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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
See More
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Most Recent Highlights In Environmental
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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 updates on EPA’s docket include 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 regulations for four PFAS established under the NPDWRs.
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 Standards 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 | Title |
| 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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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 |
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.
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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!
Most Recent Highlights In Transportation
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!
NewsHazardous WasteEnforcement and Audits - OSHAToxic Substances Control Act - EPAToxic Subtances Control Act - EPAElectronic Reporting of Injury and Illness RecordsTSCA ComplianceMonthly Roundup VideoCAA ComplianceUSAInjury and Illness RecordkeepingWaste/HazWasteEnglishOSHA Violations and PenaltiesIndustry NewsCrystalline SilicaWaste HandlersSafety & HealthGeneral Industry SafetyWasteWaste TransportersEnvironmentalFocus AreaToxic and Hazardous Substances - OSHAVideo
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!
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.
Most Recent Highlights In Safety & Health
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 ComplianceEnglishMunicipal WastewaterWater PermittingChange 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).
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.
NewsHazardous WasteWaste HandlersChange NoticesChange NoticeWasteWaste/HazWasteWaste ManagementEnvironmentalNevadaEnglishFocus Area
2026-06-24T05:00:00Z
Nevada adds requirements for hazardous waste recyclers
Effective date: June 8, 2026
This applies to: Hazardous waste recyclers
Description of change: The State Environmental Commission adopted regulations to add requirements for entities that recycle certain hazardous waste, including compliance with:
- Certain federal requirements;
- Local zoning requirements, if applicable;
- Specific reporting and notification requirements; and
- Other particular regulations of the commission.
The rules also:
- Exempt owners and operators of certain facilities that recycle certain hazardous materials without storing those materials before they’re recycled from the above requirements, and
- Add fees for written determinations (required to construct or operate a facility or mobile unit for hazardous waste recycling) and for the facilities that recycle certain hazardous materials without storing those materials before they’re recycled.
Most Recent Highlights In Human Resources
NewsToxic Substances Control Act - EPAChange NoticesChange NoticeTSCA ComplianceToxic Substances - EPACaliforniaEnvironmentalEnglishFocus Area
2026-06-24T05:00:00Z
California adds TPhP nail products to Priority Products list
Effective date: October 1, 2026
This applies to: Nail products containing triphenyl phosphate (TPhP) at concentrations greater than 250 parts per million (ppm)
Description of change: The California Department of Toxic Substances Control added nail products with concentrations of 250 ppm or more of TPhP to the Priority Product list, making the substance subject to the Safer Consumer Products (SCP) Regulations.
By November 30, 2026, manufacturers must submit a Priority Product Notification. By March 30, 2027, manufacturers must submit:
- A Chemical Removal Intent/Confirmation Notification,
- A Product Removal Intent/Confirmation Notification,
- A Product-Chemical Replacement Intent/Confirmation Notification, or
- A Preliminary Alternatives Analysis Report or alternate reporting options.
NewsIndianaSafe Drinking WaterChange NoticesChange NoticeWater ProgramsEnvironmentalCWA ComplianceEnglishUnderground Injection ControlFocus Area
2026-06-24T05:00:00Z
Indiana adds permanent underground carbon dioxide storage rules
Effective date: June 10, 2026
This applies to: Entities that seek to participate in carbon sequestration projects
Description of change: The Natural Resources Commission adopted rules for permanent underground carbon dioxide storage, establishing:
- The rules for entities seeking to petition the Indiana Department of Natural Resources to issue involuntary integration orders for pore spaces, and
- The rules for storage operators seeking to apply for certificates of project completion.
These regulations add options for entities; the requirements apply only if the options are utilized.
The rules impact entities seeking to participate in carbon sequestration projects. The regulations also affect pore space owners and surface owners.
NewsTier II Inventory ReportingIndustry NewsIndustry NewsCERCLA, SARA, EPCRAEnvironmental Protection Agency (EPA)Safety Data Sheet ReportingEnvironmentalEnglishSARA ComplianceFocus AreaUSA
2026-06-24T05:00:00Z
EPA aligns EPCRA rules with OSHA’s HazCom amendments
The Environmental Protection Agency (EPA) published a final rule on June 22, 2026, conforming the hazardous chemical inventory reporting regulations under the Emergency Planning and Community Right-to-Know Act (EPCRA) to the Occupational Safety and Health Administration’s (OSHA’s) Hazardous Communication (HazCom) standard amendments of 2012 and 2024.
Who’s covered?
The final rule applies to facilities regulated under EPCRA Sections 311 and 312. These facilities are:
- Required by OSHA’s HazCom standard to maintain Safety Data Sheets (SDSs) for hazardous chemicals on-site at or above the reporting threshold, and
- Required by EPA’s EPCRA Section 312 rules (40 CFR Part 370) to submit annual hazardous chemical inventory reports (commonly known as Tier II reports) for the same chemicals by March 1.
Covered facilities submit SDSs and annual inventory reports to the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and local fire department.
How does this impact facilities?
EPA’s final rule replaces the previous EPCRA hazard categories with OSHA’s GHS-aligned hazard classes and hazard categories (totaling 118), which are already used in SDSs. Facilities must use OSHA’s hazard classes with their categories for SDS submissions and hazardous chemical inventory reports required under EPCRA Sections 311 and 312.
Note: SDSs for substances already contain the updated hazard classes and hazard categories. SDSs for mixtures must incorporate them by November 2027.
What’s the compliance timeline?
Covered facilities must use the new hazard categories by January 1, 2028. EPA expects facilities to incorporate them into the reporting year 2027 Tier II report (due March 1, 2028).
Key to remember: EPA has aligned regulations under EPCRA Sections 311 and 312 with OSHA’s HazCom amendments for hazardous chemical reporting requirements.
NewsProcess Safety ManagementRisk Management ProgramRisk Management ProgramCAA ComplianceIn-Depth ArticleEnglishSafety Data SheetsIndustry NewsSafety & HealthGeneral Industry SafetyGeneral Duty ClauseEnvironmentalFocus AreaHazardous Materials Safety - OSHAHazard CommunicationGeneral Duty ClauseAir ProgramsUSA
2026-06-23T05:00:00Z
CSB mounts pressure on OSHA, EPA over deadly process safety gap
Sugar may seem pretty harmless. However, a deadly explosion at a Kentucky caramel coloring facility reveals how this assumption can lead to disaster. The Chemical Safety and Hazard Investigation Board (CSB) is again urging OSHA and EPA to address a gap in their chemical safety regulations.
The board is calling for them to tackle “reactive hazards.” These are the hazards CSB says triggered the tragedy. The familiar message has been repeated since 2002, but the alarm bells grow louder and more urgent now. These warnings are not just for OSHA and EPA. They are also for chemical plants and food ingredient manufacturers. Despite not being covered in the process safety and risk management standards, reactive hazards can and have led to catastrophe.
Runaway reaction
CSB determined that the explosion happened when a 2,500-gallon reactor experienced a runaway decomposition reaction. The reaction involved an “invert sugar” ingredient used to make caramel coloring. It rapidly increased the temperature and pressure. Then it overwhelmed the reactor’s emergency pressure relief system.
The reactor ruptured violently. Two workers died when the blast damaged a control room 40 feet from the reactor. Debris from the incident traveled as far as 400 feet beyond the facility fence line. It also caused approximately $40 million in damage.
CSB found that the reactor’s emergency pressure relief system would have needed to be about four times larger. This would have allowed it to safely relieve pressure generated during the runaway reaction.
Failure to recognize the hazard
CSB’s investigation found that the company did not understand the severe reactive hazards associated with the sugar ingredient. According to the board, this failure contributed to an undersized pressure relief system. It also created confusion on the day of the incident about the increasing pressure.
The report further states that the company’s lack of knowledge stemmed from:
- An incomplete investigation of the ingredients’ reaction potential,
- A lack of industry guidance on the safe manufacture of caramel coloring, and
- No warning on the safety data sheet (SDS) of reaction hazards.
SDS lacked critical information
The board found that the SDS provided by the sugar manufacturer did not warn of its reactivity hazards. CSB concluded that safety information communicated in sugar ingredient SDSs can vary significantly among suppliers. The board noted that improved hazard information in SDSs can help prevent future sugar decomposition incidents. CSB is urging industry groups and suppliers who manufacture invert sugar or corn syrup to update their SDSs for decomposition hazards.
Known regulatory gap
The report emphasizes a gap in:
- OSHA 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals (PSM); and
- EPA 40 CFR 68, Chemical Accident Prevention Provisions, also known as the Risk Management Program (RMP).
