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NewsFleet SafetyPipeline and Hazardous Materials Safety Administration (PHMSA), DOTDrug testing - Motor CarrierDrug and Alcohol Testing - DOTOffice of the Secretary of TransportationHazmat SafetyRulemakingFocus AreaProposed RuleEnglishTransportationUSA
89 FR 82957 Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records
2024-10-15T05:00:00Z
DEPARTMENT OF TRANSPORTATION
Office of the Secretary
49 CFR Part 40
Pipeline and Hazardous Materials Safety Administration
49 CFR Part 199
[Docket DOT-OST-2022-0027]
RIN 2105-AF01
Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records
AGENCY: Office of the Secretary, Department of Transportation (DOT).
ACTION: Notice of proposed rulemaking (NPRM).
SUMMARY: The Department of Transportation (DOT or Department) proposes to amend its regulations for conducting workplace drug and alcohol testing for the federally regulated transportation industry to allow, but not require, electronic signatures on documents required to be created and utilized under the regulations, the use of electronic versions of forms, and the electronic storage of forms and data. The regulatory changes would apply to DOT-regulated employers and their contractors (“service agents”) who administer their DOT-regulated drug and alcohol testing programs. Currently, employers and their service agents must use, sign and store paper documents exclusively, unless the employer is utilizing a laboratory's electronic Federal Drug Testing Custody and Control Form (electronic CCF) system that has been approved by the Department of Health and Human Services (HHS). DOT is required by statute to amend its regulations to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms. This rulemaking also responds to an April 2, 2020, petition for rulemaking from DISA Global Solutions, Inc. (DISA), requesting that DOT regulations be amended to allow the use of an electronic version of the alcohol testing form (ATF) for DOT-authorized alcohol testing. The proposed regulatory amendments are expected to provide additional flexibility and reduced costs for the industry while maintaining the integrity and confidentiality requirements of the drug and alcohol testing regulations. In addition, DOT proposes to amend the Pipeline and Hazardous Materials Safety Administration (PHMSA) regulation for conformity and to make other miscellaneous technical changes and corrections.
DATES: Comments on this NPRM must be received on or before December 16, 2024.
ADDRESSES: You may submit comments identified by Docket Number DOT-OST-2022-0027 using any of the following methods:
• Federal eRulemaking Portal: Go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document. Follow the online instructions for submitting comments.
• Mail: Docket Management Facility, U.S. Department of Transportation, 1200 New Jersey Avenue SE, West Building, Ground Floor, Room W12-140, Washington, DC 20590-0001.
• Hand Delivery or Courier: West Building, Ground Floor, Room W12-140, 1200 New Jersey Avenue SE, Washington, DC, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting Dockets Operations.
• Fax: 202-493-2251.
To avoid duplication, please use only one of these methods. See the “Public Participation and Request for Comments” portion of the SUPPLEMENTARY INFORMATION section for instructions on submitting comments, including collection of information comments for the Office of Information and Regulatory Affairs, Office of Management and Budget (OMB).
FOR FURTHER INFORMATION CONTACT:
Mike Huntley, Office of Drug and Alcohol Policy and Compliance, 1200 New Jersey Avenue SE, Washington, DC 20590; telephone number 202-366-3784; ODAPCwebmail@dot.gov. If you have questions on viewing or submitting material to the docket, contact Docket Services, telephone (202) 366-9826.
SUPPLEMENTARY INFORMATION:
This NPRM is organized as follows:
I. Executive Summary
II. Public Participation and Request for Comments
A. Submitting Comments
B. Viewing Comments and Documents
C. Privacy Act
III. Legal Basis for the Rulemaking
IV. Background
V. Advance Notice of Proposed Rulemaking (ANPRM) Overview
VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures
VII. Amending Part 40 To Permit Electronic Documents and Signatures
VIII. Electronic ATF
IX. Section-by-Section Analysis
X. Regulatory Analyses and Notices
I. Executive Summary
Purpose and Summary of the Major Provisions
This proposed rule would establish parity between paper and electronic documents and signatures and expand businesses' and individuals' ability to use electronic methods to comply with the Department's drug and alcohol testing regulation, 49 CFR part 40, “Procedures for Transportation Workplace Drug and Alcohol Testing Programs” (part 40). Businesses and individuals subject to part 40 would continue to have the choice to use paper documents and traditional “wet” signatures. This proposed rule would also modify references to recordkeeping and reporting methods throughout part 40 to make them technologically neutral.
This proposed rulemaking responds to a statutory mandate set forth in section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271 (see 49 U.S.C. 322 note). The proposed rulemaking would take action consistent with the Government Paperwork Elimination Act (GPEA) (division C, title XVII, secs. 1701-1710, Pub. L. 105-277) and the Electronic Signatures in Global and National Commerce Act (E-SIGN) (Pub. L. 106-229) with regard to DOT's part 40 regulations.
II. Public Participation and Request for Comments
A. Submitting Comments
If you submit a comment, please include the docket number for this NPRM (Docket No. DOT-OST-2022-0027), indicate the specific section of this document to which each comment applies, and provide a reason for each suggestion or recommendation. You may submit your comments and material online or by fax, mail, or hand delivery, but please use only one of these means. The Office of the Secretary (OST) recommends that you include your name and a mailing address, an email address, or a phone number in a cover letter or an email so that OST can contact you if there are questions regarding your submission.
To submit your comment online, go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document, click on this NPRM, click “Comment,” and type your comment into the text box on the following screen.
If you submit your comments by mail or hand delivery, submit them in an unbound format, no larger than 8 1/2 by 11 inches, suitable for copying and electronic filing. If you submit comments by mail and would like to know that they reached the facility, please enclose a stamped, self-addressed postcard or envelope.
OST will consider all comments and material received during the comment period in determining how to proceed with any final rule.
B. Viewing Comments and Documents
To view comments, as well as any documents mentioned in this preamble as available in the docket, go to https://www.regulations.gov. Insert the docket number, DOT-OST-2022-0027, in the keyword box, and click “Search.” Next, click the “Open Docket Folder” button and choose the document to review. If you do not have access to the internet, you may view the docket online by visiting the Docket Management Facility in Room W12-140 on the ground floor of the DOT West Building, 1200 New Jersey Avenue SE, Washington, DC 20590-0001, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting the Docket Management Facility.
C. Privacy Act
In accordance with 5 U.S.C. 553(c), DOT solicits comments from the public to better inform its rulemaking process. DOT posts these comments, without edit, including any personal information the commenter provides, to www.regulations.gov, as described in the system of records notice (DOT/ALL-14 FDMS), which can be reviewed at https://www.transportation.gov/individuals/privacy/privacy-act-system-records-notices under the heading of “Department-Wide System of Records Notices”.
III. Legal Basis for the Rulemaking
This rulemaking is promulgated under the authority enacted in the Omnibus Transportation Employee Testing Act of 1991 (OTETA) (Pub. L. 102-143, tit. V, 105 Stat. 952) and codified at 49 U.S.C. 45102 (aviation), 49 U.S.C. 20140 (rail), 49 U.S.C. 31306 (motor carrier), and 49 U.S.C. 5331 (public transportation), as well as the Department's authority in 49 U.S.C. 322 and the PHMSA authorities specified in the proposed regulatory text for this action.
According to Public Law 115-271, the Secretary of Transportation is required to “issue a final rule revising part 40 of title 49, Code of Federal Regulations, to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms.” (49 U.S.C. 322 note) The statute set the deadline for this action as not later than 18 months after HHS establishes a deadline for a certified laboratory to request approval for fully electronic CCFs ( Id. ) On April 7, 2022, HHS set that deadline as August 31, 2023 (87 FR 20528). HHS has extended the deadline to August 31, 2026, to enable sufficient time for all HHS-certified laboratories to identify and contract with an electronic CCF supplier or to develop an electronic CCF. The deadline for DOT's regulatory amendments would therefore be February 29, 2028.
There are two additional Federal statutes relevant to the implementation of electronic document and signature requirements.
The Government Paperwork Elimination Act (GPEA), codified at 44 U.S.C. 3504 note, 1 was enacted to improve customer service and governmental efficiency through the use of information technology. The GPEA defines an electronic signature as a method of signing an electronic communication that: (a) identifies and authenticates a particular person as the source of the electronic communication; and (b) indicates such person's approval of the information contained in the electronic communication. Id. It also requires OMB to ensure Federal agencies provide for: (a) the option of maintaining, submitting; or disclosing information electronically, when practicable; and (b) the use and acceptance of electronic signatures when practicable. The GPEA states that electronic records submitted pursuant to procedures developed under title XVII for the submission of records to Federal agencies and electronic signatures used in accordance with those procedures shall not be denied legal effect, validity, or enforceability merely because they are in electronic form. Id.
1 Division C, title XVII (sec. 1701-1710) of Public Law 105-277, 112 Stat. 2681-749, enacted on October 21, 1998.
The Electronic Signatures in Global and National Commerce Act (E-SIGN), codified at 15 U.S.C. 7001-7031, 2 was designed to promote the use of electronic contract formation, signatures, and recordkeeping in private commerce by establishing legal equivalence between traditional paper-based methods and electronic methods. The E-SIGN Act allows the use of electronic records to satisfy any statute, regulation, or rule of law requiring that such information be provided in writing if the consumer has affirmatively consented to such use and has not withdrawn consent. Specifically, the statute establishes the legal equivalence of the following types of documents with respect to any transaction in or affecting interstate or foreign commerce, whether in traditional paper or electronic form: (a) contracts, (b) signatures, and (c) other records (15 U.S.C. 7001(a)(1)).
2 Public Law 106-229, 114 Stat. 464, enacted on June 30, 2000.
IV. Background
The Department's drug and alcohol testing regulations were promulgated at a time when the ability to sign and retain official records electronically—now commonplace in many business segments—was not available. Over the course of several years, we have adopted measures that have reduced the paper documentation associated with the drug and alcohol testing program without compromising the integrity and confidentiality requirements of the program. In 2003, we standardized the form for employers to report their Management Information System (MIS) aggregate drug and alcohol testing data, as well as the specific data collected. 3 When creating a ONE-DOT MIS Form, we then authorized employers to submit a single standardized form via a web portal. In 2015, we issued a final rule to allow employers, collectors, laboratories, and medical review officers (MROs) to use the electronic version of the Federal Drug Testing CCF in the DOT-regulated drug testing program. 4 That final rule also incorporated into the regulations the requirement to establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons when using the electronic CCF. We also included language protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form when using the electronic CCF.
3 68 FR 43946 (July 25, 2003).
4 80 FR 19551 (Apr. 13, 2015).
Consistent with the statutory mandate in 49 U.S.C. 322 note, we propose amendments to part 40 to permit the use of electronic signatures, forms, and records storage for drug and alcohol testing records throughout the regulation, including the use of an electronic ATF for DOT-authorized alcohol testing. We emphasize that electronic signatures, forms, and records would not be required; we would continue to allow paper, or hard-copy use with traditional “wet signatures.”
These proposed amendments would establish parity between paper and electronic collection and submission of information required under our regulations (and remain compatible with applicable OMB guidance on implementing electronic signatures 5 ) by allowing further use of electronic means and methods to comply with part 40 requirements. Many employers and their service agents have already instituted the use of electronic signatures, forms, and records storage for the non-DOT regulated testing that they conduct. DOT supports this transition to a paperless system and is committed to ensuring that the movement to a partially or fully electronic part 40 is done to maximize program efficiencies and reduce costs, while maintaining the integrity and confidentiality requirements of the program.
5https://www.whitehouse.gov/wp-content/uploads/2017/11/2000-M-00-15-OMB-Guidance-on-Implementing-the-Electronic-Signatures-in-Global-and-National-Commerce-Act.pdf.
Electronic documents would have a high degree of forensic defensibility as long as any changes made to the document are in the document's electronic footprint, which shows when the document or signature, as applicable, was created; when, and if, changes were made; who made the changes; and when, as applicable, a document was transmitted to and received by the receiving entity. The use of electronic forms and signatures in part 40 would help DOT-regulated employers and their service agents improve their workflow efficiency through faster turnaround times for required documents. Cost savings would result through reduced printing and delivery/shipping costs, and expedited transmission of information allowing for more timely decisions. We believe this proposed rule, if adopted, would also mitigate the longstanding problems ( e.g., delays in processing times of test results, cancelling of test results, etc.) associated with illegible and lost copies of paper documents.
V. Advance Notice of Proposed Rulemaking (ANPRM) Overview
On August 5, 2022, we published an ANPRM requesting public comment on how part 40 could be amended, as required by the statute, to allow electronic signatures, forms, and recordkeeping (87 FR 47951). We requested information from DOT-regulated employers and their service agents regarding if and how they are already handling electronic signatures, records transmission, and records storage in their non-DOT testing programs. In addition, we requested comments and information on appropriate performance standards, and on whether particular methods or performance standards have been successful or unsuccessful. We also asked a number of general questions on the potential advantages, risks, ramifications, and required safeguards associated with the use of electronic signatures, forms, and records in the DOT drug and alcohol testing program. We asked questions about specific sections of part 40 that we anticipated would be affected by prospective changes to implement electronic signatures, forms, and records. Finally, we asked a number of questions regarding the use of an electronic ATF for DOT-regulated alcohol tests.
We received 72 comments in response to the ANPRM, including comments from individuals, testing laboratories, MROs, and MRO organizations, substance abuse professionals (SAP) and SAP organizations, and various associations representing DOT-regulated transportation workers subject to mandatory drug and alcohol testing under part 40.
A few individuals expressed opposition to the adoption of electronic signatures, forms, and recordkeeping, citing concerns about the need for the rulemaking, risk to personal information from hackers or mismanaged electronic processes and procedures, and misuse of electronic forms and signatures. To meet our statutory mandate and in consideration of concerns about safeguarding personal information and appropriate use of the information in developing the NPRM, DOT proposes to require security measures for electronic forms and signatures used under part 40 that are the same as those currently in place for the electronic CCF specified in 49 CFR 40.40(c)(5).
Most commenters were supportive of changes to amend part 40 that would permit, but not require, the use of electronic signatures, forms, and recordkeeping. Commenters supporting revisions to part 40 noted that electronic signatures, forms, and recordkeeping are used in virtually every industry today—including but not limited to the banking, insurance, medical, and legal industries. Commenters supported the use of performance standards instead of technology-specific standards to ensure that, once established, standards do not become obsolete given the rapidly evolving nature of information technology standards and practices. Commenters stated that allowing electronic signatures, forms, and recordkeeping would make the drug testing process much more efficient and would result in cost savings. Commenters also stated that it would be safer to store records electronically since records could be backed-up, secured, and protected from tampering and unauthorized access and use.
VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures
In developing this NPRM, we looked to a rule promulgated by DOT's FMCSA that permits the use of electronic methods to generate, certify, sign, maintain, or exchange records so long as the documents accurately reflect the required information and can be used for their intended purpose. (83 FR 16210, Apr. 16, 2018) The rule applies to documents that FMCSA requires entities or individuals to retain. FMCSA permits, but does not require, anyone to satisfy FMCSA requirements by using electronic methods to generate, maintain, or exchange documents. The substance of the document must otherwise comply with applicable Federal laws and FMCSA rules. FMCSA also permits, but does not require, anyone required to sign or certify a document to do so using electronic signatures, defined, as in the GPEA, as a method of signing an electronic communication that: (1) identifies and authenticates a particular person as the source of the electronic communication; and (2) indicates such person's approval of the information contained in the electronic communication. FMCSA allows for the use any available technology for electronic signatures, so long as the signature otherwise complies with FMCSA's requirements.
FMCSA adopted broad performance standards for electronic documents and signatures—as specified in GPEA and E-SIGN—rather than detailed, technology specific standards that would likely become obsolete with inevitable changes in information technology standards and practices. FMCSA's April 2018 rule has been in effect for more than five years, and the definitions and requirements established in that rule have stood the test of time despite the many changes that have occurred with respect to electronic documents and signatures. We are unaware of any FMCSA-regulated entities that have reported issues to FMCSA regarding the use of electronic documents or signatures to meet the requirements of the FMCSRs since the rule became effective in 2018.
VII. Amending Part 40 To Permit Electronic Documents and Signatures
In this NPRM, we propose to permit but not require electronic documents, signatures, and recordkeeping in part 40. Additionally, we propose a performance standard approach as opposed to establishing technology-specific standards. Where it is possible to do so, establishing the same or substantively similar regulatory requirements for common issues across DOT modal agencies—such as the use of electronic documents and signatures—helps the Department maintain a consistent regulatory approach for those common issues.
There are currently more than 60 references to the term “written” in part 40, and more than 20 additional references to the term “in writing.” We propose to add a definition of “written or in writing” in part 40, to eliminate any distinction between paper and electronic documentation and establish technological neutrality throughout the entirety of part 40.
FMCSA's rule does not apply to documents that individuals or entities are required to file directly with FMCSA. In its April 2018 final rule, FMCSA explained that while industry could use electronic signatures and submit information directly to the FMCSA in certain situations, 6 adapting all FMCSA systems to allow for use of electronic signatures and submissions would significantly delay the implementation of the rule for use by third parties as it would require FMCSA to develop and implement technology systems to allow for direct submission to FMCSA from regulated parties. FMCSA noted that development of such systems could take several years, and therefore saw no reason to make private parties' use of electronic signatures and records retention contingent upon FMCSA's ability to receive submissions electronically because doing so would delay potential benefits to be gained by third parties.
6 As an example, Certified Medical Examiners may use electronic signatures, if they choose to do so, to sign medical forms, certificates, and a new driver medication report. If FMCSA requests these forms, they are uploaded in portable document format (PDF) to the Medical Examiner's account associated with the National Registry of Certified Medical Examiners for FMCSA to access.
In contrast to FMCSA's regulations, part 40 does not require entities or individuals to submit documents directly to the Department except for MIS aggregate drug and alcohol testing data that employers subject to DOT or U.S. Coast Guard (USCG) drug and alcohol testing regulations must submit annually. Each of the various documents required and used as part of the DOT drug and alcohol testing program under part 40 ( e.g., employee drug and alcohol testing records, MRO reports and records, SAP reports and records) are documents that are created by, exchanged between, and maintained by a person or entity involved in the testing process—but are not required to be submitted directly to DOT.
As noted earlier, and specifically with respect to the required MIS data, we standardized the form for employers to report their aggregate drug and alcohol testing data, as well as the specific data collected, more than 20 years ago. At that time, we authorized employers to submit the ONE-DOT MIS form via a web portal. Today, the Federal Aviation Administration, FMCSA, Federal Railroad Administration, and Federal Transit Administration permit employers to submit that same drug and alcohol testing data via the internet, and PHMSA requires that the data be submitted electronically. If employers submit the data electronically via the internet, they are not required to submit a hard copy. DOT recommends that employers have a copy of their data available (either hard copy or in electronic format) in the event an auditor or inspector requests a copy.
From the above, and because the only documents that part 40 requires to be submitted directly to the Department are already permitted to be, and in some cases required to be, submitted electronically, there is no need for us to limit the applicability of our proposal as FMCSA did in its 2018 final rule.
