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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

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Most Recent Highlights In Environmental

EPA adds new HAPs to hazardous waste combustor requirements
2026-06-03T05:00:00Z

EPA adds new HAPs to hazardous waste combustor requirements

The Environmental Protection Agency (EPA) finalized the residual risk and technology review of the National Emission Standards for Hazardous Air Pollutants (NESHAP) from Hazardous Waste Combustors (HWCs). Most significantly, the final rule:

  • Maintains the existing standards;
  • Adds requirements for previously unregulated hazardous air pollutants from specific major source HWCs; and
  • Establishes work practice standards for periods of startup, shutdown, and malfunction (SSM).

Who’s impacted?

EPA’s final rule applies to major sources subject to the HWC NESHAP at 40 CFR 63 Subpart EEE, including:

  • Hazardous waste-burning incinerators,
  • Cement kilns,
  • Lightweight aggregate kilns,
  • Solid fuel-fired boilers,
  • Liquid fuel-fired boilers, and
  • Hydrochloric acid production furnaces.

What are the changes?

The final rule adds standards for hydrogen fluoride (HF) and hydrogen cyanide (HCN) emissions to specific sources:

Major source HWCNew regulation(s)
Incinerators
  • Work practice standard for HF (3 options)
Cement kilns
  • Emission limits for HCN
Solid fuel boilers
  • Emission limits for HF and HCN
Liquid fuel boilers
  • Work practice standard for HF (3 options)
    (all liquid fuel boilers)

  • Emission limits for HCN
    (liquid fuel boilers with capacities > 50 million British thermal units per hour (MMBTU/hr))

The final rule also:

  • Establishes work practice standards for periods of SSM;
  • Requires electronic reporting for specific reports (e.g., compliance progress reports, performance tests, Notifications of Compliance); and
  • Makes technical changes.

What’s the compliance timeline?

Existing HWCs must:

  • Develop, submit to the regulatory authority for approval, and implement SSM plans and start complying with SSM requirements by November 30, 2026;
  • Comply with any applicable HF and HCN emission limits and work practice standards by June 3, 2029; and
  • Begin electronic reporting by August 3, 2026.

New HWCs must comply upon startup.

Key to remember: EPA's final rule maintains the existing NESHAP regulations for hazardous waste combustors and establishes emission limits and work practice standards for previously unregulated HAPs.

2026-06-03T05:00:00Z

Colorado finalizes emission regulations for priority toxic air contaminants

Effective date: June 14, 2026

This applies to: New, modified, and existing stationary sources of priority toxic air contaminants (PTACs)

Description of change: The Colorado Air Quality Control Commission adopted state-level emission control requirements for PTACs. The rules apply to specific source categories of stationary sources that emit one or more PTAC, including benzene, hexavalent chromium, ethylene oxide (EtO), formaldehyde, and hydrogen sulfide. The commission revised Regulation Numbers 24, 26, and 30.

Regulated sources must reduce emissions by implementing new technologies, adjusting work practices, and using fewer toxic materials. The revisions add regulations for emissions of:

  • Benzene from petroleum refineries,
  • Formaldehyde from stationary spark-ignition reciprocating internal combustion engines and combustion turbines,
  • Hexavalent chromium from decorative and functional chrome plating,
  • EtO from sterilization facilities, and
  • Hydrogen sulfide from asphalt processing products, roofing products, and manure digesters.

Various requirements for different PTACs and sources start on June 14, 2026.

Related state info: Clean air operating permits state comparison

2026-06-03T05:00:00Z

Maryland adopts regulations for packaging and paper products

Effective date: May 25, 2026

This applies to: Producers of packaging and paper products (covered materials)

Description of change: Maryland’s Department of the Environment adopted regulations to implement the Packaging and Paper Products — Producer Responsibility Plans Act under the department’s Extended Producer Responsibility program.

The rules establish requirements for producers of covered materials to submit producer responsibility plans and comply with other requirements, such as:

  • Annual registration of covered materials,
  • Recordkeeping, and
  • Reporting.

Producers of covered materials must:

  • Pay fees;
  • Either:
    • Join a Producer Responsibility Organization (PRO) Producer Responsibility Plan;
    • Have an approved Individual Producer Responsibility Plan (IPP); or
    • Have an approved IPP for a specific covered material and join a PRO plan for other covered materials;
  • Register annually with the PRO or department;
  • Submit reports to the PRO or department; and
  • Comply with recordkeeping requirements.
2026-06-03T05:00:00Z

Michigan adds requirements to wastewater collection systems

Effective date: April 29, 2026

This applies to: Wastewater collection systems with more than 50 connections and retention treatment basin (RTB) facilities

Description of change: The Michigan Department of Environment, Great Lakes, and Energy amended regulations for wastewater collection systems and RTB facilities by requiring:

  • Facility classification, and
  • Collection system operators to have system-specific certification (and recertify every 3 years).

The rules also streamline wastewater construction permitting, clarifying requirements for privately owned, publicly used systems when applying for Part 41 Permits.

Related state info: Industrial water permitting — Michigan

2026-06-03T05:00:00Z

Florida amends on-site sewage treatment and disposal rules

Effective date: June 8, 2026

This applies to: On-site sewage treatment and disposal systems (OSTDS)

Description of change: The Florida Department of Environmental Protection amended the regulatory requirements for OSTDS. In addition to streamlining specific permit application processing procedures, the final rule amends the requirements for:

  • Installing and locating OSTDS,
  • Abandoning OSTDS,
  • Treatment receptacle construction standards,
  • Registration requirements for septic tanks and Master Septic Tank Contractors,
  • Registration certificate renewals,
  • Discipline and penalties for registered persons,
  • Certification of partnerships and corporations as septic tank contracting businesses, and
  • Service and registration fees.

