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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 scraps Endangerment Finding, GHG emission standards: What you need to know
2026-02-25T06:00:00Z

EPA scraps Endangerment Finding, GHG emission standards: What you need to know

“Road Closed Ahead.” That’s the sign that now stands at the entrance of the regulatory road leading to the federal greenhouse gas (GHG) emission standards for vehicle and engine manufacturers.

The Environmental Protection Agency (EPA) finalized a rule on February 18, 2026, to rescind the 2009 Endangerment Finding and repeal all GHG emission standards for new motor vehicles and motor vehicle engines. The final rule applies to vehicles and engines of model years 2012 to 2027 and beyond.

This overview will help you navigate EPA’s final rule that puts GHG emission requirements for vehicles in the rearview mirror.

What does this mean?

Manufacturers (including importers) of new motor vehicles and motor vehicle engines will no longer have future obligations to measure, control, report, or comply with federal GHG emission standards.

Specifically, the final rule removes the requirements for controlling GHG emissions, which include:

  • Emission standards;
  • Test procedures;
  • Averaging, banking, and trading requirements;
  • Reporting requirements; and
  • Fleet-average emission requirements.

Additionally, the final rule eliminates off-cycle credits for manufacturers that added certain technologies to their vehicles and engines (like waste heat recovery) and EPA’s incentives for manufacturers to install a start-stop system (which automatically shuts off a vehicle’s engine when idling).

When do the changes apply?

The final rule takes effect on April 20, 2026. However, a legal challenge has already been brought against the rulemaking, and more litigation is likely.

It’s important to keep an eye on the status of the rule. Legal challenges could result in changes to the rule, such as delaying its effective date.

What regulations were removed?

The final rule repeals all GHG emission regulations in 40 CFR:

Why did EPA remove the standards?

The road to reversal begins in 2009. That’s when EPA issued two findings: the Endangerment Finding and the Cause or Contribute Finding. Collectively, these findings are referred to as the 2009 Endangerment Finding. The agency used the 2009 Endangerment Finding as the legal basis under Section 202(a) of the Clean Air Act (CAA) to regulate GHG emissions from new motor vehicles and motor vehicle engines based on global climate change concerns.

However, upon reconsideration, EPA no longer believes that it has the statutory authority under Section 202(a) of the CAA to regulate GHG emissions from new motor vehicles and motor vehicle engines in response to global climate change concerns. The agency bases its determination on three factors:

  • EPA concludes that the best reading of Section 202(a) of the CAA authorizes the agency to regulate air pollution that threatens to endanger health and welfare through local and regional exposure. Therefore, the CAA doesn’t give EPA the authority to regulate GHG emissions based on global climate change concerns. The agency conducted the “best reading” by using standard interpretation principles and being informed by the Supreme Court’s overturning of “Chevron deference” in Loper Bright Enterprises v. Raimondo (2024).
  • EPA lacks the congressional authorization required to regulate GHG emissions based on global climate change concerns. The agency determined that the major questions doctrine (i.e., federal agencies may not decide issues of major national significance without clear authorization granted by Congress) applies to the Endangerment Finding and that Congress doesn’t give EPA the authority under Section 202(a) of the CAA to decide a national policy response to global climate change concerns.
  • The GHG emission regulations don’t and can’t have a meaningful impact on the identified health and welfare dangers that the Endangerment Finding attributed to global climate change. EPA based this conclusion on the results of climate impact modeling that the public submitted in response to the proposed rule and on the agency’s modeling analysis used to evaluate the submissions.

By rescinding the Endangerment Finding, EPA has no legal basis to regulate GHG emissions from new motor vehicles and motor vehicle engines. Accordingly, the final rule also repeals all GHG emission standards for light-, medium-, and heavy-duty vehicles and heavy-duty engines.

Key to remember: EPA’s final rule eliminates the 2009 Endangerment Finding and the related GHG emission requirements for on-highway vehicles and vehicle engines.

EPA repeals stricter Mercury and Air Toxics Standards for coal-, oil-fired power plants
2026-02-24T06:00:00Z

EPA repeals stricter Mercury and Air Toxics Standards for coal-, oil-fired power plants

On February 24, 2026, the Environmental Protection Agency (EPA) published a final rule repealing the 2024 amendments made to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Coal- and Oil-Fired Electric Utility Steam Generating Units (EGUs). It’s also referred to as the Mercury and Air Toxics Standards (MATS) for power plants.

Effective April 27, 2026, this rule (2026 Final Rule) repeals stricter compliance requirements made to the MATS rule in May 2024 (2024 Final Rule) and reverts them to the less stringent standards established by the 2012 MATS Rule.

Who’s affected?

The rule applies to power plants with coal- and oil-fired EGUs subject to the NESHAP (40 CFR 63 Subpart UUUUU).

What are the changes?

The final rule repeals these 2024 amendments:

  • The revised filterable particulate matter (fPM) emission standard and corresponding total and individual non-metal hazardous air pollutant (HAP) metal standards for existing coal-fired EGUs (reverting to the 2012 MATS Rule requirements);
  • The revised compliance demonstration requirements for all EGUs to install continuous emission monitoring systems (CEMS) for fPM emissions and the adjusted quality assurance (QA) criteria (reverting to the previous standard, allowing EGUs to choose from three compliance demonstration methods); and
  • The revised mercury (Hg) emission standard for lignite-fired EGUs (reverting to the 2012 MATS Rule limit).