Several commenters noted that they already use electronic signatures and documents for their non-DOT drug and alcohol testing program, and in some cases, have done so for many years. In doing so, these commenters have had to establish appropriate confidentiality and security measures to ensure that confidential employee records cannot be accessed by unauthorized persons, including protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The same general requirements were added to the current §40.40(c)(5) when we approved the use of the electronic CCF for use in DOT drug testing in 2015, 7 and we propose the same requirements in this NPRM for the use of electronic signatures, documents, and recordkeeping throughout the entirety of part 40.
7 The 2015 revisions amended then §40.45(c)(5), which was redesignated as §40.40(c)(5) in the May 2023 final rule to include oral fluid testing in the DOT drug testing program (88 FR 27596, May 2, 2023).
Ensuring that confidential employee records are not available to unauthorized persons is an important element of part 40's protections for employees that are subject to DOT's drug and alcohol testing rules. We believe that the failure of a service agent to provide or maintain a secure/confidential electronic system should constitute the basis for the Department to start a public interest exclusion (PIE) proceeding, and propose to add this to the list of examples provided in §40.365(b).
Throughout part 40, information and documents are required to be transmitted and/or communicated between service agents ( e.g., collectors, screening test technicians (STTs) and breath alcohol technicians (BATs), laboratories, MROs, SAPs, and consortium/third party administrators (C/TPAs)), employers, and employees). Although part 40 does not currently require the party receiving these communications and/or documents to affirmatively confirm receipt of such from the sender, in some instances, regardless of whether the document is electronic or a hard copy, we believe that it may be important for the receiving party to verify that those required communications and/or documents were received.
For example, under §40.25, an employer intending to use an employee to perform safety-sensitive functions must, after obtaining an employee's written consent, request information about the employee's drug and alcohol testing record from previous DOT-regulated employers. After receiving a copy of the employee's written consent, the previous employer must immediately provide the requested information to the employer making the inquiry. If an employer is subsequently investigated/audited by the appropriate DOT mode, it may be beneficial for both the gaining employer and the previous employer to be able to affirmatively demonstrate that the employee's written consent and previous testing record were sent and received as required.
Sections 40.191(d) and 40.261(c)(1) require a collector or MRO (for drug tests) or a BAT, STT, or a physician evaluating a “shy lung” situation (for alcohol tests), respectively, to—when an employee refuses to participate in a part of the testing process—terminate the testing process, document the refusal, and immediately and directly notify the employer's designated employer representative (DER) by any means that ensures the refusal notification is immediately received. Because this notification of a refusal to an employer is of an urgent nature, it may be advisable to require the DER to affirmatively confirm receipt of the required notification from the collector, MRO, BAT, STT, or physician. For example, §§40.191(d) and 40.261(c)(1) could be amended to read “. . . immediately notify the DER by any means and ensure that the refusal notification is immediately received”.
While we are not proposing new requirements in this NPRM regarding confirmation of receipt in the sections discussed above (or in other part 40 requirements), we seek comment regarding whether it may be beneficial or advisable to do so, and if so, for which specific sections of part 40.
VIII. Electronic ATF
The ATF has been in use in the DOT alcohol testing program since 1994 (see 59 FR 7349, Feb. 15, 1994). The ATF must be used to document every DOT alcohol test. DOT regulations at 49 CFR 40.225 set forth the requirements for use of the form, and 49 CFR part 40, appendix G, contains a facsimile (reference copy) of the form. The ATF is a three-part carbonless manifold form used by DOT-regulated employers to document the testing event when testing employees subject to DOT alcohol testing. When the employee is tested, both the employee and the STT and/or the BAT will complete the ATF in various sections. The STT/BAT documents the result(s) by either writing in the screening result or attaching the screening and/or confirmation result printed by the evidential breath testing devices (EBT) onto the ATF, and then sends Copy 1 to the employer, provides Copy 2 to the employee, and retains Copy 3 for their records.
On April 2, 2020, DISA petitioned the Department to amend part 40 to allow for the use of an electronic version of the ATF for DOT mandated alcohol testing. In support of its petition, DISA stated that “The requested amendment to 49 CFR part 40 will enable a parallel process for the documentation of DOT-mandated alcohol tests aligned with the similarly situated amendment previously approved for drug testing.” DISA believes that allowing the use of an electronic ATF will result in several benefits to the industry, including “increased efficiency, security and accuracy in documentation of DOT alcohol tests; paperwork reduction; improved process for conducting a DOT alcohol test in conjunction with a DOT drug test when an electronic version of the federal CCF is used for the drug test; reduction of errors and omissions in the completion of the ATF; and improved efficiency and efficacy in the transmission and record retention of alcohol test results.”
DISA noted that non-DOT workplace breath alcohol testing has been conducted using electronic versions of an alcohol testing form that mirrors the DOT ATF for more than five years. Based on experience using those electronic forms for non-DOT testing, DISA cites improved efficiency and accuracy of documentation because: (1) employer and employee information is entered via computer and thus not dependent on reading and deciphering hand-written entries, (2) date time stamps of the testing are automated and not subject to fluctuation or error, (3) transmission of documentation on completed tests is more secure using databases accessed only via protected password and personal identification number (PIN) to authorized employers or their designated agents, and (4) transmission of test result information is faster and more secure than existing transmission options of scanning and emailing attachments or facsimile.
DISA also noted that permitting use of an electronic ATF for DOT-regulated alcohol testing “will substantially reduce cost, by eliminating the requirement for the printing and distribution of carbonless three-ply paper ATFs. The proposed electronic ATF option would still provide for printed paper images to be made available to the employee, the employer, and the alcohol technician, [but] eliminates the requirement for the more expensive carbonless 3 ply paper ATF.”
For the reasons described by DISA in its petition, and recognizing that significant benefits and cost reductions have resulted from use of the electronic CCF for drug testing, we believe that it is likewise appropriate to permit the use of electronic ATFs in part 40 for DOT-regulated testing. Permitting but not requiring the use of an electronic ATF would be consistent with our proposal to permit, but not require, the use of electronic documents and signatures throughout the entirety of part 40 as discussed above. As several commenters noted, the use of an electronic ATF has been used in non-DOT testing for 5-10 years, and the same developers of the electronic CCFs have developed the electronic ATFs. Any electronic ATF used under part 40 for DOT-regulated employees would have to be identical in form and content to the DOT ATF in appendix I to part 40. 8 Just as we imposed general confidentiality and security requirements when electronic CCFs were permitted to be used under part 40, we believe that it is necessary to include the same general requirements relating to the use of electronic ATFs to ensure that confidential employee records cannot be accessed by unauthorized persons.
8 The ATF form was redesignated from appendix G to appendix I as part of the rulemaking process culminating in the May 2023 final rule. During that process, the form was reviewed by the public and DOT received no comment on the form.
Manufacturers of EBTs and alcohol screening devices (ASD) used in DOT alcohol tests must obtain approval from the National Highway Traffic Safety Administration (NHTSA) and then be listed on the Office of Drug and Alcohol Policy and Compliance's (ODAPC) website before those devices may be used in DOT alcohol testing.
IX. PHMSA Proposed Changes
PHMSA is proposing to amend §§199.3, 199.117, and 199.227 and to add §199.4 to conform to the proposed changes in part 40 and to clarify that the proposed changes in part 40 apply to part 199. These changes will help the readers of part 199 find the applicable regulations in part 40 with regards to the definition of terms and record keeping requirements. We also propose to amend §§199.119 and 199.229 by changing the reference of “appendix H” to “appendix J” to conform to the amendment of part 40 published on May 2, 2023.
X. Section-by-Section Analysis
Section 40.3 What do the terms used in this regulation mean?
We propose to add a definition of “electronic signature.” The rule would define an electronic signature as a method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 44 U.S.C. 3504 note, 112 Stat. 2681-749). Including the specific cross reference to GPEA would ensure that regulated entities know that we are using GPEA's performance standard for allowing use of electronic signatures.
We propose to add a definition of “written or in writing.” The rule would define written or in writing as printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of 49 CFR 40.4. This definition would eliminate any distinction between paper and electronic methods of communication/documentation.
Section 40.4 May electronic documents and signatures be used?
We propose to add a new §40.4 that would prescribe the requirements pertaining to electronic documents and signatures throughout part 40.
Paragraph (a) would specify that §40.4 would apply to all documents required by part 40, except for the CCF, as an electronic CCF may only be used when approved by HHS and in compliance with §40.40(c)(5). As background, before an HHS-certified laboratory can use a Federal electronic CCF for regulated specimens, the test facility must submit a detailed plan and proposed standard operating procedures for the electronic CCF system for HHS review and approval through the National Laboratory Certification Program. At the current time, several HHS-certified laboratories have received approval to use a combination electronic/paper CCF, while four laboratories have received approval to use a fully electronic CCF. As noted earlier, and in a separate section of the SUPPORT Act, HHS was required to set a deadline for certified laboratories to request approval for use of fully electronic CCFs. That deadline is now August 31, 2026.
Paragraph (b) would permit, but not require, any person or entity to use electronic methods to comply with any provision in part 40 that requires a document to be signed, certified, generated, maintained, or transmitted between parties. It would apply to all forms of written documentation, including forms, records, notations, and other documents. The substance of the document would otherwise have to comply with part 40 requirements. This would establish parity between paper and electronic documents and signatures, greatly expanding interested parties' ability to use electronic methods to comply with the requirements of part 40.
Paragraph (c) would permit, but not require, any entity required to sign or certify a document to do so using electronic signatures as defined in §40.3. The rule specifies that a person may use any available technology so long as the signature otherwise complies with the requirements of part 40.
Paragraph (d) would establish the minimum requirements for electronic documents and signatures. Any electronic document or signature would be considered the legal equivalent of a paper document or signature if it is the functional equivalent with respect to integrity, accuracy, and accessibility. In other words, the electronic documents or signatures need to accurately and reliably reflect the information in the record. They must remain accessible in a form that could be accurately viewed or reproduced according to Agency rules. As with any documents, paper or electronic, documents that are not legible—for any reason—do not satisfy the Department's requirements.
Electronic documents are not to be considered the legal equivalent of traditional paper documents if they (1) are not capable of being retained, (2) are not used for the purpose for which they were created, or (3) cannot be accurately reproduced for reference by any entity entitled to access by law, for the period of time required by the Department's recordkeeping requirements.
Paragraph (d) would also require that any electronically signed documents must incorporate or otherwise include evidence that both parties to the document have consented to the use of electronic signatures, as required by the E-SIGN Act (15 U.S.C. 7001(c)).
Paragraph (e) would require that when using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records cannot be accessed by unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The proposed requirements are analogous to those established in the current §40.40(c)(5) when we approved use of the electronic CCF in part 40.
Section 40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?
Currently, paragraph (g) makes it clear that the release of information under this section must be in any written form, and the parenthetical clarifies that this can be paper-based (written, fax) or electronic (email). Under the proposed definition of “written or in writing,” there is no distinction between paper-based and electronic communications. Because “written or in writing” would mean either paper or electronic communications, we propose to remove parenthetical reference to “fax, email, letter” to eliminate redundancy and confusion. All parties can conduct their business using either paper or electronic means of documentation and communication.
Section 40.79 How is the collection process completed?
Currently, paragraph (a)(9) of this section requires the collector to “fax or otherwise transmit” Copy 2 of the CCF to the MRO and Copy 4 to the DER within 24 hours or during the next business day. We propose to amend this section by removing reference to the methods of transmitting receipts, so parties can choose their own medium of communication.
Section 40.97 What do laboratories report and how do they report it?
For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraphs (c)(1) and (2) of this section.
Section 40.111 When and how must a laboratory disclose statistical summaries and other information it maintains?
For the same reasons explained in the discussion of §40.79, we propose to amend paragraph (b) of this section to remove the references to the methods of transmitting the summary or report required by this section. Because the summary or report can be transmitted via hard copy or electronically, there is no need to specify how it must be transmitted. As such, we propose to amend the title of this section accordingly.
Section 40.127 What are the MRO's functions in reviewing negative test results?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (c)(2) of this section.
Section 40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative test results?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (b)(2) of this section.
Section 40.163 How does the MRO report drug test results?
For the same reasons explained in the discussion of §40.25, we propose to remove the reference to a “letter” in paragraph (c) of this section. In paragraph (e) of this section, we propose to replace the term “letter” with “written report” for consistency with paragraph (c).
Section 40.167 How are MRO reports of drug results transmitted to the employer?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (c)(1) of this section.
Section 40.185 Through what methods and to whom must a laboratory report split specimen results?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (b) of this section. In addition, because Copy 1 of the CCF can be transmitted in writing or electronically, there is no need to specify the methods through which it must be transmitted. As such, we propose to amend the title of this section accordingly.
Section 40.187 What does the MRO do with split specimen laboratory results?
For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraph (c)(2)(iv)(C) of this section.
Section 40.191 What is a refusal to take a DOT drug test, and what are the consequences?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (d) of this section as means of transmitting notification that an employee has refused to participate in part of the testing process from the collector or MRO to the DER.
Section 40.193 What happens when an employee does not provide a sufficient amount of urine for a drug test?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “send or fax” as the means for the collector to transmit copies of the CCF to the MRO and the DER in paragraph (b)(3) of this section.
Section 40.205 How are drug test problems corrected?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a collector, laboratory, MRO, employer, or other person to supply signed statements regarding correctable problems in a drug test in paragraphs (b)(1) and (2) of this section.
Section 40.225 What form is used for an alcohol test?
We propose to amend this section to permit, but not require, the use of an electronic version of the DOT ATF that is identical in form and content to the form provided in appendix I to part 40. The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT, and if an EBT provides a separate printout of confirmation test results pursuant to §40.253(g), the electronic ATF must include that separate printout. This section would also be amended to specify the same general confidentiality and security measures in §40.45 relating to electronic CCFs to ensure that confidential employee records cannot be accessed by unauthorized persons.
Section 40.255 What happens next after the alcohol confirmation test result?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (a)(5)(i) of this section as means of transmitting results of the alcohol confirmation test from the BAT to the DER. Similarly, there is no need to specify that Copy 1 of the ATF may be transmitted “in person, by telephone, or by electronic means.”
Section 40.261 What is a refusal to take an alcohol test, and what are the consequences?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (c) of this section as means of transmitting a refusal notification from a BAT, STT, or referral physician to the DER.
Section 40.271 How are alcohol testing problems corrected?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a STT, BAT, employer, or other service agent to supply a signed statement regarding correctable flaws in an alcohol test in paragraph (b)(2) of this section.
Section 40.365 What is the Department's policy concerning starting a PIE proceeding?
We propose to amend this section by adding a new paragraph (b)(15) that would identify the failure of a service agent to provide or maintain a secure/confidential electronic system as appropriate grounds for starting a PIE proceeding.
X. Regulatory Analyses and Notices
Executive Orders 12866, 13563, and 14094 (Regulatory Planning and Review)
The Secretary has examined the impact of the proposed part 40 amendments under Executive Order 12866 (“Regulatory Planning and Review”), as supplemented by Executive Order 13563 (“Improving Regulation and Regulatory Review”) and amended by Executive Order 14094 (“Modernizing Regulatory Review”), which directs Federal agencies to assess all costs and benefits of available regulatory alternatives and, when regulation is necessary, to select regulatory approaches that maximize net benefits (including potential economic, environmental, public health and safety, and other advantages; distributive impacts; and equity).
According to these Executive orders, a regulatory action is “significant” if it meets any one of a number of specified conditions, including having an annual effect on the economy of $200 million or more, as adjusted every three years by the Office of Information and Regulatory Affairs (OIRA); adversely affecting in a material way a sector of the economy, competition, or jobs; or if it raises novel legal or policy issues. The proposed amendments, which would allow the use of electronic documents and signatures, do not meet the Executive order's criteria for being a significant rule. Consequently, OMB has determined that the rulemaking action is not significant under the Executive order.
The proposed rule responds to the statutory mandate set forth in Section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271. The proposed rule would not impose new requirements on the industry; rather, it would simply permit—but not require—regulated entities to use electronic signatures, forms, and recordkeeping, and remove outdated and obsolete references in the regulatory text. The proposed rule would not impose new costs on the industry because regulated entities would be allowed to choose to continue to use paper-based documents as they had before. The benefits of the rule would stem from savings in paper and printing expense and other efficiency gains. Examples of documents affected by this rule include, but are not limited to, records of a prospective employee's drug and alcohol testing history that employers must obtain prior to permitting that employee to perform safety-sensitive duties, MRO records and reports, SAP records and reports, and ATFs. While there is no way to estimate how many entities or individuals would change their practices given the new options, or how many documents would be affected, several commenters to the ANPRM stated that they have been using electronic documents and signatures in their non-DOT drug and alcohol testing programs for many years. While neither the benefits nor the costs of this rule can be reliably estimated, we expect this proposed rule to provide flexibility to the industry. Under this proposed rule, regulated entities would have the flexibility to conduct business using either electronic or traditional paper-based methods. We also expect regulated entities to choose technologies that would maximize benefits in accordance with their individual needs and circumstances.
Regulatory Flexibility Act and Small Business Regulatory Enforcement Fairness Act (SBREFA)
The Regulatory Flexibility Act of 1980 (5 U.S.C. 601 et seq. ) requires Federal agencies to consider the effects of their regulatory actions on small businesses and other small entities and minimize any significant economic impact. The term “small entities” comprises small businesses and not-for-profit organizations that are independently owned and operated and are not dominant in their fields, and governmental jurisdictions with a population of less than 50,000. For this rulemaking, potentially affected small entities include drug testing companies (U.S. Small Business Administration (SBA) North American Industry Classification System (NAICS) Sector 54 (Professional, Scientific and Technical Services), Code 541380 (Testing Laboratories and Services)) as well as DOT-regulated entities (SBA NAICS Sectors 48-49 (Transportation and Warehousing)).
The Department does not expect that the proposed rule would have a significant economic impact on a substantial number of small entities. The proposed rule, if adopted, would increase flexibility for all small-entity transportation employers and their service agents by allowing them to use electronic documents, signatures, and recordkeeping to meet part 40 requirements. Use of electronic documents, electronic signatures, and electronic recordkeeping would be voluntary for affected small entities, which will provide added flexibility to these entities in meeting the part 40 requirements. For these reasons, and as explained in more detail in the preamble to this proposed rule, the Secretary certifies that the proposed rule would not have a significant economic impact on a substantial number of small entities within the meaning of the Regulatory Flexibility Act. Consequently, an initial regulatory flexibility analysis is not required for this proposed rule.
Unfunded Mandates
The Secretary has examined the impact of the final rule under the Unfunded Mandates Reform Act (UMRA) of 1995 (Pub. L. 104-4). This NPRM does not trigger the requirement for a written statement under sec. 202(a) of the UMRA because this rulemaking does not impose a mandate that results in an expenditure of $100 million (adjusted annually for inflation) or more by either State, local, and tribal governments in the aggregate or by the private sector in any one year. In fact, by providing an alternative to traditional paper-based records, the proposed rule would be expected to reduce costs to regulated parties, including State and local entities ( e.g., public transit authorities, and public works departments) whose employees are subject to testing and that choose to use electronic documents as opposed to paper-based documents.
