The good news is that EPA built in an escape hatch. The 2016 Generator Improvements Rule added 40 CFR Part 262, Subpart L (the "episodic event" provision), which lets you keep your normal generator category for that month, if you follow the rules in 40 CFR 262.232 exactly.
Scenario 1: The planned tank clean-out
Picture a metal finishing shop that's normally an SQG, generating about 400 kg/month of spent plating solution. They finally get around to cleaning out an old process tank that's been sitting idle for three years. That clean-out produces about 1,800 kg of sludge in one shot and enough to push them into LQG numbers for the month.
Since this is something the facility planned and scheduled for, it's a planned episodic event. Here's what the employer would need to do:
- Notify EPA (or the delegated state agency) at least 30 calendar days before the clean-out starts, using EPA Form 8700-12. Include the start/end dates, why the event is happening, estimated waste types and quantities, and a 24-hour emergency contact.
- Double-check the facility's EPA ID number to make sure it is current.
- Stage the waste properly with compliant containers or tanks and labeled with the episodic event start date.
- Get it manifested and shipped off-site within 60 calendar days of the start date.
- Hang onto every record including the notification, manifests for 3 years after the event ends.
Scenario 2: The unplanned spill
Next, picture a packaging plant. They are a VSQG generating around 80 kg/month. They have a forklift punch a hole in a 275-gallon tote of listed solvent and by the time cleanup is done, they're looking at about 900 kg of contaminated absorbent and solvent residue. Nobody planned this. It's not part of normal operations. That makes it an unplanned episodic event. Here is what they should do:
- They have 72 hours to notify EPA or the state by phone, email, or fax. There will be no time to fill out paperwork first.
- Follow that up by submitting EPA Form 8700-12 after the fact, documenting what happened since you couldn't give advance notice.
- Keep the spill cleanup waste separate from your routine waste streams and label it with the episodic start date.
- The same 60-day shipping window and 3-year recordkeeping requirement apply here too.
The things you can't skip
Whether the event is planned or unplanned, there are a handful of conditions that apply across the board and missing any one of them could cost you the episodic event relief entirely.
- One event per year, period. Both VSQGs and SQGs get exactly one episodic event a year unless they petition the Regional Administrator under 40 CFR 262.233 for a second. That second one must be the opposite type, so if your first was planned, the next must be unplanned.
- The clock doesn't wait. Exactly 30 days out for planned and 72 hours for unplanned are required. Miss either window or you lose the relief entirely, meaning full LQG status kicks in for that period.
- The 60-day shipping clock starts on day one of the event, not when you send the notification, so make sure to track it immediately.
- Manifest the waste properly. Episodic waste can ship under the standard Subpart B manifest rules, even in the same load as your regular waste.
- Write everything down. Three years of solid records such as dates, causes of event, quantities, and where it went is what separates a clean inspection from an enforcement headache.
Keys to remember: The episodic event provision rewards generators who plan, classify the event correctly, notify on time, ship within 60 days, and document everything for three years.
NewsGreenhouse GasesAir QualityAir EmissionsChange NoticesChange NoticeVirginiaCAA ComplianceEnvironmentalFocus AreaEnglishAir ProgramsAir Programs
2026-06-24T05:00:00Z
Virginia reinstates power plant CO2 budget program
Effective date: April 24, 2026
This applies to: Power plant owners
Description of change: The Virginia Department of Environmental Quality reinstated the Virginia CO2 Budget Trading Program Regulation, which implements the Regional Greenhouse Gas Initiative (RGGI). Participation in the RGGI was stopped in 2023, but the state will resume participation on July 1, 2026, the same date on which the compliance requirements take effect.
The regulation requires fossil fuel-fired units that serve an electricity generator with a capacity of 25 megawatts or more to obtain enough allowances to cover CO2 emissions, which they can purchase in the September and December RGGI auctions.
The department also adopted amendments to the regulations, including establishing a one-time 6-month control period from July 1, 2026, to December 31, 2026.
Related state info: Clean air operating permits state comparison
NewsMunicipal WastewaterChange NoticesChange NoticeWater ProgramsEnvironmentalCWA ComplianceEnglishFocus AreaNorth Carolina
2026-06-24T05:00:00Z
North Carolina approved revisions to wastewater discharge rules
Effective date: May 1, 2026
This applies to: Facilities with domestic wastewater discharges up to 2 million gallons per day
Description of change: The North Carolina Department of Environmental Quality (DEQ) adopted a rule that adds a permitting option to the National Pollutant Discharge Elimination System (NPDES) program for facilities with domestic wastewater discharges of up to 2 million gallons per day.
DEQ removed the ban on new or expanded discharges of oxygen-consuming waste when the 7Q10 and 30Q2 flows are both 0 for these facilities. In other words, it allows systems to discharge domestic wastewater to zero-flow receiving streams, provided the system:
- Meets qualifying criteria,
- Complies with specific effluent limits, and
- Uses low-energy methods before discharging wastewater to the receiving stream.
It’ll likely benefit areas where the cost of piping to a higher-flowing stream farther away is prohibitive.
NewsGroundwaterSafe Drinking WaterWater ProgramsWater QualityWater ProgramsCWA ComplianceEnglishWater PermittingMunicipal WastewaterChange NoticesChange NoticeWater ReportingIndustrial WastewaterEnvironmentalNew HampshireFocus Area
2026-06-24T05:00:00Z
New Hampshire updates sludge management rules
Effective date: May 15, 2026
This applies to: Owners and operators of drinking water and wastewater treatment plants that generate sludge; land application sites; and facilities that treat, manage, or dispose of sludge
Description of change: The New Hampshire Department of Environmental Services amended sludge management rules. Major changes include:
- Reinstating 5-year site and facility permit renewals (instead of 10 years),
- Adding annual reporting requirements for sludge haulers (which already apply to septage haulers), and
- Requiring all applications to be submitted electronically.
The rule also codifies per- and polyfluoroalkyl substances (PFAS) sampling (implemented in 2019 for the sludge quality certificate program).
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2026-07-09T05:00:00Z
EPA releases 2026 regulatory agenda
The Environmental Protection Agency (EPA) published the 2026 Agenda of Regulatory and Deregulatory Actions on July 3, 2026. The agenda outlines the agency’s upcoming regulatory actions and their status in the rulemaking process. Many of the proposed and final rules support EPA’s continued deregulatory efforts.
Significant rulemaking on EPA’s docket includes the following:
- Proposing risk management regulations under the Toxic Substances Control Act (TSCA) for various chemical substances, such as formaldehyde, diisodecyl phthalate (DIDP), and diisononyl phthalate (DINP);
- Aligning the definition of “waters of the United States” with the Supreme Court’s Sackett v. Environmental Protection Agency (2023) decision, which narrowed the definition under the Clean Water Act;
- Finalizing the part 2 risk management regulations for asbestos, including use and associated disposal requirements for legacy asbestos, asbestos-containing talc, and asbestos fibers other than chrysotile;
- Repealing the Carbon Pollution Standards (CPS) that limit greenhouse gas emissions from fossil fuel-fired plants (or repealing a narrower set of requirements under the CPS); and
- Establishing a federal permitting program under the Resource Conservation and Recovery Act (RCRA) for the disposal of coal combustion residuals (CCR).
Additionally, EPA continues to conduct rulemaking related to per- and polyfluoroalkyl substances (PFAS), such as:
- Revising existing effluent limitations guidelines and standards (ELGs) to address PFAS discharges from PFAS manufacturing facilities and chromium electroplating facilities;
- Extending the compliance deadlines for Maximum Contaminant Levels established by the National Primary Drinking Water Regulations (NPDWRs) for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS); and
- Rescinding the NPDWRs for four PFAS.