The 2026 Final Rule also reinstates the low-emitting EGU (LEE) program for fPM and non-Hg HAP metals. The LEE program requires less frequent stack testing for sources with emissions below 50 percent of the corresponding limit for 3 consecutive years.

Further, EPA’s final rule updates the fPM sampling requirements for EGUs that demonstrate compliance with a PM CEMS. These units must collect either a minimum catch of 6.0 milligrams or a minimum sample volume of 4 dry standard cubic meters (dscm) per test run. EGUs demonstrating compliance using other methods must collect a lower minimum sample volume of 1 dscm per PM test run.

Compliance requirement2024 Final Rule2026 Final Rule
fPM emission limit for existing coal-fired EGUs0.010 pounds per million British thermal units of heat input (lb/MMBtu)0.030 lb/MMBTu
fPM emission compliance demonstration for all coal-and oil-fired EGUsEGUs must use PM CEMS.EGUs may use:
  • Quarterly stack testing,
  • PM continuous parametric monitoring systems, or
  • PM CEMS.
Hg emission limit for existing lignite-fired EGUs1.2 pounds per trillion British thermal units of heat input (lb/TBtu)4.0 lb/TBtu
Key to remember: EPA’s final rule repeals the stricter emission limits set by the 2024 amendments to the Mercury and Air Toxics Standard for coal- and oil-fired power plants.
PFAS, pretreatment, and biosolids: The growing challenge for water permitting
2026-02-20T06:00:00Z

PFAS, pretreatment, and biosolids: The growing challenge for water permitting

Per and polyfluoroalkyl substances (PFAS) pose one of the most urgent and complex challenges for wastewater systems in the United States. As federal agencies reconsider their regulatory strategies and states impose their own standards, publicly owned treatment works (POTWs) and the industries that discharge to them face increasing pressure to control PFAS at the source. These pressures affect pretreatment permits, industrial dischargers, and biosolids management, forming a rapidly evolving compliance landscape. Recent federal assessments and state actions show that PFAS in wastewater and biosolids is no longer a distant regulatory issue. It is a primary driver shaping future POTW permitting.

PFAS in POTW systems: A problem that starts upstream

PFAS enter POTWs through a mix of industrial wastewater, landfill leachate, household products, and consumer goods. Because PFAS are persistent and resistant to conventional treatment, they pass through biological processes largely unchanged. This means industrial contributors sending PFAS to a POTW can cause downstream compliance problems, even at low concentrations. EPA has emphasized that the best way to manage PFAS in wastewater is to prevent the chemicals from entering treatment systems in the first place, placing new attention on upstream industrial sources.

EPA’s 2025 trajectory indicates broader PFAS rulemaking is coming under several environmental statutes, including the Clean Water Act (CWA), Resource Conservation and Recovery Act, and Safe Drinking Water Act, although the federal landscape remains in flux. Still, agencies agree on one point: pretreatment programs will be an essential component of PFAS control.

Pretreatment permits: The first line of defense

Pretreatment permits regulate indirect dischargers, meaning industrial facilities that send wastewater to POTWs instead of directly to surface waters. These permits already manage pollutants that interfere with treatment or pass through into receiving waters. Now, PFAS has become a central focus.

States and POTWs are increasingly requiring:

  • PFAS monitoring in industrial wastewater,
  • Source identification surveys,
  • Product substitution or process changes,
  • Best management practices to reduce PFAS at the facility, and
  • Local limits or prohibitions on PFAS discharges

EPA’s PFAS strategy specifically encourages states and POTWs to deploy all available pretreatment authorities to control PFAS at the source. This approach aligns with statements from EPA representatives asserting that upstream controls are one of the most effective tools for preventing PFAS from entering wastewater systems.

Biosolids under scrutiny: The impact of PFAS

The PFAS problem does not end with liquid effluent. It extends into biosolids, the treated sewage sludge generated by POTWs. In 2025, EPA released a Draft Sewage Sludge Risk Assessment evaluating risks associated with PFOS and PFOA in biosolids applied to land. The assessment found potential human health risks under certain scenarios when biosolid concentrations exceeded 1 part per billion. Although EPA emphasized the assessment is not a regulatory standard, many states immediately treated the value as a de facto limit for biosolid land application.

This rapid adoption has created a challenging environment for POTWs. Unless PFAS inputs from industrial sources are reduced, biosolid PFAS levels remain high, limiting disposal options such as:

  • Agricultural land application,
  • Composting,
  • Surface disposal,
  • Landfilling, and
  • Incineration

Some states have already implemented bans or strict standards on biosolid land application due to PFAS concerns.

Regulatory uncertainty adds pressure

EPA’s PFAS regulatory posture has shifted several times. In 2025, EPA announced its intent to rescind certain PFAS drinking water designations while maintaining standards for PFOS and PFOA, signaling continued reassessment of its overall PFAS approach. These actions underscore the unsettled nature of federal rulemaking.

Meanwhile, the 2021 PFAS Strategic Roadmap and its subsequent progress updates outline multiple forthcoming actions under the CWA, including potential effluent limitation guidelines (ELGs) for PFAS manufacturers and metal finishers. These ELGs, if finalized, would apply to industrial direct and indirect dischargers and shape pretreatment standards nationwide. Yet, as of early 2026, EPA has not finalized technology based effluent limits for PFAS nor established national PFAS biosolids requirements, leaving states to fill the regulatory void.