Environmental Impact
The DOT has analyzed the environmental impacts of this action pursuant to the National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321 et seq. ) and has determined that it is categorically excluded pursuant to DOT Order 5610.1C, “Procedures for Considering Environmental Impacts” (44 FR 56420, October 1, 1979). Categorical exclusions are actions identified in an agency's NEPA implementing procedures that do not normally have a significant impact on the environment and therefore do not require either an environmental assessment (EA) or environmental impact statement (EIS). This proposed rule would amend the transportation industry drug testing program procedures regulation to permit the use of electronic documents, signatures, and recordkeeping. This action is covered by the categorical exclusion listed at 23 CFR 771.118(c)(4), “[p]lanning and administrative activities that do not involve or lead directly to construction, such as: . . . promulgation of rules, regulations, directives . . .” The Department does not anticipate any environmental impacts, and there are no extraordinary circumstances present in connection with this rulemaking.
Executive Order 13132: Federalism
The Secretary has analyzed the final rule in accordance with Executive Order 13132: Federalism. Executive Order 13132 requires Federal agencies to carefully examine actions to determine if they contain policies that have federalism implications or that preempt State law. As defined in the order, “policies that have federalism implications” refer to regulations, legislative comments or proposed legislation, and other policy statements or actions that have substantial direct effects on the States, on the relationship between the National Government and the States, or on the distribution of power and responsibilities among the various levels of government.
Most of the regulated parties under the Department's drug testing program are private entities. Some regulated entities are public entities ( e.g., transit authorities and public works departments); however, as noted above, this proposal would reduce costs of the Department's drug testing program and provide additional flexibility for regulated parties. Accordingly, the Secretary has determined that the proposed rule, which would allow but not require use of electronic signatures and recordkeeping, does not contain policies that have federalism implications.
Executive Order 13175: Consultation and Coordination With Indian Tribal Governments
Executive Order 13175 (65 FR 67249, November 6, 2000) requires Federal agencies to develop an accountable process to ensure “meaningful and timely input by tribal officials in the development of regulatory policies that have tribal implications.” “Policies that have tribal implications” as defined in the Executive order, include regulations that have “substantial direct effects on one or more Indian tribes, on the relationship between the Federal government and the Indian tribes, or on the distribution of power and responsibilities between the Federal government and Indian tribes.” This proposed rule does not have tribal implications. The proposed rule will also not have substantial direct effects on tribal governments, on the relationship between the Federal Government and Indian tribes, or on the distribution of power and responsibilities between the Federal Government and Indian tribes, as specified in Executive Order 13175.
Paperwork Reduction Act
The Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520) (PRA) requires that DOT consider the impact of paperwork and other information collection burdens imposed on the public. This proposed rule would call for no new collection of information under the PRA. Instead, there would likely be a significant reduction in the burden hours required for information collection 2105-0529, Procedures for Transportation Drug and Alcohol Testing Program, due to the ability to use electronic signatures and forms, and largely due to the ability to use an electronic ATF for DOT-regulated alcohol testing under part 40. We request comments on this issue. Notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information subject to the PRA that does not display a currently valid OMB control number.
Privacy Act
Anyone is able to search the electronic form of all comments received in any of our dockets by the name of the individual submitting the comment (or signing the comment, if submitted on behalf of an association, business, labor union, etc.) For information on DOT's compliance with the Privacy Act, please visit https://www.transportation.gov/privacy.
5 U.S.C. 553(b)(4)
As required by 5 U.S.C. 553(b)(4), a summary of this proposed rule can be found at the entry for RIN 2105-AF01 in the Department's Portion of the Unified Agenda of Regulatory and Deregulatory Affairs, available at https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202404&RIN=2105-AF01 .
Pay-As-You-Go Act of 2023
In accordance with Compliance with Pay-As-You-Go Act of 2023 (Fiscal Responsibility Act of 2023, Pub. L. 118-5, div. B, title III) and OMB Memorandum (M-23-21) dated September 1, 2023, the Department has determined that this proposed rule is not subject to the Pay-As-You-Go Act of 2023 because it will not increase direct spending beyond specified thresholds.
List of Subjects
49 CFR Part 40
Administrative practice and procedures, Alcohol abuse, Alcohol testing, Drug abuse, Drug testing, Laboratories, Reporting and recordkeeping requirements, Safety, Transportation.
49 CFR Part 199
Alcohol testing, Drug testing, Pipeline safety, Reporting and recordkeeping requirements, Safety, Transportation.
For the reasons stated in the preamble, the Department proposes to amend 49 CFR parts 40 and 199 as follows:
PART 40—PROCEDURES FOR TRANSPORTATION WORKPLACE DRUG AND ALCOHOL TESTING PROGRAMS
1. The authority for part 40 continues to read as follows:
Authority:
49 U.S.C. 102, 301, 322, 5331, 20140, 31306, and 54101 et seq.
2. In §40.3, add the definitions of “Electronic signature” and “Written or in writing” in alphabetical order to read as follows:
§40.3 What do the terms used in this part mean?
* * * * *
Electronic signature. A method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 112 Stat. 2681-749, 44 U.S.C. 3504 note).
* * * * *
Written or in writing. Printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of §40.4.
3. Add §40.4 to read as follows:
§40.4 May electronic documents and signatures be used?
(a) Applicability. This section applies to all documents required by this part, except for the CCF. An electronic CCF may be used only if it has been approved for use by the Department of Health and Human Services and is used in compliance with §40.40(c)(5).
(b) Electronic records or documents. Any person or entity required to generate, maintain, or exchange and/or transmit documents to satisfy requirements in this part may use electronic methods to satisfy those requirements.
(c) Electronic signatures. (1) Any person or entity required to sign or certify a document to satisfy the requirements of this part may use an electronic signature, as defined in §40.3.
(2) Any available technology may be used that satisfies the requirements of an electronic signature as defined in §40.3.
(d) Electronic document requirements. Any person or entity may use documents signed, certified, generated, maintained, or exchanged using electronic methods, as long as the documents accurately reflect the information otherwise required to be contained in them.
(1) Records, documents, or signatures generated, maintained, or exchanged using electronic methods satisfy the requirements of this section if they are capable of being retained, are used for the purpose for which they were created, and can be accurately reproduced within required timeframes for reference by any party entitled to access.
(2) Records or documents generated electronically satisfy the requirements of this section if they include proof of consent to use electronically generated records or documents, as required by 15 U.S.C. 7001(c).
(e) Confidentiality and security. When using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form to include protecting against destruction, deterioration, and data corruption.
4. In §40.25, revise paragraph (g) to read as follows:
§40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?
* * * * *
(g) The release of information under this section must be in any written form that ensures confidentiality. As the previous employer, you must maintain a written record of the information released, including the date, the party to whom it was released, and a summary of the information provided.
* * * * *
5. In §40.79, revise paragraph (a)(9) to read as follows:
§40.79 How is the collection process completed?
(a) * * *
(9) Send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or during the next business day. Keep Copy 3 for at least 30 days, unless otherwise specified by applicable DOT agency regulations.
* * * * *
6. In §40.97, revise paragraphs (c) introductory text, (c)(1) introductory text, and (c)(2) to read as follows:
§40. 97 What do laboratories report and how do they report it?
* * * * *
(c) As a laboratory, you must report laboratory results directly, and only, to the MRO at his or her place of business. You must not report results to or through the DER or a service agent ( e.g., C/TPA).
(1) Negative results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF which has been signed by the certifying scientist, or you may provide the laboratory results report electronically.
* * * * *
(2) Non-negative and rejected for testing results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF that has been signed by the certifying scientist. In addition, you may provide the laboratory results report following the format and procedures set forth in paragraphs (c)(1)(i) and (ii) of this section.
* * * * *
7. In §40.111, revise the section heading and paragraph (b) to read as follows:
§40.111 When must a laboratory disclose statistical summaries and other information it maintains?
* * * * *
(b) When the employer requests a summary in response to an inspection, audit, or review by a DOT agency, you must provide it unless the employer had fewer than five aggregate test results. In that case, you must send the employer a report indicating that not enough testing was conducted to warrant a summary.
* * * * *
8. In §40.127, revise paragraph (c)(2) to read as follows:
§40.127 What are the MRO's functions in reviewing negative test results?
* * * * *
(c) * * *
(2) A legible copy of Copy 1 of the CCF or the electronic laboratory results report that conveys the negative laboratory test result.
* * * * *
9. In §40.129, revise paragraphs (b) introductory text and (b)(2) to read as follows:
§40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative drug test results?
* * * * *
(b) Before you report a verified negative, positive, test cancelled, refusal to test because of adulteration or substitution, you must have in your possession the following documents:
* * * * *
(2) A legible copy of Copy 1 of the CCF, containing the certifying scientist's signature.
* * * * *
10. In §40.163, revise paragraphs (c) introductory text and (e) to read as follows:
§40.163 How does the MRO report drug test results?
* * * * *
(c) If you do not report test results using Copy 2 of the CCF for the purposes of this section, you must provide a written report for each test result. This report must, as a minimum, include the following information:
* * * * *
(e) You must retain a signed or stamped and dated copy of Copy 2 of the CCF in your records. If you do not use Copy 2 for reporting results, you must maintain a copy of the signed or stamped and dated written report in addition to the signed or stamped and dated Copy 2. If you use the electronic data file to report negatives, you must maintain a retrievable copy of that report in a format suitable for inspection and auditing by a DOT representative.
* * * * *
11. In §40.167, revise paragraph (c)(1) to read as follows:
§40.167 How are MRO reports of drug test results transmitted to the employer?
* * * * *
(c) * * *
(1) You must transmit a legible image or copy of either the signed or stamped and dated Copy 2 or the written report (see §40.163(b) and (c)).
* * * * *
12. In §40.185, revise the section heading and paragraph (b) to read as follows:
§40.185 What and to whom must a laboratory report split specimen results?
* * * * *
(b) You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF, which has been signed by the certifying scientist.
* * * * *
13. In §40.187, revise paragraph (c)(2)(iv)(C) to read as follows:
§40.187 What does the MRO do with split specimen laboratory results?
* * * * *
(c) * * *
(2) * * *
(iv) * * *
(C) As the laboratory that tests the primary specimen to reconfirm the presence of the adulterant found in the split specimen and/or to determine that the primary specimen meets appropriate substitution criteria, report your result to the MRO using a copy of Copy 1 of the CCF.
* * * * *
14. In §40.191, revise paragraph (d) introductory text to read as follows:
§40.191 What is a refusal to take a DOT drug test, and what are the consequences?
* * * * *
(d) As a collector or an MRO, when an employee refuses to participate in the part of the testing process in which you are involved, you must terminate the portion of the testing process in which you are involved, document the refusal on the CCF (including, in the case of the collector, printing the employee's name on Copy 2 of the CCF), immediately notify the DER by any means that ensures that the refusal notification is immediately received. As a referral physician ( e.g., physician evaluating a “shy bladder” condition or a claim of a legitimate medical explanation in a validity testing situation), you must notify the MRO, who in turn will notify the DER.
* * * * *
15. In §40.193, revise paragraph (b)(3) to read as follows:
§40.193 What happens when an employee does not provide a sufficient amount of specimen for a drug test?
* * * * *
(b) * * *
(3) As the collector, you must send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or the next business day.
* * * * *
16. In §40.205, revise paragraphs (b)(1) and (2) to read as follows:
§40.205 How are drug test problems corrected?
* * * * *
(b) * * *
(1) If the problem resulted from the omission of required information, you must, as the person responsible for providing that information, supply in writing the missing information and a statement that it is true and accurate. For example, suppose you are a collector, and you forgot to make a notation on the “Remarks” line of the CCF that the employee did not sign the certification. You would, when the problem is called to your attention, supply a signed statement that the employee failed or refused to sign the certification and that your statement is true and accurate. You must supply this information on the same business day on which you are notified of the problem.
(2) If the problem is the use of a non-Federal form or an expired Federal form, you must provide a signed statement ( i.e., a memorandum for the record). It must state that the incorrect form contains all the information needed for a valid DOT drug test, and that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control. The statement must also list the steps you have taken to prevent future use of non-Federal forms or expired Federal forms for DOT tests. For this flaw to be corrected, the test of the specimen must have occurred at an HHS-certified laboratory where it was tested consistent with the requirements of this part. You must supply this information on the same business day on which you are notified of the problem.
* * * * *
17. In §40.225, revise paragraph (a) and add paragraphs (d) and (e) to read as follows:
§40.225 What form is used for an alcohol test?
(a) The DOT Alcohol Testing Form (ATF) must be used for every DOT alcohol test. The ATF must be a three-part carbonless manifold form or an electronic ATF that meets the requirements of paragraph (d) of this section. The ATF is found in appendix G to this part. You may view this form on the ODAPC website ( https://www.transportation.gov/odapc ).
* * * * *
(d) As an employer, you may use an electronic ATF that meets the following requirements:
(1) The electronic ATF must be identical in form and content to the ATF found in appendix G to this part.
(2) The electronic ATF must meet the requirements of §40.4(d).
(3) The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT.
(4) If an EBT provides a separate printout of confirmation test results (see §40.253(g)), the electronic ATF must include that separate printout.
(e) As an employer, BAT, or STT using an electronic ATF, you must establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form.
18. In §40.255, revise paragraph (a)(5)(i) to read as follows:
§40.255 What happens next after the alcohol confirmation test result?
(a) * * *
(5) * * *
(i) You may transmit the results using Copy 1 of the ATF, in person, by telephone, or by electronic means. In any case, you must immediately notify the DER of any result of 0.02 or greater by any means that ensures the result is immediately received by the DER. You must not transmit these results through C/TPAs or other service agents.
* * * * *
19. In §40.261, revise paragraph (c)(1) to read as follows:
§40.261 What is a refusal to take an alcohol test, and what are the consequences?
* * * * *
(c)(1) As a BAT or an STT, or as the physician evaluating a “shy lung” situation, when an employee refuses to test as provided in paragraph (a) of this section, you must terminate the portion of the testing process in which you are involved, document the refusal on the ATF (or in a separate document which you cause to be attached to the form), immediately notify the DER by any means that ensures the refusal notification is immediately received. You must make this notification directly to the DER (not using a C/TPA as an intermediary).
* * * * *
20. In §40.271, revise paragraph (b)(2) to read as follows:
§40.271 How are alcohol testing problems corrected?
* * * * *
(b) * * *
(2) If the problem is the use of a non-DOT form, you must, as the person responsible for the use of the incorrect form, certify in writing that the incorrect form contains all the information needed for a valid DOT alcohol test. You must also provide a signed statement that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control, and the steps you have taken to prevent future use of non-DOT forms for DOT tests. You must supply this information on the same business day on which you are notified of the problem.
* * * * *
21. In §40.365, revise paragraphs (b)(13) and (14) and add paragraph (b)(15) to read as follows:
§40.365 What is the Department's policy concerning starting a PIE proceeding?
* * * * *
(b) * * *
(13) For any service agent, directing or recommending that an employer fail or refuse to implement any provision of this part;
(14) With respect to noncompliance with a DOT agency regulation, conduct that affects important provisions of Department-wide concern ( e.g., failure to properly conduct the selection process for random testing); or
(15) For a service agent, failing to provide or maintain a secure/confidential electronic system. PART 199—DRUG AND ALCOHOL TESTING
22. The authority citation for part 199 continues to read as follows:
Authority:
49 U.S.C. 5103, 60102, 60104, 60108, 60117, and 60118; 49 CFR 1.53.
23. In §199.3:
a. Designate the introductory text as paragraph (b); and
b. Add paragraph (a).
The addition reads as follows:
§199.3 Definitions.
(a) Terms used in this part have the same meaning as in 49 CFR 40.3.
* * * * *
24. Add §199.4 to read as follows:
§199.4 Electronic documents, records, and signatures.
Electronic documents, records, and signatures may be used to comply with this part provided they meet the requirements specified in 49 CFR part 40.
25. In §199.117, revise paragraph (a) introductory text to read as follows:
§199.117 Recordkeeping.
(a) Each operator shall keep the records in paragraphs (a)(1) through (5) of this section for the periods specified by this section or for the periods specified by 49 CFR part 40, whichever is greater; and will permit access to the records as provided by §190.203.
* * * * *
26. In §199.119, revise paragraph (a) to read as follows:
§199.119 Reporting of anti-drug testing results.
(a) Each large operator (having more than 50 covered employees) must submit an annual Management Information System (MIS) report to PHMSA of its anti-drug testing using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.
* * * * *
27. In §199.227, revise paragraph (b) introductory text to read as follows:
§199.227 Retention of records.
* * * * *
(b) Period of retention. Each operator shall maintain the records in accordance with the following schedule or for the periods specified by 49 CFR part 40, whichever is greater:
* * * * *
28. In §199.229, revise paragraph (a) to read as follows:
§199.229 Reporting of alcohol testing results.
(a) Each large operator (having more than 50 covered employees) must submit an annual MIS report to PHMSA of its alcohol testing results using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.
* * * * *
Signed on: Thursday, October 3, 2024.
Pete Buttigieg,
Secretary of Transportation.
[FR Doc. 2024-23427 Filed 10-11-24; 8:45 am]
BILLING CODE 4910-9X-P
NewsFleet SafetyPipeline and Hazardous Materials Safety Administration (PHMSA), DOTDrug testing - Motor CarrierDrug and Alcohol Testing - DOTOffice of the Secretary of TransportationHazmat SafetyRulemakingFocus AreaProposed RuleEnglishTransportationUSA
89 FR 82957 Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records
2024-10-15T05:00:00Z
DEPARTMENT OF TRANSPORTATION
Office of the Secretary
49 CFR Part 40
Pipeline and Hazardous Materials Safety Administration
49 CFR Part 199
[Docket DOT-OST-2022-0027]
RIN 2105-AF01
Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records
AGENCY: Office of the Secretary, Department of Transportation (DOT).
ACTION: Notice of proposed rulemaking (NPRM).
SUMMARY: The Department of Transportation (DOT or Department) proposes to amend its regulations for conducting workplace drug and alcohol testing for the federally regulated transportation industry to allow, but not require, electronic signatures on documents required to be created and utilized under the regulations, the use of electronic versions of forms, and the electronic storage of forms and data. The regulatory changes would apply to DOT-regulated employers and their contractors (“service agents”) who administer their DOT-regulated drug and alcohol testing programs. Currently, employers and their service agents must use, sign and store paper documents exclusively, unless the employer is utilizing a laboratory's electronic Federal Drug Testing Custody and Control Form (electronic CCF) system that has been approved by the Department of Health and Human Services (HHS). DOT is required by statute to amend its regulations to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms. This rulemaking also responds to an April 2, 2020, petition for rulemaking from DISA Global Solutions, Inc. (DISA), requesting that DOT regulations be amended to allow the use of an electronic version of the alcohol testing form (ATF) for DOT-authorized alcohol testing. The proposed regulatory amendments are expected to provide additional flexibility and reduced costs for the industry while maintaining the integrity and confidentiality requirements of the drug and alcohol testing regulations. In addition, DOT proposes to amend the Pipeline and Hazardous Materials Safety Administration (PHMSA) regulation for conformity and to make other miscellaneous technical changes and corrections.
DATES: Comments on this NPRM must be received on or before December 16, 2024.