That gap is a lack of coverage of facilities processing chemicals with reactive hazards that could have catastrophic consequences.
The Kentucky caramel coloring plant was not subject to PSM and RMP. Had the facility been required to implement either regulation, the reactor designers would have had a better opportunity to be aware of the sugar ingredients’ decomposition hazards, says CSB. The board argues that this may have resulted in a safer design of the emergency pressure relief system.
Repeated recommendations
Since 2002, CSB has reiterated its recommendations for OSHA and EPA to fill the regulatory gap. Neither agency has implemented those recommendations.
Over that same period, the board investigated 15 additional incidents involving reactive chemicals not covered by PSM and RMP. Those incidents resulted in 31 fatalities and hundreds of injuries.
CSB is not deterred
CSB again recommends that OSHA and EPA broaden the coverage of PSM and RMP, respectively, to achieve more comprehensive control of reactive hazards.
Both OSHA and EPA currently use chemical lists to identify the processes subject to coverage. However, CSB claims the two agencies did not adequately consider reactive chemical hazards when developing those chemical lists. As a result, many reactive chemicals are currently not covered.
Word for employers and safety professionals
The latest report highlights the need for:
- Facilities to review not just the SDS for their chemicals but also additional sources of information about their reactive hazards.
- Chemical plants and food manufacturers to address reactive hazards regardless of coverage under 1910.119 and Part 68. At a minimum, these facilities may already be required to meet OSHA’s General Duty Clause and EPA’s Clean Air Act General Duty Clause.
Key to remember
The latest CSB report taps OSHA and EPA to address reactivity hazards. It is also a wake-up call for facilities to understand their reactive chemical hazards. What’s more, the report calls on chemical and food ingredient manufacturers to revisit their SDSs regarding reactive hazards.
NewsIndustry NewsWaste IdentificationEnglishWasteWaste ManagementEnvironmentalIn-Depth ArticleWaste/HazWasteFocus AreaUSA
2026-06-18T05:00:00Z
Hazardous waste determinations in practice: Lessons from aerosols, residues, and empty containers
Hazardous waste determinations remain one of the most common sources of noncompliance under RCRA. The requirement is simple on paper. Generators must determine whether a material is a hazardous waste at the point of generation. In practice, facilities often struggle with how the rules apply to everyday situations. Aerosol cans, process residues, and empty containers are frequent gray areas that lead to inconsistent decisions, inspection findings, and, in some cases, enforcement.
At the core, the regulatory expectation is clear: generators must evaluate each waste to determine if it is listed or exhibits a characteristic of hazardous waste (40 CFR 262.11). That evaluation must be made when the waste is first generated and must be documented. The challenge is not the rule itself, but how it applies to materials that fall between operational categories – products, wastes, and residuals.
Aerosols: When a common waste becomes a compliance risk
Aerosol cans are widely used across industries for maintenance, coatings, and cleaning. Facilities often assume that once a can is “empty” or depressurized, it is no longer subject to hazardous waste rules. That assumption can be risky.
If an aerosol can contains a listed solvent or exhibits ignitability (D001), it is a hazardous waste unless managed under an exclusion or alternative standard. Since 2019, many aerosol cans can be managed as universal waste (40 CFR Part 273), which simplifies handling. However, this option introduces its own requirements, including labeling, accumulation time limits, and proper puncturing practices.
A common issue arises at puncturing stations. For example, a maintenance shop installs a puncturing device and begins draining leftover propellant and product into a drum. The cans themselves may now meet the empty container standard, but the collected liquid often remains hazardous waste. In several inspections, regulators have cited facilities not for the cans, but for failing to characterize the accumulated liquid or for allowing it to evaporate without proper controls.
The lesson is straightforward: shifting management methods (e.g., puncturing or using universal waste standards) does not eliminate the obligation to evaluate all resulting waste streams.
Residues: Small quantities, big implications
Residues are another frequent source of confusion. These can include paint booth sludge, tank bottoms, or material left in process equipment. Facilities sometimes view these materials as insignificant or assume they take on the classification of the original product. In reality, residues must be evaluated as newly generated wastes.
For example, a facility cleaning a parts washer may generate a sludge that contains spent solvent. Even if the waste solvent was originally a listed waste (e.g., F003 or F005), the generator must determine whether the residue is itself a listed waste or exhibits a characteristic. Missteps often occur when facilities rely on outdated Safety Data Sheets (SDSs) or assume that dilution or drying changes the classification.
Another scenario involves “letting residues dry out” in containers before disposal. While intended to reduce volume, this practice can be interpreted as treatment if it is done to change the waste’s characteristics (40 CFR 260.10 definition of treatment). For generators without a permit, this creates additional compliance risk.
The key takeaway is that residues are not an afterthought. They are distinct waste streams that require their own evaluation and, in some cases, can trigger more stringent requirements than expected.
Empty containers: A rule often misapplied
The empty container rule (40 CFR 261.7) is widely cited but frequently misunderstood. A container that held hazardous waste is considered empty if all wastes have been removed using common practices (e.g., pouring, pumping), and no more than one inch of residue remains (or 3% by weight for smaller containers).
In practice, facilities often overapply this rule. For example, a drum that held a listed solvent may be declared “empty” even though significant sludge remains at the bottom. Inspectors routinely check this by tipping containers or visually assessing residue. If the container does not meet the standard, it is still subject to full hazardous waste requirements.
Another common issue involves containers that held acute hazardous waste (P-listed). These have stricter emptying standards, including triple rinsing. Facilities that overlook this distinction can inadvertently manage regulated containers as non-hazardous scrap.
Importantly, even when a container meets the empty standard, any removed residue must still be evaluated as a waste. The container may be exempt, but the material removed from it is not.
Bringing it together in practice
Across these examples, a consistent pattern emerges: compliance issues arise when facilities rely on assumptions rather than applying the regulatory framework to each specific situation. Aerosols, residues, and empty containers all sit at the boundary between product use and waste management. That boundary is where most determination errors occur.
Facilities can reduce risk by standardizing evaluation procedures, training staff on common gray areas, and documenting determinations clearly. In inspections, regulators often focus less on the conclusion and more on whether the generator followed a defensible process under 40 CFR 262.11.
Key to remember: Every waste stream, no matter how small or routine, requires a fresh, documented determination at the point of generation. Management shortcuts do not replace regulatory obligations.
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Most Popular Highlights In Environmental
NewsGroundwaterChange NoticesChange NoticeWater ProgramsColoradoEnvironmentalCWA ComplianceEnglishFocus Area
2025-08-29T05:00:00Z
Colorado revises water well construction rules
Effective date: January 1, 2026
This applies to: Entities subject to the Well Construction Rules
Description of change: The Board of Examiners of Water Construction and Pump Installation Contractors adopted amendments to:
- Establish online, open-book assessments for well owners constructing wells or installing pumping equipment;
- Change well construction requirements for Confined (Type 1) Aquifers by:
- Expanding minimum annular space for grout,
- Specifying sealing requirements,
- Allowing solid casing for all confined aquifer wells, and
- Allowing solid granular bentonite for minimum grouting requirements.
- Change monitoring and observation requirements by:
- Establishing minimum grouting interval and grouting annular space requirements,
- Restricting filter packs to the monitored interval, and
- Improving abandonment requirements.
NewsWater PermittingChange NoticesChange NoticeWater ProgramsWater QualityWater ReportingFloridaEnvironmentalWater ProgramsEnglishFocus AreaCWA Compliance
2025-12-02T06:00:00Z
Florida allows reciprocity for water system operator licensing
Effective date: November 6, 2025
This rule applies to: Out-of-state licensed treatment plant operators and distribution system operators
Description of change: The Florida Department of Environmental Protection adopted rules to:
- Implement licensure reciprocity, allowing the department to issue licenses by reciprocity to water treatment, domestic water treatment, and water distribution system operators with out-of-state licenses; and
- Allow the department to issue temporary operator licenses during a declared state of emergency to out-of-state licensed treatment plant and distribution system operators during a declared state of emergency.
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 updates on EPA’s docket include 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 regulations for four PFAS established under the NPDWRs.