Related state info: Industrial water permitting — Florida

See More

Most Recent Highlights In Transportation

EPA restores emergency-related affirmative defense provisions for Title V operating permits
2026-06-01T05:00:00Z

EPA restores emergency-related affirmative defense provisions for Title V operating permits

In response to a court mandate, the Environmental Protection Agency (EPA) has rescinded a 2023 final rule that removed emergency-related affirmative defense provisions from the Title V operating permit regulations (the 2023 Affirmative Defense Rule) under the Clean Air Act.

The final rule (published on June 1, 2026) reinstates the emergency-related affirmative defense provisions for state and federal Title V operating permit programs (at 40 CFR 70.6(g) and 71.6(g), respectively).

Who’s impacted?

EPA’s final rule affects stationary sources subject to Title V operating permit requirements.

What does this mean?

The emergency-related affirmative defense provisions establish a framework for regulated facilities to assert an affirmative defense in enforcement proceedings for violations of technology-based emission limits caused by sudden, unavoidable emergencies, provided certain conditions are met.

To rely on the emergency-related affirmative defense, stationary sources must demonstrate that:

  • A qualifying emergency occurred,
  • The facility was being properly operated,
  • The facility took all reasonable actions to limit excess emissions, and
  • The facility properly notified the permitting authority.

EPA’s demonstration requirements are listed at 70.6(g)(3)/71.6(g)(3).

What affirmative defense covers

An “emergency,” as defined by 70.6(g)(1)/71.6(g)(1), generally refers to a sudden, unforeseeable event beyond the facility’s control that causes noncompliance with technology-based emission limits established in its Title V operating permit.

What affirmative defense doesn’t cover

The provisions don’t apply to noncompliance due to:

  • Improperly designed equipment,
  • Lack of preventive maintenance,
  • Careless or improper operation, or
  • Operator error.

Key to remember: EPA has restored the emergency-related affirmative defense provisions for Title V operating permits, allowing stationary sources to assert a regulatory affirmative defense for certain emission violations caused by events beyond the facility’s control.

Water reuse: Put your facility’s wastewater to work
2026-05-29T05:00:00Z

Water reuse: Put your facility’s wastewater to work

Did you know that one entity’s wastewater may be another organization’s treasure? Through water reuse, businesses reclaim municipal and industrial stormwater and wastewater, treat it to make it safe, and repurpose it for beneficial uses.

Reusing water can help companies lower costs, secure a more reliable water supply, and reduce environmental impact. While water reuse is usually voluntary, it must align with federal discharge requirements and state reuse regulations.

The Environmental Protection Agency (EPA) recently launched Water Reuse Action Plan (WRAP) 2.0, an initiative that seeks to advance water reuse in the industrial, technology, and energy sectors. Published in May 2026, Water Reuse Action Plan 2.0: Multiplying Water Benefits, Maximizing American Prosperity provides a comprehensive overview of WRAP 2.0, including specific case studies of how entities have improved operational efficiency by reusing water.

Let’s look at three of these successful water reuse examples and consider factors to help you determine whether water reuse can benefit your business.

Real-world examples of water reuse

Water reuse has been successfully integrated into operations across a range of industries by all types of businesses (from local car washes to national food production companies).

Automobile manufacturing

Painting uses more water than other processes in automobile manufacturing. One major vehicle manufacturer has addressed this through water reuse. At one of its Kentucky assembly plants, the manufacturer started reusing treated wastewater in the paint pretreatment process.

As a result, the assembly plant sends less wastewater to the publicly owned treatment works, uses less freshwater in the manufacturing process, and achieves cost savings by purchasing less water. For instance, during the first year of implementation, the water reuse initiative saved the plant about $50,000.

Stadium operations

A large stadium in Georgia contains a stormwater management system, including a cistern that catches rainwater runoff from the stadium’s roof and plaza structure. The stadium uses this rainwater runoff for exterior landscape irrigation and for make-up water for its cooling towers.

Additionally, nearly all of the plumbing fixtures installed in the stadium are low-flow fixtures, using less water than traditional fixtures.

Similar to the automobile manufacturer, reusing water means that the stadium purchases less water. The stadium’s water reuse efforts have also helped the facility secure a reputation for sustainability.

Refinery processing

A major refinery in California partners with the municipal utility district to reuse recycled water for its boilers.

Boilers require high-purity water, so the utility treats the recycled water with specific technologies (including reverse osmosis) to meet the quality standards. The utility treats the wastewater on-site, supplying the refinery with the recycled water. The refinery then uses the water in its boilers to generate steam needed to manufacture gasoline, diesel, and other products.

By reusing water, the refinery greatly reduces the amount of freshwater it uses (and therefore, reduces the cost of purchasing water). It also allows the refinery to continue operations during drought restrictions, making it more resilient to weather-related changes.

How’s water reuse regulated?

Water reuse is generally voluntary; however, it operates within existing regulatory frameworks that govern wastewater discharges and water quality.

Most states regulate water reuse, although some programs may be implemented at the local level. In California, for instance, the Regional Water Quality Control Boards issue water reuse permits in their respective covered areas, whereas the Texas Commission on Environmental Quality (a state agency) regulates water reuse projects.

Tip: Use EPA’s REUSExplorer tool to find water reuse guidelines or regulations for your facility’s state.

Can water reuse benefit your business?

Each company must evaluate its operational processes to determine whether water reuse can help improve efficiency. Use these tips as a starting point:

  • First, assess existing processes to determine whether and how water can be reused.
  • Estimate the costs of implementing water reuse projects, such as installing or upgrading the facility’s equipment or infrastructure.
  • Compare the potential benefits to the associated costs of reusing water. Consider both the short-term and long-term effects.
  • Confirm the compliance requirements for water reuse with the proper regulatory authority (generally, the state environmental agency).

Water reuse may offer your business the opportunity to put its wastewater to work.

Key to remember: Water reuse implemented in compliance with applicable regulations can help facilities improve operational efficiency, lower costs, and reduce environmental impact.