ADDRESSES: You may submit comments identified by Docket Number DOT-OST-2022-0027 using any of the following methods:
• Federal eRulemaking Portal: Go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document. Follow the online instructions for submitting comments.
• Mail: Docket Management Facility, U.S. Department of Transportation, 1200 New Jersey Avenue SE, West Building, Ground Floor, Room W12-140, Washington, DC 20590-0001.
• Hand Delivery or Courier: West Building, Ground Floor, Room W12-140, 1200 New Jersey Avenue SE, Washington, DC, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting Dockets Operations.
• Fax: 202-493-2251.
To avoid duplication, please use only one of these methods. See the “Public Participation and Request for Comments” portion of the SUPPLEMENTARY INFORMATION section for instructions on submitting comments, including collection of information comments for the Office of Information and Regulatory Affairs, Office of Management and Budget (OMB).
FOR FURTHER INFORMATION CONTACT:
Mike Huntley, Office of Drug and Alcohol Policy and Compliance, 1200 New Jersey Avenue SE, Washington, DC 20590; telephone number 202-366-3784; ODAPCwebmail@dot.gov. If you have questions on viewing or submitting material to the docket, contact Docket Services, telephone (202) 366-9826.
SUPPLEMENTARY INFORMATION:
This NPRM is organized as follows:
I. Executive Summary
II. Public Participation and Request for Comments
A. Submitting Comments
B. Viewing Comments and Documents
C. Privacy Act
III. Legal Basis for the Rulemaking
IV. Background
V. Advance Notice of Proposed Rulemaking (ANPRM) Overview
VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures
VII. Amending Part 40 To Permit Electronic Documents and Signatures
VIII. Electronic ATF
IX. Section-by-Section Analysis
X. Regulatory Analyses and Notices
I. Executive Summary
Purpose and Summary of the Major Provisions
This proposed rule would establish parity between paper and electronic documents and signatures and expand businesses' and individuals' ability to use electronic methods to comply with the Department's drug and alcohol testing regulation, 49 CFR part 40, “Procedures for Transportation Workplace Drug and Alcohol Testing Programs” (part 40). Businesses and individuals subject to part 40 would continue to have the choice to use paper documents and traditional “wet” signatures. This proposed rule would also modify references to recordkeeping and reporting methods throughout part 40 to make them technologically neutral.
This proposed rulemaking responds to a statutory mandate set forth in section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271 (see 49 U.S.C. 322 note). The proposed rulemaking would take action consistent with the Government Paperwork Elimination Act (GPEA) (division C, title XVII, secs. 1701-1710, Pub. L. 105-277) and the Electronic Signatures in Global and National Commerce Act (E-SIGN) (Pub. L. 106-229) with regard to DOT's part 40 regulations.
II. Public Participation and Request for Comments
A. Submitting Comments
If you submit a comment, please include the docket number for this NPRM (Docket No. DOT-OST-2022-0027), indicate the specific section of this document to which each comment applies, and provide a reason for each suggestion or recommendation. You may submit your comments and material online or by fax, mail, or hand delivery, but please use only one of these means. The Office of the Secretary (OST) recommends that you include your name and a mailing address, an email address, or a phone number in a cover letter or an email so that OST can contact you if there are questions regarding your submission.
To submit your comment online, go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document, click on this NPRM, click “Comment,” and type your comment into the text box on the following screen.
If you submit your comments by mail or hand delivery, submit them in an unbound format, no larger than 8 1/2 by 11 inches, suitable for copying and electronic filing. If you submit comments by mail and would like to know that they reached the facility, please enclose a stamped, self-addressed postcard or envelope.
OST will consider all comments and material received during the comment period in determining how to proceed with any final rule.
B. Viewing Comments and Documents
To view comments, as well as any documents mentioned in this preamble as available in the docket, go to https://www.regulations.gov. Insert the docket number, DOT-OST-2022-0027, in the keyword box, and click “Search.” Next, click the “Open Docket Folder” button and choose the document to review. If you do not have access to the internet, you may view the docket online by visiting the Docket Management Facility in Room W12-140 on the ground floor of the DOT West Building, 1200 New Jersey Avenue SE, Washington, DC 20590-0001, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting the Docket Management Facility.
C. Privacy Act
In accordance with 5 U.S.C. 553(c), DOT solicits comments from the public to better inform its rulemaking process. DOT posts these comments, without edit, including any personal information the commenter provides, to www.regulations.gov, as described in the system of records notice (DOT/ALL-14 FDMS), which can be reviewed at https://www.transportation.gov/individuals/privacy/privacy-act-system-records-notices under the heading of “Department-Wide System of Records Notices”.
III. Legal Basis for the Rulemaking
This rulemaking is promulgated under the authority enacted in the Omnibus Transportation Employee Testing Act of 1991 (OTETA) (Pub. L. 102-143, tit. V, 105 Stat. 952) and codified at 49 U.S.C. 45102 (aviation), 49 U.S.C. 20140 (rail), 49 U.S.C. 31306 (motor carrier), and 49 U.S.C. 5331 (public transportation), as well as the Department's authority in 49 U.S.C. 322 and the PHMSA authorities specified in the proposed regulatory text for this action.
According to Public Law 115-271, the Secretary of Transportation is required to “issue a final rule revising part 40 of title 49, Code of Federal Regulations, to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms.” (49 U.S.C. 322 note) The statute set the deadline for this action as not later than 18 months after HHS establishes a deadline for a certified laboratory to request approval for fully electronic CCFs ( Id. ) On April 7, 2022, HHS set that deadline as August 31, 2023 (87 FR 20528). HHS has extended the deadline to August 31, 2026, to enable sufficient time for all HHS-certified laboratories to identify and contract with an electronic CCF supplier or to develop an electronic CCF. The deadline for DOT's regulatory amendments would therefore be February 29, 2028.
There are two additional Federal statutes relevant to the implementation of electronic document and signature requirements.
The Government Paperwork Elimination Act (GPEA), codified at 44 U.S.C. 3504 note, 1 was enacted to improve customer service and governmental efficiency through the use of information technology. The GPEA defines an electronic signature as a method of signing an electronic communication that: (a) identifies and authenticates a particular person as the source of the electronic communication; and (b) indicates such person's approval of the information contained in the electronic communication. Id. It also requires OMB to ensure Federal agencies provide for: (a) the option of maintaining, submitting; or disclosing information electronically, when practicable; and (b) the use and acceptance of electronic signatures when practicable. The GPEA states that electronic records submitted pursuant to procedures developed under title XVII for the submission of records to Federal agencies and electronic signatures used in accordance with those procedures shall not be denied legal effect, validity, or enforceability merely because they are in electronic form. Id.
1 Division C, title XVII (sec. 1701-1710) of Public Law 105-277, 112 Stat. 2681-749, enacted on October 21, 1998.
The Electronic Signatures in Global and National Commerce Act (E-SIGN), codified at 15 U.S.C. 7001-7031, 2 was designed to promote the use of electronic contract formation, signatures, and recordkeeping in private commerce by establishing legal equivalence between traditional paper-based methods and electronic methods. The E-SIGN Act allows the use of electronic records to satisfy any statute, regulation, or rule of law requiring that such information be provided in writing if the consumer has affirmatively consented to such use and has not withdrawn consent. Specifically, the statute establishes the legal equivalence of the following types of documents with respect to any transaction in or affecting interstate or foreign commerce, whether in traditional paper or electronic form: (a) contracts, (b) signatures, and (c) other records (15 U.S.C. 7001(a)(1)).
2 Public Law 106-229, 114 Stat. 464, enacted on June 30, 2000.
IV. Background
The Department's drug and alcohol testing regulations were promulgated at a time when the ability to sign and retain official records electronically—now commonplace in many business segments—was not available. Over the course of several years, we have adopted measures that have reduced the paper documentation associated with the drug and alcohol testing program without compromising the integrity and confidentiality requirements of the program. In 2003, we standardized the form for employers to report their Management Information System (MIS) aggregate drug and alcohol testing data, as well as the specific data collected. 3 When creating a ONE-DOT MIS Form, we then authorized employers to submit a single standardized form via a web portal. In 2015, we issued a final rule to allow employers, collectors, laboratories, and medical review officers (MROs) to use the electronic version of the Federal Drug Testing CCF in the DOT-regulated drug testing program. 4 That final rule also incorporated into the regulations the requirement to establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons when using the electronic CCF. We also included language protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form when using the electronic CCF.
3 68 FR 43946 (July 25, 2003).
4 80 FR 19551 (Apr. 13, 2015).
Consistent with the statutory mandate in 49 U.S.C. 322 note, we propose amendments to part 40 to permit the use of electronic signatures, forms, and records storage for drug and alcohol testing records throughout the regulation, including the use of an electronic ATF for DOT-authorized alcohol testing. We emphasize that electronic signatures, forms, and records would not be required; we would continue to allow paper, or hard-copy use with traditional “wet signatures.”
These proposed amendments would establish parity between paper and electronic collection and submission of information required under our regulations (and remain compatible with applicable OMB guidance on implementing electronic signatures 5 ) by allowing further use of electronic means and methods to comply with part 40 requirements. Many employers and their service agents have already instituted the use of electronic signatures, forms, and records storage for the non-DOT regulated testing that they conduct. DOT supports this transition to a paperless system and is committed to ensuring that the movement to a partially or fully electronic part 40 is done to maximize program efficiencies and reduce costs, while maintaining the integrity and confidentiality requirements of the program.
5https://www.whitehouse.gov/wp-content/uploads/2017/11/2000-M-00-15-OMB-Guidance-on-Implementing-the-Electronic-Signatures-in-Global-and-National-Commerce-Act.pdf.
Electronic documents would have a high degree of forensic defensibility as long as any changes made to the document are in the document's electronic footprint, which shows when the document or signature, as applicable, was created; when, and if, changes were made; who made the changes; and when, as applicable, a document was transmitted to and received by the receiving entity. The use of electronic forms and signatures in part 40 would help DOT-regulated employers and their service agents improve their workflow efficiency through faster turnaround times for required documents. Cost savings would result through reduced printing and delivery/shipping costs, and expedited transmission of information allowing for more timely decisions. We believe this proposed rule, if adopted, would also mitigate the longstanding problems ( e.g., delays in processing times of test results, cancelling of test results, etc.) associated with illegible and lost copies of paper documents.
V. Advance Notice of Proposed Rulemaking (ANPRM) Overview
On August 5, 2022, we published an ANPRM requesting public comment on how part 40 could be amended, as required by the statute, to allow electronic signatures, forms, and recordkeeping (87 FR 47951). We requested information from DOT-regulated employers and their service agents regarding if and how they are already handling electronic signatures, records transmission, and records storage in their non-DOT testing programs. In addition, we requested comments and information on appropriate performance standards, and on whether particular methods or performance standards have been successful or unsuccessful. We also asked a number of general questions on the potential advantages, risks, ramifications, and required safeguards associated with the use of electronic signatures, forms, and records in the DOT drug and alcohol testing program. We asked questions about specific sections of part 40 that we anticipated would be affected by prospective changes to implement electronic signatures, forms, and records. Finally, we asked a number of questions regarding the use of an electronic ATF for DOT-regulated alcohol tests.
We received 72 comments in response to the ANPRM, including comments from individuals, testing laboratories, MROs, and MRO organizations, substance abuse professionals (SAP) and SAP organizations, and various associations representing DOT-regulated transportation workers subject to mandatory drug and alcohol testing under part 40.
A few individuals expressed opposition to the adoption of electronic signatures, forms, and recordkeeping, citing concerns about the need for the rulemaking, risk to personal information from hackers or mismanaged electronic processes and procedures, and misuse of electronic forms and signatures. To meet our statutory mandate and in consideration of concerns about safeguarding personal information and appropriate use of the information in developing the NPRM, DOT proposes to require security measures for electronic forms and signatures used under part 40 that are the same as those currently in place for the electronic CCF specified in 49 CFR 40.40(c)(5).
Most commenters were supportive of changes to amend part 40 that would permit, but not require, the use of electronic signatures, forms, and recordkeeping. Commenters supporting revisions to part 40 noted that electronic signatures, forms, and recordkeeping are used in virtually every industry today—including but not limited to the banking, insurance, medical, and legal industries. Commenters supported the use of performance standards instead of technology-specific standards to ensure that, once established, standards do not become obsolete given the rapidly evolving nature of information technology standards and practices. Commenters stated that allowing electronic signatures, forms, and recordkeeping would make the drug testing process much more efficient and would result in cost savings. Commenters also stated that it would be safer to store records electronically since records could be backed-up, secured, and protected from tampering and unauthorized access and use.
VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures
In developing this NPRM, we looked to a rule promulgated by DOT's FMCSA that permits the use of electronic methods to generate, certify, sign, maintain, or exchange records so long as the documents accurately reflect the required information and can be used for their intended purpose. (83 FR 16210, Apr. 16, 2018) The rule applies to documents that FMCSA requires entities or individuals to retain. FMCSA permits, but does not require, anyone to satisfy FMCSA requirements by using electronic methods to generate, maintain, or exchange documents. The substance of the document must otherwise comply with applicable Federal laws and FMCSA rules. FMCSA also permits, but does not require, anyone required to sign or certify a document to do so using electronic signatures, defined, as in the GPEA, as a method of signing an electronic communication that: (1) identifies and authenticates a particular person as the source of the electronic communication; and (2) indicates such person's approval of the information contained in the electronic communication. FMCSA allows for the use any available technology for electronic signatures, so long as the signature otherwise complies with FMCSA's requirements.
FMCSA adopted broad performance standards for electronic documents and signatures—as specified in GPEA and E-SIGN—rather than detailed, technology specific standards that would likely become obsolete with inevitable changes in information technology standards and practices. FMCSA's April 2018 rule has been in effect for more than five years, and the definitions and requirements established in that rule have stood the test of time despite the many changes that have occurred with respect to electronic documents and signatures. We are unaware of any FMCSA-regulated entities that have reported issues to FMCSA regarding the use of electronic documents or signatures to meet the requirements of the FMCSRs since the rule became effective in 2018.
VII. Amending Part 40 To Permit Electronic Documents and Signatures
In this NPRM, we propose to permit but not require electronic documents, signatures, and recordkeeping in part 40. Additionally, we propose a performance standard approach as opposed to establishing technology-specific standards. Where it is possible to do so, establishing the same or substantively similar regulatory requirements for common issues across DOT modal agencies—such as the use of electronic documents and signatures—helps the Department maintain a consistent regulatory approach for those common issues.
There are currently more than 60 references to the term “written” in part 40, and more than 20 additional references to the term “in writing.” We propose to add a definition of “written or in writing” in part 40, to eliminate any distinction between paper and electronic documentation and establish technological neutrality throughout the entirety of part 40.
FMCSA's rule does not apply to documents that individuals or entities are required to file directly with FMCSA. In its April 2018 final rule, FMCSA explained that while industry could use electronic signatures and submit information directly to the FMCSA in certain situations, 6 adapting all FMCSA systems to allow for use of electronic signatures and submissions would significantly delay the implementation of the rule for use by third parties as it would require FMCSA to develop and implement technology systems to allow for direct submission to FMCSA from regulated parties. FMCSA noted that development of such systems could take several years, and therefore saw no reason to make private parties' use of electronic signatures and records retention contingent upon FMCSA's ability to receive submissions electronically because doing so would delay potential benefits to be gained by third parties.
6 As an example, Certified Medical Examiners may use electronic signatures, if they choose to do so, to sign medical forms, certificates, and a new driver medication report. If FMCSA requests these forms, they are uploaded in portable document format (PDF) to the Medical Examiner's account associated with the National Registry of Certified Medical Examiners for FMCSA to access.
In contrast to FMCSA's regulations, part 40 does not require entities or individuals to submit documents directly to the Department except for MIS aggregate drug and alcohol testing data that employers subject to DOT or U.S. Coast Guard (USCG) drug and alcohol testing regulations must submit annually. Each of the various documents required and used as part of the DOT drug and alcohol testing program under part 40 ( e.g., employee drug and alcohol testing records, MRO reports and records, SAP reports and records) are documents that are created by, exchanged between, and maintained by a person or entity involved in the testing process—but are not required to be submitted directly to DOT.
As noted earlier, and specifically with respect to the required MIS data, we standardized the form for employers to report their aggregate drug and alcohol testing data, as well as the specific data collected, more than 20 years ago. At that time, we authorized employers to submit the ONE-DOT MIS form via a web portal. Today, the Federal Aviation Administration, FMCSA, Federal Railroad Administration, and Federal Transit Administration permit employers to submit that same drug and alcohol testing data via the internet, and PHMSA requires that the data be submitted electronically. If employers submit the data electronically via the internet, they are not required to submit a hard copy. DOT recommends that employers have a copy of their data available (either hard copy or in electronic format) in the event an auditor or inspector requests a copy.
From the above, and because the only documents that part 40 requires to be submitted directly to the Department are already permitted to be, and in some cases required to be, submitted electronically, there is no need for us to limit the applicability of our proposal as FMCSA did in its 2018 final rule.
Several commenters noted that they already use electronic signatures and documents for their non-DOT drug and alcohol testing program, and in some cases, have done so for many years. In doing so, these commenters have had to establish appropriate confidentiality and security measures to ensure that confidential employee records cannot be accessed by unauthorized persons, including protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The same general requirements were added to the current §40.40(c)(5) when we approved the use of the electronic CCF for use in DOT drug testing in 2015, 7 and we propose the same requirements in this NPRM for the use of electronic signatures, documents, and recordkeeping throughout the entirety of part 40.
7 The 2015 revisions amended then §40.45(c)(5), which was redesignated as §40.40(c)(5) in the May 2023 final rule to include oral fluid testing in the DOT drug testing program (88 FR 27596, May 2, 2023).
Ensuring that confidential employee records are not available to unauthorized persons is an important element of part 40's protections for employees that are subject to DOT's drug and alcohol testing rules. We believe that the failure of a service agent to provide or maintain a secure/confidential electronic system should constitute the basis for the Department to start a public interest exclusion (PIE) proceeding, and propose to add this to the list of examples provided in §40.365(b).
Throughout part 40, information and documents are required to be transmitted and/or communicated between service agents ( e.g., collectors, screening test technicians (STTs) and breath alcohol technicians (BATs), laboratories, MROs, SAPs, and consortium/third party administrators (C/TPAs)), employers, and employees). Although part 40 does not currently require the party receiving these communications and/or documents to affirmatively confirm receipt of such from the sender, in some instances, regardless of whether the document is electronic or a hard copy, we believe that it may be important for the receiving party to verify that those required communications and/or documents were received.
For example, under §40.25, an employer intending to use an employee to perform safety-sensitive functions must, after obtaining an employee's written consent, request information about the employee's drug and alcohol testing record from previous DOT-regulated employers. After receiving a copy of the employee's written consent, the previous employer must immediately provide the requested information to the employer making the inquiry. If an employer is subsequently investigated/audited by the appropriate DOT mode, it may be beneficial for both the gaining employer and the previous employer to be able to affirmatively demonstrate that the employee's written consent and previous testing record were sent and received as required.