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 Standards 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 | Title |
| 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) |
NewsToxic Substances Control Act - EPAWasteWater ProgramsWater ProgramsCWA ComplianceEnglishAir ProgramsIndustry NewsIndustry NewsToxic Substances - EPAWasteAir ProgramsEnvironmentalFocus AreaUSA
2021-05-14T05:00:00Z
Enforcement Focus
A look at where regulators are focusing their enforcement efforts
Enforcement action and monetary penalties are unfortunately common in environmental programs and prove costly to companies. Beyond the penalty assessed, companies often spend even more improving processes to prevent recurrence. This section shares some of the headlines and presents take-away lessons. What happened and how do you avoid the same situation?
Air
Washington Department of Ecology issued a penalty to a pulp and paper mill in the state for air emissions released from the facility’s wastewater treatment plant. As the result of wastewater treatment plant upset conditions, the mill failed to meet emission reduction requirements for a seven-week period in 2020. The mill calculated an additional 7 tons of methanol and other types of hazardous air pollution were emitted from the operation during this period. In addition to the monetary penalty, the mill has been required to increase monitoring as a long-term preventative measure.
Enforcement action: $28,500 civil penalty
Lesson learned: A process upset in one part of an operation can have effects on related, but separate areas. Identifying and planning for these indirect impacts can reduce risk of noncompliance.
Hazardous waste
California’s Department of Toxic Substances Control (DTSC) reached a settlement with an electronic recycling facility in the state for hazardous and universal waste violations. Found during an inspection, DTSC identified multiple problems within the company’s waste management program. Violations included:
- Shredding of mercury-containing devices without a permit;
- Administrative issues including the lack of training, manifest deficiencies, improper emergency response procedures, and inadequate financial assurance;
- Storing of universal and hazardous wastes outside of designated areas and in excessive amounts; and
- Missing and inadequate labeling.
Enforcement action: $310,000 civil penalty
Lessons learned: Because of the serious health risks, mercury containing wastes require handling and disposal beyond those of other electronic wastes.
DTSC has taken a number of similar actions with other facilities in the state and appears to be making an extra push to hold sources accountable for potential and actual releases of toxic substances.
Water quality
The State of Illinois has entered settlement with a trucking distribution center related to an oil release that occurred in 2018. In 2018, the terminal released approximately 4,000 gallons of diesel fuel, from a leaking storage tank. The fuel entered the site drainage system, making its way to the nearby 4-acre pond, that then flows out into a local creek. The leak was not reported by the trucking terminal, escalating the severity of the incident. However, since the initial release the company has participated in cleanup plans and actions.
Enforcement action: $25,000 civil penalty
Lesson learned: Maintaining secondary containment, inspection programs, and level monitoring equipment are all best practices that can reduce risks of releases and associated costs.
Chemical reporting
U.S. EPA Region 5 announced settlement with a specialty chemical distributor for violations of the chemical data reporting (CDR) section of the federal Toxic Substances Control Act. The company failed to accurately report 18 chemicals that had been imported during the 2012 to 2015 compliance period. Chemicals distributed by the company are sold to a variety of manufacturing industries, that in turn use the substances in formulation of rubber, plastics, adhesives, sealants, and coatings.
Enforcement action: $357,000 civil penalty
Lesson learned: CDR reporting is an important source of data for EPA and something it takes seriously. Even though intermittent, these reports must be accurate and timely.
2026-01-02T06:00:00Z
Florida adds grease waste hauler requirements
Effective date: December 7, 2025
This applies to: Haulers of grease waste from food establishments
Description of change: The Florida Department of Environmental Protection established removal and disposal regulations for haulers of grease waste from originator food establishments. Haulers must dispose of grease waste at certified facilities and document removals and disposals using a service manifest.
NewsIndustry NewsTSCA ComplianceCAA ComplianceSustainabilityIn-Depth ArticleCWA ComplianceEnvironmentalEnglishSustainabilityESG (Environmental, Social, and Governance)Focus AreaUSA
2025-12-05T06:00:00Z
EPA’s 2026 regulatory shift: How environmental managers can stay ahead
The clock is ticking for environmental teams. By 2026, several new EPA regulations will reshape compliance obligations for U.S. companies. Organizations that act now will avoid costly penalties and operational disruptions.
What’s changing and why it matters
Although EPA has been deregulating or loosening some requirements, there are still some standards being tightened across multiple fronts in the coming year:
- Renewable fuel standards (RFS): The EPA proposed higher volume requirements for 2026, including 24.02 billion renewable identification numbers (RINs), up nearly 8% from 2025. This increase pushes stricter expectations on fuel producers and organizations purchasing renewable fuels.
- Stormwater multi-sector general permit (MSGP): A new MSGP set to take effect by February 2026 will require quarterly PFAS indicator monitoring, expanded benchmark sampling, and resiliency measures in stormwater control designs.
- PFAS Reporting under the Toxic Substances Control Act (TSCA): TSCA Section 8(a)(7) mandates PFAS manufacturing and import data collection beginning in April 2026, through October 2026, with extended deadlines for certain small manufacturers.
Failure to prepare could lead to fines, reputational damage, supply chain disruptions, and permit delays. Companies that weave compliance planning into their 2026 strategy will be positioned not just to meet legal deadlines but to sustain operations smoothly.
Key areas of impact
- Renewable fuel standards (RFS) and air emissions The proposed increase in 2026 Renewable Identification Numbers (RIN) volumes, from 24.02 billion to 24.46 billion for 2027, signals tightening air and fuels policy that affects fuel use and emissions accounting.
- Stormwater management The upcoming 2026 MSGP requires expanded quarterly PFAS monitoring, new benchmark triggers, corrective action plans, and integration of climate resilience in design standards.
- PFAS disclosure (TSCA Section 8(a)(7)) Manufacturers and importers of PFAS must submit electronic reporting of usage, volumes, disposal, and exposure data between April and October 2026, with extensions available for smaller operations.
Steps to take now
- Audit compliance programs: Cross-check operations against RIN inventory, stormwater permits, and TSCA reporting duties.
- Upgrade monitoring and recordkeeping: Implement robust electronic systems to track PFAS, stormwater quality, fuel volumes, and emissions.
- Staff training: Educate teams on PFAS obligations, new stormwater protocols, and RFS structures.
- Engage regulators early: Comment on proposed rules, consult during permit drafting, and flag issues during the notice-and-comment period.
Looking ahead
The EPA’s 2026 updates reflect a trend toward increased transparency and environmental accountability. Companies that treat compliance as strategic will not only avoid enforcement but also gain resilience and stakeholder trust.
Key to remember: Start planning now. Early action on EPA rule changes will save time, money, and headaches when enforcement begins.
Most Popular Highlights In Transportation
NewsIndustry NewsIndustry NewsFleet SafetyLockout/TagoutFocus AreaHeavy vehicle use tax HVUTEnglishInternational Fuel Tax Agreement (IFTA)TransportationUSA
2021-09-08T05:00:00Z
Keep New Mexico weight-distance taxes on the radar
You’re up to date on your IFTA and HVUT tax payments, congratulations! Not so fast. If you operate in New Mexico, you’re not quite finished.
Beyond the routine
You’re probably familiar with the routine taxes that most carriers must pay.
One main program, the International Fuel Tax Agreement (IFTA), requires carriers to obtain a license and file quarterly tax returns with a base jurisdiction. The base jurisdiction then distributes the necessary fuel taxes to other jurisdictions.
Another tax that often applies to carriers, the Heavy Vehicle Use Tax (HVUT), is collected by the Internal Revenue Service (IRS) and applies to highway motor vehicles with taxable gross weights of 55,000 pounds or more.
Those programs are fairly well known. But there are a handful of states — New Mexico is one — that also assess carriers with a “weight-distance” tax in addition to the heavy vehicle use and IFTA taxes.
New Mexico specifics
In New Mexico, the weight-distance tax (WDT) applies to owners, operators, and registrants of intra- and interstate commercial vehicles with a declared gross vehicle weight in excess of 26,000 pounds.
Owners and operators of all motor vehicles with a declared gross weight or gross vehicle weight in excess of 26,000 pounds who are using highways in the state must file a return and pay the tax.
If your trucks operate on New Mexico highways, you do have options. You can register each vehicle and then report and pay weight-distance tax quarterly, or you could pay the trip tax each time one of your trucks enters or exits the state.
The tax is based on vehicle weight and miles traveled on New Mexico roads, so you’ll need those records. The tax is computed by multiplying the miles traveled in New Mexico by the applicable tax rate. If your operation is subject to the weight-distance tax, remember to:
- File a New Mexico weight-distance tax return on a quarterly basis, and
- Pay the tax due to the Motor Vehicle Division.
