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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

Specialized Industries

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Most Recent Highlights In Environmental

e-Manifest Third Rule compliance checklist: Countdown to December 1
2025-09-12T05:00:00Z

e-Manifest Third Rule compliance checklist: Countdown to December 1

The date of December 1 often evokes thoughts of colder weather, the start of the Christmas season, and … waste manifests?! That’s certainly the case this year for hazardous waste handlers. On December 1, 2025, the rest of the Third Rule’s compliance requirements for electronic manifests take effect.

The Environmental Protection Agency’s (EPA’s) final Third Rule, established under the Resource Conservation and Recovery Act (RCRA), amends the Hazardous Waste Electronic Manifest System (e-Manifest system) standards. Many of the requirements began in January 2025. The Third Rule’s remaining regulatory changes start on December 1, 2025. Are you prepared to comply?

e-Manifest compliance check

Use this checklist to help you ensure that your business is set to comply with the rest of the Third Rule’s requirements that take effect in December.

Transition to the 4-copy forms

Under the Third Rule, EPA replaced the 5-copy paper manifests and continuation sheets with 4-copy paper manifests (EPA Form 8700-22) and continuation sheets (EPA Form 8700-22A). However, the agency allows hazardous waste handlers to continue using the 5-copy paper forms until further notice. EPA will provide a 90-day notice before it intends to stop accepting the 5-copy forms.

Note: At the time of the publication of this article, EPA has not yet given any authorized printer approval to print the new 4-copy manifest forms. As an authorized printer of the hazardous waste manifest forms, J. J. Keller & Associates, Inc. is working closely with EPA for approval to print the new 4-copy forms.

Users need Certifier permission on the e-Manifest module or Site Manager permission on the RCRA Information (RCRAInfo) Industry Application to submit manifests.

Compliance check:

☑ Begin to use the 4-copy manifests and continuation sheets as soon as they’re made available.

☑ Ensure that at least one user has Certifier or Site Manager permission.

Submit export manifests and related fees to e-Manifest

As of December 1, 2025, domestic hazardous waste exporters must submit all export manifests and continuation sheets (paper and electronic) to the e-Manifest system and pay the associated user fees.

An exporter is considered any entity that originates a manifest to export a hazardous waste shipment. This includes generators; transporters; treatment, storage, and disposal facilities; and recognized traders.

EPA will invoice exporters monthly for the manifest activities conducted during the previous month. The agency applies a fee per manifest, and the amount varies based on the type of submission (scanned image upload, data and image upload, or fully/hybrid electronic manifest).

Only individuals with Site Manager permission on RCRAInfo can pay manifest fees.

Compliance check:

☑ Prepare to use the e-Manifest system for export manifests and pay user fees.

☑ Verify that at least one person has Site Manager permission.

Submit manifest-related reports to e-Manifest

The Third Rule requires hazardous waste handlers to submit all Discrepancy, Exception, and Unmanifested Waste Reports to the e-Manifest system starting on December 1, 2025.

Generators submit Exception Reports, and receiving facilities submit Discrepancy and Unmanifested Waste Reports. No fees apply.

To submit the manifest-related reports to the e-Manifest system, users require Certifier permission for the module.

Compliance check:

☑ Be ready to submit manifest-related reports to the e-Manifest system.

☑ Confirm that at least one user has Certifier permission.

Send manifest copies to exporters

Beginning on December 1, 2025, entities that transport hazardous waste export shipments out of the U.S. (i.e., last transporters) have to send a signed copy of the manifest and continuation sheet to the exporter instead of the generator.

Further, the Third Rule clarifies that starting on December 1, 2025, transporters can use the e-Manifest system to export hazardous waste and send exporters copies of the signed manifest and continuation sheet. Transporters planning to do so need to set up a RCRAInfo account to use the e-Manifest system and assign Certifier permission to the user(s) who will submit the manifests.

Compliance check:

☑ Plan to send signed copies of the manifest and continuation sheet to the exporter.

☑ If applicable, register an account on RCRAInfo, and ensure at least one user has Certifier permission.

Use e-Manifest resources for additional help

EPA has multiple resources to help regulated hazardous waste handlers comply with e-Manifest regulations, including the upcoming Third Rule’s requirements that take effect on December 1, 2025. Consider using the resources the agency provides on “The Hazardous Waste Electronic Manifest (e-Manifest) System” website, such as:

  • Webinars,
  • Demonstration videos,
  • General and user-specific FAQs about the e-Manifest program, and
  • The e-Manifest Helpdesk for industry users.

The compliance checklist and e-Manifest resources can help you ensure that your facility will be ready to comply with the rest of the Third Rule’s requirements by December.

Key to remember: The remaining e-Manifest Third Rule requirements take effect on December 1, 2025. Facilities should confirm that they’re prepared to comply.

Hazardous waste handlers may continue use of 5-copy manifest forms
2025-09-12T05:00:00Z

Hazardous waste handlers may continue use of 5-copy manifest forms

The Environmental Protection Agency (EPA) announced that it will accept 5-copy paper manifest forms from entities regulated by the Resource Conservation and Recovery Act (RCRA) hazardous waste manifest program until further notice.

What changed?