What POTWs and industrial users should do now

Despite uncertainty, actions today can reduce long term liability:

  • Conduct PFAS source identification at industrial users,
  • Require PFAS monitoring in pretreatment permits,
  • Develop local limits where state guidance is emerging,
  • Engage with industrial facilities early on substitution and pollution prevention,
  • Evaluate biosolids PFAS levels to assess disposal risks, and
  • Participate in state rulemaking to anticipate new limits

POTWs should also coordinate with state environmental agencies, which continue to implement PFAS restrictions independent of federal action.

Pretreatment programs and biosolids management are becoming central to U.S. PFAS compliance. POTWs sit at the intersection of regulatory expectations, industrial discharges, and community concerns. While federal PFAS rules remain in development, state actions and EPA’s strategic direction make one fact clear: controlling PFAS at the source is essential.

Key to remember: For both industrial users and POTWs, proactive PFAS management is no longer optional. It is a core element of future permitting, planning, and risk reduction.

2026-02-13T06:00:00Z

Expert Insights: States take the lead as federal environmental rules pull back

Recent changes in federal environmental policy have created uncertainty for regulated industries. When federal agencies slow rulemaking, reduce enforcement, or narrow requirements, states often step in. As a result, states are taking a stronger role in setting environmental rules, especially on climate change, air quality, and environmental justice.

This shift is changing how industrial facilities understand and manage regulatory risks.

States as environmental policy leaders

Several states have moved to the front of environmental policymaking. California is the most well-known example. Through the California Air Resources Board (CARB), the state enforces air and climate rules that go beyond federal standards. These include strict vehicle emissions limits and greenhouse gas controls for industrial sources. Because California’s economy is so large, its rules often shape compliance decisions across the country.

Other states are following similar paths. For example, New York’s Climate Leadership and Community Protection Act sets clear, enforceable emissions-reduction goals. It also requires agencies to consider climate and environmental justice impacts during permitting. Washington has adopted a cap-and-invest program that limits carbon emissions from major sources and fuel suppliers.

Growing impacts on industrial facilities

For industrial operators, state-led regulation adds complexity and risk. Companies with facilities in multiple states may face very different rules, timelines, and reporting requirements. Meeting federal standards alone may no longer be enough.

Facilities can still fall out of compliance with state rules covering air emissions, water discharges, waste management, or community impacts. These differences can affect permitting schedules, capital planning, and long-term site decisions.

State enforcement and local focus

State enforcement is often more focused and, in many cases, more stringent than federal enforcement. Many states are increasing inspections and placing greater emphasis on environmental justice.

Facilities located near overburdened or historically impacted communities may face closer review, even when federal enforcement activity is limited.

Practical strategies for compliance

To operate successfully in this environment, companies need a proactive approach. Tracking state regulatory changes is essential, since states often move faster than federal agencies. Building compliance programs around the most stringent applicable rules can reduce long-term risk.

Early engagement with state regulators and local communities can also make a difference. Open communication can improve relationships, reduce conflict, and support smoother permitting outcomes.

For industrial facilities, success now depends less on watching Washington and more on understanding the growing influence of state capitals.

EPA reverses Endangerment Finding, scraps GHG emission standards for vehicles
2026-02-13T06:00:00Z

EPA reverses Endangerment Finding, scraps GHG emission standards for vehicles

The Environmental Protection Agency (EPA) published a final rule on February 18, 2026, to rescind the 2009 Endangerment Finding and repeal all federal greenhouse gas (GHG) emission standards for:

  • On-highway light-, medium-, and heavy-duty vehicles; and
  • On-highway heavy-duty vehicle engines.

The final rule takes effect on April 20, 2026, and applies to vehicles and engines of model years 2012 to 2027 and beyond.

What are the changes?

Manufacturers (including importers) of new motor vehicles and motor vehicle engines no longer have to measure, report, or comply with federal GHG emission standards. The final rule removes all GHG emission regulations in 40 CFR:

  • Parts 85, 86, and 600 (light- and medium-duty vehicles);
  • Part 1036 (heavy-duty vehicle engines); and
  • Part 1037 (heavy-duty vehicles).

The final rule also eliminates:

  • All off-cycle credits for the addition of certain technological features (e.g., high-efficiency exterior lighting, waste heat recovery, and active seat ventilation); and
  • EPA’s incentives for manufacturers to add a start-stop system (which automatically shuts off a vehicle’s engine during idling).

What doesn’t change?

EPA’s following regulations remain in effect for new motor vehicles and vehicle engines:

  • Criteria pollutant and air toxic measurement and standards,
  • Corporate Average Fuel Economy testing, and
  • Associated fuel economy labeling requirements.

About the 2009 Endangerment Finding

In 2009, EPA issued two findings: the Endangerment Finding and the Cause or Contribute Finding. Collectively, these findings are referred to as the 2009 Endangerment Finding. The agency used the 2009 Endangerment Finding as the legal basis to regulate GHG emissions from new motor vehicles and vehicle engines under Section 202(a) of the Clean Air Act.

EPA regulated GHG emissions from new motor vehicles and vehicle engines through:

  • Emission standards and related requirements, and
  • Engine and vehicle certification requirements.