If this program applies to your fleet, you must register and apply each year for a New Mexico Weight-Distance Tax Electronic Permit for each of your vehicles. If a quarterly weight-distance tax report has not been submitted, the system will not allow the e-permit to be processed.
Key to remember: If you operate in New Mexico, be sure to add the weight-distance tax to your list of quarterly payments.
NewsIndustry NewsInternational Registration Plan (IRP)Vehicle registration exemptionsMotorcoach vehicle license or registrationVehicle Registration PermitsFocus AreaIn-Depth ArticleFleet OperationsEnglishTransportationRegistration and Permits - Motor CarrierUSA
2026-07-09T05:00:00Z
Does your registration still match your operations?
A truck may have valid plates, current registration, and no obvious paperwork problem, yet still be improperly registered for the work it’s doing today.
As your fleet grows and operations change, it's easy for vehicle registration to lag behind reality. The result can be citations, permit issues, unexpected fees, operational delays, and compliance headaches. Here are three common situations where a registration may no longer match the operation.
Is your registered weight still accurate?
One of the most common registration issues involves registered weight. A vehicle may be legally capable of hauling heavier loads, but that doesn't necessarily mean it’s registered to do so.
As business grows, carriers often begin hauling larger loads, adding customers, or expanding routes. If your vehicle's registered weight isn't updated to reflect those changes, you could face penalties for operating above the weight authorized by its registration.
This issue often goes unnoticed because the truck itself hasn't changed. However, enforcement officials are concerned with how the vehicle is registered, not just what it’s capable of hauling.
Whenever freight volumes, routes, or operating weights change, review your registration records to ensure they still align with actual operations.
Is the vehicle operating under the right plate type?
Not all registrations are created equal. Many states offer specialty or reduced-fee registrations for certain operations, such as:
- Farm vehicles,
- Natural resource vehicles,
- Forestry operations, or
- Other restricted uses.
Specialty plates can save money, but they also come with strings attached. Carriers must comply with those limits for the registration to remain valid. Problems arise when a vehicle's operation changes but its registration does not.
For example, a vehicle may have been properly registered under a specialty plate when it was performing one type of work. If the vehicle later begins hauling different commodities, traveling outside permitted areas, or performing general commercial transportation, it may no longer qualify for that registration class.
A good practice is to review registration classifications whenever equipment is reassigned, new customers are added, or business activities expand beyond their original scope. The registration and the vehicle's use must continue to match.
Has interstate travel changed the rules?
Another common issue occurs when operations expand beyond your home state.
A vehicle that is properly registered for intrastate operations may require additional credentials or registrations once it begins operating across state lines. What starts as an occasional out-of-state trip can gradually evolve into a regular part of the business.
Because the change often happens incrementally, carriers may not realize that their registration and credentialing requirements have changed along with their operations.
Before crossing state lines, evaluate whether additional registration, apportioned registration, permits, or other interstate credentials are required. Waiting until a roadside inspection or audit to discover a registration issue can be a costly mistake.
Three questions to ask
New customers, new commodities, expanded routes, and heavier loads can all affect registration requirements. Before a vehicle goes back on the road after business changes, ask:
- Is this vehicle registered for the weight I'm operating at?
- Does the registration type still match how I'm using the vehicle?
- Has my operating area expanded beyond what the registration was intended to cover?
If the answer to any of those questions is "I'm not sure," it's time for a registration review.
Key to remember: Registration should never be treated as “set it and forget it.” If the operation changes, the registration may need to change with it.
NewsDriver qualificationsTransportationPerformance ManagementAnnual MVR reviewTraining & DevelopmentEmployment application driverIn-Depth ArticleHuman ResourcesEnglishIndustry NewsFleet SafetyDrivers qualification (DQ file)Driving RecordsPerformance AppraisalsFocus AreaUSA
2023-11-27T06:00:00Z
Canadian Driver Abstracts: Why evaluating them matters.
A driver abstract is a government-issued document that provides a summary of a driver’s driving record, such as license status, demerit points, convictions, suspensions, and collisions. The term abstract is more commonly used in Alberta, Quebec, and Ontario, while the term driver’s record is more commonly used in British Columbia and Saskatchewan. However, they both refer to the same type of document that summarizes the basic driving history of a driver.
Canada’s National Safety Code, Standard 15 requires commercial driver abstracts to be reviewed on an annual basis for existing drivers, however, industry best practice is a quarterly review.
Reviewing driver abstracts can also serve as an excellent tool to help identify training needs across your team. By taking the time to understand where your drivers may struggle or have issues, you can adjust or implement training programs to reduce your risk of future incidents.
Here are some general tips on how to review and evaluate a driver abstract.
What is the right type?
Before we get to reviewing and evaluating a driver abstract, you first need to understand the different types of abstracts. There are two types of abstracts available so depending on the purpose: a standard abstract, also known as a personal abstract, or a commercial driver abstract.
A standard driver abstract provides information from the individual’s driving record and will include the following information:
- Driver information (name, address, driver licence numbers, class and issue date etc);
- Driver’s appearance (height, weight, etc);
- Current status of the driver’s licence;
- Conviction information;
- Demerit points, and;
- Suspensions.
A commercial driver abstract or a commercial vehicle operator’s registration abstract (CVOR) will include safety risks associated with the driver when operating a commercially registered vehicle. It provides most of the same information (excluding driver appearance details) as the standard but has additional information about Commercial Vehicle Safety Alliance (CVSA) inspections and enforcement.
Abstract are available covering a 3-year, 5-year, or 10-year period. Since most convictions stay on a driver abstract for at least three years, it is the most common record to request. Some convictions however, such as those for impaired driving, will remain on the record for longer.
Evaluating a driver abstract.
To evaluate a driver abstract, you may need to compare it with the standards and requirements of the purpose for which you need it. For example, you may have a policy on the maximum number of demerit points or convictions that you accept for your drivers. Some jurisdictions may have different rules and regulations when transferring a driver’s licence from another province or territory.
The codes and symbols on a driver abstract may also vary by province or territory. You can find explanations of the codes and symbols on the abstract itself or on the website of the issuing authority. For example, in British Columbia the “N” indicates an enhanced abstract containing non-moving violations and was designed for National Safety Code (NSC) purposes in conjunction with the NSC column indicating whether the vehicle is registered under a NSC certificate and the violation was during the operation of a commercial vehicle.
To evaluate a driver abstract, it is recommended you look for:
- The validity and expiry date of the driver’s licence;
- The class and endorsements of the driver’s licence;
- The number, type and frequency of demerit points;
- The number and severity of suspensions and convictions;
- The date and details of any accidents or violations; and
- Whether the driver is in compliance with any reinstatement conditions or restrictions.
Once you see patterns in the abstracts, you can take action to correct the behavior. For example, if a driver has been struggling with X and racking up demerit points, re-train the driver on X. Or, maybe you notice that several drivers are getting in rear-end collisions and decide it’s time to retrain on defensive driving. Collect the driver abstract and look at it, but also take time to evaluate the data. It can guide you in ensuring you’re focusing efforts in the right areas.
Key to remember: Evaluating your drivers’ behaviors and driving habits can help you improve their skills and the safe operation of your trucks.
NewsIndustry NewsAdverse driving conditionsFleet Safety15-hour on-duty ruleHours of Service10-hour driving rule14-hour rule11-hour driving ruleFocus AreaIn-Depth ArticleEnglishTransportationUSA
2022-12-01T06:00:00Z
Making good use of the ‘bad weather’ exception
At this time of year, bad weather or an ice-covered road can be as close as the next bend. When these unexpected conditions arise, they can result in lengthy, expensive delays, sometimes forcing drivers to reach their hours-of-service limits sooner than expected. Fortunately, the federal hours-of-service rules contain an exception that allows drivers to stay on the road a little longer in these situations, to complete their runs or find a safe place to park.
It’s important for dispatchers and drivers to know exactly how and when they can use this exception, though, because bad weather is definitely NOT an excuse to drive as much as you want.
Both limits are extended
The exception allows truck and bus drivers to exceed the normal driving and on-duty limits by up to two additional hours to complete their run. When using this exception:
- Truck drivers may drive for up to 13 hours within a 16-consecutive-hour period, and
- Bus drivers may drive for up to 12 hours within their first 17 hours on duty.
Even when the exception applies, drivers do not receive an automatic two-hour extension. The idea is that drivers can gain back the time they lost to the delay, up to two hours. If conditions are so bad that continued driving is unsafe, drivers are expected to stop driving as soon as they can find a safe parking area, even if they still have hours available.
Was it really unforeseen?