The final Third Rule (effective on January 22, 2025) made multiple changes to the hazardous waste manifest regulations, one of which requires regulated entities to use 4-copy manifests (EPA Form 8700-22) and continuation sheets (EPA Form 8700-22A) instead of the previous 5-copy forms.

Initially, EPA stated that it would no longer accept 5-copy forms starting on December 1, 2025. However, the agency has removed the limit and will accept the 5-copy forms until further notice. Additionally, EPA will give a 90-day notice before the agency plans to stop accepting the 5-copy forms.

As an authorized printer of the hazardous waste manifest forms, J. J. Keller & Associates, Inc. is working closely with EPA for approval to print the new 4-copy forms. At the time of publication of this news article, the federal agency hasn’t yet approved any authorized printer to print the new forms.

Exporter and importer requirements

Hazardous waste exporters and importers that use the 5-copy manifest forms are required to put the consent numbers for their wastes in the Special Handling Instructions and Additional Information Field (Item 14) of the 5-copy manifest. If applicable, exporters must also enter their EPA Identification (ID) Numbers in Item 14. The agency recommends using this format: “Exporter EPA ID #AAANNNNNNNNN."

Please note that we will monitor any additional changes that result from EPA's decision to continue accepting 5-copy paper manifest forms and provide updates accordingly.

Key to remember: EPA will accept 5-copy manifests and continuation sheets beyond the initial deadline of December 1, 2025, until further notice.

Countdown to compliance: EPA’s AIM Act and its impact on refrigerant users
2025-09-11T05:00:00Z

Countdown to compliance: EPA’s AIM Act and its impact on refrigerant users

Starting January 1, 2026, the Environmental Protection Agency (EPA) will enforce sweeping changes under the American Innovation and Manufacturing (AIM) Act, targeting the use and management of hydrofluorocarbons (HFCs)—potent greenhouse gases used in refrigeration, air conditioning, and fire suppression.

These rules apply to all businesses with equipment containing 15 pounds or more of refrigerant with a Global Warming Potential (GWP) over 53, including but not limited to grocery stores, refrigerated transport fleets, repair shops, and small businesses.

Key requirements for end users

1. Leak detection and repair

  • Automatic leak detection systems (ALDs) are mandatory for systems with 1,500 pounds or more of refrigerant.
  • Leaks must be repaired within 30 days or a retirement/retrofit plan must be submitted
  • Leak rate thresholds:
    • Industrial process refrigeration: 30%
    • Commercial refrigeration: 20%
    • Transport & comfort cooling: 10%

2. Refrigerant reclamation

  • Repairs must use reclaimed refrigerants in supermarket systems, refrigerated transport, and commercial ice makers
  • Reclaimed HFCs must contain no more than 15% virgin HFCs and be properly labeled

3. Recordkeeping and reporting

  • Businesses must maintain detailed logs of:
    • Refrigerant purchases and usage
    • Leak events and repairs
    • Equipment servicing and disposal
  • Records must be available for EPA audits at any time.

4. Disposal and recycling

  • HFCs must be recovered from disposable cylinders before disposal
  • Fire suppression systems must be recycled prior to disposal, and technician training is required

Sector-specific impacts

Grocery retailers

  • Must retrofit or replace systems using restricted HFCs like R-404A or R-22
  • Natural refrigerants (CO₂, ammonia) are encouraged but require new equipment and trained technicians
  • Legacy systems may become costly to maintain due to refrigerant scarcity

Refrigerated transport

  • Subject to leak repair thresholds and reclamation rules
  • Must track refrigerant use across fleets and ensure timely repairs

Repair shops

  • Must use reclaimed refrigerants for servicing regulated systems
  • Required to follow EPA labeling and documentation standards

All end users: what you must do now

  • Inventory your equipment: Identify all systems with refrigerants over 15 lbs and GWP greater than 53
  • Install ALDs: For large systems, ensure real-time leak monitoring is in place
  • Train staff: Ensure technicians understand new servicing, reporting, and disposal rules
  • Upgrade Recordkeeping: Use digital tools to automate tracking and reporting

Looking ahead: state-level rules may be stricter

States like California, Washington, and New York are implementing stricter refrigerant rules that may exceed federal AIM Act standards. Businesses operating across state lines must monitor local regulations and prepare for additional reporting and inspections.

Key to remember: If your business uses refrigerants, the AIM Act likely applies to you. Start preparing now to avoid penalties and ensure compliance by 2026.

EPA's Spring 2025 regulatory agenda focuses on PFAS, fossil fuels, and rule reconsiderations
2025-09-09T05:00:00Z

EPA's Spring 2025 regulatory agenda focuses on PFAS, fossil fuels, and rule reconsiderations

The Environmental Protection Agency (EPA) published the Spring 2025 Semiannual Agenda of Regulatory and Deregulatory Actions on August 30, 2025. The agenda outlines the agency’s upcoming regulatory actions and their status in the rulemaking process.