This article highlights some of the major rules we’re monitoring closely. You can review the entire agenda to learn about all the rulemakings EPA plans to review, propose, and finalize. Please note that the agenda dates are tentative, indicating when the agency seeks to publish the rulemakings in the Federal Register.
| Final Rule Stage | |
| Projected publication date | Title |
| July 2026 | Reconsideration of the Greenhouse Gas Reporting Program |
| August 2026 | 1-Bromopropane (1-BP); Regulation Under the Toxic Substances Control Act (TSCA) |
| October 2026 | Revisions to Standards for the Open Burning/Open Detonation of Waste Explosives |
| October 2026 | Secondary Lead Smelting: National Emissions Standard for Hazardous Air Pollutants (NESHAP) Technology Review and Reconsideration |
| January 2027 | Listing of Specific PFAS as Hazardous Constituents |
| Proposed Rule Stage | |
| Projected publication date of notice of proposed rulemaking | |
| August 2026 | Improving Recycling and Management of Renewable Energy Wastes: Universal Waste Regulations for Solar Panels and Lithium Batteries |
| September 2026 | Effluent Limitations Guidelines and Standards for the Oil and Gas Extraction Category (40 CFR 435 Subpart E) |
| October 2026 | Effluent Limitations Guidelines and Standards for the Centralized Waste Treatment Category (40 CFR 437) |
| December 2026 | Clean Water Act Hazardous Substance Facility Response Plans; Amendment Reconsideration |
| December 2026 | National Emission Standards for Hazardous Air Pollutants: Stationary Combustion Turbines; Amendments |
| Pre-Rule Stage | |
| Projected publication date or other action | Title |
| January 2027 (final rule) | Risk Management Program, CAA Section 112(r)(7) (Section 610 Review) |
| August 2026 (begin review) | Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources (Section 610 Review) |
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2026-06-24T05:00:00Z
New Hampshire updates sludge management rules
Effective date: May 15, 2026
This applies to: Owners and operators of drinking water and wastewater treatment plants that generate sludge; land application sites; and facilities that treat, manage, or dispose of sludge
Description of change: The New Hampshire Department of Environmental Services amended sludge management rules. Major changes include:
- Reinstating 5-year site and facility permit renewals (instead of 10 years),
- Adding annual reporting requirements for sludge haulers (which already apply to septage haulers), and
- Requiring all applications to be submitted electronically.
The rule also codifies per- and polyfluoroalkyl substances (PFAS) sampling (implemented in 2019 for the sludge quality certificate program).
NewsGroundwaterToxic/Hazardous Substance ReleasesCERCLA, SARA, EPCRASafe Drinking WaterChange NoticesChange NoticeWater ProgramsNew JerseyEnvironmentalCWA ComplianceEnglishFocus Area
2026-06-24T05:00:00Z
New Jersey adopts permanent remediation standards for PFAS
Effective date: June 15, 2026
This applies to: Contaminated sites subject to the remediation regulations for contaminated groundwater, soil, and soil leachate
Description of change: The New Jersey Department of Environmental Protection (NJDEP) formally adopted its interim remediation standards for specific per- and polyfluoroalkyl substances (PFAS), including:
- Groundwater quality standards for hexafluoropropylene oxide dimer acid and its ammonium salt (GenX chemicals); and
- Soil and soil leachate remediation standards for:
- Perfluorononanoic acid (PFNA);
- Perfluorooctane sulfonate (PFOS);
- Perfluorooctanoic acid (PFOA);
- GenX chemicals; and
- Methanol.
The interim standards have been in place since 2022 and 2023, requiring regulated entities to conduct remediation to ensure these PFAS are cleaned up.
Additionally, the NJDEP amended the technical requirements to mandate analyses of the following chemicals in all media when contaminants are unknown or not well documented at a contaminated site:
- PFNA,
- PFOS,
- PFOA,
- GenX chemicals, and
- 2,3,7,8-tetrachlorodibenzo-p-dioxin.
NewsIndustry NewsIndustry NewsPesticidesPesticide Registration and LabelingEnvironmental Protection Agency (EPA)EnvironmentalEnglishFocus AreaPesticidesUSA
2026-07-01T05:00:00Z
EPA sets MyPeST compliance reporting deadlines for bilingual pesticide labeling requirements
The Environmental Protection Agency (EPA) published instructions and deadlines for pesticide registrants to report compliance with bilingual labeling requirements in the MyPeST application. The first compliance reporting deadline is July 31, 2026, for pesticide products with the highest toxicity.
Who’s impacted?
Compliance reporting applies to registrants of pesticide products subject to the bilingual labeling requirements established by the Pesticide Registration Improvement Act of 2022 (PRIA 5) amendments to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
PRIA 5 requires all end-use pesticide product labels to provide Spanish translations of the human health and safety sections by including the translated sections directly on the label or providing a link via scannable technology or other readily accessible electronic methods to the translated sections. EPA allows certain antimicrobial and non-agricultural pesticide products to comply by providing access to Spanish-language Safety Data Sheets instead of direct label translations.
Compliance timelines are based on the type of pesticide and its toxicity category.
What’s required?
Pesticide registrants must report compliance with the PRIA 5 bilingual labeling requirements using EPA’s MyPeST app. The agency recently published detailed reporting instructions in the MyPeST Application User Guide (accessible in the MyPeST app).
EPA also established the following deadlines for reporting compliance in MyPeST:
| Pesticide product type | Bilingual labeling deadline | Compliance reporting deadline |
|---|---|---|
| Restricted use pesticides (RUPs) | December 29, 2025 | July 31, 2026 |
| Non-RUP agricultural products | ||
| Acute Toxicity Category I | December 29, 2025 | July 31, 2026 |
| Acute Toxicity Category II | December 29, 2027 | January 28, 2028 |
| Antimicrobials and non-agricultural products | ||
| Acute Toxicity Category I | December 29, 2026 | January 28, 2027 |
| Acute Toxicity Category II | December 29, 2028 | January 28, 2029 |
| All other pesticide products | December 29, 2030 | January 28, 2031 |
NewsMunicipal WastewaterChange NoticesChange NoticeWater ProgramsEnvironmentalCWA ComplianceEnglishFocus AreaNorth Carolina
2026-06-24T05:00:00Z
North Carolina approved revisions to wastewater discharge rules
Effective date: May 1, 2026
This applies to: Facilities with domestic wastewater discharges up to 2 million gallons per day
Description of change: The North Carolina Department of Environmental Quality (DEQ) adopted a rule that adds a permitting option to the National Pollutant Discharge Elimination System (NPDES) program for facilities with domestic wastewater discharges of up to 2 million gallons per day.
DEQ removed the ban on new or expanded discharges of oxygen-consuming waste when the 7Q10 and 30Q2 flows are both 0 for these facilities. In other words, it allows systems to discharge domestic wastewater to zero-flow receiving streams, provided the system:
- Meets qualifying criteria,
- Complies with specific effluent limits, and
- Uses low-energy methods before discharging wastewater to the receiving stream.
It’ll likely benefit areas where the cost of piping to a higher-flowing stream farther away is prohibitive.
NewsIndustry NewsIndustry NewsToxic Substances Control Act - EPAToxic Subtances Control Act - EPATSCA ComplianceToxic Substances - EPAEnvironmental Protection Agency (EPA)EnvironmentalEnglishFocus AreaUSA
2026-07-28T05:00:00Z
EPA extends PCE and CTC compliance deadlines
The Environmental Protection Agency (EPA) has extended the compliance dates of certain Workplace Chemical Protection Program (WCPP) requirements for perchloroethylene (PCE) and carbon tetrachloride (CTC) established under the Toxic Substances Control Act (TSCA).
Published on July 28, 2026, EPA’s final rule changes specific compliance dates but doesn’t alter the underlying WCPP requirements or the agency’s determination that PCE and CTC present unreasonable risks.
Who’s impacted?
The revised deadlines affect facilities subject to the TSCA PCE and CTC risk management rules finalized in 2024. These include entities that manufacture (including import), process, distribute in commerce, use, or dispose of:
- PCE,
- CTC, or
- Products containing PCE or CTC.
What are the new PCE and CTC compliance dates?