The exception can be used only when there are unforeseen “adverse driving conditions.” For example, if the driver or the person dispatching the run knows — before the run begins — that the driver will be heading through a major snowstorm, the exception cannot be used. Refer to this important definition:
“Adverse driving conditions means snow, ice, sleet, fog, or other adverse weather conditions or unusual road or traffic conditions that were not known, or could not reasonably be known, to a driver immediately prior to beginning the duty day or immediately before beginning driving after a qualifying rest break or sleeper berth period, or to a motor carrier immediately prior to dispatching the driver.”
Based on this definition:
- The exception cannot be used to overcome normal, expected delays, such as rush-hour traffic around a major city or delays caused by loading and unloading.
- “Unusual traffic conditions” may include anything that unexpectedly causes a backup in traffic, such as a vehicle crash.
- You don’t need to go to extraordinary lengths to figure out if a driver might encounter adverse conditions on a given trip, you just need to make a “reasonable” attempt. For example, checking road conditions via navigation software and/or state DOT websites, and checking a weather app or online forecast, would be reasonable ways to learn of potential delays.
If a driver does encounter unforeseen “adverse driving conditions” and is unable to complete the run within the normal hours-of-service limits, the two-hour extension can be used to reach the end of the run or to find a safe place to park.
The “adverse driving conditions” exception can be found in 49 CFR 395.1(b).
Key to remember: Winter weather often brings adverse driving conditions, which means your drivers may become eligible for an exception from the normal hours-of-service limits. Make sure you know how to apply the exception properly.
NewsIndustry NewsViolations - HazmatIn-Depth ArticleHazmat SafetyHazmat: HighwayFocus AreaShipping papers - HazmatShipping papers - HazmatEnglishTransportationUSA
2022-10-12T05:00:00Z
Mixed loads - How to differentiate hazmat and non-hazmat shipping papers
When hauling hazmat in the same load with non-hazardous materials, the hazmat information must be easily seen and readily available when needed. This begins with emphasizing the hazmat entries on the shipping papers and locating the papers in a specific place in the truck.
With shipping paper accessibility in the top three hazmat violations again this year, now’s a good time to review your practices to keep your operations in compliance.
Easy to see: Make the hazmat obvious
The shipping paper must make it obvious that hazardous materials are listed, and the information must be quickly and easily identifiable in case of an emergency. While this is normally the shipper’s responsibility, in certain situations the driver may need to create shipping papers and would need to follow these guidelines.
Whenever a shipping paper includes descriptions of both a hazmat and a non-hazardous material, use one of the following methods to identify the hazmat:
- Enter the hazmat description first on the shipping papers; or
- Identify the hazmat entry by an "X" or "RQ" (as appropriate) in a column designated "HM"; or
- Enter the hazmat description in a color that clearly contrasts with the non-hazardous entry.
On a reproduction of the shipping paper, the hazmat description may be highlighted in a contrasting color.
Easy to access: Make sure they can find it
When transporting hazmat, the hazmat shipping papers must be readily available to and recognizable by authorities in the event of an accident or inspection.
In the pile of documents
If a hazmat shipping paper is carried with any other papers, it must be clearly distinguished by:
- Distinctively tabbing it, or
- Having it appear first.
In the cab of the truck
The hazmat shipping paper must be either:
- Readily visible to a person entering the driver's compartment, or
- In a holder that is mounted on the inside of the door on the driver's side of the vehicle.
When the driver is at the vehicle controls, the hazmat shipping paper must be within immediate reach when the driver is restrained by the lap belt.
When the driver is not at the vehicle controls, the hazmat shipping paper must be:
- In a holder mounted on the inside of the driver's door, or
- On the driver's seat in the vehicle.
What NOT to do
In “real life,” things happen. While it might be easy for a driver to hop into the truck and toss the shipping papers in a cubby above the visor or behind the seat on their bed, those locations do not satisfy the access requirements for shipping papers.
Key to remember: To maximize safety and compliance, clearly emphasize hazmat on shipping papers and make the documents easily accessible in the truck.
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 NewsRecordkeepingRecordkeepingHR GeneralistFamily and Medical Leave Act (FMLA)In-Depth ArticleFamily and Medical Leave Act (FMLA)HR ManagementEnglishUSAFocus AreaHuman Resources
2026-05-20T05:00:00Z
Do the FMLA notices and certifications expire in June?
The answer to that question for employers is, “No.” The answer to that question for the U.S. Government’s Office of Management and Budget (OMB), however, is, “Yes.”
Employers might notice that the following federal Family and Medical Leave Act (FMLA) documents from the U.S. Department of Labor (DOL) have an expiration date listed as “6/30/26” in the upper right-hand corner:
- WH-381: Eligibility/Rights and Responsibilities Notice
- WH-382: Designation notice
- WH-380-E: Certification of an employee’s serious health condition
- WH-380-F: Certification of a family member’s serious health condition
- WH-384: Certification of a qualifying exigency
- WH-385: Certification for military caregiver of a current military member
- WH-385-V: Certification for military caregiver of a veteran
This, however, doesn’t mean that employers aren’t allowed to use these forms after that date. They may. Employers and employees are allowed to use the current forms beyond that date because the content remains applicable under FMLA law.
The June 30, 2026, date on the FMLA notices and certification forms, doesn’t represent a deadline for FMLA leave itself. It’s the OMB’s expiration date for the forms’ collection and recordkeeping requirements, not the end of the forms’ legal validity.
What the date means
These government documents are subject to certain checks and balances, such as the following:
- OMB control number 1235‑0003 governs the collection of information from employers and employees for DOL compliance purposes.
- The June 30, 2026, date is when the latest version of the forms will be replaced by a new OMB‑approved version.
The OMB has to review the FMLA notices and certification forms every 3 years. The last time it did so, it didn’t make any material changes.
The OMB is part of the U.S. Executive Office and helps the president meet policy and budget, manage details, oversee regulatory objectives, and helps fulfill the agency’s statutory responsibilities.
Model forms optional
Employers aren’t required to use the DOL’s model forms. Many do, however, because it’s easier than creating their own forms. Using the DOL’s forms also helps ensure the notices provide enough information and the certifications don’t ask employees for information beyond what the FMLA allows.
Key to remember: The June 30, 2026, expiration date of FMLA documents is just a form‑collection deadline, not a legal cutoff for FMLA leave or certification. Employers may still use the current forms until a new version is issued.
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.
NewsIndustry NewsAssociate Benefits & CompensationHR GeneralistFamily and Medical Leave Act (FMLA)In-Depth ArticleFamily and Medical Leave Act (FMLA)Associate RelationsEnglishHR ManagementFocus AreaHuman ResourcesUSA
2025-03-27T05:00:00Z
Who can fill out FMLA forms? The answer might surprise you
One of the most common questions involving the federal Family and Medical Leave Act (FMLA) that we see is: “Can ________ fill out the medical certification?”
This question stumps a lot of HR people and can be a little confusing.
It might be easier to start with who CAN’T fill out an FMLA certification. That includes your coworker, best friend, neighbor, or pet.
Jokes aside, often (but not always) a doctor fills out the FMLA certification, and since March 30 is “Doctors’ Day,” this is a great time to discuss this topic.
FMLA certification basics
Employers aren’t required to use certifications, but if they do, the U.S. Department of Labor (DOL) has five different certification forms to use for various FMLA leave situations.
The forms are as follows:
- Certification of Health Care Provider for Employee's Serious Health Condition,
- Certification of Health Care Provider for Family Member's Serious Health Condition,
- Certification of Qualifying Exigency for Military Family Leave,
- Certification for Serious Injury or Illness of a Current Servicemember for Military Family Leave, and
- Certification for Serious Injury or Illness of a Veteran for Military Family Leave.
Let’s focus on the first two, as these are the most common ones HR administrators use.
Who can fill out an FMLA certification?
The FMLA regulations describe the person who has the authority to fill out a certification as a “health care provider.” The good news is, the regulations include a lengthy list of medical professionals who fit this role.
Under the FMLA, a health care provider includes:
- A doctor of medicine or osteopathy,
- A podiatrist,
- A dentist,
- A clinical psychologist,
- An optometrist,
- A chiropractor (limited to manual manipulation of the spine as demonstrated by X-ray),
- A nurse practitioner,
- A nurse midwife,
- A clinical social worker,
- A physician assistant,
- A Christian Science practitioner, and
- Any health care provider from whom the employer or the employer's group health plan's benefits manager will accept a medical certification to substantiate a claim for benefits.