EPA has major updates on the docket, such as:

  • Repealing all greenhouse gas (GHG) standards for fossil fuel-fired power plants and the 2024 amendments to the Mercury Air Toxics Standard for power plants (final rules expected December 2025);
  • Establishing risk management rules for multiple chemical substances, such as 1-bromopropane and n-methylpyrrolidone (final rules expected April 2026);
  • Adding hazardous waste solar panels to the federal universal waste program and setting universal waste standards specific to lithium batteries (proposed rule expected February 2026);
  • Setting the Renewable Fuel Standards for 2026 and 2027 and implementing regulatory program changes (final rule expected October 2025); and
  • Reconsidering current rules, like:
    • The GHG Reporting Program (final rule expected November 2025),
    • The National Emission Standards for Hazardous Air Pollutants (NESHAP) for iron and steel and the NESHAP for oil and natural gas (proposed rules expected November 2025 and December 2025, respectively), and
    • The 2024 amendments to the procedures for conducting Toxic Substances Control Act chemical risk evaluations (final rule expected April 2026).

Additionally, the agency intends to address per- and polyfluoroalkyl substances (PFAS) across multiple media. For example, EPA plans to:

  • Rescind the National Primary Drinking Water Regulations for PFHxS, PFNA, GenX, and mixtures of these three as well as for PFBS (proposed rule expected September 2025);
  • Add certain PFAS to the Toxics Release Inventory (final rule expected February 2026); and
  • Address PFAS discharges from PFAS manufacturers (proposed rule expected January 2026).

This article highlights some of the major rules we’re monitoring closely. You can review the entire agenda to learn about all the rulemakings on EPA’s docket. 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 dateTitle
December 2025Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Under the Technology Transitions Provisions of the American Innovation and Manufacturing Act of 2020
January 2026Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Common Sense Approach to Chemical Accident Prevention
February 2026Addition of Certain Per- and Polyfluoroalkyl Substances (PFAS) to the Toxics Release Inventory (TRI)
February 2026Initial Air Quality Designations for the 2024 Revised Primary Annual Fine Particle (PM2.5) National Ambient Air Quality Standards (NAAQS)
April 2026Listing of Specific PFAS as Hazardous Constituents
Proposed Rule Stage
Projected publication date of notice of proposed rulemaking
Title
October 2025Effluent Limitations Guidelines and Standards for the Oil and Gas Extraction Category (40 CFR 435 Subpart E)
October 2025New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry
November 2025Additional Reconsideration of Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review
November 2025PFAS Requirements in NPDES Permit Applications
November 2025Steam Electric Effluent Limitations Guideline Reconsideration Rule
December 2025Updates to the RCRA Hazardous Waste Regulations and Related Technical Corrections — Permitting Updates Rule 
January 2026Paper Manifest Sunset Rule; Modification of the Hazardous Waste Manifest System 
January 2026Revision to “Begin Actual Construction” in the New Source Review Preconstruction Permitting Program
April 2026Reconsideration of National Emission Standards for Hazardous Air Pollutants: Gasoline Distribution Technology Reviews and New Source Performance Standards Review for Bulk Gasoline Terminals
May 2026Formaldehyde; Regulation Under the Toxic Substances Control Act (TSCA)
Pre-Rule Stage
Projected publication date or other actionTitle
September 2025 (advanced notice of proposed rulemaking)Visibility Protection: Regional Haze State Plan Requirements Rule Revision
December 2025 (end review)National Emission Standards for Hazardous Air Pollutants for Brick and Structural Clay Products Manufacturing; and Clay Ceramics Manufacturing
Key to remember: EPA’s planned rulemakings may impact regulatory compliance with air, land, and water rules.
EHS Monthly Round Up - August 2025

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!

See More

Most Recent Highlights In Transportation

Update: EPA withdraws direct rule, keeps proposed rule for alternative CCR reporting option
2025-09-05T05:00:00Z

Update: EPA withdraws direct rule, keeps proposed rule for alternative CCR reporting option

On September 4, 2025, the Environmental Protection Agency (EPA) withdrew a direct final rule it issued on July 22, 2025, that offered active and inactive coal combustion residuals (CCR) facilities an alternative reporting option and delayed corresponding compliance obligations for CCR management units (CCRMUs). However, the parallel proposed rule that was published with the direct final rule remains in place, and EPA has extended the comment period through September 15, 2025.

Who does this affect?

The direct and proposed rules impact (a) active CCR facilities and (b) inactive CCR facilities with inactive surface impoundments (called legacy CCR surface impoundments) that are regulated by the 2024 Legacy Rule.

What does this mean?

Because the direct rule was withdrawn, the alternative reporting option for the Facility Evaluation Report (FER) Part 1 doesn’t apply, and the compliance deadlines for the related CCRMU requirements revert to the previous timelines.

The parallel proposed rule remains active and contains the same changes as the withdrawn direct final rule, including:

  • Adding an alternative option for active CCR facilities and legacy CCR surface impoundments to submit FER Parts 1 and 2 together by February 8, 2027; and
  • Extending the related compliance deadlines for facilities with CCRMUs.

Further, the proposed rule seeks public input on potentially delaying both FER reporting deadlines and adjusting the CCRMU compliance timelines accordingly. The proposed additional extension would give CCR facilities the option to:

  • Submit FER Part 1 by February 8, 2027, and FER Part 2 by February 8, 2028; or
  • Submit FER Parts 1 and 2 together by February 8, 2028.

You can submit comments to Docket ID No. EPA-HQ-OLEM-2020-0107.

Please see the original Industry News article ("EPA offers CCR facilities delayed reporting option and extends compliance deadlines") for more information about the withdrawn direct rule and the active proposed rule.