Final rule revises HFC use restrictions and compliance timelines for specific subsectors
2026-05-27T05:00:00Z

Final rule revises HFC use restrictions and compliance timelines for specific subsectors

On May 26, 2026, the Environmental Protection Agency (EPA) finalized a rule (2026 Final Rule) revising regulations on the use of hydrofluorocarbons (HFCs) in certain subsectors. The final rule specifically amends requirements established by the 2023 Technology Transitions Rule under the American Innovation and Manufacturing Act of 2020 (AIM Act).

EPA also published a proposed rule to exempt road and intermodal container transport refrigeration units (TRUs) from leak repair requirements set by the 2024 Emissions Reduction and Reclamation (ER&R) Rule.

Who’s impacted?

The 2026 Final Rule applies to entities that are subject to the 2023 Technology Transition Rule requirements (40 CFR 84.54) for these subsectors:

  • Refrigerated transport — intermodal containers,
  • Industrial process refrigeration (IPR) and chillers for IPR used in semiconductor manufacturing,
  • Retail food — supermarket systems,
  • Retail food — remote condensing units,
  • Cold storage warehouses,
  • Residential and light commercial air conditioning and heat pumps (RACHP), and
  • IPR (not using chillers) — refrigerated laboratory centrifuges and refrigerated laboratory shakers.

The 2026 proposed rule applies to refrigerant-containing road and intermodal container transport refrigeration units (TRUs) regulated by the 2024 ER&R Rule.

What are the changes?

The 2026 Final Rule:

  • Adjusts the lower bound temperature and measurement location for refrigerated transport intermodal containers from -50°C to -35°C;
  • Extends the compliance dates to January 1, 2030, for restrictions on uses of HFCs and HFC blends by IPR and chillers for IPR in semiconductor manufacturing process equipment (limited to equipment with a charge size of 100 pounds or less);
  • Allows retail food supermarket systems to increase the cooling capacity of existing systems by up to 15 percent without triggering new installation requirements;
  • Establishes temporary, relaxed interim global warming potential (GWP) limits (implementing stricter GWP limits starting on January 1, 2032) for:
    • Retail food supermarket systems,
    • Retail food remote condensing unit systems, and
    • Cold storage warehouses.
  • Allows RACHP equipment using specific components that were domestically manufactured or imported before January 1, 2025, to continue to be installed; and
  • Delays the compliance dates to January 1, 2028, for restrictions on uses of HFCs and HFC blends by refrigerated laboratory centrifuges and refrigerated laboratory shakers.

Please note that the final rule states that EPA maintains existing requirements for new condensing units used as replacements in the RACHP subsector.

What’s the proposed rule?

The 2024 ER&R Rule added leak repair requirements (84.106) for refrigerant-containing appliances with a charge size of 15 pounds or more containing an HFC or a specific HFC substitute, which took effect on January 1, 2026. Examples of the requirements include leak inspections, appliance repairs, and reporting.

EPA proposes to exempt all refrigerant-containing road and intermodal container TRUs from the leak repair provisions (regardless of charge size).

Key to remember: EPA has issued a final rule revising HFC use restrictions for certain subsectors and has proposed a rule exempting transportation refrigeration units from leak repair requirements.

OSHA packs new HazCom directive with enforcement clues
2026-05-26T05:00:00Z

OSHA packs new HazCom directive with enforcement clues

The first compliance date for the amended Hazard Communication (HazCom) standard has arrived, and OSHA finally issued its updated directive. The CPL instructs OSHA officers on how to conduct inspections and issue citations under the standard. However, it also provides chemical manufacturers, importers, distributors, and employers with insight into what officers will be assessing.

In effect, this CPL translates regulatory text into inspector expectations. It shows what adherence to the standard looks like in practice. That makes it a critical resource given recent and upcoming dates at 29 CFR 1910.1200(j).

CPL rewritten for the 2024 standard

On May 19, 2026, OSHA posted a revised CPL 02-02-079, “Inspection Procedures for the Hazard Communication Standard (HCS 2024),” replacing the July 9, 2015, version. The 132-page document reflects the reconfigured HazCom standard published May 20, 2024, effective on July 19, 2024, along with corrections issued through early 2026.

The agency designed this enforcement playbook to maintain uniform inspections during the transition period and after full implementation. Because of the extensive regulatory changes to definitions, hazard classification, labeling, safety data sheets, and trade secrets, the CPL is not a light refresh.

For those familiar with the rulemaking, the new CPL edits will not be surprising. Still, the directive should provide more clarity than the regulatory text.

Front matter and appendices

Updates to Sections I to IX are typical of a CPL, including:

OSHA also modernized appendices for dates, hazard lists, pictogram hazards, SDS review guidance, chemical resources, and related directives.

Reworked inspection guidelines

Section X outlines inspector instructions for paragraphs (b) through (j) of the standard. The latest modifications impact most sections:

  • Scope, applicability, and exemptions — The directive offers new examples and expanded explanations, such as:
    • A formaldehyde hazard example for hair smoothing products;
    • An overview of pesticide labeling requirements and exemptions;
    • Discussion of the EPA Agricultural Worker Protection standard preemption; and
    • Greater detail about biological hazards from plants.
  • Definitions — The document introduces terms and explains bulk shipment, immediate outer package, physical hazard, released for shipment, and more. It also revisits the terms combustible dust and manufacturer. Lithium-ion batteries are now referenced in the distributor context.
  • Hazard classification — The directive instructs OSHA officers to consider the classification of:
    • Hazards associated with a chemical’s intrinsic properties, including changes in physical form and reactions from known or reasonably anticipated uses; and
    • Impurities, additives, and individual constituents.
  • Written plan — The directive clarifies:
    • Employers must revise programs by the compliance dates when new information is received from suppliers;
    • The use of computers and third-party administrators of safety data sheets (SDSs); and
    • The written program must describe how employees will be trained in a language and at a literacy level they understand.
  • Labeling — The directive broadens the sections on Department of Transportation labeling, bulk shipments, and small container labeling. It incorporates final rule flexibility too:
    • Phased-in compliance dates for labeling;
    • Hazards not otherwise classified (HNOCs) and hazards identified and classified under 1910.1200(d)(1)(ii) don’t need to be addressed on the container;
    • The exclamation mark pictogram is permitted (but not required) for HNOCs, under certain conditions;
    • Minor textual variations for precautionary statements are allowed; and
    • OSHA offers alternatives for chemical containers released for shipment.
  • Safety data sheets (SDSs) — Amended text focuses on U.S. jurisdiction and technical provisions, such as:
    • Phased-in compliance dates for SDSs;
    • Importer SDS responsibilities;
    • Using a U.S. address and phone number;
    • The hazard class and category reflecting intrinsic properties;
    • Required Chemical Abstracts Service (CAS) number or other unique identifiers; and
    • No need to obtain updated SDSs to replace already received SDSs.
  • Employee information/training — The directive references a temporary workers bulletin. It also emphasizes:
    • Phased-in compliance dates for necessary training adjustments; and
    • Delivering training in a language employees understand.
  • Trade secrets — The instruction aligns with the 2024 rule:
    • Allows the exact percentage, exact concentration range, or CAS number to be withheld if certain criteria are met; and
    • Addresses the use of confidentiality agreements.
  • Dates — The directive overhauls compliance timelines and discusses documentation of due diligence and good faith efforts.

In addition, the directive softens citation language with phrases like “should normally cite” instead of “shall cite.” This shift suggests inspectors may have greater discretion based on case-specific circumstances.

Key to remember

While 1910.1200 remains the baseline for employers and chemical manufacturers, importers, and distributors, the revised CPL 02-02-079 provides an enforcement lens. With implementation underway, regulated entities can use the CPL to steer their efforts and conform with how OSHA will inspect them in the field.

Where workplace exposure meets air permitting: Bridging OSHA industrial hygiene and EPA air programs
2026-05-22T05:00:00Z

Where workplace exposure meets air permitting: Bridging OSHA industrial hygiene and EPA air programs

Air quality inside a facility and emissions leaving a stack are closely linked. The same chemicals that drive occupational exposure limits under the Occupational Safety and Health Administration (OSHA) often form the basis of regulated air pollutants under the Environmental Protection Agency's (EPA's) programs.

When industrial hygiene (IH) and environmental compliance teams work together, they can spot risks sooner, strengthen controls, and avoid surprises in permits or inspections. The overlap is practical. Worker exposure data can inform stack testing, and permit conditions can signal where IH monitoring should focus.

Shared chemistry, different lenses

Both programs start with the same substances, such as solvents, metals, acids, and combustion byproducts. IH focuses on what workers breathe in the workplace. It uses exposure limits such as OSHA permissible exposure limits or more protective guidelines from the National Institute for Occupational Safety and Health (NIOSH) and the American Conference of Governmental Industrial Hygienists (ACGIH). Environmental air programs focus on what leaves the property. They regulate criteria pollutants, hazardous air pollutants (HAPs), and toxics using emission limits, control requirements, and reporting rules.

The data tools look similar. IH uses personal and area sampling, direct-reading instruments, and task-based assessments. Environmental programs use emission factors, mass balance, continuous monitoring, and periodic stack testing. Both require documentation, quality control, and records.

Key differences that matter

The point of exposure is the biggest difference. IH evaluates the breathing zone of a worker during a task or shift. Environmental programs measure emissions at a release point, such as a stack, or estimate them across the site.

The time frame also differs. IH often looks at short-term peaks and full-shift averages to protect health during work. Air permits may set hourly, daily, or annual limits, and they may cap total emissions per year. Control strategies follow these goals. IH may rely on local exhaust ventilation, enclosure, or work practice changes. Air permits may require add-on controls such as thermal oxidizers, scrubbers, or filters.

Practical crossover: Using IH to inform permitting

IH data can reveal which tasks generate the highest concentrations and which compounds dominate exposure. That insight can refine emission estimates. For example, if wipe cleaning with a solvent produces the highest worker exposure, the same solvent may drive facility-wide volatile organic compound (VOC) emissions. The environmental team can use that knowledge to prioritize accurate emission factors, refine mass balance, or plan stack testing during peak operations.

IH data also helps define realistic operating scenarios for compliance testing. Stack tests that occur only at typical loads may miss worst-case conditions. Pairing test timing with identified peak tasks can provide a more representative test and reduce the risk of later noncompliance.

Practical crossover: Using permits to inform IH

Air permits define regulated compounds, control devices, and operating limits. These details can guide IH planning. If a permit lists specific HAPs or requires a control device for a process, there's a clear signal that exposure to those compounds is possible near the source. IH can target those areas for baseline sampling, validate control performance, and confirm that capture systems are effective where workers are present.

Permit conditions also flag upset and startup modes. These periods can increase emissions. IH can align monitoring during these windows to assess short-term exposures and ensure that work practices and protective measures are adequate.

Aligning controls for dual benefit

Engineering controls can serve both goals when designed as a system. Capture at the source reduces worker exposure and lowers emissions to the stack. Good enclosure and balanced ventilation improve control efficiency and reduce fugitive releases. Preventive maintenance on control devices supports permit limits and keeps workplace air clean.

Administrative controls can align as well. Standard operating procedures can link production rates, control device settings, and ventilation checks. Change management should include both an IH review and an air permitting check to see if a modification triggers a permit update.

Communication and workflows

Successful crossover depends on routine communication. Regular meetings enable safety and environmental staff to share results, plan sampling, and coordinate testing windows. Shared inventories of chemicals and processes reduce duplication and errors. A common data platform, or at least a consistent file structure, makes it easier to compare IH results with emission estimates and permit limits.