EPA’s final rule extends compliance deadlines for various WCPP requirements, including:
- Conducting initial monitoring,
- Meeting the existing chemical exposure limit (ECEL),
- Establishing a regulated area,
- Providing any required respiratory personal protective equipment (PPE) and establishing a respiratory PPE program,
- Implementing a workplace information and training program, and
- Establishing and implementing an exposure control plan (ECP).
Below is a summary of the new compliance deadlines.
| WCPP requirement | New compliance deadline | PCE applicability | CTC applicability |
|---|---|---|---|
| June 21, 2027 | Non-federal facilities | Non-federal facilities |
| September 20, 2027 | Non-federal facilities | Non-federal facilities |
| September 20, 2027 | Federal and non-federal facilities | Non-federal facilities |
| December 20, 2027 | Non-federal facilities | — |
* EPA maintains the CTC rule’s WCPP compliance date of December 3, 2027, for federal and non-federal facilities to establish and implement an ECP.
Key to remember: EPA has extended compliance dates for certain PCE and CTC Workplace Chemical Protection Program requirements into 2027.
Most Popular Highlights In Transportation
NewsIndustry NewsFleet SafetyDriver qualificationsTransportationDrivers qualification (DQ file)Driving RecordsDriver abstractsIn-Depth ArticleEnglishFocus AreaUSA
2026-07-23T05:00:00Z
Why driver self-certification deserves a closer look
Most carriers review motor vehicle records (MVRs) looking for the obvious red flags. They check traffic convictions, suspensions, endorsements, restrictions, and medical certification information. But there's another item on a commercial driver’s license (CDL) driver's MVR that can easily be overlooked: the driver's self-certification status.
That oversight can create significant compliance problems.
When CDL drivers apply for, renew, or update their CDL, they must self-certify the type of commercial driving they perform. Depending on their operation, a driver may be classified as:
- Non-excepted interstate,
- Excepted interstate,
- Non-excepted intrastate, or
- Excepted intrastate.
For most motor carriers, drivers should be operating under a non-excepted category because they’re subject to medical qualification requirements. Drivers can update their self-certification status directly with their state driver licensing agency, typically with little employer involvement. But that's where mistakes can occur.
In some cases, a driver may change their status to an excepted category without fully understanding the requirements. In other cases, they may have legitimately qualified for an excepted category while working for a previous employer but never updated their status after changing jobs. Either way, if a carrier isn't paying close attention to this information, the error can go unnoticed until it's discovered during an audit or a roadside inspection.
Why ‘excepted’ matters
An excepted category isn’t simply an option that a CDL driver can choose for convenience. To self-certify as “excepted interstate,” a driver must operate exclusively under one of the FMCSA's excepted activities, such as certain government operations, emergency response functions, or other specifically exempted activities.
Likewise, a driver claiming “excepted intrastate” status must meet the exemption requirements established by the state in which they’re licensed. These exemptions vary from state to state. Many CDL holders incorrectly assume that if they’re not currently driving CDL-required commercial motor vehicles , they can self-certify as ”excepted intrastate” and avoid maintaining a DOT medical certificate on their driving record. Many states specifically prohibit this practice. The key takeaway is that carriers should understand their state’s self-certification rules rather than assume a driver’s selection is correct.
Interstate vs. intrastate
A couple of words on an MVR can make a big difference. When hiring a new driver, carriers should pay close attention to whether the driver is self-certified as interstate or intrastate. It is common to hire drivers who previously worked for an employer that operated exclusively in intrastate commerce.
If a driver is self-certified as “Non-Excepted Intrastate” and then begins operating in interstate commerce, this will quickly come to light during a roadside inspection or compliance review. Carries should make sure the individual reviewing MVRs understands what these categories mean and verifies that a driver's self-certification status aligns with the operations the driver will actually perform.
Key to remember: Because drivers update their self-certification status directly with their licensing agency, carriers shouldn’t assume the information is always accurate or consistent with the driver's current job duties. Taking extra time to closely review and verify a driver's self-certification category will prevent compliance issues down the road.
NewsTiresCMV Parts and MaintenanceTransportationIn-Depth ArticleCommercial motor vehicle definitionEnglishCommercial motor vehicle definitionBusiness planning - Motor CarrierIndustry NewsFederal Motor Carrier Safety RegulationsFleet SafetyElectronic logging device (ELD)Electronic logging device (ELD)Maintenance and periodic inspectionsFocus AreaVehicle weight definitionsUSA
2026-07-24T05:00:00Z
5 important DOT rule changes just went into effect
Five important rule changes from the Federal Motor Carrier Safety Administration (FMCSA) just went into effect. While four of them removed recordkeeping obligations, a fifth serves as a reminder that commercial trucks can be regulated even if they weigh less than 10,001 pounds.
All five changes took effect July 21-22, 2026. The following is a summary of the changes and their impact on fleet operations, along with key precautions.
1. ELD user’s manuals
Drivers are no longer required to carry an electronic logging device (ELD) user’s manual in the vehicle.
The FMCSA says the requirement no longer provides a meaningful safety benefit because ELDs have been in widespread use since 2019 and many devices either contain electronic versions of the manual or provide easy access to it online.
Caution: Drivers must still carry ELD transfer and malfunction instructions, along with at least 8 blank logs. Carrying the user manual remains a good idea, since drivers must be able to transfer ELD data and demonstrate how the device works during an inspection.
2. Roadside inspection reports
For years, motor carriers were required to return completed roadside inspection reports to the issuing state agency after correcting any defects. That federal requirement has now been scaled back.
Under the rule change, motor carriers must return the report only if the issuing state requests it. The FMCSA acknowledged that many states either didn’t want, didn’t review, or simply discarded the returned reports, making the blanket federal requirement unnecessary.
Caution: Important compliance duties remain unchanged. Motor carriers must still correct cited defects, certify that repairs were made, and retain the report for 12 months.
3. CDL driver violation reports
Commercial driver’s license (CDL) holders no longer have to self-report traffic convictions to their home state. The FMCSA eliminated the requirement because states exchange conviction information electronically.
Caution: Drivers must still report traffic convictions to their employer within 30 days, and some states may continue to impose their own reporting requirements.
4. Tire size
Another little-known change removes the requirement for maintenance records to identify tire size.
The tire-size entry had been part of the vehicle maintenance file requirements for decades, with many motor carriers and auditors unsure of its purpose. The FMCSA determined the recordkeeping requirement had become obsolete and removed it from 49 CFR 396.3.
Caution: Motor carriers must still maintain maintenance records and vehicle identification information, including the company number (if marked on the vehicle), make, serial number, and year.
5. GVWR clarification
The fifth change is technically a clarification, but it may have the greatest practical impact.
The FMCSA revised the definition of “gross vehicle weight rating (GVWR)” in 49 CFR 390.5 to make perfectly clear that a vehicle’s GVWR is the manufacturer’s maximum loaded weight rating and does not change based on the vehicle’s actual weight.
More importantly, the agency explained that a vehicle with a GVWR of 10,001 pounds or more, operating in interstate commerce, remains a commercial motor vehicle even when its scale weight is below 10,001 pounds.
This clarification targets a common misunderstanding among operators of cargo vans, pickup trucks, box trucks, and other smaller vehicles. Some carriers assume they are outside the FMCSA’s jurisdiction because the vehicle’s actual weight is under 10,001 pounds. The agency has now made it clear that enforcement officials rely on the weight or the rating – whichever is higher at the time of inspection.
Caution: The clarification doesn’t create a new requirement, but it may expose compliance gaps that some smaller operations never realized they had. Make sure you know the GVWR across your fleet and ensure compliance for all regulated vehicles, even when they’re empty.
Key to remember: Four DOT regulation changes, now in effect, reduce paperwork and reporting burdens. A fifth change does the opposite: It reinforces that a vehicle’s GVWR, not its actual weight on a given day, determines whether the vehicle falls under FMCSA safety regulations.