Key to remember: EPA has withdrawn a direct final rule that offered active and inactive coal combustion facilities an alternative reporting option, but the agency has kept the corresponding proposed rule in place.

OSHA renews alliance to improve worker safety in waste and recycling industry
2025-09-03T05:00:00Z

OSHA renews alliance to improve worker safety in waste and recycling industry

In a renewed alliance, OSHA, the National Waste & Recycling Association (NWRA), and the Solid Waste Association of North America (SWANA) will continue to work together to improve the safety and health of workers in the solid waste and recycling industry.

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.

OSHA, NWRA, and SWANA will develop resources to help employers prevent and mitigate hazards, including:

  • Educational articles,
  • Fact sheets, and
  • Toolkits.

The group will share these resources and additional information at conferences, forums, and meetings, with much of their outreach aimed at reaching small- and medium-sized employers who may have limited access to safety information.

2025-08-29T05:00:00Z

New Mexico bans PFAS from oil and gas well completions and recompletions

Effective date: July 29, 2025

This applies to: Oil and gas operations

Description of change: The New Mexico Oil Conservation Commission adopted amendments to ban per- and polyfluoroalkyl substances (PFAS) from being used in completions (bringing into production) or recompletions (restarting production) of oil wells. The amendments to 19.15 N.M.A.C.:

  • Require operators to provide certification that no PFAS chemicals were used;
  • Require applicants for a permit to drill, deepen, or plug back a well to certify that they won’t introduce PFAS-containing additives;
  • Adds completion operations to the factors that trigger notification and diligence action requirements when potential loss of containment or damage occurs; and
  • Adds FracFocus disclosure requirements.
2025-08-29T05:00:00Z

Colorado provides alternative window, door, skylight efficiency standards

Effective date: January 1, 2026

This applies to: Residential windows, doors, and skylights sold or leased for residential use in the state

Description of change: As of January 1, 2026, all residential windows, doors, and skylights sold or leased for residential use in Colorado must meet specific energy efficiency standards established by House Bill 23-1161. The Colorado Energy Office established an alternative energy standard for compliance. Manufacturers may choose between the standard at C.R.S. 6-7.5-105(5)(j)(l) and the alternative standard at 5 CCR 1004-2(1.1).

2025-08-29T05:00:00Z

Washington updates protocol for Cap-and-Invest Program

Effective date: August 21, 2025

This applies to: Businesses subject to the Climate Commitment Act Program rule

Description of change: The Department of Ecology updated the offset protocol for ozone-depleting substances (ODS) to expand the scope of offset projects available to Cap-and-Invest Program participants. The amendments to chapter 173-446 WAC:

  • Restrict project invalidation liability for ODS projects,
  • Adopt a new ODS protocol based on one used by the California Air Resources Board, and
  • Require all ODS offset projects that begin after the effective date of this rule to use the new protocol.

View related state info: Clean air operating permits — Washington

See More

Most Recent Highlights In Safety & Health

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.
2025-08-29T05:00:00Z

California strengthens Low Carbon Fuel Standard

Effective date: July 1, 2025

This applies to: Any entity that sells or supplies transportation fuel in the state

Description of change: The California Air Resources Board (or CARB) amended the Low Carbon Fuel Standard (LCFS) to set more stringent LCFS carbon intensity (CI) benchmarks. The amendments require:

  • A 30 percent reduction in fuel CI by 2030, and
  • A 90 percent reduction in fuel CI by 2045.

The amendments also:

  • Adopt a near-term step down of CI benchmarks and automatic increases of CI benchmark stringency when triggered;
  • Streamline application and reporting requirements, quantification methods, and analysis tools; and
  • Updates third-party verification and validation requirements.

View related state info: Greenhouse Gas Emissions Regulation State Comparison

2025-08-29T05:00:00Z

Rhode Island adds monthly recordkeeping flexibility

Effective date: June 6, 2025

This applies to: Sources required to record monthly data for nitrogen oxide emissions and/or distributed/emergency generators with a general permit

Description of change: The Office of Air Resources removed monthly recordkeeping limits for:

  • Stationary sources that emit nitrogen oxides (NOx), and
  • Stationary sources with general permits for emergency generators and distributed generators.

The office amended Part 27 to remove the requirement to record within the first 15 days of the month:

  • Fuel usage and the quantity of NOx emitted, and/or
  • The hours of operation for each engine and/or combustion unit.

The office also amended Part 43 to remove the requirement to record within the first five days of the month:

  • Fuel usage for each distributed generator, and/or
  • Hours of operation for each emergency generator.

Sources may record the data at any time within the month.

View related state info: Clean air operating permits — Rhode Island

ABCs of UST operator training
2025-08-28T05:00:00Z

ABCs of UST operator training

“Operator error” isn’t something anyone likes to see, especially when it applies to leaks from underground tanks of petroleum or hazardous materials. That’s why it’s essential to train individuals to manage underground storage tanks (USTs) correctly. Training obligations vary for each type of UST operator. Federal regulations establish three categories:

  • Class A operators,
  • Class B operators, and
  • Class C operators.

Properly trained operators are vital to managing USTs safely and in compliance. Use this guide to understand the different training requirements for Class A, B, and C operators.