To be qualified to fill out FMLA forms, medical professionals must be authorized to practice in the state and perform within the scope of their practice. This means that the provider must be authorized to diagnose and treat physical or mental health conditions.
What about doctors in a foreign country?
If an employee or an employee's family member is visiting another country, or a family member resides in another country, and a serious health condition develops, the employer must accept a medical certification from a health care provider who practices in that country. This includes second and third opinions.
If a medical certification from a foreign health care provider is not in English, the employee may be required to provide a written translation of the certification.
Key to remember: The FMLA regulations spell out which medical professionals can fill out certification forms.
NewsDrug and Alcohol TestingDrug and Alcohol TestingDrug Free WorkplaceMarijuanaIn-Depth ArticleHR ManagementEnglishHuman ResourcesIndustry NewsSafety & HealthGeneral Industry SafetyHR GeneralistAssociate RelationsFocus AreaUSA
2023-12-28T06:00:00Z
New marijuana testing restrictions in effect for 2024: How to handle them
As of January 1, California and Washington have new marijuana laws that restrict testing for the drug.
Both states, which have legalized recreational and medical use, put limits on pre-employment testing for cannabis at the start of the year.
Washington’s rationale for the new law is that a pre-employment marijuana test limits job opportunities for those who use cannabis, because an applicant will test positive for up to 30 days after using it. The new law is designed to prevent the restriction of job opportunities based on an applicant’s past cannabis use.
California’s law notes that a test for marijuana detects past use of the drug, but does not prove whether or not an individual is impaired by it. Its protections are broader than Washington’s, and apply to employees as well as applicants. As a result, they also restrict reasonable suspicion, post-accident, and random marijuana tests.
Testing restrictions in California and Washington
The new state laws take aim at tests measuring nonpsychoactive cannabis metabolites. These metabolites are created by the body after cannabis is smoked or consumed in an edible.
Their presence indicates that cannabis has been used, but the fact that they are present does not prove at a person is impaired by the drug.
The laws do not allow employers to make employment decisions based on marijuana tests that show the presence of nonspychoactive cannabis metabolites. While tests that do not detect these metabolites are technically allowed, from a practical standpoint they are difficult to find.
Current drug tests that detect the presence of THC (the chemical in marijuana causing impairment) are likely to detect nonpsychactive metabolites as well. Other tests that rely on baseline performance to prove impairment would be difficult to use for applicants, as there would be no previous information to use for comparison.
Exceptions to state laws
Both states have exceptions that allow employers to conduct marijuana tests under certain circumstances.
Washington’s restrictions do not apply to:
- A position requiring a federal government background investigation or security clearance.
- A position with a general authority for a Washington law enforcement agency.
- A position with a fire department, fire protection district, or regional fire protection service authority.
- A position as a first responder, including a dispatcher position with a public or private 911 emergency communications system or position responsible for the provision of emergency medical services.
- A position as a corrections officer with a jail, detention facility, or the department of corrections.
- A position in the airline or aerospace industries.
- A safety-sensitive position for which impairment while working presents a substantial risk of death. (These positions must be identified by the employer prior to the applicant’s application for employment.)
- Testing under state or federal laws requiring an applicant to be tested for controlled substances.
California’s law allows marijuana tests for:
An employee in the building and construction trades.
Applicants or employees hired for positions that require a federal government background investigation or security clearance in accordance with regulations issued by the U.S. Department of Defense or equivalent regulations applying to other agencies.
Testing conducted under state or federal laws requiring applicants or employees to be tested for controlled substances.
3 steps for employers to take
To make sure workplace drug testing in California and Washington is conducted appropriately, employers should:
Update pre-employment drug testing policies in California and Washington so they comply with the new laws.
Identify positions that are exempt from testing restrictions. When a position qualifies for an exception, make applicants aware that that marijuana testing will be conducted.
Train hiring managers and supervisors about the new requirements. Make sure they understand when marijuana testing is not allowed.
Key to remember: California and Washington have new marijuana testing restrictions that are in place as of January 1. Workplace policies and practices need to be updated to comply with the new laws.
NewsIndustry NewsHR GeneralistFamily and Medical Leave Act (FMLA)In-Depth ArticleFamily and Medical Leave Act (FMLA)Associate RelationsEnglishUSAHR ManagementFocus AreaHuman Resources
2022-12-14T06:00:00Z
Must employers tell employees if they run out of FMLA?
There’s a lot to keep track of when administering employees’ time off, especially when it falls under the Family and Medical Leave Act (FMLA).
Employers might wonder if they need to tell employees when their FMLA leave is running out. And the simple answer is “not really.”
Neither the statute nor the regulations specifically require you to notify or remind employees that their FMLA leave exhausted or is close to it. If you know how much time FMLA leave an employee is taking, you are, however, required to include that information on the designation notice. But, otherwise, there isn’t any other form or required document to tell an employee, “Hey, you’re running low on FMLA leave.”
Does this mean you may not give employees such a reminder?
Again, the simple answer is “no.” Employers may even have good arguments for doing so.
Why a gentle reminder can be helpful
When employees are on FMLA leave, the reason behind the need for leave will probably be of great importance to the employee. It could be because a baby was born or because a family member has a serious health condition. In any case, the employees most likely have a lot on their mind. They might not be constantly thinking about when they will return to work or when they will run out of FMLA leave.
Providing a gentle reminder can show employees that you’re thinking of them, and that you expect them to return on a particular date. Employees generally appreciate knowing what is expected of them. Giving them such a reminder can also help allay any questions about whether they knew they were expected back on such a date.
This could also be a good opportunity to remind employees that if they cannot return to work because of continued issues with their own serious health condition, they should let the employer know. In cases like this, an employer then can engage in an interactive process (dialogue) with the employee regarding possible reasonable accommodations under the Americans with Disabilities Act. One accommodation, for example, might be more leave time.
Providing employees with reminders about how much leave time they have left can also address the consequences for any absences after FMLA protections expire. This is especially important in terms of maintaining employee benefits.
Designation notice changes
If the information in the designation notice changes, such as if the employee exhausts FMLA leave then requests more leave, you must provide a written notice of the change. Like with the original designation notice, a change notice must be given to the employee within five business days of receipt of the employee’s first notice of need for additional leave.
Therefore, if, after an employee exhausts all 12 weeks of FMLA leave, the employee asks for more leave, you are to notify the employee of the changes to the designation notice. You may use another designation notice if you wish, but you are not required to do so. You could simply indicate to the employee that there is no more FMLA leave available, so the additional leave will not be designated as FMLA leave.
Key to remember: Keeping the lines of communication open between you and employees who are on FMLA leave can benefit both employers and employees, even if all types of communication aren’t necessarily required.
NewsFamily and Medical Leave Act (FMLA)In-Depth ArticleFamily and Medical Leave Act (FMLA)HR ManagementEnglishHuman ResourcesTalent Management & RecruitingAssociate Benefits & CompensationIndustry NewsCompensationCompensationHR GeneralistAssociate RelationsFocus AreaUSA
2022-06-14T05:00:00Z
Can an employee be denied a raise for missing work due to medical reasons?
With so many companies recruiting and hiring, employers may want to reward employees with a raise for staying onboard. But must employers give raises to everyone? What if a company has a newer employee who missed a lot of work last year for various medical reasons, and because of all the missed work time, no raise would be given this year? Is it okay for the employer to deny this person a raise? It depends. If this employee belongs to a protected class, the employer could be at risk of an illegal discrimination claim.
However, employers generally are not obligated by law to issue raises; it’s typically at their discretion, if:
- there is no contract in place guaranteeing a raise, and
- there was no illegal discrimination at play.
In other words, the employer couldn’t make employment decisions (such as issuing raises) based on an employee being in a protected class due to their race, sex, religion, age, disability status, etc.
If the employee’s leave time was protected under the Family and Medical Leave Act (FMLA) or was off work as an accommodation under the Americans with Disabilities Act (ADA), then there could also be an issue.
But if all employees who missed work for other, non-medical reasons didn’t get raises either (i.e., were treated similarly), then the employer should be justified in this decision.
The bottom line is, there are many factors for employers to consider before issuing raises.
Most Popular Highlights In Safety & Health
NewsIndustry NewsMaterials Handling and StorageSafety & HealthConstruction SafetyGeneral Industry SafetySlings for Materials HandlingIn-Depth ArticleEnglishFocus AreaUSA
2026-07-09T05:00:00Z
When the sling is the weak link
A dropped load can change a workday in seconds. In material handling, we often focus on the crane, hoist, forklift, or equipment doing the lifting, but the sling is what connects the load to the lift. If the connection fails, it can create a serious struck-by or caught-between hazard that may result in damaged equipment, production delays, serious injuries, or even fatalities.