NewsIndustry NewsViolations - HazmatHazmat SafetyHazmat: HighwayFocus AreaIn-Depth ArticleEnglishTransportationUSA
2026-07-13T05:00:00Z
A midyear look at FMCSA's top hazmat violations
Roadside inspections are a fact of life for hazmat carriers. While inspectors encounter a wide range of compliance issues, Federal Motor Carrier Safety Administration (FMCSA) data shows that a handful of violations account for a significant share of hazmat citations year after year. Understanding these trends can help carriers focus their compliance efforts where they're likely to have the biggest impact.
Here's a look at the five most frequently cited hazmat roadside inspection violations so far in 2026 and what you can do to stay off the list.
1. Cargo not properly secured
The most common hazmat violation so far this year involves hazardous materials that weren’t properly blocked, braced, or secured during transportation. Inspectors recorded more than 1,000 of these violations.
To avoid this issue, verify that hazmat packages are adequately secured before departure and periodically check cargo during transit. Drivers should never assume a load was secured properly without conducting their own inspection.
2. Failure to produce a current hazmat registration
More than 400 violations were issued for failing to produce a current Pipeline and Hazardous Material Safety Administration (PHMSA) hazmat registration certificate or registration number during an inspection.
Usually, the company is registered but can’t provide proof of registration. Make sure registrations are renewed on time, current certificates are maintained, and employees know where the documentation is located.
3. No required shipping paper
FMCSA reported more than 360 violations involving vehicles operating without a required hazmat shipping paper.
Before a vehicle leaves the facility, confirm that the required shipping paper is present and complete. A simple shipping paper review as part of the pre-trip process can help prevent this violation.
4. Damaged or obscured placards
Nearly 350 violations involved placards that were damaged, faded, dirty, or otherwise difficult to read.
Include placards in routine vehicle inspections and replace them when necessary. Also ensure mud, snow, road grime, or other materials aren't obstructing their visibility.
5. Shipping paper accessibility
Rounding out the top five is shipping paper accessibility, with more than 340 violations reported so far this year.
Having a shipping paper isn't enough. It also has to be readily accessible. Drivers should be trained on accessibility requirements and consistently store shipping papers in the designated location. The best place for hazmat shipping papers in a vehicle is in a holder on the inside of the driver’s door.
A common theme
What's striking about the top violations so far this year is that most involve basic compliance fundamentals rather than complex regulatory requirements. Cargo securement, documentation, and placarding remain the areas where inspectors are finding the most problems.
Key to remember: Don't overlook the basics. Regular pre-trip inspections, refresher training, and periodic compliance reviews can go a long way toward preventing the violations that inspectors continue to find most often on the road.
NewsIndustry NewsOn-duty time - Motor CarrierFleet SafetyHours of ServiceRisk Management TransportationRisk Management - Motor CarrierFocus AreaIn-Depth ArticleFleet OperationsEnglishTransportationUSA
2022-12-15T06:00:00Z
6 Yard Move FAQs – Need-to-know answers for carriers and drivers
A “yard move” (YM) is an electronic logging device (ELD) special driving category, which carriers have the option to authorize. Putting an ELD in the YM status can give a yard or road driver added flexibility or another avenue for falsification.
To avoid violations and increased risk, ensure that your drivers, dispatchers, and safety personnel know the answers to these frequently asked questions (FAQs).
1. What falls under the definition of a “yard”?
The Federal Motor Carrier Safety Administration (FMCSA) does not officially define a yard. Still, it is generally accepted an area that is not open to public travel due to being restricted by signs or gates.
A carrier’s terminal, a customer’s facility, or a rail yard can be a yard if the area cannot be defined as a highway per 390.5. A driver may also cross a public road to reach another part of private property under yard-move time if traffic controls (i.e., flagger) for the public are in place.
Malls, truck stops, and parking lots the public can access, however, are all examples of places that cannot be a yard for ELD and on-duty (not driving) purposes.
2. Is a yard driver subject to federal regulations?
Commercial motor vehicles (CMVs) are federally regulated at 10,001 pounds or greater — rated or actual, alone or in combination with a trailer. State definitions of a CMV vary.
Suppose a yard truck met the definition of a CMV and operates in an area open to public travel in interstate commerce. In that case, the yard driver must be qualified under Part 391 and is subject to all other applicable federal regulations. If the yard truck and trailer meet the definition of a CDL vehicle in 383.5 as most do, the driver is also subject to drug and alcohol testing and CDL requirements.
Yard drivers might not be required by their carrier to use an ELD to create a log. They are stillsubject to the hours-of-service limits in 395.3 and the same rules for on-duty (not driving) time in a yard or on-duty driving (Line-3) on a public roadway.
A carrier may allow the use of a time record instead of an ELD to track a yard driver’s time under the 150 air-mile exception in 395.1(e). If the yard driver uses an ELD, the carrier can designate the driver as “Exempt” (exempt from grid logs only) in the ELD back-office system.
3. How is a yard move recorded on an ELD?
YM time is visible in the ELD grid as driving time with a dashed or dotted line. Before using YM time, the driver must select the “YM” special driving category and annotate the ELD record describing the reason for the activity.
According to federal hours-of-service rules, a driver cannot use “Line-3” or on-duty driving time after 14 consecutive hours from the start of on-duty time for the day. However, yard moves are recorded as “Line-4 time” or on-duty not (driving) time. Therefore, YM time doesn’t stop the 14-hour clock, but can be appropriately used beyond the 14-hour or other driving limits.
4. Does a yard move count toward the 30-minute break from eight total hours of on-duty driving?
Yes. Because a YM is on-duty (not driving), it counts toward the 30-consecutive minute break from on-duty driving required after eight total hours of on-duty driving. (see 395.3(a)(3))However, if a driver is involved in a fatigue-related crash, driving in a yard to satisfy a break from driving requirement will not look prudent to a jury.
5. What if a driver forgets to change the driving status, and the ELD remains in YM-status after they leave the yard?
The time will be incorrectly captured as Yard Move (on-duty yard time rather than on-duty driving time) and could be considered a false log. To address this, the driver should attach a comment to the log explaining the error as soon as safely possible.
The driver’s log must be manually edited to the correct driving time if the ELD system allows the off-yard time to be changed to on-duty driving time. Otherwise, an annotation must be made noting the correct on-duty (not driving) and on-duty driving time.
6. How are yard moves audited?
Verify the location at the time of the YM with the location description or the longitude and latitude data from the ELD or vehicle tracking device. If the driver was not in a yard at the time of the YM, the driver falsified the record.
A driver using a public road in YM status to get fuel or take the truck in for maintenance is considered falsification. If the driver was over the 11-hour driving limit, 14-consecutive on-duty period, or the 60- or 70-hour limit, they now have an out-of-service violation and a false log.
Carriers can define a geo-fence or virtual boundary of the yard if the system allows that feature to indicate a departure from the yard.
Keys to remember:
Carriers must train their team to understand when the Yard Move status or on-duty (not driving) can and can’t be used when operating a CMV. Audit yard moves to ensure this ELD special driving category, or duty status for drivers on time records, is not used to falsify logs.
NewsIndustry NewsFleet SafetyRisk Management TransportationRisk Management - Motor CarrierDriver qualificationsDrivers qualification (DQ file)Focus AreaIn-Depth ArticleEnglishTransportationUSA
2023-03-17T05:00:00Z
When a fleet is acquired, are new DQ files and queries needed?
Carrier acquisitions have increased based on 2022 trucking industry data. During and after an acquisition, questions arise regarding driver qualification (DQ) files and Clearinghouse queries for the acquired fleet’s drivers.
Federal Motor Carrier Safety Administration (FMCSA) allows an acquiring carrier to accept the DQ files from the acquired company and forego a pre-employment query. Below are FMCSA’s requirements in more depth and industry best practices to mitigate DQ file and query risks at the time of an acquisition.
FMCSA guidance
1. DQ files - An acquiring carrier does not have to create a new DQ file for drivers when:
- The acquired company deactivates their United States Department of Transportation (USDOT) number and Federal Employer Identification Number (FEIN), and
- There is no break in employment for the drivers.
“No break in employment” means that the acquired company’s drivers did not have to reapply for their job.