An overview of roles

The Environmental Protection Agency (EPA) requires all owners and operators of UST systems to designate:

  • One Class A operator and one Class B operator for each UST or groups of USTs, and
  • Each qualifying person at the facility as a Class C operator.

Class A operators are responsible for operating and maintaining USTs in line with the regulations. A Class A operator generally manages the resources and personnel involved to ensure UST operations comply.

A successfully trained Class A operator:

  • Makes informed decisions about compliance; and
  • Determines whether the facility complies with operation, maintenance, and recordkeeping requirements.

Class B operators handle the day-to-day responsibilities for managing USTs (like conducting in-field operations).

A Class B operator with sufficient training implements applicable regulatory requirements in the field on typical UST system components or site-specific equipment.

Class C operators provide immediate responses to UST-related problems.

An adequately trained Class C operator takes the necessary response actions to emergencies or alarms caused by UST spills and releases.

Basic training requirements

EPA outlines the minimum training requirements for each operator type at 40 CFR Part 280 Subpart J. All classes of operators must be trained or pass a comparable examination. Class C operators have the additional option to receive training from a Class A or B operator at the facility.

A facility can designate an individual for multiple operator classes. Any person with multiple designations must complete the required training or comparable examination for all applicable classes.

Class A and Class B operators must be trained within 30 days of beginning UST duties. Class C operators have to be trained before starting their UST responsibilities.

Class A operators should understand the purpose, methods, and functions of:

  • Spill and overfill prevention;
  • Release detection;
  • Corrosion protection;
  • Emergency response;
  • Product and equipment compatibility and demonstration;
  • Financial responsibility;
  • Notification and storage tank registration;
  • Temporary and permanent closure;
  • Related reporting, recordkeeping, testing, and inspections;
  • Environmental and regulatory consequences of releases; and
  • Training requirements for Class B and Class C operators.

Class B operators may be trained in either:

  • General requirements for all compliance rules and the equipment commonly used at UST facilities, or
  • Site-specific requirements that only cover the regulations and equipment applicable to the facility.

Additionally, Class B operators need to know the purpose, methods, and functions of:

  • Operation and maintenance;
  • Spill and overfill prevention;
  • Release detection and related reporting;
  • Corrosion protection;
  • Emergency response;
  • Product and equipment compatibility and demonstration;
  • Reporting, recordkeeping, testing, and inspections;
  • Environmental and regulatory consequences of releases; and
  • Training requirements for Class C operators.

Class C operators must know how to respond with the correct actions to emergencies or alarms that are caused by spills or releases from UST operations, including notifying the authorities.

Common training questions

Consider these FAQs to help ensure your UST operator training programs comply.

How are operators evaluated?

Facilities must evaluate each operator via testing, a practical demonstration, or another approved approach.

When is retraining required?

If a UST system is found to be noncompliant, Class A and Class B operators at the facility must complete a training program or comparable examination that at least covers the areas out of compliance (unless exempt per 280.244).

Retraining should be completed within 30 days of the noncompliance determination. The training program or examination has to be developed or administered by a third party (i.e., an independent organization, the implementing agency, or a recognized authority).

How is training tracked?

Facilities are required to keep paper or electronic records that verify training and retraining for as long as the operators are designated. The records should contain at a minimum the information at 280.245(b).

What about state requirements?

It’s essential to check state UST regulations where your facilities operate. EPA has approved most states to implement the UST program. State requirements are at least as stringent as federal standards, and many state programs impose stricter rules.

Usually, operator training is obtained from third-party organizations that must be registered and approved by state environmental agencies to ensure the programs comply with federal and state requirements.

Key to remember: Training requirements for underground storage tank operators are based on their designated class: A, B, or C.

Avoiding compliance pitfalls: Understanding the overlap between HAPs and VOCs
2025-08-25T05:00:00Z

Avoiding compliance pitfalls: Understanding the overlap between HAPs and VOCs

Understanding how hazardous air pollutants (HAPs) and volatile organic compounds (VOCs) are counted is key to accurate reporting and staying in compliance. These pollutants often overlap, but how they're treated depends on the situation — especially when comparing emission inventories to permitting rules. Misunderstanding the differences can lead to underreporting, permit mistakes, and other compliance problems. This article will also discuss how state rules can make things more complex.

Emission inventories: often counted together

Emission inventories help regulatory agencies track actual emissions from facilities over time. These records support air quality models, guide policy, and help protect public health.

In many cases, HAPs that are also VOCs (like toluene or xylene) are included in the total VOC count. For example, the Environmental Protection Agency (EPA) includes HAP-VOCs in its National Emissions Inventory, which supports regional air quality models, like the Community Multiscale Air Quality (CMAQ) system.

Frequently Asked Question: What's the National Emissions Inventory?

As an example, the Texas Commission on Environmental Quality recommends using conservative “first-cut” estimates for both VOCs and HAPs. This makes early reporting easier and helps avoid underestimating emissions.

Potential to emit (PTE): counted separately

PTE calculations are used to determine a facility’s regulatory status, such as whether it qualifies as a major source under the New Source Review (NSR) or Title V programs or is subject to Maximum Achievable Control Technology (MACT) standards.