Clear triggers help teams act. Examples include a new chemical introduction, a process change, a spike in IH results, or a deviation in control device performance. Each trigger should prompt both an IH review and an environmental compliance check.

Key to remember: When teams connect their data and plans, they gain a clearer picture of risk. The results are stronger compliance, better worker protection, and more efficient operations.

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Most Recent Highlights In Safety & Health

Final rule extends TSCA Section 8(d) health and safety reporting deadline
2026-05-22T05:00:00Z

Final rule extends TSCA Section 8(d) health and safety reporting deadline

The Environmental Protection Agency (EPA) issued a final rule on May 22, 2026, extending the reporting deadline for the Toxic Substances Control Act (TSCA) Section 8(d) Health and Safety Data Reporting Rule from May 22, 2026, to May 21, 2027.

Who’s impacted?

The TSCA Section 8(d) Health and Safety Data Reporting Rule applies to manufacturers (including importers) of any of the 16 chemical substances listed at 40 CFR 716.120(d), including:

  • Entities that currently manufacture (including import) any of the chemicals; and
  • Entities that have manufactured (including imported) or have proposed to manufacture (including import) any of the chemicals since January 13, 2015.

What’s required?

The rule requires covered manufacturers (including importers) to submit a one-time report of data on the chemicals from unpublished studies on:

  • Health and safety;
  • Environmental effects; and
  • Occupational, general population, and consumer exposure.

Which chemicals are covered?

The TSCA Section 8(d) Health and Safety Data Reporting Rule applies to:

  • 4,4-Methylene bis(2-chloraniline);
  • 4-tert-octylphenol(4-(1,1,3,3-Tetramethylbutyl)-phenol);
  • Acetaldehyde;
  • Acrylonitrile;
  • Benzenamine;
  • Benzene;
  • Bisphenol A;
  • Ethylbenzene;
  • Hydrogen fluoride;
  • N-(1,3-Dimethylbutyl)-N’-phenyl-p-phenylenediamine (6PPD);
  • 2-anilino-5-[(4-methylpentan-2-yl)amino]cyclohexa-2,5-diene-1,4-dione (6PPD-quinone);
  • Naphthalene;
  • Styrene;
  • Tribromomethane (Bromoform);
  • Triglycidyl isocyanurate; and
  • Vinyl Chloride.

Why the delay?

EPA has extended the deadline to allow additional time to reconsider the rule’s scope and possibly propose revisions to the regulations. Once any major changes are finalized, EPA will communicate the updated reporting requirements and timelines accordingly.

Key to remember: EPA has extended the submission date for the TSCA Section 8(d) Health and Safety Data Reporting Rule’s one-time report to May 2027.

EPA floats major changes to current PFAS drinking water rules
2026-05-20T05:00:00Z

EPA floats major changes to current PFAS drinking water rules

The Environmental Protection Agency (EPA) has released two proposed rules that, if finalized, would have major impacts on drinking water regulations for per- and polyfluoroalkyl substances (PFAS), specifically, the 2024 National Primary Drinking Water Regulation (NPDWR) for PFAS (2024 PFAS NPDWR).

Proposed rule: MCL compliance extension

The first rule proposes to establish a federal exemption that allows public water systems (PWSs) to request an extension of the deadline to comply with the Maximum Contaminant Levels (MCLs) for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) from April 26, 2029, to April 26, 2031.

The rule would require PWSs that meet the eligibility requirements to submit a request to EPA for the federal exemption within 180 days of the date a final rule is published. PWSs would have to provide specific information in the request (such as recent water sample results and a certified statement that the system can’t comply with the original MCL deadline).

Additionally, EPA’s proposed rule would require:

  • All PWSs with the federal exemption to notify customers of the exemption, and
  • PWSs with PFOA or PFOS levels at or above 12 parts per trillion to implement two control measures (from six options) during the exemption period.

Who would be impacted?

The proposed federal exemption would apply to PWSs:

  • Regulated by the 2024 PFAS NPDWR for PFOA and PFOS;
  • In operation on or before June 25, 2024;
  • Not under a variance for small systems for the PFOA and PFOS MCLs; and
  • In a state that doesn’t have primacy for the 2024 PFAS NPDWR.

PWSs in states with primacy for the 2024 PFAS NPDWR may request an exemption from the primacy agency.

Proposed rule: Rescinding PFAS NPDWRs

The second rule proposes to rescind EPA’s determinations to regulate:

  • Perfluorohexane sulfonic acid (PFHxS);
  • Perfluorononanoic acid (PFNA);
  • Hexafluoropropylene oxide dimer acid and its ammonium salt (HFPO-DA, called GenX chemicals); and
  • Perfluorobutane sulfonic acid (PFBS).

It also proposes to remove the related 2024 PFAS NPDWR provisions from 40 CFR Parts 141 and 142, including:

  • The MCLs and MCL Goals (MCLGs) for PFHxS, PFNA, and HFPO-DA;
  • The MCL and MCLG for mixtures with two or more of PFHxS, PFNA, HFPO-DA, and PFBS (referred to as the Index PFAS); and
  • All other compliance requirements.

The proposed rule would maintain the 2024 PFAS NPDWR requirements for PFOA and PFOS.

Who would be impacted?

The rule would impact PWSs, including community water systems (CWSs) and non-transient non-CWSs, subject to the 2024 PFAS NPDWR standards for PFHxS, PFNA, HFPO-DA, or the Index PFAS.

How do I give feedback?

EPA will hold a virtual public hearing for verbal comments on the proposed rules on July 7, 2026. Written comments for the proposed compliance extension rule (Docket ID No. EPA-HQ-OW-2025-1742) and proposed rescission rule (Docket ID No. EPA-HQ-OW-2025-0654) are due by July 20, 2026.

Key to remember: EPA has proposed major changes to the national drinking water regulations for PFAS.