Best Practice: To avoid confusion during an FMCSA audit, put a note in each file showing that the driver files were part of an acquisition, along with the date the drivers started working for the acquiring company.
2. Clearinghouse queries - There is no need to run a pre-employment Drug and Alcohol Clearinghouse query for the acquired company’s commercial driver’s license (CDL) drivers if there is no break in employment. However, an annual query must be run within one year of the last query while at the acquired company. The dates of the prior annual query may be a different date for each driver, which is not easy to track.
Best Practice: Run the annual query on the new drivers before they operate a commercial motor vehicle (CMV) requiring a commercial driver’s license (CDL) for the acquiring company. This query is to verify that no driver is in a “Prohibited” status due to a positive test and missing a negative return-to-duty test. The query also resets the next annual query date to a known day a year in advance for each driver.
What are the risks of not creating new DQ files?
The acquiring company owns all errors and omissions in a DQ file. If, for any reason, a driver is not fully qualified and all documents are not current, the acquiring carrier is responsible.
Suppose serious violations on a new driver’s motor vehicle record (MVR) do not meet the company’s hiring criteria. If an MVR wasn’t run as is normally required for new-hire DQ files, a plaintiff’s attorney may accuse the acquiring company of negligent hiring in post-crash litigation.
Best practices:
- Audit each file for compliance gaps as part of the acquisition process.
- Document violations along with remedial actions, if any.
- Review the MVR and any other performance history available for each driver.
If documents are missing or incorrect, the acquiring carrier would still be subject to a violation if audited by FMCSA. Acknowledging errors and documenting “meaningful action” could mitigate penalties.
Keys to remember: Audit the DQ files of an acquired company’s drivers and document compliance issues and remedial actions. Also, run an annual query to detect drivers prohibited from driving a CMV.
NewsIndustry NewsFleet SafetyDrug and Alcohol Testing - DOTDriver qualificationsDrivers qualification (DQ file)Driver qualification and hiringFocus AreaIn-Depth ArticlePre-employment drug testing - Motor CarrierEnglishTransportationUSA
2022-07-19T05:00:00Z
Rehiring drivers: 5 “watch-outs” when bringing drivers back
The shortage of qualified drivers has worsened, according to industry experts and carriers. Rehiring good employees is a logical option for carriers to put drivers in seats of unused commercial motor vehicles (CMVs).
If former drivers reapply — whether two months or two years later — you must ensure they still meet your hiring criteria and the federal requirements.
Here are five “watch outs” when bringing back non-CDL and CDL drivers. The first two apply to all drivers, and numbers 3 through 5 apply to CDL-vehicle drivers only.
1. Know what constitutes a rehire.
A leave of absence, layoff, or a furlough is not a rehire if the driver remained on the driver roster and you expected them to return to driving. You will not need to create a new driver qualification (DQ) file, pre-employment drug test, or pre-employment Clearinghouse query.
However, when a driver is taken off a carrier’s roster and brought back to the company, the Federal Motor Carrier Safety Administration (FMCSA) considers the driver a new hire. If there is any break in employment, a new DQ file is needed.
For a rehire DQ file, you can use copies of the following documents from the old DQ file under certain conditions:
- Road test and road test certificate — if completed within the last three years (391.33(a)(2)).
- Medical certificate — if still valid and the driver experienced no disqualifying conditions.
- Safety Performance History (SPH) forms from prior employers — if compliant with 391.23 and employment was in the past three years.
You must create all other DQ file documents per 391.51 and obtain SPH documents from employers since the driver left your company as required by 391.23.
2. Understand the facts about the driver’s prior departure.
To avoid rehiring a problem employee, ensure you have details about why the driver left the company. If there are not enough details, contact the prior driver supervisor to confirm the facts about the break in employment.
A “No rehire” designation with details in the driver’s record can help avoid a bad rehire. A solid performer may also be turned away if there was a hasty “No rehire” flag in the driver’s record. For example, a personality conflict with one supervisor may not be a good reason to list a driver as no-rehire. Get the facts and decide.
3. Run a full query when rehiring CDL-vehicle drivers, with no exceptions.
Conduct a pre-employment full query in the Clearinghouse if there was any break in employment. There is no exception. Make sure the driver is not prohibited from driving due to a reported drug and alcohol testing violation while at another job.
4. Consider the time needed to comply with the pre-employment testing exception.
A CDL-vehicle driver must have a pre-employment drug test unless you meet the exception requirements in 382.301(b) and (c). Be aware that the exception could be more work and take longer than sending the driver for the test and getting the result.
Pre-employment drug testing exception overview:
If less than 30 days have elapsed since participating in an FMCSA drug and alcohol testing program, you need documentation from yours and any other DOT program that show:
- The driver was tested in the past six months or participated in a DOT testing program for the past 12 months, and
- You ensure that no prior employer knows of a violation under another DOT agency in the past six months.
Documentation required in 382.301(c)(1) from the other carriers must be in hand before dispatching the driver.
5. Don’t forget these CDL-driver compliance items.
Two rehire checklist items that are easy to overlook during the hiring process:
- Ask the driver about pre-employment drug test violations in the past two years where the driver was not hired. The Clearinghouse may cover all or part of this period. However, there has not been any rulemaking eliminating this requirement in 40.25(j).
- Reissue the DOT drug and alcohol policy educational materials and receive a signed receipt from the driver.
Keys to remember:
When rehiring drivers you need to confirm the potential rehire’s prior performance and reason for leaving, along with meeting all other qualification requirements. Don’t skip any steps in the hiring process just to get the driver on the road sooner.
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.
NewsFamily and Medical Leave Act (FMLA)LeaveTime offFamily and Medical Leave Act (FMLA)HR ManagementEnglishLeaveLouisianaAssociate Benefits & CompensationChange NoticesChange NoticeHR GeneralistAssociate RelationsFocus AreaHuman Resources
2026-07-27T05:00:00Z
Louisiana adds living donor leave
Effective date: August 1, 2026
This applies to: State agencies and private employers with one or more employees,
Description of change: Effective August 1, 2026, Louisiana state employees may take paid, job-protected leave to donate organs. Employees of private employers in the state may take unpaid, job-protected leave to be donors.
To be eligible to take the paid leave, a full-time employee of a state agency must have been continuously employed by the same agency for at least 12 months.
The law doesn’t have eligibility criteria specifically for employees of private employers, but employees must request the leave in writing.
Employees may take up to 30 consecutive calendar days of leave to serve as human organ or bone marrow donors.
Employers are prohibited from retaliating against employees who request or take such leave.
The donor leave can run concurrently with leave under the federal Family and Medical Leave Act (FMLA).
View related state info: FMLA - Louisiana
NewsIndustry NewsHR GeneralistFamily and Medical Leave Act (FMLA)In-Depth ArticleFamily and Medical Leave Act (FMLA)HR ManagementEnglishUSAFocus AreaHuman Resources
2026-07-14T05:00:00Z
5 lesser-known FMLA requirements
Many employers have a process they follow when employees ask for leave under the federal Family and Medical Leave Act (FMLA). While each FMLA case can have its own quirks, employers might not be familiar with some of the law’s unique provisions.
What employers should know about the FMLA but might not
Here are five little-known FMLA requirements:
1. Poster: The FMLA poster has to be seen by applicants. Once employers are covered by the law, they must put the poster up where not only employees can see it, but applicants as well. This is true even if employers have no eligible employees.
If employers post job openings online and interview candidates electronically, they should place a prominent notice on the website where the job postings are listed stating that “Applicants have rights under federal employment laws” and link to the FMLA, EEO (Equal Employment Opportunity), and EPPA (Employee Polygraph Protection Act) posters.
825.300(a)(1)
2. Eligibility: The 1,250 hours worked that employees must meet to be eligible to take FMLA leave don’t include time not worked, like vacation, paid time off, and so forth. Employees must actually have worked the 1,250 hours, not just been paid for them. Therefore, when looking at whether an employee meets the 1,250 hours worked eligibility criteria, employers shouldn’t include hours that aren’t actually worked.