Sling safety must start before the load leaves the ground. One missed detail, such as a damaged sling, unreadable tag, wrong hitch, or underestimated load weight, can be enough to turn a planned lift into an emergency.
Where lifting risks begin
They often build from small decisions that seem harmless at the time: using a sling “just one more time,” assuming the load weight is close enough, ignoring a worn edge, or grabbing whatever sling is nearby because the job needs to keep moving.
Slings aren’t all designed for the same conditions. Alloy steel chain, wire rope, synthetic web, synthetic round slings, metal mesh, and fiber rope all have different strengths, limits, and inspection concerns. A sling that works well for one task may be a poor choice for another if the load has sharp edges, high heat, chemical exposure, abrasion points, or an unstable center of gravity.
Additionally, many incidents lead back to load control. A suspended load does not have to fall straight down to hurt someone. It can swing, shift, rotate, pinch, or strike nearby workers if the lift is not planned and controlled.
Controls that help keep the load secure
Those risks are why the inspection and planning steps cannot be treated as a quick formality. Before the hook is raised, the crew needs to confirm that the sling fits the load, the conditions, and the way the load will move. OSHA’s sling requirements for general industry are found in 1910.184, and construction rigging requirements are addressed under 1926.251, but the practical goal is the same: use a sling that is suitable, inspected, properly identified, and within its rated capacity.
A stronger lift starts with slowing down long enough to answer a few basic questions during the setup:
- Load planning: Confirm the weight, center of gravity, attachment points, hitch type, sling angle, and travel path at the planning stage. Guessing may feel faster, but it removes the safety margin the lift depends on.
- Sling inspection: Look for cuts, burns, broken wires, crushed areas, stretched links, chemical damage, corrosion, damaged stitching, knots, or hardware that does not match the sling’s capacity. If the sling is damaged, questionable, or missing required identification, remove it from service.
- Edge and surface protection: Protect slings from sharp, rough, or abrasive load edges that can cut, crush, or wear down the material once tension is applied. Padding, sleeves, corner protectors, or a different sling type may be needed based on the load and conditions.
- Worker positioning and communication: Keep employees clear of areas where the load could swing, shift, or fall. Use clear signals, taglines when appropriate, and stop the lift if conditions change or communication breaks down.
The compliance side of sling safety
The requirements should show up in everyday lifting practices, not just in the written program. Slings must be inspected before use, damaged or defective slings must be removed from service, and slings must not be loaded beyond their rated capacity. In construction, rigging equipment must also have permanently affixed and legible identification markings that show the recommended safe working load, and equipment without those markings cannot be used.
The tag matters. The condition matters. The configuration matters. And the person selecting and using the sling needs to understand how those pieces work together while the load is still on the ground.
Key to remember: Every lift depends on using the right sling the right way. Confirm that it is rated, marked, and protected from damage, and keep employees clear of the suspended load.
NewsIndustry NewsElements of a General Duty Clause ViolationSafety & HealthConstruction SafetyGeneral Industry SafetyAgriculture SafetyMaritime SafetyGeneral Duty ClauseGeneral Duty Clause Enforcement AreasIn-Depth ArticleEnglishGeneral Duty ClauseFocus AreaUSA
2026-07-10T05:00:00Z
Don’t forget the General Duty Clause when identifying workplace hazards
What do heat stress, ergonomics, and struck-by hazards have in common? When employees aren’t adequately protected from these and other serious, recognized hazards for which there’s no OSHA standard, the agency can use the General Duty Clause (GDC) to cite employers. However, the agency must prove four things:
- That a hazard exists,
- That it’s recognized,
- That it’s causing or likely to cause serious physical harm or death, and
- That feasible abatement is available.
As an example, a hazard exists when employees work in extreme heat. It’s recognized because the hazard is widely known by employers, safety professionals, and industry. Extreme heat can pose harm because employees are at risk of heat illness or even death. And, it can be feasibly abated by providing water, rest breaks, and shade. Without all four of these elements, OSHA can’t use the GDC. But when they’re present, it’s a strong enforcement tool.
Recognized hazards
OSHA determines whether a hazard is “recognized” by looking at several sources, including:
- Industry consensus standards like the American National Standards Institute (ANSI) or the National Fire Protection Association (NFPA);
- An employer’s own safety rules and training materials;
- Previous incidents involving the hazard; and
- Industry recognition of the hazard, such as statements by safety or health experts who are familiar with the relevant conditions, and evidence of implementation of abatement methods to deal with the particular hazard by other members of the employer's industry.
Examples of recognized hazards include:
- Employees operating forklifts without wearing available seat belts;
- Damaged warehouse racks that could collapse;
- Workplace violence risks in certain settings, such as healthcare or gas stations, where the hazard is well documented; and
- Employees riding on the exterior rear step of refuse-collection trucks while vehicles are in transit.
Struck-by hazards and combustible dust are also recognized hazards. Recent cases where OSHA cited the GDC include:
- Employees walking in poorly illuminated areas on a jobsite where heavy vehicle traffic was present, and
- Employees exposed to fire and explosions associated with combustible dust generated during the manufacturing of dietary supplements.
Ergonomic hazards include strain from activities such as lifting, pushing, or repetitive motion. Musculoskeletal disorders (MSDs) like tendonitis, carpal tunnel syndrome, and back injuries can result from these exposures.
Identifying and controlling recognized hazards
A proactive approach is the best defense against a GDC citation. Conducting a job hazard analysis (JHA) helps identify hazards that might otherwise be missed. Observe employees as they perform tasks and ask for their input. They may identify hazards that employers or safety professionals don’t recognize, especially with tasks that occur infrequently or only under specific conditions.
In addition to JHAs, reviewing injury and illness records, near-miss reports, incident investigations, equipment manuals, workers’ compensation claims, industry guidance, and consensus standards can also provide insights.
Once you identify hazards, determine which ones don’t have an OSHA standard, like heat or ergonomics, and prioritize those that could cause serious physical harm or death. Consider the hierarchy of controls and whether the hazard can be eliminated or reduced.
Put reasonable controls in place (such as water, rest breaks, and shade for heat, or lift-assist devices for repeated manual lifting) and keep records showing what’s been done. Documented JHAs, training records, inspection logs, and corrective action reports can all help show that you took the hazard seriously and acted to protect employees.
The GDC and “inherently risky professions”
On July 1, 2025, OSHA issued a proposed rule that would limit the scope of the GDC. If finalized, OSHA could no longer use the GDC to cite employers of “inherently risky professions,” which includes such activities as motor sports, animal handling and performance, and combat simulation training. (See our related article, “OSHA proposes giving employers with ‘inherently risky professions’ a free pass.”) The agency’s most recent regulatory and deregulatory agenda, published July 3, 2026, reveals OSHA intends to hold public hearings on the proposal starting mid-August.
Key to remember: OSHA uses the General Duty Clause to cite serious, recognized hazards for which there’s no OSHA standard. When you identify and control these hazards and document your actions, OSHA may find it more difficult to establish the four elements necessary for a GDC citation.
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 |
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| September 2026 |
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| November 2026 |
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| April 2027 |
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| October 2027 |
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| Proposed rule stage | |
| Projected publication date or other action | Title |
| July 2026 |
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| August 2026 - public hearings |
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| September 2026 |
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| November 2026 |
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| December 2026 - Supplemental Notice of Proposed Rulemaking |
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| Long-term actions | |
| |
NewsSafety & HealthChange NoticesChange NoticeMaritime SafetyOccupational Safety and Health Administration (OSHA), DOLSpecialized IndustriesMarine Terminal OperationsEnglishFocus AreaUSA
2026-04-28T05:00:00Z
OSHA Final Rule: Open Fires in Marine Terminals
OSHA is finalizing the revocation of the agency's Open Fires in Marine Terminals Standard.
DATES:
The final rule is effective April 28, 2026. Published in the Federal Register Apr. 28, 2026, page 22723.
View final rule.
| PART 1917—Marine Terminals | ||
| Authority | Revised | View Text |
| §1917.21 Open Fires. | ||
| Entire section | Removed and reserved | View Text |
Previous Text
PART 1917—Marine Terminals
Authority: 33 U.S.C. 941; 29 U.S.C.