In this context, HAPs and VOCs are counted separately because they're subject to different thresholds, including:

  • 10 tons per year (TPY) for a single HAP or 25 TPY for total HAPs; and
  • Typically 100 TPY for major source classification under NSR, though this can vary by attainment status.

This separation is critical. A facility might exceed the HAP threshold and trigger MACT requirements, even if its VOC emissions are below NSR thresholds — or vice versa. As an example, if a paint booth has the potential to emit 500 pounds of toluene, this is counted as 500 pounds of HAP and 500 pounds of VOC. Even though that seems like double-counting for the same emission, it's important to include both totals separately.

State-by-state variability

While federal rules provide a baseline, states often have their own interpretations and requirements:

  • Ohio offers detailed guidance on calculating VOC and HAP emissions separately for permitting purposes. Facilities must demonstrate compliance with both sets of thresholds.
  • Texas uses a tiered approach. Facilities begin with conservative estimates and refine them only if emissions approach regulatory thresholds.
  • California maintains stricter standards and often requires separate reporting for toxic air contaminants (TACs), which include many HAPs. The state’s Air Toxics Hot Spots Program adds another layer of complexity.

Why the distinction matters

Failing to understand how HAPs and VOCs are counted can lead to serious compliance issues:

  • Permitting errors: Misclassification can result in incorrect permit applications or missed regulatory obligations.
  • Underreporting risks: Facilities may inadvertently underreport emissions if they assume HAPs are always included in VOC totals.
  • Modeling impacts: While combined inventories help with regional modeling, they may obscure the risks posed by individual pollutants.

Recommendations for facilities

To stay compliant and avoid costly mistakes, implement the following:

  • Check state guidance: Requirements vary widely. Always consult your state environmental agency.
  • Use Safety Data Sheet data: Identify both VOC and HAP content in raw materials.
  • Maintain separate records: Keep VOC and HAP data distinct, especially for PTE calculations.
  • Consult experts: When in doubt, seek help from J. J. Keller & Associates, Inc. subject matter experts using the Expert Help feature.

Key to Remember: The way HAPs and VOCs are counted depends heavily on context. Understanding these distinctions — and how they vary by state — is key to maintaining compliance and protecting air quality.

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Most Recent Highlights In Human Resources

Clock ticking for bilingual pesticide labels; EPA reveals tracking method and Q&As
2025-08-21T05:00:00Z

Clock ticking for bilingual pesticide labels; EPA reveals tracking method and Q&As

A 2022 law requires that some sections of end-use pesticide product labeling be translated into Spanish. So, now the Environmental Protection Agency (EPA) has issued a notice requesting comments on how it wants to track the adoption of bilingual labeling. The agency also updated its Bilingual Labeling Questions & Answers webpage.

Spanish translations prompted by law

The Pesticide Registration Improvement Act (PRIA) has been enacted and reauthorized five times. The latest version (PRIA 5) was signed on December 29, 2022. It amended the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to require Spanish language translation for sections of the end-use pesticide product labels. However, those translations are only required where translation is available in EPA's Spanish Translation Guide for Pesticide Labeling.

Those sections deal with the health and safety of the product. Specifically, the guide has Spanish translations of the:

  • “Keep out of reach of children” statement,
  • Restricted use pesticide (RUP) statement for restricted use products,
  • Misuse statements,
  • Signal word,
  • First aid section,
  • Precautionary statements,
  • Personal protective equipment section,
  • Engineering controls,
  • Environmental hazards,
  • Physical or chemical hazards, and
  • Storage and disposal statements.

Methods of communicating translations

When a registered pesticide product is released for shipment, PRIA 5 requires translations or a link to translations on the product container. Any link would be via scannable technology or other accessible methods. Antimicrobial pesticide products and non-agricultural/non-RUP products have yet another option. They may provide a link to the Spanish Safety Data Sheets instead of a link to label translations.

Deadlines for translations

PRIA 5 establishes a rolling schedule for the implementation of bilingual labeling. The schedule runs from December 2025 to 2030, with the translations for the most hazardous and toxic pesticide products required first. In fact, EPA is starting with RUPs and agricultural pesticides classified as acute toxicity category I. All end-use pesticide labels must have translations by 2030. 

The dates when bilingual labeling is due are based on pesticide product type:

Pesticide product type:Bilingual labeling due:
RUPsDecember 29, 2025
Agricultural products (non-RUPs):
Acute toxicity category IDecember 29, 2025
Acute toxicity category IIDecember 29, 2027
Antimicrobial and non-agricultural products:
Acute toxicity category IDecember 29, 2026
Acute toxicity category IIDecember 29, 2028
All other pesticide productsDecember 29, 2030

EPA tracking required

PRIA 5 also requires EPA to develop, implement, and make publicly available a plan for keeping track of the adoption of bilingual labeling. The agency previously proposed and received comments on using the annual paper maintenance fee filing form to track adoption. It would have used a checkbox to indicate whether products included bilingual labeling.

However, EPA has scrapped that approach. It’s now proposing to track adoption through its electronic MyPeST app. In this case, registrants would electronically check a box next to each pesticide product indicating whether it includes the required bilingual labeling. MyPeST would display product information — such as product type and signal word — to help registrants determine their products’ compliance dates.

The agency also wants to add a checkbox to MyPeST to indicate that a pesticide product will not be released for shipment. This helps distinguish between noncompliance and nonapplicable circumstances.