825.110.(c)(1)
3. Temp workers: Employers must include the time a temporary (“temp”) employee spent working for them toward their FMLA eligibility. As long as temp employees have worked for the company for at least 12 months and have performed at least 1,250 hours of work, they’re entitled to FMLA leave. If employers have temp employees that they then hire as regular employees, they must count all the time spent working as a temp employee toward their eligibility.
825.106 (OL FMLA-37)
4. Transferring: Employers may not transfer an employee to an alternative job during unforeseeable intermittent leave. The only time employers may transfer an employee to an alternate job is when the need for leave is foreseeable based on planned medical treatment. If employers allow employees to take bonding leave intermittently, they may also transfer employees.
825.204
5. Workers’ compensation: Employees on workers’ compensation (WC) can refuse light duty and remain on FMLA leave. They would lose their WC benefits. Employers may offer a "light duty" job to the employee to encourage them to return to work early, but if the employee is taking FMLA leave simultaneously, the employee isn’t required to end FMLA leave and accept the light-duty assignment. Employees who continue on FMLA leave may lose WC benefits, but may not be subjected to any form of disciplinary action for having exercised their FMLA rights.
825.207(e) (OL FMLA-38)
Key to remember: Employers won’t frequently run into the lesser-known FMLA provisions, but they must know what to do when they are in play.
NewsDrug and Alcohol TestingMarijuanaSafety & HealthChange NoticesChange NoticeGeneral Industry SafetyAssociate Benefits & CompensationHR GeneralistNew JerseyAssociate RelationsEnglishHR ManagementFocus AreaHuman Resources
2026-07-28T05:00:00Z
New Jersey state court rules in cannabis law
Effective date: May 26, 2026
This applies to: Employers in New Jersey doing drug testing
Description of change: A New Jersey state court ruled in May 2026 that the state’s cannabis law allows individuals to bring a private lawsuit against an employer alleging discrimination because of marijuana use. This is contrary to federal court decision issued in 2024 which determined that the state’s Cannabis Regulatory, Enforcement Assistance, and Market Modernization Act (CREAMMA) didn’t create a private right of action.
While the state court acknowledges that it reached a different conclusion than the federal court, it noted in the decision that state courts aren’t bound to federal court decisions with respect to state law.
In light of the court’s decision, employers in New Jersey shouldn’t base employment decisions only on an individual’s use of cannabis.
View related state info: Marijuana – New Jersey
NewsDisabilities and ADAHuman ResourcesEnglishTalent Management & RecruitingAssociate Benefits & CompensationIndustry NewsIndustry NewsDiscriminationTitle VII (The Civil Rights Act of 1964)DiscriminationRecordkeepingPregnancy DiscriminationEEO-1 ReportingAssociate RelationsFocus AreaDisabilities and ADAUSA
2026-07-06T05:00:00Z
The EEOC’s 2026 regulatory agenda includes changes to the PWFA
On July 6, the Equal Employment Opportunity Commission (EEOC) published its 2026 regulatory agenda. The EEOC plans to publish a proposed rule revising the Pregnant Workers Fairness Act (PWFA) regulations in November. The agency proposes revising the interpretation of the words “pregnancy, childbirth, or related medical conditions.”
The EEOC also proposes rescinding some requirements this month. The proposals include the following:
- Rescinding EEO-1, EEO-2, EEO-3, EEO-4, EEO-5, and reporting requirements under Title VII, the ADA, GINA, and the PWFA; and
- Rescinding the Uniform Guidelines on Employee Selection Procedures – Recordkeeping.
When a rule is earmarked in the regulatory agenda as a “proposed rule,” that means the public expects to see written documentation on which they can provide their comments. The agencies involved, in this case the EEOC, then review the comments, and the rule proceeds to the next step in the legislative process. The dates provided are estimates that the EEOC thinks it’ll have something posted for review.
The agency’s final rules include rescinding the following this month, and the expected dates in 2026:
- The 1979 Interpretive Rule "Affirmative Action Appropriate Under Title VII of the Civil Rights Act of 1964."
- The Interpretive Rule "The Guidelines on Discrimination Because of National Origin."
- The Appendix to Guidelines on Discrimination Because of Sex.
In November, employers can expect a final rule rescinding the Uniform Guidelines on Employee Selection Procedures.
A final rule addresses the public comments submitted in response to a proposed rule to help determine the final regulatory language. When an agency publishes a final rule, generally the rule is effective no less than 30 days after the date of publication in the Federal Register. A final rule doesn’t take effect until its “effective date” is reached.
Key to remember: Employers can expect to see some potential changes to their requirements under EEOC regulations.
NewsIndependent ContractorsContingent WorkforceFamily and Medical Leave Act (FMLA)Family and Medical Leave Act (FMLA)USAHR ManagementEnglishAssociate Benefits & CompensationIndustry NewsIndustry NewsWage and HourContingent WorkforceWage and HourHR GeneralistFair Labor Standards Act (FLSA)OvertimeAssociate RelationsFocus AreaHuman Resources
2026-07-06T05:00:00Z
Wage and Hour Division publishes its 2026 regulatory agenda
On July 6, the U.S. Department of Labor’s (DOL) Wage and Hour Division (WHD) published its 2026 unified regulatory agenda. The agenda offers a glimpse into what the WHD is planning for its regulations and when.
Joint employer proposed rule: July 2026
Since 2021, the WHD has had no regulatory guidance addressing joint employer liability under the Fair Labor Standards Act (FLSA). The WHD is considering a proposed rule to adopt regulations that would guide WHD enforcement of joint employer liability under the FLSA, the Family and Medical Leave Act (FMLA), and the Migrant and Seasonal Agricultural Workers Protection Act (MSPA). The WHD says that joint employer status under the FMLA and MSPA should be determined using the FLSA analysis.
When a rule is earmarked in the regulatory agenda as a “proposed rule,” that means the public expects to see written documentation on which they can provide their comments. The agencies involved then review the comments, and the rule moves to the next step in the legislative process. The dates listed are estimates that the agencies think they’ll have something posted for review.
Independent contractor final rule: October 2026
In 2024, the WHD published a final rule providing an analysis for determining employee or independent contractor (IC) classification under the FLSA. The 2024 IC rule took effect on March 11, 2024. The 2024 IC rule, however, is the subject of legal challenges. The WHD intends to rescind the 2024 IC rule. The WHD has also proposed to modify regulations interpreting the FMLA and MSPA to clarify that the analysis for determining employee or IC status under the FLSA also applies under the FMLA and MSPA.
The WHD considered three alternatives to the proposed rule, listed below from least to most restrictive:
- Adopting the common law control test, which applies in distinguishing between employees and ICs under various other federal laws;
- Adopting the WHD’s current enforcement policy, which is comprised of sub-regulatory guidance from before 2021 applying a multifactor economic reality balancing test; and
- Adopting a 3-pronged “ABC” test (which several states have adopted).
The WHD issued a proposed rule in February 2026, and the comment period ended on April 28.
A final rule addresses the public comments submitted in response to a proposed rule to help determine the final regulatory language. When an agency publishes a final rule, generally the rule is effective no less than 30 days after the date of publication in the Federal Register. A final rule doesn’t take effect until its “effective date” is reached.
Key to remember: The Wage and Hour Division is looking to revise the joint employer and independent contractor regulations.
Most Popular Highlights In Safety & Health
NewsIndustry NewsAccident Investigation - OSHAAccident Investigation - OSHASafety & HealthConstruction SafetyGeneral Industry SafetyIn-Depth ArticleEnglishFocus AreaUSA
2026-07-21T05:00:00Z
Not your worker, but still your problem
A single sulfuric acid spill at a Texas industrial facility triggered more than $3.5 million in proposed OSHA penalties, proving that finger-pointing is not a defense against OSHA citations. On December 27, 2025, the chemical storage facility in Texas suffered a catastrophic release when workers mixed fresh and spent sulfuric acid. This caused a tank over-pressure that ruptured a supply line and released roughly one million gallons of sulfuric acid, injuring multiple employees in the process. That event alone would have been serious enough, but there was more to the story that unfolded during the cleanup. It’s a story every employer who works alongside contractors, subcontractors, or even staffing agencies needs to understand.