2026-05-20T05:00:00Z

California approves plastic packaging regulations

Effective date: May 1, 2026

This applies to: Producers of single-use packaging and plastic single-use food service ware

Description of change: CalRecycle approved permanent regulations to implement the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54). The regulations require producers of covered materials (single-use packaging and plastic single-use food service ware) to administer an extended producer responsibility program.

Producers must meet minimum recycled content requirements for covered materials and pay fees (including annual mitigation surcharges for all producers and fees to producers participating in a producer responsibility organization (PRO) plan).

By June 1, 2026, producers must:

  • Register with Circular Action Alliance (CAA) and submit supply data to CAA if participating in an approved PRO plan,
  • Register with CalRecycle and apply to be an independent producer if complying individually, or
  • Register with CalRecycle and apply for the small producer exemption if qualified.
2026-05-20T05:00:00Z

New Mexico adopts PFAS product phaseout regulations

Effective date: July 1, 2026

This applies to: Manufacturers, distributors, and retailers that sell, offer for sale, distribute, or distribute for sale products that contain intentionally added per- and polyfluoroalkyl substances (PFAS) in New Mexico

Description of change: The New Mexico Environment Department adopted regulations implementing the PFAS Protection Act (HB212), which phases out consumer products with intentionally added PFAS. The regulations contain:

  • The prohibitions of products (with specific product categories and timelines),
  • Reporting and testing requirements,
  • Labeling requirements, and
  • Fees for mandatory reporting and “currently unavoidable use” designation applications.

The regulations establish three phaseout deadlines:

  • The first group of products must be phased out by January 1, 2027.
  • The second group of products must be phased out by January 1, 2028.
  • All other nonexempt products and products without currently unavoidable use designations must be phased out by January 1, 2032.
2026-05-20T05:00:00Z

California adopts risk-based water quality standards for nonpotable water

Effective date: April 22, 2026

This applies to: Owners and operators of on-site treated nonpotable water systems (OTNWS)

Description of change: The California State Water Resources Control Board adopted risk-based water quality standards that apply to OTNWS for the on-site treatment and reuse of nonpotable water for nonpotable end uses in:

  • Multifamily residential buildings,
  • Commercial buildings, and
  • Mixed-use buildings.

The types of nonpotable water include on-site:

  • Wastewater,
  • Graywater,
  • Stormwater, and
  • Roof runoff.

The regulations apply to indoor and outdoor nonpotable uses, including:

  • Toilet and urinal flushing,
  • Drain trap priming,
  • Clothes washing,
  • Decorative fountains,
  • Landscape irrigation,
  • Ornamental plant irrigation,
  • Dust suppression, and
  • Car washing.

Related state info: Industrial water permitting — California

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Most Recent Highlights In Human Resources

EPA proposes major changes to multiple rules
2026-05-19T05:00:00Z

EPA proposes major changes to multiple rules

The Environmental Protection Agency (EPA) has been on a rulemaking roll! In recent weeks, the agency has published significant proposed rules in the Federal Register that affect coal-fired power plant wastewater, pre-construction air permits, and vehicle emission requirements.

Coal-fired power plants: Unmanaged CRL discharges

EPA proposes to revise the wastewater requirements established by a 2024 final rule (2024 Rule) for unmanaged combustion residual leachate (CRL) from coal-fired power plants.

Unmanaged CRL (a type of waste stream) is water that contains coal combustion residuals and leaks from landfills or surface impoundments (i.e., waste management units). Unmanaged CRL includes:

  • Pumped unmanaged CRL (leached CRL that’s captured, pumped to the surface, and discharged directly to waters of the United States); and
  • The functional equivalent of an unmanaged CRL direct discharge (determined by the permitting authority).

The proposed rule applies to coal-fired power plants with unmanaged CRL that are subject to the 2024 Rule’s technology-based effluent limitations guidelines and standards.

The agency proposes three options to revise the unmanaged CRL requirements:

  • Option 1 (preferred by EPA) would maintain the 2024 rule’s mercury and arsenic numeric limits for pumped unmanaged CRL discharges, but it would delay the compliance deadline from December 31, 2029, to December 31, 2034. Additionally, the permitting authorities would determine best available technology economically achievable (BAT) limits for functional equivalents on a case-by-case basis.
  • Option 2 would maintain the 2024 rule’s mercury and arsenic numeric limits for pumped unmanaged CRL discharges and functional equivalents. It would also maintain the original compliance timeline of December 31, 2029.
  • Option 3 would impose zero-discharge limits for all pollutants in pumped unmanaged CRL discharges and functional equivalents. It would also establish interim BAT limits for mercury and arsenic. Facilities would have to meet the zero-discharge limits by December 31, 2034.

Public comments are due by June 17, 2026 (Docket ID No. EPA–HQ–OW–2009–0819).

Pre-construction air permits: Begin actual construction

EPA proposes to allow construction-related activities on components or structures that don’t emit air pollutants to start before obtaining a New Source Review (NSR) pre-construction permit to build or modify a stationary source. The proposed rule:

  • Redefines “begin actual construction," and
  • Adds “pollutant-emitting activities” to the regulatory definitions.

Both definitions list equipment, components, and processes that are excluded, meaning that construction on these activities may begin before obtaining an NSR permit. Examples of exempt activities include compacting and stabilizing soil, paving surfaces, and installing concrete pads.

If finalized, the proposed rule will distinguish between construction on stationary sources and construction on non-emitting components (e.g., utility infrastructure, certain building foundations) and codify that on-site construction of non-emitting components or structures can begin before getting an NSR permit.

Public comments are due by June 29, 2026 (Docket ID No. EPA-HQ-OAR-2025-0618).