Sections 40.191(d) and 40.261(c)(1) require a collector or MRO (for drug tests) or a BAT, STT, or a physician evaluating a “shy lung” situation (for alcohol tests), respectively, to—when an employee refuses to participate in a part of the testing process—terminate the testing process, document the refusal, and immediately and directly notify the employer's designated employer representative (DER) by any means that ensures the refusal notification is immediately received. Because this notification of a refusal to an employer is of an urgent nature, it may be advisable to require the DER to affirmatively confirm receipt of the required notification from the collector, MRO, BAT, STT, or physician. For example, §§40.191(d) and 40.261(c)(1) could be amended to read “. . . immediately notify the DER by any means and ensure that the refusal notification is immediately received”.
While we are not proposing new requirements in this NPRM regarding confirmation of receipt in the sections discussed above (or in other part 40 requirements), we seek comment regarding whether it may be beneficial or advisable to do so, and if so, for which specific sections of part 40.
VIII. Electronic ATF
The ATF has been in use in the DOT alcohol testing program since 1994 (see 59 FR 7349, Feb. 15, 1994). The ATF must be used to document every DOT alcohol test. DOT regulations at 49 CFR 40.225 set forth the requirements for use of the form, and 49 CFR part 40, appendix G, contains a facsimile (reference copy) of the form. The ATF is a three-part carbonless manifold form used by DOT-regulated employers to document the testing event when testing employees subject to DOT alcohol testing. When the employee is tested, both the employee and the STT and/or the BAT will complete the ATF in various sections. The STT/BAT documents the result(s) by either writing in the screening result or attaching the screening and/or confirmation result printed by the evidential breath testing devices (EBT) onto the ATF, and then sends Copy 1 to the employer, provides Copy 2 to the employee, and retains Copy 3 for their records.
On April 2, 2020, DISA petitioned the Department to amend part 40 to allow for the use of an electronic version of the ATF for DOT mandated alcohol testing. In support of its petition, DISA stated that “The requested amendment to 49 CFR part 40 will enable a parallel process for the documentation of DOT-mandated alcohol tests aligned with the similarly situated amendment previously approved for drug testing.” DISA believes that allowing the use of an electronic ATF will result in several benefits to the industry, including “increased efficiency, security and accuracy in documentation of DOT alcohol tests; paperwork reduction; improved process for conducting a DOT alcohol test in conjunction with a DOT drug test when an electronic version of the federal CCF is used for the drug test; reduction of errors and omissions in the completion of the ATF; and improved efficiency and efficacy in the transmission and record retention of alcohol test results.”
DISA noted that non-DOT workplace breath alcohol testing has been conducted using electronic versions of an alcohol testing form that mirrors the DOT ATF for more than five years. Based on experience using those electronic forms for non-DOT testing, DISA cites improved efficiency and accuracy of documentation because: (1) employer and employee information is entered via computer and thus not dependent on reading and deciphering hand-written entries, (2) date time stamps of the testing are automated and not subject to fluctuation or error, (3) transmission of documentation on completed tests is more secure using databases accessed only via protected password and personal identification number (PIN) to authorized employers or their designated agents, and (4) transmission of test result information is faster and more secure than existing transmission options of scanning and emailing attachments or facsimile.
DISA also noted that permitting use of an electronic ATF for DOT-regulated alcohol testing “will substantially reduce cost, by eliminating the requirement for the printing and distribution of carbonless three-ply paper ATFs. The proposed electronic ATF option would still provide for printed paper images to be made available to the employee, the employer, and the alcohol technician, [but] eliminates the requirement for the more expensive carbonless 3 ply paper ATF.”
For the reasons described by DISA in its petition, and recognizing that significant benefits and cost reductions have resulted from use of the electronic CCF for drug testing, we believe that it is likewise appropriate to permit the use of electronic ATFs in part 40 for DOT-regulated testing. Permitting but not requiring the use of an electronic ATF would be consistent with our proposal to permit, but not require, the use of electronic documents and signatures throughout the entirety of part 40 as discussed above. As several commenters noted, the use of an electronic ATF has been used in non-DOT testing for 5-10 years, and the same developers of the electronic CCFs have developed the electronic ATFs. Any electronic ATF used under part 40 for DOT-regulated employees would have to be identical in form and content to the DOT ATF in appendix I to part 40. 8 Just as we imposed general confidentiality and security requirements when electronic CCFs were permitted to be used under part 40, we believe that it is necessary to include the same general requirements relating to the use of electronic ATFs to ensure that confidential employee records cannot be accessed by unauthorized persons.
8 The ATF form was redesignated from appendix G to appendix I as part of the rulemaking process culminating in the May 2023 final rule. During that process, the form was reviewed by the public and DOT received no comment on the form.
Manufacturers of EBTs and alcohol screening devices (ASD) used in DOT alcohol tests must obtain approval from the National Highway Traffic Safety Administration (NHTSA) and then be listed on the Office of Drug and Alcohol Policy and Compliance's (ODAPC) website before those devices may be used in DOT alcohol testing.
IX. PHMSA Proposed Changes
PHMSA is proposing to amend §§199.3, 199.117, and 199.227 and to add §199.4 to conform to the proposed changes in part 40 and to clarify that the proposed changes in part 40 apply to part 199. These changes will help the readers of part 199 find the applicable regulations in part 40 with regards to the definition of terms and record keeping requirements. We also propose to amend §§199.119 and 199.229 by changing the reference of “appendix H” to “appendix J” to conform to the amendment of part 40 published on May 2, 2023.
X. Section-by-Section Analysis
Section 40.3 What do the terms used in this regulation mean?
We propose to add a definition of “electronic signature.” The rule would define an electronic signature as a method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 44 U.S.C. 3504 note, 112 Stat. 2681-749). Including the specific cross reference to GPEA would ensure that regulated entities know that we are using GPEA's performance standard for allowing use of electronic signatures.
We propose to add a definition of “written or in writing.” The rule would define written or in writing as printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of 49 CFR 40.4. This definition would eliminate any distinction between paper and electronic methods of communication/documentation.
Section 40.4 May electronic documents and signatures be used?
We propose to add a new §40.4 that would prescribe the requirements pertaining to electronic documents and signatures throughout part 40.
Paragraph (a) would specify that §40.4 would apply to all documents required by part 40, except for the CCF, as an electronic CCF may only be used when approved by HHS and in compliance with §40.40(c)(5). As background, before an HHS-certified laboratory can use a Federal electronic CCF for regulated specimens, the test facility must submit a detailed plan and proposed standard operating procedures for the electronic CCF system for HHS review and approval through the National Laboratory Certification Program. At the current time, several HHS-certified laboratories have received approval to use a combination electronic/paper CCF, while four laboratories have received approval to use a fully electronic CCF. As noted earlier, and in a separate section of the SUPPORT Act, HHS was required to set a deadline for certified laboratories to request approval for use of fully electronic CCFs. That deadline is now August 31, 2026.
Paragraph (b) would permit, but not require, any person or entity to use electronic methods to comply with any provision in part 40 that requires a document to be signed, certified, generated, maintained, or transmitted between parties. It would apply to all forms of written documentation, including forms, records, notations, and other documents. The substance of the document would otherwise have to comply with part 40 requirements. This would establish parity between paper and electronic documents and signatures, greatly expanding interested parties' ability to use electronic methods to comply with the requirements of part 40.
Paragraph (c) would permit, but not require, any entity required to sign or certify a document to do so using electronic signatures as defined in §40.3. The rule specifies that a person may use any available technology so long as the signature otherwise complies with the requirements of part 40.
Paragraph (d) would establish the minimum requirements for electronic documents and signatures. Any electronic document or signature would be considered the legal equivalent of a paper document or signature if it is the functional equivalent with respect to integrity, accuracy, and accessibility. In other words, the electronic documents or signatures need to accurately and reliably reflect the information in the record. They must remain accessible in a form that could be accurately viewed or reproduced according to Agency rules. As with any documents, paper or electronic, documents that are not legible—for any reason—do not satisfy the Department's requirements.
Electronic documents are not to be considered the legal equivalent of traditional paper documents if they (1) are not capable of being retained, (2) are not used for the purpose for which they were created, or (3) cannot be accurately reproduced for reference by any entity entitled to access by law, for the period of time required by the Department's recordkeeping requirements.
Paragraph (d) would also require that any electronically signed documents must incorporate or otherwise include evidence that both parties to the document have consented to the use of electronic signatures, as required by the E-SIGN Act (15 U.S.C. 7001(c)).
Paragraph (e) would require that when using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records cannot be accessed by unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The proposed requirements are analogous to those established in the current §40.40(c)(5) when we approved use of the electronic CCF in part 40.
Section 40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?
Currently, paragraph (g) makes it clear that the release of information under this section must be in any written form, and the parenthetical clarifies that this can be paper-based (written, fax) or electronic (email). Under the proposed definition of “written or in writing,” there is no distinction between paper-based and electronic communications. Because “written or in writing” would mean either paper or electronic communications, we propose to remove parenthetical reference to “fax, email, letter” to eliminate redundancy and confusion. All parties can conduct their business using either paper or electronic means of documentation and communication.
Section 40.79 How is the collection process completed?
Currently, paragraph (a)(9) of this section requires the collector to “fax or otherwise transmit” Copy 2 of the CCF to the MRO and Copy 4 to the DER within 24 hours or during the next business day. We propose to amend this section by removing reference to the methods of transmitting receipts, so parties can choose their own medium of communication.
Section 40.97 What do laboratories report and how do they report it?
For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraphs (c)(1) and (2) of this section.
Section 40.111 When and how must a laboratory disclose statistical summaries and other information it maintains?
For the same reasons explained in the discussion of §40.79, we propose to amend paragraph (b) of this section to remove the references to the methods of transmitting the summary or report required by this section. Because the summary or report can be transmitted via hard copy or electronically, there is no need to specify how it must be transmitted. As such, we propose to amend the title of this section accordingly.
Section 40.127 What are the MRO's functions in reviewing negative test results?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (c)(2) of this section.
Section 40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative test results?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (b)(2) of this section.
Section 40.163 How does the MRO report drug test results?
For the same reasons explained in the discussion of §40.25, we propose to remove the reference to a “letter” in paragraph (c) of this section. In paragraph (e) of this section, we propose to replace the term “letter” with “written report” for consistency with paragraph (c).
Section 40.167 How are MRO reports of drug results transmitted to the employer?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (c)(1) of this section.
Section 40.185 Through what methods and to whom must a laboratory report split specimen results?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (b) of this section. In addition, because Copy 1 of the CCF can be transmitted in writing or electronically, there is no need to specify the methods through which it must be transmitted. As such, we propose to amend the title of this section accordingly.
Section 40.187 What does the MRO do with split specimen laboratory results?
For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraph (c)(2)(iv)(C) of this section.
Section 40.191 What is a refusal to take a DOT drug test, and what are the consequences?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (d) of this section as means of transmitting notification that an employee has refused to participate in part of the testing process from the collector or MRO to the DER.
Section 40.193 What happens when an employee does not provide a sufficient amount of urine for a drug test?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “send or fax” as the means for the collector to transmit copies of the CCF to the MRO and the DER in paragraph (b)(3) of this section.
Section 40.205 How are drug test problems corrected?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a collector, laboratory, MRO, employer, or other person to supply signed statements regarding correctable problems in a drug test in paragraphs (b)(1) and (2) of this section.
Section 40.225 What form is used for an alcohol test?
We propose to amend this section to permit, but not require, the use of an electronic version of the DOT ATF that is identical in form and content to the form provided in appendix I to part 40. The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT, and if an EBT provides a separate printout of confirmation test results pursuant to §40.253(g), the electronic ATF must include that separate printout. This section would also be amended to specify the same general confidentiality and security measures in §40.45 relating to electronic CCFs to ensure that confidential employee records cannot be accessed by unauthorized persons.
Section 40.255 What happens next after the alcohol confirmation test result?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (a)(5)(i) of this section as means of transmitting results of the alcohol confirmation test from the BAT to the DER. Similarly, there is no need to specify that Copy 1 of the ATF may be transmitted “in person, by telephone, or by electronic means.”
Section 40.261 What is a refusal to take an alcohol test, and what are the consequences?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (c) of this section as means of transmitting a refusal notification from a BAT, STT, or referral physician to the DER.
Section 40.271 How are alcohol testing problems corrected?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a STT, BAT, employer, or other service agent to supply a signed statement regarding correctable flaws in an alcohol test in paragraph (b)(2) of this section.
Section 40.365 What is the Department's policy concerning starting a PIE proceeding?
We propose to amend this section by adding a new paragraph (b)(15) that would identify the failure of a service agent to provide or maintain a secure/confidential electronic system as appropriate grounds for starting a PIE proceeding.
X. Regulatory Analyses and Notices
Executive Orders 12866, 13563, and 14094 (Regulatory Planning and Review)
The Secretary has examined the impact of the proposed part 40 amendments under Executive Order 12866 (“Regulatory Planning and Review”), as supplemented by Executive Order 13563 (“Improving Regulation and Regulatory Review”) and amended by Executive Order 14094 (“Modernizing Regulatory Review”), which directs Federal agencies to assess all costs and benefits of available regulatory alternatives and, when regulation is necessary, to select regulatory approaches that maximize net benefits (including potential economic, environmental, public health and safety, and other advantages; distributive impacts; and equity).
According to these Executive orders, a regulatory action is “significant” if it meets any one of a number of specified conditions, including having an annual effect on the economy of $200 million or more, as adjusted every three years by the Office of Information and Regulatory Affairs (OIRA); adversely affecting in a material way a sector of the economy, competition, or jobs; or if it raises novel legal or policy issues. The proposed amendments, which would allow the use of electronic documents and signatures, do not meet the Executive order's criteria for being a significant rule. Consequently, OMB has determined that the rulemaking action is not significant under the Executive order.
The proposed rule responds to the statutory mandate set forth in Section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271. The proposed rule would not impose new requirements on the industry; rather, it would simply permit—but not require—regulated entities to use electronic signatures, forms, and recordkeeping, and remove outdated and obsolete references in the regulatory text. The proposed rule would not impose new costs on the industry because regulated entities would be allowed to choose to continue to use paper-based documents as they had before. The benefits of the rule would stem from savings in paper and printing expense and other efficiency gains. Examples of documents affected by this rule include, but are not limited to, records of a prospective employee's drug and alcohol testing history that employers must obtain prior to permitting that employee to perform safety-sensitive duties, MRO records and reports, SAP records and reports, and ATFs. While there is no way to estimate how many entities or individuals would change their practices given the new options, or how many documents would be affected, several commenters to the ANPRM stated that they have been using electronic documents and signatures in their non-DOT drug and alcohol testing programs for many years. While neither the benefits nor the costs of this rule can be reliably estimated, we expect this proposed rule to provide flexibility to the industry. Under this proposed rule, regulated entities would have the flexibility to conduct business using either electronic or traditional paper-based methods. We also expect regulated entities to choose technologies that would maximize benefits in accordance with their individual needs and circumstances.
Regulatory Flexibility Act and Small Business Regulatory Enforcement Fairness Act (SBREFA)
The Regulatory Flexibility Act of 1980 (5 U.S.C. 601 et seq. ) requires Federal agencies to consider the effects of their regulatory actions on small businesses and other small entities and minimize any significant economic impact. The term “small entities” comprises small businesses and not-for-profit organizations that are independently owned and operated and are not dominant in their fields, and governmental jurisdictions with a population of less than 50,000. For this rulemaking, potentially affected small entities include drug testing companies (U.S. Small Business Administration (SBA) North American Industry Classification System (NAICS) Sector 54 (Professional, Scientific and Technical Services), Code 541380 (Testing Laboratories and Services)) as well as DOT-regulated entities (SBA NAICS Sectors 48-49 (Transportation and Warehousing)).
The Department does not expect that the proposed rule would have a significant economic impact on a substantial number of small entities. The proposed rule, if adopted, would increase flexibility for all small-entity transportation employers and their service agents by allowing them to use electronic documents, signatures, and recordkeeping to meet part 40 requirements. Use of electronic documents, electronic signatures, and electronic recordkeeping would be voluntary for affected small entities, which will provide added flexibility to these entities in meeting the part 40 requirements. For these reasons, and as explained in more detail in the preamble to this proposed rule, the Secretary certifies that the proposed rule would not have a significant economic impact on a substantial number of small entities within the meaning of the Regulatory Flexibility Act. Consequently, an initial regulatory flexibility analysis is not required for this proposed rule.
Unfunded Mandates
The Secretary has examined the impact of the final rule under the Unfunded Mandates Reform Act (UMRA) of 1995 (Pub. L. 104-4). This NPRM does not trigger the requirement for a written statement under sec. 202(a) of the UMRA because this rulemaking does not impose a mandate that results in an expenditure of $100 million (adjusted annually for inflation) or more by either State, local, and tribal governments in the aggregate or by the private sector in any one year. In fact, by providing an alternative to traditional paper-based records, the proposed rule would be expected to reduce costs to regulated parties, including State and local entities ( e.g., public transit authorities, and public works departments) whose employees are subject to testing and that choose to use electronic documents as opposed to paper-based documents.
Environmental Impact
The DOT has analyzed the environmental impacts of this action pursuant to the National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321 et seq. ) and has determined that it is categorically excluded pursuant to DOT Order 5610.1C, “Procedures for Considering Environmental Impacts” (44 FR 56420, October 1, 1979). Categorical exclusions are actions identified in an agency's NEPA implementing procedures that do not normally have a significant impact on the environment and therefore do not require either an environmental assessment (EA) or environmental impact statement (EIS). This proposed rule would amend the transportation industry drug testing program procedures regulation to permit the use of electronic documents, signatures, and recordkeeping. This action is covered by the categorical exclusion listed at 23 CFR 771.118(c)(4), “[p]lanning and administrative activities that do not involve or lead directly to construction, such as: . . . promulgation of rules, regulations, directives . . .” The Department does not anticipate any environmental impacts, and there are no extraordinary circumstances present in connection with this rulemaking.
Executive Order 13132: Federalism
The Secretary has analyzed the final rule in accordance with Executive Order 13132: Federalism. Executive Order 13132 requires Federal agencies to carefully examine actions to determine if they contain policies that have federalism implications or that preempt State law. As defined in the order, “policies that have federalism implications” refer to regulations, legislative comments or proposed legislation, and other policy statements or actions that have substantial direct effects on the States, on the relationship between the National Government and the States, or on the distribution of power and responsibilities among the various levels of government.
Most of the regulated parties under the Department's drug testing program are private entities. Some regulated entities are public entities ( e.g., transit authorities and public works departments); however, as noted above, this proposal would reduce costs of the Department's drug testing program and provide additional flexibility for regulated parties. Accordingly, the Secretary has determined that the proposed rule, which would allow but not require use of electronic signatures and recordkeeping, does not contain policies that have federalism implications.
Executive Order 13175: Consultation and Coordination With Indian Tribal Governments
Executive Order 13175 (65 FR 67249, November 6, 2000) requires Federal agencies to develop an accountable process to ensure “meaningful and timely input by tribal officials in the development of regulatory policies that have tribal implications.” “Policies that have tribal implications” as defined in the Executive order, include regulations that have “substantial direct effects on one or more Indian tribes, on the relationship between the Federal government and the Indian tribes, or on the distribution of power and responsibilities between the Federal government and Indian tribes.” This proposed rule does not have tribal implications. The proposed rule will also not have substantial direct effects on tribal governments, on the relationship between the Federal Government and Indian tribes, or on the distribution of power and responsibilities between the Federal Government and Indian tribes, as specified in Executive Order 13175.