Subcontracting the work doesn't subcontract the liability
After the spill, the host facility that owned the ruptured tank brought in an environmental remediation company to handle the hazardous cleanup. The remediation contractor, in turn, hired a subcontracted staffing firm to supply laborers for the physical remediation work. It’s an entirely ordinary practice to have a host site, general contractor, and subcontractors. It’s the same structure found on construction sites, refineries, manufacturing plants, and emergency response jobs across the country. OSHA’s investigation didn’t stop at the bottom of the chain with just the subcontractors. Federal inspectors opened three separate inspections and cited all three companies:
- The subcontractor that supplied cleanup laborers received 18 willful egregious violations and 5 serious violations, with proposed penalties of $3,045,452. This was after investigators found workers were sent into the spill area without adequate training, respirator fit testing, or basic safety measures.
- The remediation contractor was cited for 2 willful and 5 serious violations, carrying proposed penalties of $392,501, tied to gaps in training, an emergency response plan for hazardous waste operations, and respirator program deficiencies.
- The host facility that owned the tank that ruptured received 6 serious violations and $82,750 in proposed penalties for exposing workers to chemical burns and hazmat and respirator training failures.
Combined, the proposed penalties across the three employers total $3,520,703.
The regulatory principle at work
This is a textbook application of OSHA's Multi-Employer Citation Policy (CPL 02-00-124), which allows the agency to cite more than one employer on a single worksite for the same hazardous condition. Under that framework, OSHA evaluates who created a hazard, who was exposed to it, who had the power to correct it, and who controlled the site. Any employer who fits one of those four descriptions can be held liable regardless of whose name is on the paycheck.
OSHA's Assistant Secretary for Occupational Safety and Health described the failures by saying the three employers had full knowledge of the severe hazards and bypassed federal requirements anyway and called the failure to protect workers a choice rather than an oversight lapse.
What this means for your operation
If your company hires subcontractors, staffing agencies, or if you are one of those subcontractors working someone else's site, this case is a reminder that:
- Contractual boundaries do not equal regulatory boundaries. OSHA does not care who is named in the service agreement. Their focus is on who created, controlled, or was exposed to the hazard.
- “We hired someone qualified" is not a defense. Controlling and host employers have a duty to verify that contractors and subcontractors have adequate training, PPE, respiratory protection programs, and emergency response plans in place.
- Emergency response and cleanup work carries its own regulatory obligations that are distinct from the incident that triggered it and are under standards covering hazardous waste operations and emergency response (HAZWOPER), respiratory protection, and general PPE.
- Willful and egregious classifications multiply exposure fast. The largest penalty in this case came not from the party that owned the facility, but from the staffing firm several links down the contracting chain, proving that penalty exposure follows the hazard, not the organizational chart.
Keys to remember: Whatever the ultimate outcome may be for an incident; the enforcement pattern proves that for multi-employer worksites, safety responsibilities aren’t something you can subcontract away.
NewsIndustry NewsIndustry NewsEnforcement and Audits - OSHAEnforcement and Audits - OSHASafety & HealthConstruction SafetyGeneral Industry SafetyMaritime SafetyOccupational Safety and Health Administration (OSHA), DOLEnglishFocus AreaUSA
2026-07-06T05:00:00Z
OSHA publishes long-awaited Regulatory Agenda
After failing to publish a Fall 2025 or Spring 2026 regulatory agenda, on July 3 OSHA published a 2026 Regulatory Plan and the Unified Agenda of Federal Regulatory and Deregulatory Actions. Of note, a Subpoenas interim final rule is up for November 2026, the Emergency Response final rule is set for April 2027, and the Heat proposal is slated to be finalized in October 2027.
Starting August 19, 2026, OSHA will hold public hearings on numerous proposed rules, most of which relate to respiratory protection requirements for different chemical substances. The others relate to construction illumination, safety color code for marking for physical hazards, limiting the General Duty Clause for inherently risky professional activities, and fixed ladders.
Four rules fell into the long-term action category from the proposed or final stages in 2025: Communication Tower Safety, Shipyard Fall Protection, Powered Industrial Trucks Design Standard Update, and Standards Improvement Project. Long-term actions are items the agency considers under development but does not expect to take regulatory action on within 12 months after publication of the most recent regulatory agenda.
| Final rule stage | |
| Projected publication date | Title |
| July 2026 |
|
| September 2026 |
|
| November 2026 |
|
| April 2027 |
|
| October 2027 |
|
| Proposed rule stage | |
| Projected publication date or other action | Title |
| July 2026 |
|
| August 2026 - public hearings |
|
| September 2026 |
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| November 2026 |
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| December 2026 - Supplemental Notice of Proposed Rulemaking |
|
| Long-term actions | |
| |
NewsFormaldehydeMethylene ChlorideEnglishAsbestosCadmiumIndustry NewsIndustry NewsLeadSafety & HealthGeneral Industry SafetyToxic and Hazardous Substances - OSHAAcrylonitrileEthylene OxideFocus AreaToxic and Hazardous Substances - OSHAUSA
2026-07-22T05:00:00Z
OSHA reopens comment period for 13 proposed rules
OSHA has reopened the comment period for 13 chemical-specific proposed rules. The August 21 deadline provides the public 30 days to comment on recommendations made by OSHA’s Advisory Committee on Construction Safety and Health (ACCSH). The rules are:
- 1,2-dibromo-3-chloropropane
- 1, 3- Butadiene
- 13 Carcinogens (4- Nitrobiphenyl, etc.)
- Acrylonitrile
- Asbestos
- Cadmium
- Ethylene Oxide
- Formaldehyde
- Inorganic Arsenic
- Lead
- Methylene Chloride
- Methylenedianiline
- Vinyl Chloride
The proposed rules were originally published in the Federal Register on July 1, 2025. At that time, OSHA was in the process of appointing members to ACCSH. The agency stated that it would present the proposed rules to ACCSH once that process was complete and would allow the public time to provide comments on the recommendations.
To read or download the ACCSH recommendations, comments, and other materials submitted in the docket, visit www.regulations.gov.
NewsIndustry NewsSafety & HealthGeneral Industry SafetyWalking Working SurfacesIn-Depth ArticleWalking Working SurfacesLaddersEnglishFocus AreaUSA
2025-07-24T05:00:00Z
Misconceptions on dock chains, wheel chocks, fixed ladders and more
Our experts regularly receive questions on loading docks and fall protection, particularly since OSHA revised the regulations in 2017. Here are answers to some of common questions.
Can we use rope or chain as fall protection on loading docks?
Yes, if you install it correctly. Most docks are four feet or higher and require fall protection if the door is open without a trailer in place. Rope or chain must be equivalent to a guardrail, which requires a top rail and mid rail. A single chain is not acceptable.
Per 1910.29(b), the material must be at least one-quarter inch in diameter. The top rail must be 42 inches high, plus or minus 3 inches, for a range of 39 to 45 inches. The top rail cannot sag or deflect to within 39 inches of the surface under 200 pounds of force, and should be tight enough to prevent a worker from falling between the chains and the dock edge.
Are wheel chocks required at loading docks?
Employers must use some method to prevent the trailer from moving. OSHA gives examples of wheel chocks, but other options can work, such as dock locks. Even if the dock ramp is inclined downward, OSHA still requires chocks.
Note that OSHA’s directive STD 01-11-007 uses the term “mechanical means” instead of the term “dock locks.” Also, a Letter of Interpretation dated March 7, 2011, clarified that the Federal Motor Carrier Safety Administration (FMSCA) provision for relying on trailer brakes applies only to employers that are motor carriers. Other employers must ensure that forklift operators secure the trailer from movement before entering.
Do fixed ladders need cages?
Fixed ladders over 24 feet high that were installed prior to November 19, 2018, must have a personal fall arrest system, ladder safety system, cage, or well per 1910.28(b)(9)(i)(A). Employers must update those ladders with a fall arrest or ladder safety system by November 18, 2036.