For tracking purposes, registrants would not need to submit the labels to EPA.

EPA seeks comments

Comments on the proposed tracking method must be received on or before September 19, 2025. Send comments to docket ID EPA-HQ-OPP-2025-0049 at www.regulations.gov. Any comments are welcome, but EPA is particularly looking for examples of how it could reduce this tracking paperwork burden for businesses employing fewer than 25 workers.

The proposed method is anticipated to take 24 hours and cost just over $3,000 per covered entity per year. Entities potentially affected by the notice and comment request include:

  • Pesticide importers,
  • Pesticide manufacturers, and
  • Government establishments responsible for agricultural pest/weed regulation.

Q&As available

EPA says it has also updated its Bilingual Labeling Questions & Answers webpage. Additional questions and answers touch on topics relating to, but not limited to:

  • Enforcement,
  • Supplemental distributor labels,
  • QR codes and websites already on the label, and
  • How to handle subsequent label changes. 

This living document now has over 50 Q&As. It will be updated as PRIA 5 requirements and deadlines are met and new information is available.

Key to remember

EPA issued a notice requesting comments by September 19 on how it wants to track the adoption of bilingual labeling. Spanish language translation for sections of the end-use pesticide product labels has a rolling schedule from 2025 to 2030. The agency also updated its Bilingual Labeling Questions & Answers webpage.

EPA releases July 2025 TSCA Inventory
2025-08-15T05:00:00Z

EPA releases July 2025 TSCA Inventory

On August 14, 2025, the Environmental Protection Agency (EPA) released the biannual update to the nonconfidential Toxic Substances Control Act (TSCA) Chemical Substance Inventory (TSCA Inventory). The inventory includes all TSCA-regulated chemical substances manufactured, processed, or imported in the U.S.

The July 2025 TSCA Inventory contains 86,862 chemicals, adding 15 chemical substances since the last update. Nearly half of the substances (42,578) are active (i.e., in use). EPA also updated:

  • Commercial activity data,
  • Unique identifier data, and
  • Regulatory flags (which identify substances with manufacturing or use restrictions as well as substances with full or partial reporting exemptions).

Further, the agency updated the TSCA Master Inventory File. It includes chemical identity information claimed as confidential that’s excluded from the nonconfidential TSCA Inventory. The TSCA Master Inventory File is the only list with comprehensive, authoritative information about which chemical substances are on the inventory.

The agency plans to make the next inventory update in Winter 2026.

How do I access the inventory?

View the TSCA Inventory by:

  • Downloading the Microsoft Access or CSV text version of the data from EPA’s website, or
  • Using EPA’s Substance Registry Services (SRS).

How does this impact my business?

The TSCA Inventory helps facilities determine compliance requirements for chemicals they (a) manufacture or use or (b) plan to manufacture or use. Chemicals that are on the TSCA Inventory are likely subject to rules, like manufacturing limits and reporting requirements. Chemicals that aren’t on the list must meet notification and review requirements before they can be used.

Key to remember: EPA released the July 2025 nonconfidential TSCA Inventory of chemical substances manufactured, processed, or imported in the U.S.

Smart pretreatment: How digital tools are transforming industrial wastewater management
2025-08-12T05:00:00Z

Smart pretreatment: How digital tools are transforming industrial wastewater management

Industrial wastewater pretreatment systems are evolving quickly. With tighter regulations, aging infrastructure, and rising costs, many facilities are turning to digital tools to modernize their operations. From real-time monitoring to predictive analytics, these technologies help permitted systems stay compliant, reduce risks, and improve performance.

Real-time monitoring improves oversight and response

One of the most important advancements is the use of real-time sensors and Supervisory Control and Data Acquisition (SCADA) systems. These tools allow operators to monitor key factors like pH, flow rate, temperature, and contaminant levels around the clock. If something goes out of range, alerts are sent immediately – helping prevent violations and environmental damage.

Automated sampling and reporting also make it easier to meet regulatory requirements. By reducing manual work and improving accuracy, facilities can respond faster to changes in discharge conditions. This is especially helpful in industries where wastewater characteristics vary, such as food processing or chemical manufacturing.

Predictive analytics and AI support proactive management

Beyond monitoring, predictive analytics and artificial intelligence (AI) help facilities anticipate problems before they happen. By analyzing past data, these systems can predict equipment failures, detect changes in influent quality, and recommend better chemical dosing strategies.

Such a proactive approach reduces downtime, lowers maintenance costs, and improves treatment results. It also helps with long-term planning by identifying trends that may point to needed upgrades or process changes.

Digital twins enable safer, smarter optimization

Some facilities are using digital twins – virtual models of their pretreatment systems. These models simulate real-world operations, allowing engineers to test changes in flow, chemical use, or equipment without affecting actual processes.

Digital twins are also useful for training. New staff can explore how the system works and practice emergency responses in a safe, controlled environment.

Cybersecurity and data protection are growing priorities

As more systems become connected, cybersecurity is a growing concern. Facilities must protect their digital systems from unauthorized access and data breaches. This includes using secure networks, encrypted communication, and regular system checks to ensure data is safe and reliable.