Paperwork Reduction Act
The Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520) (PRA) requires that DOT consider the impact of paperwork and other information collection burdens imposed on the public. This proposed rule would call for no new collection of information under the PRA. Instead, there would likely be a significant reduction in the burden hours required for information collection 2105-0529, Procedures for Transportation Drug and Alcohol Testing Program, due to the ability to use electronic signatures and forms, and largely due to the ability to use an electronic ATF for DOT-regulated alcohol testing under part 40. We request comments on this issue. Notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information subject to the PRA that does not display a currently valid OMB control number.
Privacy Act
Anyone is able to search the electronic form of all comments received in any of our dockets by the name of the individual submitting the comment (or signing the comment, if submitted on behalf of an association, business, labor union, etc.) For information on DOT's compliance with the Privacy Act, please visit https://www.transportation.gov/privacy.
5 U.S.C. 553(b)(4)
As required by 5 U.S.C. 553(b)(4), a summary of this proposed rule can be found at the entry for RIN 2105-AF01 in the Department's Portion of the Unified Agenda of Regulatory and Deregulatory Affairs, available at https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202404&RIN=2105-AF01 .
Pay-As-You-Go Act of 2023
In accordance with Compliance with Pay-As-You-Go Act of 2023 (Fiscal Responsibility Act of 2023, Pub. L. 118-5, div. B, title III) and OMB Memorandum (M-23-21) dated September 1, 2023, the Department has determined that this proposed rule is not subject to the Pay-As-You-Go Act of 2023 because it will not increase direct spending beyond specified thresholds.
List of Subjects
49 CFR Part 40
Administrative practice and procedures, Alcohol abuse, Alcohol testing, Drug abuse, Drug testing, Laboratories, Reporting and recordkeeping requirements, Safety, Transportation.
49 CFR Part 199
Alcohol testing, Drug testing, Pipeline safety, Reporting and recordkeeping requirements, Safety, Transportation.
For the reasons stated in the preamble, the Department proposes to amend 49 CFR parts 40 and 199 as follows:
PART 40—PROCEDURES FOR TRANSPORTATION WORKPLACE DRUG AND ALCOHOL TESTING PROGRAMS
1. The authority for part 40 continues to read as follows:
Authority:
49 U.S.C. 102, 301, 322, 5331, 20140, 31306, and 54101 et seq.
2. In §40.3, add the definitions of “Electronic signature” and “Written or in writing” in alphabetical order to read as follows:
§40.3 What do the terms used in this part mean?
* * * * *
Electronic signature. A method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 112 Stat. 2681-749, 44 U.S.C. 3504 note).
* * * * *
Written or in writing. Printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of §40.4.
3. Add §40.4 to read as follows:
§40.4 May electronic documents and signatures be used?
(a) Applicability. This section applies to all documents required by this part, except for the CCF. An electronic CCF may be used only if it has been approved for use by the Department of Health and Human Services and is used in compliance with §40.40(c)(5).
(b) Electronic records or documents. Any person or entity required to generate, maintain, or exchange and/or transmit documents to satisfy requirements in this part may use electronic methods to satisfy those requirements.
(c) Electronic signatures. (1) Any person or entity required to sign or certify a document to satisfy the requirements of this part may use an electronic signature, as defined in §40.3.
(2) Any available technology may be used that satisfies the requirements of an electronic signature as defined in §40.3.
(d) Electronic document requirements. Any person or entity may use documents signed, certified, generated, maintained, or exchanged using electronic methods, as long as the documents accurately reflect the information otherwise required to be contained in them.
(1) Records, documents, or signatures generated, maintained, or exchanged using electronic methods satisfy the requirements of this section if they are capable of being retained, are used for the purpose for which they were created, and can be accurately reproduced within required timeframes for reference by any party entitled to access.
(2) Records or documents generated electronically satisfy the requirements of this section if they include proof of consent to use electronically generated records or documents, as required by 15 U.S.C. 7001(c).
(e) Confidentiality and security. When using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form to include protecting against destruction, deterioration, and data corruption.
4. In §40.25, revise paragraph (g) to read as follows:
§40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?
* * * * *
(g) The release of information under this section must be in any written form that ensures confidentiality. As the previous employer, you must maintain a written record of the information released, including the date, the party to whom it was released, and a summary of the information provided.
* * * * *
5. In §40.79, revise paragraph (a)(9) to read as follows:
§40.79 How is the collection process completed?
(a) * * *
(9) Send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or during the next business day. Keep Copy 3 for at least 30 days, unless otherwise specified by applicable DOT agency regulations.
* * * * *
6. In §40.97, revise paragraphs (c) introductory text, (c)(1) introductory text, and (c)(2) to read as follows:
§40. 97 What do laboratories report and how do they report it?
* * * * *
(c) As a laboratory, you must report laboratory results directly, and only, to the MRO at his or her place of business. You must not report results to or through the DER or a service agent ( e.g., C/TPA).
(1) Negative results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF which has been signed by the certifying scientist, or you may provide the laboratory results report electronically.
* * * * *
(2) Non-negative and rejected for testing results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF that has been signed by the certifying scientist. In addition, you may provide the laboratory results report following the format and procedures set forth in paragraphs (c)(1)(i) and (ii) of this section.
* * * * *
7. In §40.111, revise the section heading and paragraph (b) to read as follows:
§40.111 When must a laboratory disclose statistical summaries and other information it maintains?
* * * * *
(b) When the employer requests a summary in response to an inspection, audit, or review by a DOT agency, you must provide it unless the employer had fewer than five aggregate test results. In that case, you must send the employer a report indicating that not enough testing was conducted to warrant a summary.
* * * * *
8. In §40.127, revise paragraph (c)(2) to read as follows:
§40.127 What are the MRO's functions in reviewing negative test results?
* * * * *
(c) * * *
(2) A legible copy of Copy 1 of the CCF or the electronic laboratory results report that conveys the negative laboratory test result.
* * * * *
9. In §40.129, revise paragraphs (b) introductory text and (b)(2) to read as follows:
§40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative drug test results?
* * * * *
(b) Before you report a verified negative, positive, test cancelled, refusal to test because of adulteration or substitution, you must have in your possession the following documents:
* * * * *
(2) A legible copy of Copy 1 of the CCF, containing the certifying scientist's signature.
* * * * *
10. In §40.163, revise paragraphs (c) introductory text and (e) to read as follows:
§40.163 How does the MRO report drug test results?
* * * * *
(c) If you do not report test results using Copy 2 of the CCF for the purposes of this section, you must provide a written report for each test result. This report must, as a minimum, include the following information:
* * * * *
(e) You must retain a signed or stamped and dated copy of Copy 2 of the CCF in your records. If you do not use Copy 2 for reporting results, you must maintain a copy of the signed or stamped and dated written report in addition to the signed or stamped and dated Copy 2. If you use the electronic data file to report negatives, you must maintain a retrievable copy of that report in a format suitable for inspection and auditing by a DOT representative.
* * * * *
11. In §40.167, revise paragraph (c)(1) to read as follows:
§40.167 How are MRO reports of drug test results transmitted to the employer?
* * * * *
(c) * * *
(1) You must transmit a legible image or copy of either the signed or stamped and dated Copy 2 or the written report (see §40.163(b) and (c)).
* * * * *
12. In §40.185, revise the section heading and paragraph (b) to read as follows:
§40.185 What and to whom must a laboratory report split specimen results?
* * * * *
(b) You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF, which has been signed by the certifying scientist.
* * * * *
13. In §40.187, revise paragraph (c)(2)(iv)(C) to read as follows:
§40.187 What does the MRO do with split specimen laboratory results?
* * * * *
(c) * * *
(2) * * *
(iv) * * *
(C) As the laboratory that tests the primary specimen to reconfirm the presence of the adulterant found in the split specimen and/or to determine that the primary specimen meets appropriate substitution criteria, report your result to the MRO using a copy of Copy 1 of the CCF.
* * * * *
14. In §40.191, revise paragraph (d) introductory text to read as follows:
§40.191 What is a refusal to take a DOT drug test, and what are the consequences?
* * * * *
(d) As a collector or an MRO, when an employee refuses to participate in the part of the testing process in which you are involved, you must terminate the portion of the testing process in which you are involved, document the refusal on the CCF (including, in the case of the collector, printing the employee's name on Copy 2 of the CCF), immediately notify the DER by any means that ensures that the refusal notification is immediately received. As a referral physician ( e.g., physician evaluating a “shy bladder” condition or a claim of a legitimate medical explanation in a validity testing situation), you must notify the MRO, who in turn will notify the DER.
* * * * *
15. In §40.193, revise paragraph (b)(3) to read as follows:
§40.193 What happens when an employee does not provide a sufficient amount of specimen for a drug test?
* * * * *
(b) * * *
(3) As the collector, you must send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or the next business day.
* * * * *
16. In §40.205, revise paragraphs (b)(1) and (2) to read as follows:
§40.205 How are drug test problems corrected?
* * * * *
(b) * * *
(1) If the problem resulted from the omission of required information, you must, as the person responsible for providing that information, supply in writing the missing information and a statement that it is true and accurate. For example, suppose you are a collector, and you forgot to make a notation on the “Remarks” line of the CCF that the employee did not sign the certification. You would, when the problem is called to your attention, supply a signed statement that the employee failed or refused to sign the certification and that your statement is true and accurate. You must supply this information on the same business day on which you are notified of the problem.
(2) If the problem is the use of a non-Federal form or an expired Federal form, you must provide a signed statement ( i.e., a memorandum for the record). It must state that the incorrect form contains all the information needed for a valid DOT drug test, and that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control. The statement must also list the steps you have taken to prevent future use of non-Federal forms or expired Federal forms for DOT tests. For this flaw to be corrected, the test of the specimen must have occurred at an HHS-certified laboratory where it was tested consistent with the requirements of this part. You must supply this information on the same business day on which you are notified of the problem.
* * * * *
17. In §40.225, revise paragraph (a) and add paragraphs (d) and (e) to read as follows:
§40.225 What form is used for an alcohol test?
(a) The DOT Alcohol Testing Form (ATF) must be used for every DOT alcohol test. The ATF must be a three-part carbonless manifold form or an electronic ATF that meets the requirements of paragraph (d) of this section. The ATF is found in appendix G to this part. You may view this form on the ODAPC website ( https://www.transportation.gov/odapc ).
* * * * *
(d) As an employer, you may use an electronic ATF that meets the following requirements:
(1) The electronic ATF must be identical in form and content to the ATF found in appendix G to this part.
(2) The electronic ATF must meet the requirements of §40.4(d).
(3) The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT.
(4) If an EBT provides a separate printout of confirmation test results (see §40.253(g)), the electronic ATF must include that separate printout.
(e) As an employer, BAT, or STT using an electronic ATF, you must establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form.
18. In §40.255, revise paragraph (a)(5)(i) to read as follows:
§40.255 What happens next after the alcohol confirmation test result?
(a) * * *
(5) * * *
(i) You may transmit the results using Copy 1 of the ATF, in person, by telephone, or by electronic means. In any case, you must immediately notify the DER of any result of 0.02 or greater by any means that ensures the result is immediately received by the DER. You must not transmit these results through C/TPAs or other service agents.
* * * * *
19. In §40.261, revise paragraph (c)(1) to read as follows:
§40.261 What is a refusal to take an alcohol test, and what are the consequences?
* * * * *
(c)(1) As a BAT or an STT, or as the physician evaluating a “shy lung” situation, when an employee refuses to test as provided in paragraph (a) of this section, you must terminate the portion of the testing process in which you are involved, document the refusal on the ATF (or in a separate document which you cause to be attached to the form), immediately notify the DER by any means that ensures the refusal notification is immediately received. You must make this notification directly to the DER (not using a C/TPA as an intermediary).
* * * * *
20. In §40.271, revise paragraph (b)(2) to read as follows:
§40.271 How are alcohol testing problems corrected?
* * * * *
(b) * * *
(2) If the problem is the use of a non-DOT form, you must, as the person responsible for the use of the incorrect form, certify in writing that the incorrect form contains all the information needed for a valid DOT alcohol test. You must also provide a signed statement that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control, and the steps you have taken to prevent future use of non-DOT forms for DOT tests. You must supply this information on the same business day on which you are notified of the problem.
* * * * *
21. In §40.365, revise paragraphs (b)(13) and (14) and add paragraph (b)(15) to read as follows:
§40.365 What is the Department's policy concerning starting a PIE proceeding?
* * * * *
(b) * * *
(13) For any service agent, directing or recommending that an employer fail or refuse to implement any provision of this part;
(14) With respect to noncompliance with a DOT agency regulation, conduct that affects important provisions of Department-wide concern ( e.g., failure to properly conduct the selection process for random testing); or
(15) For a service agent, failing to provide or maintain a secure/confidential electronic system. PART 199—DRUG AND ALCOHOL TESTING
22. The authority citation for part 199 continues to read as follows:
Authority:
49 U.S.C. 5103, 60102, 60104, 60108, 60117, and 60118; 49 CFR 1.53.
23. In §199.3:
a. Designate the introductory text as paragraph (b); and
b. Add paragraph (a).
The addition reads as follows:
§199.3 Definitions.
(a) Terms used in this part have the same meaning as in 49 CFR 40.3.
* * * * *
24. Add §199.4 to read as follows:
§199.4 Electronic documents, records, and signatures.
Electronic documents, records, and signatures may be used to comply with this part provided they meet the requirements specified in 49 CFR part 40.
25. In §199.117, revise paragraph (a) introductory text to read as follows:
§199.117 Recordkeeping.
(a) Each operator shall keep the records in paragraphs (a)(1) through (5) of this section for the periods specified by this section or for the periods specified by 49 CFR part 40, whichever is greater; and will permit access to the records as provided by §190.203.
* * * * *
26. In §199.119, revise paragraph (a) to read as follows:
§199.119 Reporting of anti-drug testing results.
(a) Each large operator (having more than 50 covered employees) must submit an annual Management Information System (MIS) report to PHMSA of its anti-drug testing using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.
* * * * *
27. In §199.227, revise paragraph (b) introductory text to read as follows:
§199.227 Retention of records.
* * * * *
(b) Period of retention. Each operator shall maintain the records in accordance with the following schedule or for the periods specified by 49 CFR part 40, whichever is greater:
* * * * *
28. In §199.229, revise paragraph (a) to read as follows:
§199.229 Reporting of alcohol testing results.
(a) Each large operator (having more than 50 covered employees) must submit an annual MIS report to PHMSA of its alcohol testing results using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.
* * * * *
Signed on: Thursday, October 3, 2024.
Pete Buttigieg,
Secretary of Transportation.
[FR Doc. 2024-23427 Filed 10-11-24; 8:45 am]
BILLING CODE 4910-9X-P
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Most Recent Highlights In Environmental
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2026-06-03T05:00:00Z
EPA adds new HAPs to hazardous waste combustor requirements
The Environmental Protection Agency (EPA) finalized the residual risk and technology review of the National Emission Standards for Hazardous Air Pollutants (NESHAP) from Hazardous Waste Combustors (HWCs). Most significantly, the final rule:
- Maintains the existing standards;
- Adds requirements for previously unregulated hazardous air pollutants from specific major source HWCs; and
- Establishes work practice standards for periods of startup, shutdown, and malfunction (SSM).
Who’s impacted?
EPA’s final rule applies to major sources subject to the HWC NESHAP at 40 CFR 63 Subpart EEE, including:
- Hazardous waste-burning incinerators,
- Cement kilns,
- Lightweight aggregate kilns,
- Solid fuel-fired boilers,
- Liquid fuel-fired boilers, and
- Hydrochloric acid production furnaces.
What are the changes?
The final rule adds standards for hydrogen fluoride (HF) and hydrogen cyanide (HCN) emissions to specific sources:
| Major source HWC | New regulation(s) |
|---|---|
| Incinerators |
|
| Cement kilns |
|
| Solid fuel boilers |
|
| Liquid fuel boilers |
|
The final rule also:
- Establishes work practice standards for periods of SSM;
- Requires electronic reporting for specific reports (e.g., compliance progress reports, performance tests, Notifications of Compliance); and
- Makes technical changes.
What’s the compliance timeline?
Existing HWCs must:
- Develop, submit to the regulatory authority for approval, and implement SSM plans and start complying with SSM requirements by November 30, 2026;
- Comply with any applicable HF and HCN emission limits and work practice standards by June 3, 2029; and
- Begin electronic reporting by August 3, 2026.
New HWCs must comply upon startup.
Key to remember: EPA's final rule maintains the existing NESHAP regulations for hazardous waste combustors and establishes emission limits and work practice standards for previously unregulated HAPs.
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2026-06-03T05:00:00Z
Colorado finalizes emission regulations for priority toxic air contaminants
Effective date: June 14, 2026
This applies to: New, modified, and existing stationary sources of priority toxic air contaminants (PTACs)
Description of change: The Colorado Air Quality Control Commission adopted state-level emission control requirements for PTACs. The rules apply to specific source categories of stationary sources that emit one or more PTAC, including benzene, hexavalent chromium, ethylene oxide (EtO), formaldehyde, and hydrogen sulfide. The commission revised Regulation Numbers 24, 26, and 30.
Regulated sources must reduce emissions by implementing new technologies, adjusting work practices, and using fewer toxic materials. The revisions add regulations for emissions of:
- Benzene from petroleum refineries,
- Formaldehyde from stationary spark-ignition reciprocating internal combustion engines and combustion turbines,
- Hexavalent chromium from decorative and functional chrome plating,
- EtO from sterilization facilities, and
- Hydrogen sulfide from asphalt processing products, roofing products, and manure digesters.
Various requirements for different PTACs and sources start on June 14, 2026.
Related state info: Clean air operating permits state comparison
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2026-06-03T05:00:00Z
Maryland adopts regulations for packaging and paper products
Effective date: May 25, 2026
This applies to: Producers of packaging and paper products (covered materials)
Description of change: Maryland’s Department of the Environment adopted regulations to implement the Packaging and Paper Products — Producer Responsibility Plans Act under the department’s Extended Producer Responsibility program.
The rules establish requirements for producers of covered materials to submit producer responsibility plans and comply with other requirements, such as:
- Annual registration of covered materials,
- Recordkeeping, and
- Reporting.
Producers of covered materials must:
- Pay fees;
- Either:
- Join a Producer Responsibility Organization (PRO) Producer Responsibility Plan;
- Have an approved Individual Producer Responsibility Plan (IPP); or
- Have an approved IPP for a specific covered material and join a PRO plan for other covered materials;
- Register annually with the PRO or department;
- Submit reports to the PRO or department; and
- Comply with recordkeeping requirements.
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2026-06-03T05:00:00Z
Michigan adds requirements to wastewater collection systems
Effective date: April 29, 2026
This applies to: Wastewater collection systems with more than 50 connections and retention treatment basin (RTB) facilities
Description of change: The Michigan Department of Environment, Great Lakes, and Energy amended regulations for wastewater collection systems and RTB facilities by requiring:
- Facility classification, and
- Collection system operators to have system-specific certification (and recertify every 3 years).