However, upon reconsideration, EPA stated that it no longer believes it has the statutory authority under Section 202(a) of the Clean Air Act to regulate GHG emissions from new motor vehicles and vehicle engines. Therefore, the agency has simultaneously rescinded the 2009 Endangerment Finding and repealed the related federal GHG emission regulations.

Key to remember: EPA's final rule eliminates the 2009 Endangerment Finding and the related GHG emission requirements for on-highway vehicles and vehicle engines.

See More

Most Recent Highlights In Transportation

EPA delays CCR management unit reporting, related requirements
2026-02-13T06:00:00Z

EPA delays CCR management unit reporting, related requirements

The Environmental Protection Agency (EPA) issued a final rule that extends the deadlines for Facility Evaluation Reports (FERs) required for active and inactive coal combustion residuals (CCR) facilities. The final rule also delays compliance deadlines for related requirements that apply to CCR facilities with CCR management units (CCRMUs).

Who’s impacted?

The final rule applies to:

  • Active CCR facilities, and
  • Inactive CCR facilities with inactive surface impoundments (i.e., legacy CCR surface impoundments).

The 2024 Legacy Final Rule (40 CFR Part 257 Subpart D) requires active CCR facilities and legacy CCR surface impoundments to submit FER Part 1 and FER Part 2, identifying any CCRMUs of 1 ton or more on-site. CCRMUs include previously unregulated CCR surface impoundments and landfills that closed before October 19, 2015, as well as inactive CCR landfills.

Additionally, the 2024 Legacy Final Rule requires facilities with CCRMUs to:

  • Establish a website to publicize the facility’s CCR information;
  • Conduct groundwater monitoring activities (specifically, install a groundwater monitoring system, develop a sampling and analysis plan, collect independent samples, and perform detection and assessment monitoring);
  • Submit the initial annual groundwater monitoring and corrective action (GWMCA) report; and
  • Comply with closure and post-closure care obligations.

What are the changes?

EPA’s final rule extends compliance deadlines for the following standards:

Compliance requirement(s)2024 Legacy Final Rule deadline2026 final rule new deadline
Establish CCR websiteFebruary 9, 2026February 9, 2027
Submit FER Part 1February 9, 2026February 9, 2027
Submit FER Part 2February 8, 2027February 8, 2028
Install groundwater monitoring systemMay 8, 2028February 10, 2031
Develop groundwater sampling and analysis programMay 8, 2028February 10, 2031
  • Start detection and assessment monitoring
  • Start evaluating groundwater monitoring data for statistically significant increases over background levels and statistically significant levels over groundwater protection standards
May 8, 2028February 10, 2031
Submit initial GWMCA reportJanuary 31, 2029January 31, 2032
Submit closure planNovember 8, 2028August 11, 2031
Submit post-closure care planNovember 8, 2028August 11, 2031
Initiate closureMay 8, 2029February 9, 2032
Key to remember: A final rule delays the deadlines for the Facility Evaluation Reports and related requirements for active and inactive coal combustion residuals (CCR) facilities with CCR management units.
Expiring TSCA CBI claims: How to request an extension
2026-02-12T06:00:00Z

Expiring TSCA CBI claims: How to request an extension

How do businesses keep confidential information “off the record”? Companies that are required to report on federally regulated chemical substances may soon face this question, as the first round of confidential business information (CBI) claims starts expiring in June 2026.

Thankfully, the Environmental Protection Agency (EPA) has answered how to keep CBI off the record. On January 6, 2026, the agency published in the Federal Register the process to request extensions of expiring CBI claims for information submitted under the Toxic Substances Control Act (TSCA).

Here’s what you need to know.

CBI extension request process

Businesses that seek to extend a CBI claim beyond its expiration date must submit an extension request. The Federal Register notice describes the following general process:

1. EPA notifies the entity of an expiring CBI claim.

The agency will publish a list of TSCA submissions with expiring CBI claims on the Confidential Business Information Under TSCA (TSCA CBI) website at least 60 days before the claims expire.

EPA will also notify submitters directly through its online Central Data Exchange (CDX). Verify that your company’s contact information on CDX is updated!

Submitters with CBI claims for specific chemical identities should reference the TSCA Chemical Substance Inventory (column EXP) to confirm expiration dates.

2. The entity submits an extension request.

The extension request for an expiring CBI claim includes:

  • A certified supporting statement confirming the four assertions at 40 CFR 703.5(a), and
  • Answers to EPA’s substantiation questions.

EPA lists the general questions that apply to all CBI claims at 703.5(b)(3). Additional questions at 703.5(b)(4) apply to entities claiming CBI for specific chemical identities.

Businesses must submit the extension through EPA’s CDX at least 30 days before the CBI claim expires. The agency is currently developing a new application on CDX for submitting extension requests, which it plans to launch before CBI claims begin expiring in June 2026.

If there’s a delay, EPA will notify submitters on the TSCA CBI website. Additionally, the agency won’t publicize any information from expiring CBI claims until businesses have the opportunity to submit extension requests and the agency reviews them.

3. EPA reviews the extension request.

If the agency approves the extension request, the information in the CBI claim will remain protected for up to another 10 years.

If the agency denies the extension request, the information in the CBI claim can be publicized once the claim expires. EPA will notify submitters of denied claims through CDX at least 30 days before it plans to disclose the information.

Expiring CBI claims: What are the options?