OSHA previously required cages or wells on fixed ladders over 20 feet but removed that requirement in 2017. Employers often install cages on ladders under 24 feet for various reasons, such as limiting access, but OSHA does not require this. For related information, see our article, Planning fixed ladder fall protection upgrades.
Can we use designated areas on flat roofs?
A personal fall arrest or travel restraint system is required for work within 6 feet of the edge, but a designated area can be an option for work further from the edge. It can be used on low-slope roofs in two situations:
- If the work will be at least 6 feet (but less than 15 feet) from the edge, a designated area may be used if the work is infrequent and temporary, such as changing an air conditioner filter once per month.
- If employees will be working 15 feet or more from the edge, a designated area may be used even if the job will take several days or weeks.
Surprisingly, if employees will be at least 15 feet from the edge and the work qualifies as infrequent and temporary, no fall protection is required (not even a designated area). OSHA offered clarification on the terms “infrequent” and “temporary” in a Letter of Interpretation dated June 12, 2020.
Key to remember: The fall protection requirements in the Walking-Working Surface regulations raise many questions, but OSHA has published some clarifying guidance.
NewsIndustry NewsConfined SpacesSafety & HealthConfined SpacesConstruction SafetyGeneral Industry SafetyPermit-Required Confined SpacesConfined Space HazardsConfined Space Entry PermitIn-Depth ArticleEnglishFocus AreaUSA
2023-05-18T05:00:00Z
Breaking the plane of a confined space doesn’t require a complete entry
Did you know that OSHA’s standard on permit-required confined spaces (PRCS) says entry occurs as soon as any part of the entrant’s body breaks the plane of the opening into the permit space?
Many workers and employers mistakenly think that placing part of the body or hands into a confined space isn’t entry. Knowing the difference between when entry occurs and not will help employers determine if a permit is required.
Letters of Interpretation
As clarified in an OSHA Letter of Interpretation (LOI) dated October 18, 1995, “When any part of the body of an entrant breaks the plane of the opening of a PRCS large enough to allow full entry, entry is considered to have occurred and a permit is required, regardless of whether there is an intent to fully enter the space.”
This definition of “entry” might seem to be too strict. Still, OSHA’s letter clarifies that there are situations where a partial entry would be hazardous: “Examples of situations where entry by only part of the body into a PRCS can expose an entrant to the possibility of injury or illness are as follows:
- An entrant can possibly suffer a burn while reaching into a PRCS, which is so classified because it contains a thermal hazard.
- An entrant can possibly fall into a below-grade PRCS while standing on a vertical ladder in the opening of the space, which is so classified because it contains an oxygen-deficient atmosphere.
- An entrant can possibly become unconscious as result of his head accidentally entering a PRCS while they are reaching into a PRCS, which is so classified because it contains an oxygen deficient atmosphere.”
As another example, if the space contains a flammable or oxygen-enriched atmosphere, and if the activities during a partial entry could produce a spark or other ignition source, then a fire in the space could flash out of the opening and cause serious injuries to the employee.
OSHA’s guidance continues
This doesn’t necessarily mean you’d be fined if a permit wasn’t followed when someone reached a tank. OSHA’s guidance continues: “However, if entry by only part of the body does not expose the entrant to the possibility of injury or illness, then the violation may be considered a ‘de minimis’ violation.”
A de minimis violation is one in which a standard is violated, but the violation has no direct or immediate relationship to employee safety or health. These violations are documented but no citations are issued.
OSHA says examples of situations where entry by only part of the body into a PRCS would not expose an entrant to the possibility of injury or illness are as follows:
- An entrant reaches through the opening of a horizontal PRCS, which is so classified only because it contains exposed live electrical parts ten feet from the opening.
- An entrant puts his head through the opening of an overhead PRCS, which is so classified only because it contains unguarded rotating parts ten feet from the opening.
Also, consider a situation such as a worker reaching through a small grate to take a sample from a permitted space. The LOI further states, “If a part of the body were placed in an opening through which the worker could not pass into the permit-required confined space, no PRCS entry will have occurred.”
Keep in mind, however, that the employee would still need protection from any hazards involved in the task, but a permit would not be needed.
Key to remember
When any part of the body of an entrant breaks the plane of the opening of a PRCS large enough to allow full entry, entry is considered to have occurred, and a permit is required.
NewsIndustry NewsSafety & HealthConstruction SafetyGeneral Industry SafetyGeneral Duty ClauseIn-Depth ArticleEnglishGeneral Duty ClauseFocus AreaUSA
2026-07-22T05:00:00Z
When summer shows up, so do the bugs
Heat stress isn't the only outdoor hazard that ramps up during the summer months. While hydration and cooling strategies are essential, employers shouldn't overlook the insects that emerge with the warmer weather. Ticks, mosquitoes, bees, and wasps can expose workers to diseases, allergic reactions, and other serious health risks that deserve the same level of attention as the heat.
Bug-proofing your workers
Preventing insect and tick exposures doesn't require a complicated program. The goal is to help workers recognize the hazards they may encounter, take simple precautions, and reduce the chances that a routine bite or sting turns into a serious injury, illness, or medical emergency. A few practical steps can go a long way:
- Build awareness. Make sure workers know what they might encounter, where exposures are most likely, and what symptoms to watch for.
- Provide protection. Keep insect repellent, appropriate clothing, and any needed PPE available when work may involve exposure.
- Reduce the risk at the source. Control standing water, trim vegetation, and inspect equipment, materials, and work areas for nests before work begins.
- Be prepared to respond. Have first aid supplies readily available and establish a process for reporting bites, stings, and signs of illness.
- Know your workforce. Understand whether employees have severe insect-sting allergies and ensure appropriate emergency response procedures are in place.
- Make prevention part of the routine. Include insect hazards in pre-task planning, keep repellent accessible in vehicles and job boxes, and encourage tick checks at the end of the day.
- Track incidents and trends. Document bites, stings, and insect-related illnesses so recurring hazards can be identified and addressed.
More than just nuisance bugs
Workers don’t have to be deep in the woods to face risks from insects and ticks. Exposure can happen during routine tasks along fence lines, near drainage ditches, around overgrown vegetation, or when working on equipment that has been sitting unused.
Ticks thrive in grassy, brushy areas and can attach to a worker without being noticed. Mosquitoes breed in standing water and become especially active during warmer months. Bees and wasps often build nests in structures, underground, or inside equipment and materials, creating unexpected hazards in active work areas.
These exposures are more than a minor annoyance. Stings can trigger severe allergic reactions, including anaphylaxis, a life-threatening medical emergency that requires immediate treatment. Ticks and mosquitoes can also transmit diseases such as Lyme disease, West Nile virus, and other illnesses that may not appear until days or even weeks after exposure.
The potential consequences are real. According to CDC data, 788 people in the United States died from bee, wasp, and hornet stings between 2011 and 2021, an average of about 72 deaths each year, with most fatalities linked to severe allergic reactions. What may seem like a routine outdoor task can quickly become a serious medical event if insect and tick hazards are overlooked.
Indoors, outdoors, both covered
OSHA doesn't have a standard devoted solely to insect hazards in outdoor work environments. However, under the General Duty Clause, employers are responsible for protecting workers from recognized hazards, which can include exposures such as ticks in brushy areas or wasps nesting on equipment and structures.
For indoor and enclosed workspaces, OSHA is more direct. The vermin control provisions of the Sanitation standard, 29 CFR 1910.141(a)(5), require employers to maintain workplaces in a manner that prevents insects and other pests from entering or nesting and to implement an effective extermination program when infestations are present.
Whether the concern is a tick-infested worksite, standing water attracting mosquitoes, or a wasp nest tucked inside a job trailer, employers should take reasonable steps to identify and control these hazards before workers are exposed.
Key to remember: Insect hazards can show up in just about any work environment. A little awareness and a few simple controls can help keep a routine bite or sting from turning into something more serious. Bugs may be part of the job, but being unprepared for them doesn't have to be.
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