Light- and medium-duty vehicle regulations: Tier 4 standards

EPA published Part 1 of a two-part rulemaking effort to revise the Tier 4 criteria air pollutant standards set in 2024 (Tier 4 Rule) for light- and medium-duty vehicles (LMDVs), which include:

  • Light-duty vehicles and trucks,
  • Medium-duty passenger vehicles, and
  • Medium-duty vehicles.

In Part 1, EPA proposes to amend the phase-in schedule for Tier 4 criteria air pollutant requirements by:

  • Extending the Tier 3 standards set in 2014 (Tier 3 Rule) for LMDVs to model years (MYs) 2027 and 2028,
  • Delaying the start of phasing in Tier 4 standards for LMDVs from MY 2027 to MY 2029, and
  • Removing the optional early phase-in of Tier 4 standards for LMDVs with a gross vehicle weight rating of more than 6,000 pounds from MYs 2027 and 2028.

The agency also proposes to delay changes to the test protocols for emissions performance certification evaluations to MY 2029.

In Part 2, EPA will reconsider the Tier 4 Rule for LMDVs, which may include changing emission standards, lead time and phase-in schedules, and test procedures.

Public comments are due by July 6, 2026 (Docket ID No. EPA–HQ–OAR–2025–3297).

Key to remember: EPA has issued a series of proposed rules that, if finalized, may have significant regulatory impacts on power plant wastewater, pre-construction air permits, and vehicle emission requirements.

MACT emission standards: 7 questions answered
2026-05-14T05:00:00Z

MACT emission standards: 7 questions answered

Standards are more than just suggestions when it comes to environmental regulations; they define the minimum level of performance that must be achieved and, as a result, determine who complies and who doesn’t. For industrial facilities that release air toxics, emission standards are foundational to compliance.

The Environmental Protection Agency (EPA) controls the release of more than 180 air toxics, known as hazardous air pollutants (HAPs), from industrial sources (such as factories and refineries) through the National Emission Standards for Hazardous Air Pollutants (NESHAP) program. For major sources, EPA develops maximum achievable control technology (MACT) standards to reduce HAP emissions.

Understanding the basics of MACT standards can help you navigate the requirements specific to your facility. Here’s what you need to know.

What’s a MACT standard?

A MACT standard refers to the specific technology-based requirements set by EPA to control HAP emissions from major sources in a specific industrial source category. The agency bases the standards on the emission levels already being achieved with existing control technologies by the best-controlled and lowest-emitting facilities in an industry.

What’s a MACT floor?

MACT floors are the minimum control levels that regulated facilities must meet. EPA sets MACT floors differently for new and existing facilities:

  • The MACT floors for new facilities must be at least as stringent as the emission control achieved by the best-controlled similar source.
  • The MACT floors for existing facilities (which may be less stringent than the floors for new sources) have to be at least as strict as the average emission limitation achieved by either:
    • The top-performing 12 percent of sources in a category or subcategory with 30 or more sources, or
    • The top-performing 5 sources in a category or subcategory with fewer than 30 sources.

Keep in mind that EPA may establish requirements stricter than the MACT floor, known as “beyond-the-floor” standards.

What types of facilities are subject to MACT standards?

MACT standards generally apply to major sources of HAP emissions. A facility is considered a major source if it emits or has the potential to emit:

  • 10 tons per year (tpy) of any one HAP, or
  • 25 tpy of any combination of HAPs.

How are MACT standards organized?

EPA develops MACT standards by industry sector and publishes them as part of the NESHAP regulations. Most of the rules appear under 40 CFR Part 63, organized by subparts based on source category. Facilities must identify their source category to determine which NESHAP subpart applies.

A limited number of the rules are found under Part 61, organized by subparts based on specific HAPs (such as vinyl chloride) or activities (like asbestos demolition). Facilities need to confirm whether any of the NESHAPs for specific HAPs or activities apply.

How are MACT standards enforced?

The air permitting authority (usually a state or local air agency) incorporates applicable NESHAP requirements, including MACT standards, into a facility’s Title V operating permit.

What do MACT standards cover?

MACT standards can include a combination of measures, methods, processes, systems, and techniques to reduce or eliminate HAP emissions. Examples include:

  • Conducting process changes;
  • Substituting materials;
  • Enclosing systems or processes; and
  • Collecting, capturing, and/or treating HAP releases from emission points.

MACT standards may also contain design, equipment, work practice, and operation requirements.

Can MACT standards change?

Yes. The Clean Air Act requires EPA to evaluate MACT standards every 8 years (known as a risk and technology review). The agency will revise MACT standards when it determines improvements in technologies, practices, processes, or other emission-reduction methods warrant revisions.

Real-world example

Let’s take a look at the NESHAP for Polyether Polyols (PEPO) Production (PEPO NESHAP), recently updated in March 2026.

The MACT standards that apply to the PEPO NESHAP (Part 63 Subpart PPP) include:

  • Emission limits for process vents;
  • Equipment and work practice requirements for storage vessels, wastewater, and equipment leaks; and
  • Work practice standards for heat exchange systems.

EPA concluded that improvements in controls warranted updates to specific MACT standards in the PEPO NESHAP, including for heat exchange systems. Specifically, the revised rule requires owners and operators of existing and new heat exchange systems in organic HAP service to:

  • Conduct quarterly monitoring using the Modified El Paso Method (also known as the Air Stripping Method), and
  • Repair leaks of total strippable hydrocarbon concentration (as methane) in the stripping gas of 6.2 parts per million by volume or greater.

The agency found that the Modified El Paso Method is more effective at identifying leaks, and it measures more compounds than previously required methods. As a result, this revised MACT standard will further reduce HAP emissions from heat exchange systems.

Key to remember: EPA controls hazardous air pollutant emissions from major sources through MACT standards based on the emission levels already achieved by the best-controlled facilities in an industry.

EHS Monthly Round Up - April 2026

EHS Monthly Round Up - April 2026

In this April 2026 roundup video, we’ll review the most impactful environmental health and safety news.

Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.