Regulated entities have three ways to address expiring CBI claims:

  • If you choose to maintain the CBI claim, submit the extension request to EPA.
  • If you decide not to renew the CBI claim, you can either:
    • Withdraw the CBI claim through CDX, or
    • Allow the CBI claim to expire (i.e., take no action).

Keep in mind that if you withdraw a CBI claim or allow it to expire, EPA can publicize this information without notifying you beforehand.

Who’s impacted?

The CBI extension request process applies to companies that have made CBI claims under TSCA on or after June 22, 2016.

The Frank R. Lautenberg Chemical Safety for the 21st Century Act (signed into law on June 22, 2016) made amendments to TSCA, including adding a 10-year expiration date to CBI claims.

Key to remember: EPA established the process for entities to request extensions of expiring CBI claims for information submitted under TSCA.

Common errors companies make when submitting air emissions inventories
2026-02-10T06:00:00Z

Common errors companies make when submitting air emissions inventories

Submitting accurate air emissions inventories (AEIs) is essential for regulatory compliance, public transparency, and long-term environmental planning. Yet companies routinely make mistakes that delay approvals, trigger enforcement, or compromise data quality. Many of these errors stem from misunderstanding the reporting rules, such as the Environmental Protection Agency's (EPA’s) Air Emissions Reporting Requirements (AERR) and Greenhouse Gas Reporting Program (GHGRP). Awareness of these pitfalls helps facilities avoid compliance failures and improve emission tracking systems.

Misunderstanding what must be reported

One of the most common errors is failing to understand which pollutants must be included. Under the AERR, states and delegated agencies must report annual emissions of criteria air pollutants, including sulfur dioxide, nitrogen oxides, volatile organic compounds, carbon monoxide, lead, particulate matter (PM2.5 and PM10), and ammonia. These pollutants drive national air quality planning and modeling.

However, many companies overlook hazardous air pollutants (HAPs). While past AERR rules made HAP reporting voluntary, EPA’s proposed revisions would require annual HAP reporting for many sources starting in 2027, significantly expanding reporting duties. Failing to include HAP data or assuming it's still voluntary is a growing compliance risk.

Greenhouse gases (GHGs) are another reporting blind spot. The GHGRP requires large emitters and certain suppliers to report carbon dioxide (CO2), methane, nitrous oxide, and other GHGs each year. Companies often assume GHG reporting applies only to the largest industries, yet thousands of facilities fall within the rule’s thresholds.

Using incorrect or incomplete emission calculations

Facilities often make calculation errors when converting raw activity data into emissions. Many rely on outdated emission factors or incomplete process data. EPA urges states and regulated entities to use standardized estimation guidance from the Air Emissions Inventory Improvement Program whenever possible. But companies may choose default factors without confirming they apply to the specific process, control efficiency, fuel type, or measurement method.

Under EPA’s proposed AERR revisions, if approved, the agency will require more detailed stack information, such as release point coordinates, exhaust parameters, control device data, and stack test results. Failure to collect these details early can lead to rushed estimates or missing data.

Misreporting source categories

Another major issue is misidentifying emission sources. The AERR distinguishes between point, nonpoint, mobile, and portable sources. Mislabeling a source may cause a facility to submit incomplete inventories or fail to meet the required reporting frequency. For example, point sources often require annual reporting, while nonpoint sources may follow triennial schedules.

Similarly, GHGRP reporting is broken into numerous subparts that define equipment types, fuel suppliers, industrial processes, and CO2 injection activities. Companies sometimes choose the wrong subpart or assume their process is exempt, leading to incomplete data submissions.

Incorrect use of thresholds and applicability

Both the AERR and GHGRP have emission-based thresholds. Companies frequently make errors when determining:

  • Whether they meet the AERR Type A point source criteria;
  • Whether they exceed GHGRP reporting thresholds (generally 25,000 metric tons CO2 equivalent annually); and
  • Whether HAP emissions exceed thresholds when HAP reporting is required by a state.

These mistakes usually occur when internal data systems lack consistent tracking or when actual emissions deviate from "potential to emit" estimates used in permitting.

Missing documentation and recordkeeping

EPA requires extensive documentation for emission calculations, monitoring methods, stack tests, control equipment operation, and assumptions. GHGRP rules include detailed monitoring, Quality Assurance/Quality Control (QA/QC), missing data, and record retention requirements. Under proposed AERR rules, companies would also need to submit performance test and evaluation data. Missing or incomplete records often lead to rejected inventories.

Failing to track regulatory updates

Both the AERR and GHGRP are undergoing major revisions. EPA’s proposed AERR updates aim to convert some triennial reporting to annual schedules, add HAP reporting, expand mobile source requirements, and require more detailed facility-level data. Meanwhile, the GHGRP is facing proposed cuts that would eliminate reporting requirements for many source categories while delaying petroleum and natural gas reporting until 2034.

Companies that rely on outdated guidance or assume reporting rules remain static are at risk of major compliance failures.

Improving AEI quality and compliance

Avoiding common errors begins with three fundamentals:

  • Use current regulatory guidance, emission factors, and calculation tools;
  • Maintain complete process data, stack test records, and QA/QC documentation; and
  • Assign knowledgeable staff to track AERR, GHGRP, and state-level changes.