Looking ahead: integration and interoperability

The future of smart pretreatment lies in system integration. Facilities are looking for platforms that combine data from sensors, lab tests, maintenance logs, and compliance reports. When digital tools work together, operators get a clearer view of system performance and can make better decisions.

Key to Remember: Digital tools are no longer optional—they’re essential for modern industrial wastewater pretreatment. By adopting smart technologies, facilities can improve compliance, reduce costs, and support environmental goals.

Use chemical risk evaluations to plan ahead
2025-08-12T05:00:00Z

Use chemical risk evaluations to plan ahead

Wouldn’t it be helpful to know ahead of time if a chemical that your facility uses may soon face additional or stricter regulations? Such an alert system exists! It’s in the form of risk evaluations conducted by the Environmental Protection Agency (EPA).

The Toxic Substances Control Act (TSCA) requires EPA to evaluate existing chemicals in the U.S. marketplace for safety. If the agency determines that a chemical substance poses an unreasonable risk to human or environmental health, it immediately begins the risk management process. Through the process, EPA develops compliance rules to control the risk.

Consider EPA’s final risk evaluation for 1,1-dichloroethane published in June 2025. In it, the agency determined that three uses present an unreasonable risk of injury to workers. EPA will now develop and finalize regulations to address the risk.

If EPA issues a final risk evaluation on a chemical substance that your facility manufactures (including imports), processes, distributes, uses, and/or disposes of, take note! It answers multiple questions that can help your facility prepare for future compliance obligations.

Will my facility have to comply?

EPA’s risk evaluation determines whether an existing chemical substance presents an unreasonable risk to health or the environment under specific conditions of use (COUs). Risk management regulations only apply to the COUs that present an unreasonable risk. If your facility engages in any covered COU, it will have to comply with the applicable future restrictions.

Let’s revisit the 1,1-dichloroethane risk evaluation. One of the three COUs that endanger the health of workers through inhalation exposure is the processing of the chemical substance for recycling. If a facility doesn’t process 1,1-dichloroethane for recycling, it won’t have to comply with future regulations for that COU.

Who’s affected?

The final risk evaluation defines the categories of human and environmental populations covered by the assessment (such as consumers, the general population, workers, and aquatic species), and it identifies the COUs that apply to them.

Knowing the types of populations that a covered COU affects can help facilities narrow down the kinds of compliance requirements that may apply. For instance, a final risk management rule may require facilities to:

What’s the regulatory timeline?

TSCA grants EPA one year from the publication date of the final risk evaluation to propose a risk management rule and another year after that to finalize it. So, potentially covered facilities can expect regulations within two years of the final risk evaluation.

For example, EPA published the final risk evaluation for 1,1-dichloroethane in June 2025, so the agency should finalize a rule by June 2027.

Compliance obligations for a final rule likely won’t begin immediately; EPA usually gives facilities time to make any needed changes to things like operations, equipment, etc.

How can my facility prepare?

Keep these tips in mind:

  • Search for safer alternative chemical substances to use. In addition to eliminating the potential for new or additional compliance requirements, using a safer alternative can offer your business a competitive advantage. EPA’s Safer Chemical Ingredients List may be a good place to start.
  • Look for ways to reduce employee exposure to the chemical substance. Evaluate your facility’s existing operations for ways to lower worker exposure. Consider things like changing work processes or upgrading to equipment with more protective features.
  • Participate in the rulemaking. EPA will open its proposed risk management rule for public comments. You can provide feedback on the compliance requirements the agency plans to impose on regulated facilities. EPA will consider the public comments it receives before finalizing a rule.

Key to remember: EPA’s final chemical risk evaluations give facilities a heads-up that compliance changes are likely within the next couple of years.

EHS Monthly Round Up - July 2025

EHS Monthly Round Up - July 2025

In this July 2025 roundup video, we’ll review the most impactful environmental, safety, and health 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 in the past month!

In response to Executive Orders calling for deregulation efforts, on July 1 OSHA issued one final rule and 25 proposed rules. The proposed rules cover a variety of topics, including respiratory protection, construction illumination, safety color codes for signs, and the General Duty Clause. Stakeholders have until September 2 to comment on them. The final rule took effect July 1 and makes changes to the rules of procedure for promulgating, modifying, and revoking standards applicable to construction work.

OSHA updated its penalty guidance for small employers, impacting businesses with 25 or fewer employees. This includes reduced penalties of up to 70 percent in certain circumstances. These changes took effect July 14.

Effective July 1, California OSHA extended its safety and health laws to protect domestic workers, such as house cleaners, caregivers, and gardeners. The laws apply to businesses that employ both temporary and permanent domestic service workers.

OSHA’s Safe + Sound Week is scheduled for August 11-17 and focuses on emergency preparedness and response. Businesses of all sizes are encouraged to participate by conducting safety stand-downs, evacuation drills, or other activities that help highlight the importance of safety and health programs. More information and resources can be found on OSHA’s website.

And finally, turning to environmental news, EPA issued a final rule that offers coal combustion facilities an alternative option to comply with the Facility Evaluation Report. It also adjusts the compliance timelines for regulations related to coal combustion residuals management units. In addition, EPA issued a proposed rule requesting public feedback on further delaying the Facility Evaluation Report.

Thanks for tuning in to the monthly news roundup. We’ll see you next month!

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