The rules also streamline wastewater construction permitting, clarifying requirements for privately owned, publicly used systems when applying for Part 41 Permits.
Related state info: Industrial water permitting — Michigan
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2026-06-03T05:00:00Z
Florida amends on-site sewage treatment and disposal rules
Effective date: June 8, 2026
This applies to: On-site sewage treatment and disposal systems (OSTDS)
Description of change: The Florida Department of Environmental Protection amended the regulatory requirements for OSTDS. In addition to streamlining specific permit application processing procedures, the final rule amends the requirements for:
- Installing and locating OSTDS,
- Abandoning OSTDS,
- Treatment receptacle construction standards,
- Registration requirements for septic tanks and Master Septic Tank Contractors,
- Registration certificate renewals,
- Discipline and penalties for registered persons,
- Certification of partnerships and corporations as septic tank contracting businesses, and
- Service and registration fees.
Related state info: Industrial water permitting — Florida
Most Recent Highlights In Transportation
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EPA restores emergency-related affirmative defense provisions for Title V operating permits
In response to a court mandate, the Environmental Protection Agency (EPA) has rescinded a 2023 final rule that removed emergency-related affirmative defense provisions from the Title V operating permit regulations (the 2023 Affirmative Defense Rule) under the Clean Air Act.
The final rule (published on June 1, 2026) reinstates the emergency-related affirmative defense provisions for state and federal Title V operating permit programs (at 40 CFR 70.6(g) and 71.6(g), respectively).
Who’s impacted?
EPA’s final rule affects stationary sources subject to Title V operating permit requirements.
What does this mean?
The emergency-related affirmative defense provisions establish a framework for regulated facilities to assert an affirmative defense in enforcement proceedings for violations of technology-based emission limits caused by sudden, unavoidable emergencies, provided certain conditions are met.
To rely on the emergency-related affirmative defense, stationary sources must demonstrate that:
- A qualifying emergency occurred,
- The facility was being properly operated,
- The facility took all reasonable actions to limit excess emissions, and
- The facility properly notified the permitting authority.
EPA’s demonstration requirements are listed at 70.6(g)(3)/71.6(g)(3).
What affirmative defense covers
An “emergency,” as defined by 70.6(g)(1)/71.6(g)(1), generally refers to a sudden, unforeseeable event beyond the facility’s control that causes noncompliance with technology-based emission limits established in its Title V operating permit.
What affirmative defense doesn’t cover
The provisions don’t apply to noncompliance due to:
- Improperly designed equipment,
- Lack of preventive maintenance,
- Careless or improper operation, or
- Operator error.
Key to remember: EPA has restored the emergency-related affirmative defense provisions for Title V operating permits, allowing stationary sources to assert a regulatory affirmative defense for certain emission violations caused by events beyond the facility’s control.
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Water reuse: Put your facility’s wastewater to work
Did you know that one entity’s wastewater may be another organization’s treasure? Through water reuse, businesses reclaim municipal and industrial stormwater and wastewater, treat it to make it safe, and repurpose it for beneficial uses.
Reusing water can help companies lower costs, secure a more reliable water supply, and reduce environmental impact. While water reuse is usually voluntary, it must align with federal discharge requirements and state reuse regulations.
The Environmental Protection Agency (EPA) recently launched Water Reuse Action Plan (WRAP) 2.0, an initiative that seeks to advance water reuse in the industrial, technology, and energy sectors. Published in May 2026, Water Reuse Action Plan 2.0: Multiplying Water Benefits, Maximizing American Prosperity provides a comprehensive overview of WRAP 2.0, including specific case studies of how entities have improved operational efficiency by reusing water.
Let’s look at three of these successful water reuse examples and consider factors to help you determine whether water reuse can benefit your business.
Real-world examples of water reuse
Water reuse has been successfully integrated into operations across a range of industries by all types of businesses (from local car washes to national food production companies).
Automobile manufacturing
Painting uses more water than other processes in automobile manufacturing. One major vehicle manufacturer has addressed this through water reuse. At one of its Kentucky assembly plants, the manufacturer started reusing treated wastewater in the paint pretreatment process.
As a result, the assembly plant sends less wastewater to the publicly owned treatment works, uses less freshwater in the manufacturing process, and achieves cost savings by purchasing less water. For instance, during the first year of implementation, the water reuse initiative saved the plant about $50,000.
Stadium operations
A large stadium in Georgia contains a stormwater management system, including a cistern that catches rainwater runoff from the stadium’s roof and plaza structure. The stadium uses this rainwater runoff for exterior landscape irrigation and for make-up water for its cooling towers.
Additionally, nearly all of the plumbing fixtures installed in the stadium are low-flow fixtures, using less water than traditional fixtures.
Similar to the automobile manufacturer, reusing water means that the stadium purchases less water. The stadium’s water reuse efforts have also helped the facility secure a reputation for sustainability.
Refinery processing
A major refinery in California partners with the municipal utility district to reuse recycled water for its boilers.
Boilers require high-purity water, so the utility treats the recycled water with specific technologies (including reverse osmosis) to meet the quality standards. The utility treats the wastewater on-site, supplying the refinery with the recycled water. The refinery then uses the water in its boilers to generate steam needed to manufacture gasoline, diesel, and other products.
By reusing water, the refinery greatly reduces the amount of freshwater it uses (and therefore, reduces the cost of purchasing water). It also allows the refinery to continue operations during drought restrictions, making it more resilient to weather-related changes.
How’s water reuse regulated?
Water reuse is generally voluntary; however, it operates within existing regulatory frameworks that govern wastewater discharges and water quality.
Most states regulate water reuse, although some programs may be implemented at the local level. In California, for instance, the Regional Water Quality Control Boards issue water reuse permits in their respective covered areas, whereas the Texas Commission on Environmental Quality (a state agency) regulates water reuse projects.
Tip: Use EPA’s REUSExplorer tool to find water reuse guidelines or regulations for your facility’s state.
Can water reuse benefit your business?
Each company must evaluate its operational processes to determine whether water reuse can help improve efficiency. Use these tips as a starting point:
- First, assess existing processes to determine whether and how water can be reused.
- Estimate the costs of implementing water reuse projects, such as installing or upgrading the facility’s equipment or infrastructure.
- Compare the potential benefits to the associated costs of reusing water. Consider both the short-term and long-term effects.
- Confirm the compliance requirements for water reuse with the proper regulatory authority (generally, the state environmental agency).
Water reuse may offer your business the opportunity to put its wastewater to work.
Key to remember: Water reuse implemented in compliance with applicable regulations can help facilities improve operational efficiency, lower costs, and reduce environmental impact.
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2026-05-27T05:00:00Z
Final rule revises HFC use restrictions and compliance timelines for specific subsectors
On May 26, 2026, the Environmental Protection Agency (EPA) finalized a rule (2026 Final Rule) revising regulations on the use of hydrofluorocarbons (HFCs) in certain subsectors. The final rule specifically amends requirements established by the 2023 Technology Transitions Rule under the American Innovation and Manufacturing Act of 2020 (AIM Act).
EPA also published a proposed rule to exempt road and intermodal container transport refrigeration units (TRUs) from leak repair requirements set by the 2024 Emissions Reduction and Reclamation (ER&R) Rule.
Who’s impacted?
The 2026 Final Rule applies to entities that are subject to the 2023 Technology Transition Rule requirements (40 CFR 84.54) for these subsectors:
- Refrigerated transport — intermodal containers,
- Industrial process refrigeration (IPR) and chillers for IPR used in semiconductor manufacturing,
- Retail food — supermarket systems,
- Retail food — remote condensing units,
- Cold storage warehouses,
- Residential and light commercial air conditioning and heat pumps (RACHP), and
- IPR (not using chillers) — refrigerated laboratory centrifuges and refrigerated laboratory shakers.
The 2026 proposed rule applies to refrigerant-containing road and intermodal container transport refrigeration units (TRUs) regulated by the 2024 ER&R Rule.
What are the changes?
The 2026 Final Rule:
- Adjusts the lower bound temperature and measurement location for refrigerated transport intermodal containers from -50°C to -35°C;
- Extends the compliance dates to January 1, 2030, for restrictions on uses of HFCs and HFC blends by IPR and chillers for IPR in semiconductor manufacturing process equipment (limited to equipment with a charge size of 100 pounds or less);
- Allows retail food supermarket systems to increase the cooling capacity of existing systems by up to 15 percent without triggering new installation requirements;
- Establishes temporary, relaxed interim global warming potential (GWP) limits (implementing stricter GWP limits starting on January 1, 2032) for:
- Retail food supermarket systems,
- Retail food remote condensing unit systems, and
- Cold storage warehouses.
- Allows RACHP equipment using specific components that were domestically manufactured or imported before January 1, 2025, to continue to be installed; and
- Delays the compliance dates to January 1, 2028, for restrictions on uses of HFCs and HFC blends by refrigerated laboratory centrifuges and refrigerated laboratory shakers.
Please note that the final rule states that EPA maintains existing requirements for new condensing units used as replacements in the RACHP subsector.
What’s the proposed rule?
The 2024 ER&R Rule added leak repair requirements (84.106) for refrigerant-containing appliances with a charge size of 15 pounds or more containing an HFC or a specific HFC substitute, which took effect on January 1, 2026. Examples of the requirements include leak inspections, appliance repairs, and reporting.
EPA proposes to exempt all refrigerant-containing road and intermodal container TRUs from the leak repair provisions (regardless of charge size).
Key to remember: EPA has issued a final rule revising HFC use restrictions for certain subsectors and has proposed a rule exempting transportation refrigeration units from leak repair requirements.
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2026-05-26T05:00:00Z
OSHA packs new HazCom directive with enforcement clues
The first compliance date for the amended Hazard Communication (HazCom) standard has arrived, and OSHA finally issued its updated directive. The CPL instructs OSHA officers on how to conduct inspections and issue citations under the standard. However, it also provides chemical manufacturers, importers, distributors, and employers with insight into what officers will be assessing.
In effect, this CPL translates regulatory text into inspector expectations. It shows what adherence to the standard looks like in practice. That makes it a critical resource given recent and upcoming dates at 29 CFR 1910.1200(j).
CPL rewritten for the 2024 standard
On May 19, 2026, OSHA posted a revised CPL 02-02-079, “Inspection Procedures for the Hazard Communication Standard (HCS 2024),” replacing the July 9, 2015, version. The 132-page document reflects the reconfigured HazCom standard published May 20, 2024, effective on July 19, 2024, along with corrections issued through early 2026.
The agency designed this enforcement playbook to maintain uniform inspections during the transition period and after full implementation. Because of the extensive regulatory changes to definitions, hazard classification, labeling, safety data sheets, and trade secrets, the CPL is not a light refresh.
For those familiar with the rulemaking, the new CPL edits will not be surprising. Still, the directive should provide more clarity than the regulatory text.
Front matter and appendices
Updates to Sections I to IX are typical of a CPL, including:
- Cancellation of the 2015 CPL;
- A modified title and references to the 2024 final rule and corrections;
- Alignment with revisions 7 and 8 of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS); and
- A new summary of changes, historical background, and compliance dates.
OSHA also modernized appendices for dates, hazard lists, pictogram hazards, SDS review guidance, chemical resources, and related directives.
Reworked inspection guidelines
Section X outlines inspector instructions for paragraphs (b) through (j) of the standard. The latest modifications impact most sections:
- Scope, applicability, and exemptions — The directive offers new examples and expanded explanations, such as:
- A formaldehyde hazard example for hair smoothing products;
- An overview of pesticide labeling requirements and exemptions;
- Discussion of the EPA Agricultural Worker Protection standard preemption; and
- Greater detail about biological hazards from plants.
- Definitions — The document introduces terms and explains bulk shipment, immediate outer package, physical hazard, released for shipment, and more. It also revisits the terms combustible dust and manufacturer. Lithium-ion batteries are now referenced in the distributor context.
- Hazard classification — The directive instructs OSHA officers to consider the classification of:
- Hazards associated with a chemical’s intrinsic properties, including changes in physical form and reactions from known or reasonably anticipated uses; and
- Impurities, additives, and individual constituents.
- Written plan — The directive clarifies:
- Employers must revise programs by the compliance dates when new information is received from suppliers;
- The use of computers and third-party administrators of safety data sheets (SDSs); and
- The written program must describe how employees will be trained in a language and at a literacy level they understand.
- Labeling — The directive broadens the sections on Department of Transportation labeling, bulk shipments, and small container labeling. It incorporates final rule flexibility too:
- Phased-in compliance dates for labeling;
- Hazards not otherwise classified (HNOCs) and hazards identified and classified under 1910.1200(d)(1)(ii) don’t need to be addressed on the container;
- The exclamation mark pictogram is permitted (but not required) for HNOCs, under certain conditions;
- Minor textual variations for precautionary statements are allowed; and
- OSHA offers alternatives for chemical containers released for shipment.
- Safety data sheets (SDSs) — Amended text focuses on U.S. jurisdiction and technical provisions, such as:
- Phased-in compliance dates for SDSs;
- Importer SDS responsibilities;
- Using a U.S. address and phone number;
- The hazard class and category reflecting intrinsic properties;
- Required Chemical Abstracts Service (CAS) number or other unique identifiers; and
- No need to obtain updated SDSs to replace already received SDSs.
- Employee information/training — The directive references a temporary workers bulletin. It also emphasizes:
- Phased-in compliance dates for necessary training adjustments; and
- Delivering training in a language employees understand.
- Trade secrets — The instruction aligns with the 2024 rule:
- Allows the exact percentage, exact concentration range, or CAS number to be withheld if certain criteria are met; and
- Addresses the use of confidentiality agreements.
- Dates — The directive overhauls compliance timelines and discusses documentation of due diligence and good faith efforts.
In addition, the directive softens citation language with phrases like “should normally cite” instead of “shall cite.” This shift suggests inspectors may have greater discretion based on case-specific circumstances.
Key to remember
While 1910.1200 remains the baseline for employers and chemical manufacturers, importers, and distributors, the revised CPL 02-02-079 provides an enforcement lens. With implementation underway, regulated entities can use the CPL to steer their efforts and conform with how OSHA will inspect them in the field.
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2026-05-22T05:00:00Z
Where workplace exposure meets air permitting: Bridging OSHA industrial hygiene and EPA air programs
Air quality inside a facility and emissions leaving a stack are closely linked. The same chemicals that drive occupational exposure limits under the Occupational Safety and Health Administration (OSHA) often form the basis of regulated air pollutants under the Environmental Protection Agency's (EPA's) programs.
When industrial hygiene (IH) and environmental compliance teams work together, they can spot risks sooner, strengthen controls, and avoid surprises in permits or inspections. The overlap is practical. Worker exposure data can inform stack testing, and permit conditions can signal where IH monitoring should focus.
Shared chemistry, different lenses
Both programs start with the same substances, such as solvents, metals, acids, and combustion byproducts. IH focuses on what workers breathe in the workplace. It uses exposure limits such as OSHA permissible exposure limits or more protective guidelines from the National Institute for Occupational Safety and Health (NIOSH) and the American Conference of Governmental Industrial Hygienists (ACGIH). Environmental air programs focus on what leaves the property. They regulate criteria pollutants, hazardous air pollutants (HAPs), and toxics using emission limits, control requirements, and reporting rules.
The data tools look similar. IH uses personal and area sampling, direct-reading instruments, and task-based assessments. Environmental programs use emission factors, mass balance, continuous monitoring, and periodic stack testing. Both require documentation, quality control, and records.
Key differences that matter
The point of exposure is the biggest difference. IH evaluates the breathing zone of a worker during a task or shift. Environmental programs measure emissions at a release point, such as a stack, or estimate them across the site.
The time frame also differs. IH often looks at short-term peaks and full-shift averages to protect health during work. Air permits may set hourly, daily, or annual limits, and they may cap total emissions per year. Control strategies follow these goals. IH may rely on local exhaust ventilation, enclosure, or work practice changes. Air permits may require add-on controls such as thermal oxidizers, scrubbers, or filters.
Practical crossover: Using IH to inform permitting
IH data can reveal which tasks generate the highest concentrations and which compounds dominate exposure. That insight can refine emission estimates. For example, if wipe cleaning with a solvent produces the highest worker exposure, the same solvent may drive facility-wide volatile organic compound (VOC) emissions. The environmental team can use that knowledge to prioritize accurate emission factors, refine mass balance, or plan stack testing during peak operations.
IH data also helps define realistic operating scenarios for compliance testing. Stack tests that occur only at typical loads may miss worst-case conditions. Pairing test timing with identified peak tasks can provide a more representative test and reduce the risk of later noncompliance.
Practical crossover: Using permits to inform IH
Air permits define regulated compounds, control devices, and operating limits. These details can guide IH planning. If a permit lists specific HAPs or requires a control device for a process, there's a clear signal that exposure to those compounds is possible near the source. IH can target those areas for baseline sampling, validate control performance, and confirm that capture systems are effective where workers are present.
Permit conditions also flag upset and startup modes. These periods can increase emissions. IH can align monitoring during these windows to assess short-term exposures and ensure that work practices and protective measures are adequate.
Aligning controls for dual benefit
Engineering controls can serve both goals when designed as a system. Capture at the source reduces worker exposure and lowers emissions to the stack. Good enclosure and balanced ventilation improve control efficiency and reduce fugitive releases. Preventive maintenance on control devices supports permit limits and keeps workplace air clean.
Administrative controls can align as well. Standard operating procedures can link production rates, control device settings, and ventilation checks. Change management should include both an IH review and an air permitting check to see if a modification triggers a permit update.
Communication and workflows
Successful crossover depends on routine communication. Regular meetings enable safety and environmental staff to share results, plan sampling, and coordinate testing windows. Shared inventories of chemicals and processes reduce duplication and errors. A common data platform, or at least a consistent file structure, makes it easier to compare IH results with emission estimates and permit limits.
Clear triggers help teams act. Examples include a new chemical introduction, a process change, a spike in IH results, or a deviation in control device performance. Each trigger should prompt both an IH review and an environmental compliance check.
Key to remember: When teams connect their data and plans, they gain a clearer picture of risk. The results are stronger compliance, better worker protection, and more efficient operations.
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2026-05-22T05:00:00Z
Final rule extends TSCA Section 8(d) health and safety reporting deadline
The Environmental Protection Agency (EPA) issued a final rule on May 22, 2026, extending the reporting deadline for the Toxic Substances Control Act (TSCA) Section 8(d) Health and Safety Data Reporting Rule from May 22, 2026, to May 21, 2027.
Who’s impacted?
The TSCA Section 8(d) Health and Safety Data Reporting Rule applies to manufacturers (including importers) of any of the 16 chemical substances listed at 40 CFR 716.120(d), including:
- Entities that currently manufacture (including import) any of the chemicals; and
- Entities that have manufactured (including imported) or have proposed to manufacture (including import) any of the chemicals since January 13, 2015.
What’s required?
The rule requires covered manufacturers (including importers) to submit a one-time report of data on the chemicals from unpublished studies on:
- Health and safety;
- Environmental effects; and
- Occupational, general population, and consumer exposure.