Key to Remember: Accurate air emissions inventories play a crucial role in protecting public health, supporting air quality regulation, and demonstrating corporate responsibility. By understanding the most common pitfalls, companies can improve compliance and reduce costly reporting errors.

EHS Monthly Round Up - January 2026

EHS Monthly Round Up - January 2026

In this January 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.

Chemical manufacturers, importers, distributors, and employers will have an extra four months to comply with the provisions of OSHA’s revised Hazard Communication standard. When the rule was revised in 2024, it contained staggered compliance dates for those who classify or use chemical substances and mixtures. The first compliance date is now May 19 rather than January 19 of 2026.

On January 8, OSHA issued further technical corrections to its Hazard Communication final rule. An initial set of corrections was published in October 2024, and OSHA continued to review the standard for errors. The agency said these corrections should reduce confusion during the chemical classification process and prevent errors on labels and safety data sheets.

In 2024, private industry employers reported 2.5 million nonfatal workplace injuries and illnesses, according to the Bureau of Labor Statistics. This is down 3.1 percent from 2023 and largely due to a decrease in respiratory illnesses. The greatest number of cases involving days away from work, job restriction, or transfer were caused by overexertion, repetitive motion, and bodily conditions, followed by contact incidents.

Registration is open for OSHA’s Safety Champions Program, which is designed to help employers develop and implement effective safety and health programs. Participants can work at their own pace through Introductory, Intermediate, and Advanced levels.

Turning to environmental news, on January 9, EPA withdrew its direct final rule on SDS/Tier II reporting tied to OSHA HazCom, before it had a chance to take effect. The direct final rule was published back on November 17, 2025, and was intended to relax the Tier II and safety data sheet reporting requirements and align with OSHA’s HazCom standard. EPA said it plans to write a new rule addressing all public comments.

And finally, EPA published a final rule that changes certain requirements for wastewater discharges from coal-fired steam electric power plants. It applies to the deadlines established by the preceding rule finalized in 2024.

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

Erosion vs. sediment controls: Prevent stormwater pollution at the construction site
2026-01-30T06:00:00Z

Erosion vs. sediment controls: Prevent stormwater pollution at the construction site

It’s wintertime, and many construction sites across the U.S. face unique challenges that the season brings, especially keeping workers warm! However, one challenge that construction sites face year-round is how to keep stormwater runoff (whether it’s generated by snowmelt or rain) from transporting pollutants off-site into nearby waterways.

Under the National Pollutant Discharge Elimination System (NPDES) stormwater program (40 CFR Part 450), the Environmental Protection Agency (EPA) requires construction site operators to obtain a permit to discharge stormwater runoff into waters of the United States from any construction activity that disturbs:

  • 1 acre or more of land, or
  • Less than 1 acre of land if it’s part of a plan of development or sale that will ultimately disturb 1 or more acres of land.

Construction sites must implement best management practices (BMPs), which are controls and activities used to prevent stormwater pollution. Erosion controls and sediment controls are the two leading types of BMPs that construction sites have to apply.

Understanding the differences between erosion controls and sediment controls (and how they function together) will help you choose the most effective BMPs to reduce stormwater pollution at your construction site.

Erosion controls vs. sediment controls

Both types of controls are important, but their functions are distinct. Construction sites should use erosion controls as the primary method and sediment controls as the backup method to reduce stormwater pollution.

Erosion controls prevent the land from wearing away. These measures stop soil particles from being dislodged and transported by stormwater or wind. Erosion controls are the first line of defense against stormwater pollution.

Erosion control examples include:

  • Shoring excavated areas with retaining walls,
  • Conducting construction work in concentrated areas at different times to minimize soil exposure, and
  • Installing erosion control blankets on steep slopes.

Sediment controls capture soil particles that have been dislodged (i.e., eroded) before stormwater or wind moves them off the construction site. Sediment controls are the second line of defense, serving as backup BMPs.

Examples of sediment controls are:

  • Protecting storm drain inlets with filtering materials (such as rock-filled bags),
  • Installing fiber rolls around the perimeter to retain soil dislodged by runoff from small areas, and
  • Adding a sedimentation basin to receive dewatering discharges.

Common BMP examples

EPA’s “National Menu of Best Management Practices (BMPs) for Stormwater-Construction” webpage details erosion controls and sediment controls frequently used at construction sites, including (but not limited to) the following:

Erosion control BMPsSediment control BMPs
  • Composting blankets
  • Dust control measures (e.g., irrigation)
  • Mulching
  • Riprap (i.e., a layer of large stones)
  • Wind and sand fences
  • Compost filter socks
  • Rock dams
  • Sediment filters and pretreatment sediment chambers
  • Silt fences
  • Track-out controls (for construction entrances/exits)
Another popular option is vegetative cover, which can provide both erosion and sediment control. For example, a construction site can seed disturbed land to cover exposed soil (setting up temporary controls until vegetation grows). Once vegetation is established, it can stop stormwater from eroding the soil and act as a natural filter to remove sediment from the runoff.