653, 655, 657; Secretary of Labor's Order No. 12-71 (36 FR 8754), 8-76 (41 FR 25059), 9-83 (48 FR 35736), 1-90 (55 FR 9033), 6-96 (62 FR 111), 3-2000 (65 FR 50017), 5-2002 (67 FR 65008), 5-2007 (72 FR 31160), 4-2010 (75 FR 55355), or 1-2012 (77 FR 3912), as applicable; and 29 CFR part 1911.
Section 1917.28 also issued under 5 U.S.C. 553.
Section 1917.29 also issued under 49 U.S.C. 1801-1819 and 5 U.S.C. 553.
NewsIndustry NewsHead ProtectionPersonal Protective EquipmentSafety & HealthConstruction SafetyGeneral Industry SafetyIn-Depth ArticleEnglishFocus AreaPersonal Protective EquipmentUSA
2023-10-13T05:00:00Z
Here is what you must know about head protection!
Did you know that hard hats are over 100 years old? That’s right! Construction workers were some of the first workers to wear hard hats. Common sense typically dictates when employees need head protection. However, if common sense doesn’t prevail, we have the OSHA regulations to fall back on.
In the construction industry, 1926.100 Head Protection states that employees must be protected in work areas with a possible danger of head injury from impact, falling or flying objects, or electrical shock and burns. Consequently, head protection is needed most of the time in construction. The general industry rule, 1910.135 Head Protection, states that the work environment will dictate the need for head protection. According to OSHA Enforcement Data, during 2023, the Agency has issued 60 citations to employers for violations to 1910.235, averaging $3,128 in penalties per violation.
1926.100 has been cited 9,725 times, with the average penalty totaling almost $2,000 per violation. In 2020, 43,540 workers suffered nonfatal head injuries involving days away from work. Providing head protection to workers isn’t enough. Employers must choose the correct type and class based on hazards in the workplace.
How hard hats protect your employees
OSHA doesn’t require workers to wear hard hats by default just because they’re in the workplace. It clarified this in a Letters of Interpretation dated February 20, 2004, saying, “… where no work is being performed overhead and there is no employee exposure to possible head injuries, there is no OSHA requirement that hard hats be worn …”
Head injuries are caused by falling, flying objects, or bumping your head against a fixed object. Other head injuries are from electrical shock and burns. Hard hats are designed to do two things: resist penetration and absorb the shock of a blow.
Hard hats lessen injury because they are designed with a hard outer shell and a suspension system inside. Workers should wear hard hats when working in an area with a possible danger of head injury from impact, falling or flying objects, or electrical shock and burns.
You may be exposed to the hazards of falling objects at work and need to protect yourself from the risk of head injuries. If there aren’t any falling object hazards, your employer might allow you to wear a bump cap. It protects your head if you bump into an object.
Types and classes of protective headgear
Hard hats will have a Type I or Type II rating on the manufacturer’s sticker. These markings are based on ANSI Z89.1’s impact ratings. Type I hard hats protect from objects or impacts from the top center area of the hard hat and are often used in work areas with no lateral head impact hazards. Type II head protection, on the other hand, offers protection from both top and lateral impacts and objects and is often found on construction jobsites or complex general industry settings where workers face multiple head contact exposures.
If hard hats have a bill that extends forward from the front of the hard hat or a full brim, it will help deflect objects away from workers’ face area. Type II head protections are called helmets! A growing number of employers nationally choose to use Type II helmets for their workers, recognizing the benefits of added head protection.
Workers don’t need to worry about which to choose from, though. Employers will select the proper type of hard hat to use. But if they switch between work activities, they should understand the different kinds of head protection they may be using.
Maintaining protective gear
Headgear should be inspected every day. Here are some suggestions for maintaining your headgear:
- Check your head protection for cracks (even hairline cracks), dents, and wear every time it is worn. Cracks and dents can reduce the degree of safety it provides. Exposure to temperature extremes, sunlight, or chemicals can shorten the life of thermoplastic protection. Discard head protection that is cracked or looks chalky or dull.
- Wash your head protection (especially the sweatbands and cradles) monthly in warm, soapy water and rinse thoroughly. You may need to use a solvent to remove tar, paint, oil, or other materials. However, some solvents can damage the shell, so consult the manufacturer to find out what solvents should be used. Replace worn sweatbands, if needed.
- Avoid painting your helmet. Paint contains solvents that may reduce the dielectric properties, if applicable, or affect the actual shell.
Pay special attention to the condition of the suspension system. This is important because it helps absorb the shock of a blow. Look for torn cradle straps, broken sewing lines, loose rivets, defective lugs, and other defects.
Key to remember
Remember that choosing the proper head protection for your workers will offer maximum head protection from side, rear, and severe impact blows. Prevent objects from falling by inspecting the work area for items placed where they could fall and moving them to a safer location.
NewsIndustry NewsSafety & HealthConstruction SafetyFall ProtectionFall ProtectionFall Protection for ConstructionExpert InsightsEnglishFocus AreaUSA
2026-07-09T05:00:00Z
Expert Insights: Roofing season is here—Don't let fall protection take a vacation
Summer brings sun and fun and also a lot of construction. As I walk my German shepherd through my neighborhood, I can’t help but notice all the residential roofing projects being performed. The percussive pop from nail guns and high-pitch hum from saws always draw my attention, both out of intrigue at their talent and bravery but also concern for their safety.
Being afraid of heights, my safety Spidey senses immediately zero in on fall protection, which is often absent. My concerned heart beats a bit faster knowing that falls account for the largest share of construction fatalities each year, with roofing and residential building construction representing a significant portion of those deaths. In fact, statistics show that roofing contractors accounted for about 26% of fatal falls in 2023, with 110 fatalities attributed to slips, trips, and falls. Unfortunately, the bulk of these fatal incidents involved unprotected edges, incomplete roof decking, or improperly used (or missing) fall protection.
The realities behind the roofline
Residential roofers aren’t intentionally trying to ignore safety, I assure you. They are challenged by a mix of economic, environmental, and cultural pressures, including:
- Existing structures that are not designed with fall protection in mind. Most residential roofs lack built in anchorage points, guardrails, or engineered access so adding them can be expensive and cost prohibitive.
- The belief that fall protection slows the job. NIOSH FACE investigations have shown that small residential roofing crews may believe harnesses, anchors, or lifelines slow movement which ultimately reduces productivity. • Inadequate planning before work starts. All too often in the interest of saving “time” and “money,” pre-job planning is done without worker input and the omission of fall protection discussions.
- Limited resources and safety infrastructure. Residential roofing often means smaller work crews (fewer than 10) who are less likely to have formal training, adequate tools and equipment, or a documented fall protection program in place.
- Misunderstanding regulatory requirements. Widespread confusion still continues among some residential roofers who assume OSHA allows fall protection to be bypassed when it seems “infeasible” on certain roofs. However, OSHA presumes conventional fall protection can be used, placing the responsibility on the employer to prove otherwise.
- A normalization of risk. Almost every safety professional has heard, “it’s how we’ve always done things.” However, when the high-stake dangers of roofing work becomes accepted as routine, serious injuries or fatalities occur. It isn’t always that fall protection can’t work for residential construction, it could simply be a gap in planning, training, or oversight.
Trading tradition for tethered confidence
When it comes to residential roofing, fall risks aren’t new. What is new is how many flexible, practical ways there are to manage them. Even though most residential roofs weren’t built with fall protection in mind, options exist that won’t cause major work disruption like:
- Temporary anchors,
- Portable lifelines,
- Guardrail systems, or
- Lift based work platforms.
When protective systems are selected early and set up correctly, it becomes part of the job, not something that slows progress.
To make the most of summer weather, job planning happens fast or not at all, which is when fall protection gets skipped. A few minutes before work starts to talk through roof hazards, access points, and protection options can prevent catastrophes later. Worker input matters here. Those doing the work often have the best ideas for what will and won’t work on a specific roof project.
Proper fall protection doesn’t require a complicated program or stack of paperwork. Basic training, the right equipment, and a simple written plan go a long way. Part of that training should include clearing up confusion about OSHA rules. Fall protection is expected, and “infeasible” is the exception, not the rule.
Finally, watch out for normalized risk. Just because a task feels routine doesn’t mean it’s safe. Most fatal falls aren’t caused by impossible conditions, but when there are gaps in communication and supervision.
Neighborhood walks give us a front row seat to the work happening around us. Roofing crews are building and repairing the places we call home. So, let’s plan up, tether up, and speak up so every crew member has a better chance of going home safe at the end of the day!
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