OSHA revised its National Emphasis Program on heat-related hazards. Going forward, the agency will prioritize inspections in 55 high-risk industries in indoor and outdoor work settings. The program remains in effect for 5 years from its April 10 effective date.

An OSHA proposed rule seeks to eliminate the November 18, 2036, deadline in the Walking-Working Surfaces standard that would require all fixed ladders extending more than 24 feet above a lower level to be equipped with personal fall arrest systems or ladder safety systems. OSHA also seeks feedback on nine specific questions related to the proposal, with comments due on June 5.

On April 17, OSHA revoked its House Falls in Marine Terminals standard at 1917.41. The agency said that because most cargo has been containerized and is moved by cranes, the standard is no longer necessary to protect employees.

Turning to environmental news, an EPA final rule further delays the submission period for the one-time PFAS report required of manufacturers. It pushes the start of the submission period to either 60 days after the effective date of a future final rule updating the PFAS Reporting Rule or January 31, 2027, whichever comes first.

An EPA final rule makes technical changes to the emission standards established in March 2024 for crude oil and natural gas facilities. The changes take effect June 8.

EPA published the draft 6th Contaminant Candidate List for the next group of contaminants to be considered for regulation under the Safe Drinking Water Act. The proposed list designates microplastics and pharmaceuticals as priority contaminant groups for the first time.

And finally, EPA plans to make significant changes to coal combustion residuals requirements. A proposed rule published April 13 would revise the regulations governing the disposal of coal combustion residuals in landfills and surface impoundments, as well as the beneficial use of coal combustion residuals.

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

EHS Monthly Round Up - February 2026

EHS Monthly Round Up - February 2026

In this Februrary 2026 roundup video, we'll discuss the most impactful environmental health and safety news.

Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.

Fatal work injuries fell 4 percent in 2024, largely due to a decline in workplace drug- and alcohol-related overdoses. According to the Bureau of Labor Statistics, overdose fatalities fell from 512 in 2023 to 410 in 2024. Across all types of workplace incidents, there were 5,070 fatal work injuries in 2024, compared to 5,283 in 2023. Transportation incidents continue to be the most frequent type of fatal event, accounting for over 38 percent of all occupational fatalities in 2024.

OSHA is fast-tracking a proposal to remove the 2036 obligation to upgrade fall protection systems on fixed ladders that extend over 24 feet. This follows an industry petition from major chemical and petroleum industry groups, which argue the provision is unjustified, costly, and not supported by the rulemaking record. OSHA frames the upcoming proposed action as deregulatory, allowing employers to update fixed ladders at the end of their service lives. We’ll provide updates as more information becomes available.

As OSHA leans into “deregulatory” actions, lawmakers are moving to pressure the agency to issue “regulatory” rulemaking to protect American workers. The latest legislative wave of bills aims to fill regulatory gaps, tackle emerging hazards, expand OSHA authority, and raise penalties. Topics addressed by these bills include musculoskeletal disorders, heat stress, infectious diseases, wildfire smoke, and workplace violence.

In a recently issued letter of interpretation, OSHA states that a burn injury caused by a personal lithium-ion battery fire is work related if it occurs in the workplace during assigned working hours. The letter details an incident where an employee was burned when their rechargeable lithium-ion batteries for e-cigarettes sparked a fire after coming into contact with a key used for work.

A new report from the Department of Labor Office of Inspector General concludes that OSHA struggles to meet its mission, particularly in high-risk industries like healthcare, construction, and manufacturing. Several pages point to OSHA’s difficulties in effectively enforcing annual injury and illness reporting requirements, reaching the nation’s high-risk worksites for inspection, and addressing workplace violence by regulatory or other action.

Turning to environmental news, EPA extended the deadlines for Facility Evaluation Reports and related requirements for coal combustion residuals facilities. In most instances, the deadlines have been moved one or two years out.

And finally, EPA announced a final rule eliminating the 2009 Endangerment Finding and related greenhouse gas emission requirements for on-highway vehicles and vehicle engines. When the final rule takes effect, manufacturers and importers of new motor vehicles and motor vehicle engines will no longer have to measure, report, certify, or comply with federal greenhouse gas emission standards.

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

EHS Monthly Round Up - March 2026

EHS Monthly Round Up - March 2026

In this March 2026 roundup video, we'll review the most impactful environmental health and safety news.

Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.

OSHA released an updated Job Safety and Health poster. Employers can use either the revised version or the older one, but the poster must be displayed in a conspicuous place where workers can easily see it.

OSHA recently removed a link from its Data topic webpage that displayed a list of “high-penalty cases” at or over $40,000 since 2015. The agency says it discontinued and removed it in December. The data is frozen and archived elsewhere.

OSHA published two new resources as part of its newly launched Safety Champions Program. The fact sheet provides an overview of how the program works, eligibility criteria, and key benefits. The step-by-step guide helps businesses navigate the core elements of OSHA’s Recommended Practices for Safety and Health Programs.

Several forces are nudging OSHA to address a number of workplace hazards and high-hazard industries. This comes from other agencies, safety organizations, watchdogs, legislative proposals, and persistent injury/fatality data. Among the hazards are combustible dust; first aid; personal protective equipment; and workplace violence. How all this translates into new regulations, guidance, programmed inspections, or other initiatives remains to be seen.

Turning to environmental news, EPA issued a proposed rule to require waste handlers to use electronic manifests to track all RCRA hazardous waste shipments. Stakeholders have until May 4 to comment on the proposal.

On March 10, EPA finalized stronger emission limits for new and existing large municipal waste combustors and made other changes to related standards.

And finally, EPA temporarily extended coverage under the 2021 Multi-Sector General Permit for industrial stormwater discharges until the agency issues a new general permit. The permit expired February 28 and remains in effect for facilities previously covered. EPA won’t take enforcement action against new facilities for unpermitted stormwater discharges if the facilities meet specific conditions.

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

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