Use both types of BMPs

The most effective way to control stormwater pollution at construction sites is by applying a selection of erosion controls and sediment controls that are coordinated to work together. Consider these examples:

  • After an area has been graded, the exposed soil must be stabilized. A site can lay sod over the exposed soil (erosion control) and install a silt fence to catch any contaminated soil moved out of the area by stormwater (sediment control) while the sod takes root.
  • Stormwater from upstream locations can flow through a construction site. To protect the disturbed land, a site can build a berm that diverts runoff away from the construction area (erosion control) to a basin where the sediment settles before the runoff is discharged (sediment control).
  • When grading an area with a slope, stormwater can transport contaminated soil down the disturbed slope. A site can install a temporary slope drain that directs the runoff at the top of the slope to a pipe that carries it down the side of the slope (erosion control). The site may also add a sediment trap at the slope drain outlet to remove sediment from the runoff before it’s released (sediment control).

Check state and local requirements

Most states issue NPDES construction stormwater permits. Check the permit to confirm erosion control and sediment control requirements, as they may be more stringent at the state level.

Additionally, some local governments may impose requirements on construction sites. However, unless the local program is designated as a qualifying local program, compliance with local regulations may not mean that your construction site is compliant with EPA’s rules (and vice versa). Confirm with the local government whether additional requirements apply.

Key to remember: Construction sites must implement erosion controls and sediment controls to prevent stormwater pollution.

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Most Recent Highlights In Safety & Health

Dust collector to disposal: Understanding dust as a waste stream
2026-01-28T06:00:00Z

Dust collector to disposal: Understanding dust as a waste stream

When the topic of dust is brought up, the conversation usually starts and ends with worker exposure. How much is in the air? Is ventilation adequate? Are employees protected? Once that dust has been captured and removed from the process, the critical question shifts: how should this material be classified and disposed of? That’s where many facilities run into trouble. Collected dust may no longer be floating in the air, but it hasn’t stopped being regulated. In fact, once it’s captured, dust often enters a much more complicated regulatory world.

When captured dust becomes a regulated waste

Under the Environmental Protection Agency (EPA) regulations, most collected dust qualifies as a solid waste once it’s removed from a dust collector, hopper, or filter. And despite the name, “solid waste” doesn’t mean solid, benign, or harmless. It simply means a discarded material.

At that point, facilities are expected to determine whether the dust is hazardous or non-hazardous under the Resource Conservation and Recovery Act (RCRA). This determination is based on what the dust contains, not how dusty it looks or how long it has been managed that way. Dust generated from metalworking, surface coatings, chemical processing, plastics, or specialty manufacturing can contain regulated constituents such as heavy metals or chemical residues. In these cases, facilities are required to make a waste determination using process knowledge, testing, or a combination of both.

This step is often overlooked. Many companies assume that if dust has not caused problems in the past, it must be non-hazardous. Unfortunately, regulators do not accept assumptions as documentation. If there’s no clear waste determination on file, that alone can be cited during an inspection. Misclassifying dust can also have ripple effects. If collected dust is later found to be hazardous, the facility may face issues related to improper disposal, incorrect generator status, or even cleanup liability at the disposal site. What began as a routine housekeeping task can suddenly become a significant compliance issue.

Storage, disposal, and the risks of getting it wrong

Even when dust is correctly identified as non-hazardous, it still needs to be managed properly. Open containers, poor labeling, and inconsistent handling practices are common findings during inspections. These issues are often viewed as minor, but they can quickly escalate if dust is released, mixed with other waste streams, or stored improperly.

Recycling adds another layer of complexity. Many facilities recycle metal dusts or other recoverable materials, which can be a smart environmental and economic decision. However, recyclable doesn't mean unregulated. Dust being recycled still needs to be stored safely, managed to prevent releases, and documented as legitimate recycling. Without proper controls, regulators may view the material as improperly managed waste.

Outdoor storage creates additional risk. Dust stored outside, transferred outdoors, or tracked out of the building can easily become a stormwater concern. Even non-hazardous dust can be considered a pollutant if it migrates off-site during rain events. This is a frequent source of violations under stormwater permits and Stormwater Pollution Prevention Plans (SWPPPs), especially when dust management isn’t addressed in the SWPPP.

Another common issue is mixing dust with general trash or other waste streams. Once mixed, otherwise manageable dust can become more difficult or impossible to classify correctly. This can complicate disposal, increase costs, and raise questions during audits or inspections.

What makes dust especially challenging is that responsibility for it often falls into a gray area. The safety team may assume that the environmental team is managing disposal. The environmental team may assume that the safety team has already classified the material. When no one clearly owns the waste determination and disposal process, gaps are almost guaranteed.

The most effective facilities treat dust as a waste stream that deserves the same attention as any other regulated material. They document waste determinations, define storage and labeling requirements, train employees on proper handling, and periodically revisit those determinations as processes change.

Keys to remember: Captured dust doesn’t stop being regulated once it leaves the air. Understanding whether collected dust is hazardous or non-hazardous, how it must be stored, and where it can legally go is essential to staying compliant.

2026-01-28T06:00:00Z

Wisconsin raises, adds fees to NSR construction permit program

This applies to: Construction air permit applicants

Effective date: April 1, 2026

Description of change: The New Source Review (NSR) construction permit program requires applicants to obtain an NSR permit before constructing, reconstructing, replacing, relocating, or modifying stationary sources that emit air contaminants. The amendments:

  • Increase most construction permit fees by 20 percent,
  • Adjust certain fees to better align with actual workload, and
  • Add new fees for:
    • Permit revisions,
    • Public hearing requests from someone other than the applicant, and
    • Incorporating consent decree requirements into permits.

Related state info: Clean air operating permits state comparison

2026-01-28T06:00:00Z

California codifies requirements for pesticide applications near schools

Effective date: January 1, 2026

This applies to: Pesticide applications made for agricultural commodity production within ¼ mile of a school

Description of change: Assembly Bill 1864 (effective January 1, 2025) regulates pesticide applications for the production of agricultural commodities within ¼ mile of a school.

The amendments to the rule require applicants to:

  • Obtain a separate site identification number for the part of an agricultural field within ¼ mile of a “schoolsite," and
  • List the anticipated method of application for notices of intent and pesticide use reports.

Further, the amendments change the definition of “schoolsite” to include private schools that serve six or more students (kindergarten through grade 12), which will become effective on December 31, 2026.

2026-01-28T06:00:00Z

Washington adopts regulations for battery collection program

Effective date: January 16, 2026

This applies to: Producers of batteries and battery-containing products

Description of change: The Washington Department of Ecology adopted a new rule for the Battery Stewardship Program, required by a law passed in 2023 to establish an extended producer responsibility program for battery collection. The regulations implement the law, requiring battery producers to fund a statewide recycling program with collection sites where people can drop off used or unwanted batteries.

Covered batteries include most rechargeable and single-use batteries that people use daily (e.g., AAs, AAAs, Cs, Ds, 9-Volts, and button batteries). The regulations also cover battery-containing products.

The new rule establishes program requirements (e.g., adding required information on batteries), applicable fees, and battery collection and handling standards. It requires battery producers to join and fully fund a nonprofit to serve as a Battery Stewardship Organization, which administers the program.

2026-01-28T06:00:00Z

Tennessee extends UST fee suspension

Effective date: April 9, 2026

This applies to: Petroleum underground storage tank (UST) owners and operators

Description of change: The amendment extends the suspension of annual UST fees until June 30, 2031.

Related state info: Underground storage tanks (USTs) — Tennessee

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Most Recent Highlights In Human Resources

2026-01-28T06:00:00Z

New Jersey adopts REAL rule amendments

Effective date: January 20, 2026

This applies to: New development, redevelopment, and substantial improvements to buildings

Description of change: The New Jersey Department of Environmental Protection (DEP) adopted amendments to the Resilient Environments and Landscapes (REAL) regulation that add new rules, repeal some rules, and amend other rules for land-use regulations. It affects multiple regulations, such as the:

  • Coastal Zone Management Rules,
  • Freshwater Wetlands Protection Act Rules,
  • Stormwater Management rules, and
  • Flood Hazard Area Control Act Rules.

Examples of requirements include inundation risk assessments, on-site alternatives analyses, and risk acknowledgements.

The DEP allows certain applications to be reviewed under the previous regulations until July 20, 2026. The DEP website offers guidance to help regulated entities determine which rule version applies.

Related state info: Construction water permitting state comparison — New Jersey

2026-01-28T06:00:00Z

California restricts 1,3-dichloropropene use

Effective date: January 1, 2026

This applies to: Uses of 1,3-dichloropropene for agricultural production

Description of change: The California Department of Pesticide Regulation restricts the use of 1,3-dichloropropene to minimize exposure for occupational bystanders. It establishes buffer zone distances (i.e., distances from the edge of a treated area where certain activities are restricted) and related requirements.

The rulemaking also updates the field fumigation requirements document (1,3-Dichloropropene Field Fumigation Requirements, Rev. January 1, 2026).

2026-01-28T06:00:00Z

New Hampshire amends asbestos rule

Effective date: January 1, 2026

This applies to: Any person who renovates or demolishes an asbestos-containing building and any person involved in asbestos abatement activities

Description of change: The New Hampshire Department of Environmental Services adopted and readopted with amendments rules for asbestos management and control. Changes include:

  • Adding new categories of major asbestos abatement,
  • Reducing the timeframe to submit a demolition notification for residential projects if it’s submitted online with supporting documentation,
  • Raising current notification and application fees, and
  • Removing a question from nine application forms.
2026-01-28T06:00:00Z

District of Columbia extends tuning combustion process deadline

Effective date: January 16, 2026

This applies to: Fuel-burning equipment with a heat input capacity of 5,000,000 British thermal units per hour or more

Description of change: The Department of Energy and Environment extended the annual deadline for tuning the combustion process for fuel-burning equipment from November 1 to December 31. It gives regulated sources more flexibility to complete combustion adjustments. The requirements are contained in 20 DCMR 805.5.

Related state info: Clean air operating permits state comparison

2026-01-28T06:00:00Z

California adds nail product chemical to priority list

Effective date: April 1, 2026

This applies to: Domestic and foreign manufacturers of nail coatings and artificial nails with more than 1,000 parts per million (ppm) of methyl methacrylate (MMA) that sell their products in California

Description of change: The California Department of Toxic Substances Control added nail products with concentrations of 1,000 ppm or more of MMA to the Priority Product list, making the substance subject to regulation.

Covered manufacturers must submit a Priority Product Notification by June 1, 2026, that lists the covered products sold in California as either an intentionally added ingredient, a contaminant, or a residual.

Manufacturers will then have to submit by September 28, 2026, one of the following:

  • A Chemical Removal Intent/Confirmation Notification,
  • A Product Removal Intent/Confirmation Notification,
  • A Product-Chemical Replacement Intent/Confirmation Notification, or
  • A Preliminary Alternatives Analysis Report or other alternate reporting options.
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