Which chemicals are covered?
The TSCA Section 8(d) Health and Safety Data Reporting Rule applies to:
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Why the delay?
EPA has extended the deadline to allow additional time to reconsider the rule’s scope and possibly propose revisions to the regulations. Once any major changes are finalized, EPA will communicate the updated reporting requirements and timelines accordingly.
Key to remember: EPA has extended the submission date for the TSCA Section 8(d) Health and Safety Data Reporting Rule’s one-time report to May 2027.
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2026-05-20T05:00:00Z
EPA floats major changes to current PFAS drinking water rules
The Environmental Protection Agency (EPA) has released two proposed rules that, if finalized, would have major impacts on drinking water regulations for per- and polyfluoroalkyl substances (PFAS), specifically, the 2024 National Primary Drinking Water Regulation (NPDWR) for PFAS (2024 PFAS NPDWR).
Proposed rule: MCL compliance extension
The first rule proposes to establish a federal exemption that allows public water systems (PWSs) to request an extension of the deadline to comply with the Maximum Contaminant Levels (MCLs) for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) from April 26, 2029, to April 26, 2031.
The rule would require PWSs that meet the eligibility requirements to submit a request to EPA for the federal exemption within 180 days of the date a final rule is published. PWSs would have to provide specific information in the request (such as recent water sample results and a certified statement that the system can’t comply with the original MCL deadline).
Additionally, EPA’s proposed rule would require:
- All PWSs with the federal exemption to notify customers of the exemption, and
- PWSs with PFOA or PFOS levels at or above 12 parts per trillion to implement two control measures (from six options) during the exemption period.
Who would be impacted?
The proposed federal exemption would apply to PWSs:
- Regulated by the 2024 PFAS NPDWR for PFOA and PFOS;
- In operation on or before June 25, 2024;
- Not under a variance for small systems for the PFOA and PFOS MCLs; and
- In a state that doesn’t have primacy for the 2024 PFAS NPDWR.
PWSs in states with primacy for the 2024 PFAS NPDWR may request an exemption from the primacy agency.
Proposed rule: Rescinding PFAS NPDWRs
The second rule proposes to rescind EPA’s determinations to regulate:
- Perfluorohexane sulfonic acid (PFHxS);
- Perfluorononanoic acid (PFNA);
- Hexafluoropropylene oxide dimer acid and its ammonium salt (HFPO-DA, called GenX chemicals); and
- Perfluorobutane sulfonic acid (PFBS).
It also proposes to remove the related 2024 PFAS NPDWR provisions from 40 CFR Parts 141 and 142, including:
- The MCLs and MCL Goals (MCLGs) for PFHxS, PFNA, and HFPO-DA;
- The MCL and MCLG for mixtures with two or more of PFHxS, PFNA, HFPO-DA, and PFBS (referred to as the Index PFAS); and
- All other compliance requirements.
The proposed rule would maintain the 2024 PFAS NPDWR requirements for PFOA and PFOS.
Who would be impacted?
The rule would impact PWSs, including community water systems (CWSs) and non-transient non-CWSs, subject to the 2024 PFAS NPDWR standards for PFHxS, PFNA, HFPO-DA, or the Index PFAS.
How do I give feedback?
EPA will hold a virtual public hearing for verbal comments on the proposed rules on July 7, 2026. Written comments for the proposed compliance extension rule (Docket ID No. EPA-HQ-OW-2025-1742) and proposed rescission rule (Docket ID No. EPA-HQ-OW-2025-0654) are due by July 20, 2026.
Key to remember: EPA has proposed major changes to the national drinking water regulations for PFAS.
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2026-05-20T05:00:00Z
California approves plastic packaging regulations
Effective date: May 1, 2026
This applies to: Producers of single-use packaging and plastic single-use food service ware
Description of change: CalRecycle approved permanent regulations to implement the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54). The regulations require producers of covered materials (single-use packaging and plastic single-use food service ware) to administer an extended producer responsibility program.
Producers must meet minimum recycled content requirements for covered materials and pay fees (including annual mitigation surcharges for all producers and fees to producers participating in a producer responsibility organization (PRO) plan).
By June 1, 2026, producers must:
- Register with Circular Action Alliance (CAA) and submit supply data to CAA if participating in an approved PRO plan,
- Register with CalRecycle and apply to be an independent producer if complying individually, or
- Register with CalRecycle and apply for the small producer exemption if qualified.
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2026-05-20T05:00:00Z
New Mexico adopts PFAS product phaseout regulations
Effective date: July 1, 2026
This applies to: Manufacturers, distributors, and retailers that sell, offer for sale, distribute, or distribute for sale products that contain intentionally added per- and polyfluoroalkyl substances (PFAS) in New Mexico
Description of change: The New Mexico Environment Department adopted regulations implementing the PFAS Protection Act (HB212), which phases out consumer products with intentionally added PFAS. The regulations contain:
- The prohibitions of products (with specific product categories and timelines),
- Reporting and testing requirements,
- Labeling requirements, and
- Fees for mandatory reporting and “currently unavoidable use” designation applications.
The regulations establish three phaseout deadlines:
- The first group of products must be phased out by January 1, 2027.
- The second group of products must be phased out by January 1, 2028.
- All other nonexempt products and products without currently unavoidable use designations must be phased out by January 1, 2032.
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2026-05-20T05:00:00Z
California adopts risk-based water quality standards for nonpotable water
Effective date: April 22, 2026
This applies to: Owners and operators of on-site treated nonpotable water systems (OTNWS)
Description of change: The California State Water Resources Control Board adopted risk-based water quality standards that apply to OTNWS for the on-site treatment and reuse of nonpotable water for nonpotable end uses in:
- Multifamily residential buildings,
- Commercial buildings, and
- Mixed-use buildings.
The types of nonpotable water include on-site:
- Wastewater,
- Graywater,
- Stormwater, and
- Roof runoff.
The regulations apply to indoor and outdoor nonpotable uses, including:
- Toilet and urinal flushing,
- Drain trap priming,
- Clothes washing,
- Decorative fountains,
- Landscape irrigation,
- Ornamental plant irrigation,
- Dust suppression, and
- Car washing.
Related state info: Industrial water permitting — California
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2026-05-19T05:00:00Z
EPA proposes major changes to multiple rules
The Environmental Protection Agency (EPA) has been on a rulemaking roll! In recent weeks, the agency has published significant proposed rules in the Federal Register that affect coal-fired power plant wastewater, pre-construction air permits, and vehicle emission requirements.
Coal-fired power plants: Unmanaged CRL discharges
EPA proposes to revise the wastewater requirements established by a 2024 final rule (2024 Rule) for unmanaged combustion residual leachate (CRL) from coal-fired power plants.
Unmanaged CRL (a type of waste stream) is water that contains coal combustion residuals and leaks from landfills or surface impoundments (i.e., waste management units). Unmanaged CRL includes:
- Pumped unmanaged CRL (leached CRL that’s captured, pumped to the surface, and discharged directly to waters of the United States); and
- The functional equivalent of an unmanaged CRL direct discharge (determined by the permitting authority).
The proposed rule applies to coal-fired power plants with unmanaged CRL that are subject to the 2024 Rule’s technology-based effluent limitations guidelines and standards.
The agency proposes three options to revise the unmanaged CRL requirements:
- Option 1 (preferred by EPA) would maintain the 2024 rule’s mercury and arsenic numeric limits for pumped unmanaged CRL discharges, but it would delay the compliance deadline from December 31, 2029, to December 31, 2034. Additionally, the permitting authorities would determine best available technology economically achievable (BAT) limits for functional equivalents on a case-by-case basis.
- Option 2 would maintain the 2024 rule’s mercury and arsenic numeric limits for pumped unmanaged CRL discharges and functional equivalents. It would also maintain the original compliance timeline of December 31, 2029.
- Option 3 would impose zero-discharge limits for all pollutants in pumped unmanaged CRL discharges and functional equivalents. It would also establish interim BAT limits for mercury and arsenic. Facilities would have to meet the zero-discharge limits by December 31, 2034.
Public comments are due by June 17, 2026 (Docket ID No. EPA–HQ–OW–2009–0819).
Pre-construction air permits: Begin actual construction
EPA proposes to allow construction-related activities on components or structures that don’t emit air pollutants to start before obtaining a New Source Review (NSR) pre-construction permit to build or modify a stationary source. The proposed rule:
- Redefines “begin actual construction," and
- Adds “pollutant-emitting activities” to the regulatory definitions.
Both definitions list equipment, components, and processes that are excluded, meaning that construction on these activities may begin before obtaining an NSR permit. Examples of exempt activities include compacting and stabilizing soil, paving surfaces, and installing concrete pads.
If finalized, the proposed rule will distinguish between construction on stationary sources and construction on non-emitting components (e.g., utility infrastructure, certain building foundations) and codify that on-site construction of non-emitting components or structures can begin before getting an NSR permit.
Public comments are due by June 29, 2026 (Docket ID No. EPA-HQ-OAR-2025-0618).
Light- and medium-duty vehicle regulations: Tier 4 standards
EPA published Part 1 of a two-part rulemaking effort to revise the Tier 4 criteria air pollutant standards set in 2024 (Tier 4 Rule) for light- and medium-duty vehicles (LMDVs), which include:
- Light-duty vehicles and trucks,
- Medium-duty passenger vehicles, and
- Medium-duty vehicles.
In Part 1, EPA proposes to amend the phase-in schedule for Tier 4 criteria air pollutant requirements by:
- Extending the Tier 3 standards set in 2014 (Tier 3 Rule) for LMDVs to model years (MYs) 2027 and 2028,
- Delaying the start of phasing in Tier 4 standards for LMDVs from MY 2027 to MY 2029, and
- Removing the optional early phase-in of Tier 4 standards for LMDVs with a gross vehicle weight rating of more than 6,000 pounds from MYs 2027 and 2028.
The agency also proposes to delay changes to the test protocols for emissions performance certification evaluations to MY 2029.
In Part 2, EPA will reconsider the Tier 4 Rule for LMDVs, which may include changing emission standards, lead time and phase-in schedules, and test procedures.
Public comments are due by July 6, 2026 (Docket ID No. EPA–HQ–OAR–2025–3297).
Key to remember: EPA has issued a series of proposed rules that, if finalized, may have significant regulatory impacts on power plant wastewater, pre-construction air permits, and vehicle emission requirements.
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2026-05-14T05:00:00Z
MACT emission standards: 7 questions answered
Standards are more than just suggestions when it comes to environmental regulations; they define the minimum level of performance that must be achieved and, as a result, determine who complies and who doesn’t. For industrial facilities that release air toxics, emission standards are foundational to compliance.
The Environmental Protection Agency (EPA) controls the release of more than 180 air toxics, known as hazardous air pollutants (HAPs), from industrial sources (such as factories and refineries) through the National Emission Standards for Hazardous Air Pollutants (NESHAP) program. For major sources, EPA develops maximum achievable control technology (MACT) standards to reduce HAP emissions.
Understanding the basics of MACT standards can help you navigate the requirements specific to your facility. Here’s what you need to know.
What’s a MACT standard?
A MACT standard refers to the specific technology-based requirements set by EPA to control HAP emissions from major sources in a specific industrial source category. The agency bases the standards on the emission levels already being achieved with existing control technologies by the best-controlled and lowest-emitting facilities in an industry.
What’s a MACT floor?
MACT floors are the minimum control levels that regulated facilities must meet. EPA sets MACT floors differently for new and existing facilities:
- The MACT floors for new facilities must be at least as stringent as the emission control achieved by the best-controlled similar source.
- The MACT floors for existing facilities (which may be less stringent than the floors for new sources) have to be at least as strict as the average emission limitation achieved by either:
- The top-performing 12 percent of sources in a category or subcategory with 30 or more sources, or
- The top-performing 5 sources in a category or subcategory with fewer than 30 sources.
Keep in mind that EPA may establish requirements stricter than the MACT floor, known as “beyond-the-floor” standards.
What types of facilities are subject to MACT standards?
MACT standards generally apply to major sources of HAP emissions. A facility is considered a major source if it emits or has the potential to emit:
- 10 tons per year (tpy) of any one HAP, or
- 25 tpy of any combination of HAPs.
How are MACT standards organized?
EPA develops MACT standards by industry sector and publishes them as part of the NESHAP regulations. Most of the rules appear under 40 CFR Part 63, organized by subparts based on source category. Facilities must identify their source category to determine which NESHAP subpart applies.
A limited number of the rules are found under Part 61, organized by subparts based on specific HAPs (such as vinyl chloride) or activities (like asbestos demolition). Facilities need to confirm whether any of the NESHAPs for specific HAPs or activities apply.
How are MACT standards enforced?
The air permitting authority (usually a state or local air agency) incorporates applicable NESHAP requirements, including MACT standards, into a facility’s Title V operating permit.
What do MACT standards cover?
MACT standards can include a combination of measures, methods, processes, systems, and techniques to reduce or eliminate HAP emissions. Examples include:
- Conducting process changes;
- Substituting materials;
- Enclosing systems or processes; and
- Collecting, capturing, and/or treating HAP releases from emission points.
MACT standards may also contain design, equipment, work practice, and operation requirements.
Can MACT standards change?
Yes. The Clean Air Act requires EPA to evaluate MACT standards every 8 years (known as a risk and technology review). The agency will revise MACT standards when it determines improvements in technologies, practices, processes, or other emission-reduction methods warrant revisions.
Real-world example
Let’s take a look at the NESHAP for Polyether Polyols (PEPO) Production (PEPO NESHAP), recently updated in March 2026.
The MACT standards that apply to the PEPO NESHAP (Part 63 Subpart PPP) include:
- Emission limits for process vents;
- Equipment and work practice requirements for storage vessels, wastewater, and equipment leaks; and
- Work practice standards for heat exchange systems.
EPA concluded that improvements in controls warranted updates to specific MACT standards in the PEPO NESHAP, including for heat exchange systems. Specifically, the revised rule requires owners and operators of existing and new heat exchange systems in organic HAP service to:
- Conduct quarterly monitoring using the Modified El Paso Method (also known as the Air Stripping Method), and
- Repair leaks of total strippable hydrocarbon concentration (as methane) in the stripping gas of 6.2 parts per million by volume or greater.
The agency found that the Modified El Paso Method is more effective at identifying leaks, and it measures more compounds than previously required methods. As a result, this revised MACT standard will further reduce HAP emissions from heat exchange systems.
Key to remember: EPA controls hazardous air pollutant emissions from major sources through MACT standards based on the emission levels already achieved by the best-controlled facilities in an industry.
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EHS Monthly Round Up - April 2026
In this April 2026 roundup video, we’ll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
OSHA revised its National Emphasis Program on heat-related hazards. Going forward, the agency will prioritize inspections in 55 high-risk industries in indoor and outdoor work settings. The program remains in effect for 5 years from its April 10 effective date.
An OSHA proposed rule seeks to eliminate the November 18, 2036, deadline in the Walking-Working Surfaces standard that would require all fixed ladders extending more than 24 feet above a lower level to be equipped with personal fall arrest systems or ladder safety systems. OSHA also seeks feedback on nine specific questions related to the proposal, with comments due on June 5.
On April 17, OSHA revoked its House Falls in Marine Terminals standard at 1917.41. The agency said that because most cargo has been containerized and is moved by cranes, the standard is no longer necessary to protect employees.
Turning to environmental news, an EPA final rule further delays the submission period for the one-time PFAS report required of manufacturers. It pushes the start of the submission period to either 60 days after the effective date of a future final rule updating the PFAS Reporting Rule or January 31, 2027, whichever comes first.
An EPA final rule makes technical changes to the emission standards established in March 2024 for crude oil and natural gas facilities. The changes take effect June 8.
EPA published the draft 6th Contaminant Candidate List for the next group of contaminants to be considered for regulation under the Safe Drinking Water Act. The proposed list designates microplastics and pharmaceuticals as priority contaminant groups for the first time.
And finally, EPA plans to make significant changes to coal combustion residuals requirements. A proposed rule published April 13 would revise the regulations governing the disposal of coal combustion residuals in landfills and surface impoundments, as well as the beneficial use of coal combustion residuals.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
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EHS Monthly Round Up - February 2026
In this Februrary 2026 roundup video, we'll discuss the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
Fatal work injuries fell 4 percent in 2024, largely due to a decline in workplace drug- and alcohol-related overdoses. According to the Bureau of Labor Statistics, overdose fatalities fell from 512 in 2023 to 410 in 2024. Across all types of workplace incidents, there were 5,070 fatal work injuries in 2024, compared to 5,283 in 2023. Transportation incidents continue to be the most frequent type of fatal event, accounting for over 38 percent of all occupational fatalities in 2024.
OSHA is fast-tracking a proposal to remove the 2036 obligation to upgrade fall protection systems on fixed ladders that extend over 24 feet. This follows an industry petition from major chemical and petroleum industry groups, which argue the provision is unjustified, costly, and not supported by the rulemaking record. OSHA frames the upcoming proposed action as deregulatory, allowing employers to update fixed ladders at the end of their service lives. We’ll provide updates as more information becomes available.
As OSHA leans into “deregulatory” actions, lawmakers are moving to pressure the agency to issue “regulatory” rulemaking to protect American workers. The latest legislative wave of bills aims to fill regulatory gaps, tackle emerging hazards, expand OSHA authority, and raise penalties. Topics addressed by these bills include musculoskeletal disorders, heat stress, infectious diseases, wildfire smoke, and workplace violence.
In a recently issued letter of interpretation, OSHA states that a burn injury caused by a personal lithium-ion battery fire is work related if it occurs in the workplace during assigned working hours. The letter details an incident where an employee was burned when their rechargeable lithium-ion batteries for e-cigarettes sparked a fire after coming into contact with a key used for work.
A new report from the Department of Labor Office of Inspector General concludes that OSHA struggles to meet its mission, particularly in high-risk industries like healthcare, construction, and manufacturing. Several pages point to OSHA’s difficulties in effectively enforcing annual injury and illness reporting requirements, reaching the nation’s high-risk worksites for inspection, and addressing workplace violence by regulatory or other action.
Turning to environmental news, EPA extended the deadlines for Facility Evaluation Reports and related requirements for coal combustion residuals facilities. In most instances, the deadlines have been moved one or two years out.
And finally, EPA announced a final rule eliminating the 2009 Endangerment Finding and related greenhouse gas emission requirements for on-highway vehicles and vehicle engines. When the final rule takes effect, manufacturers and importers of new motor vehicles and motor vehicle engines will no longer have to measure, report, certify, or comply with federal greenhouse gas emission standards.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
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EHS Monthly Round Up - March 2026
In this March 2026 roundup video, we'll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
OSHA released an updated Job Safety and Health poster. Employers can use either the revised version or the older one, but the poster must be displayed in a conspicuous place where workers can easily see it.
OSHA recently removed a link from its Data topic webpage that displayed a list of “high-penalty cases” at or over $40,000 since 2015. The agency says it discontinued and removed it in December. The data is frozen and archived elsewhere.
OSHA published two new resources as part of its newly launched Safety Champions Program. The fact sheet provides an overview of how the program works, eligibility criteria, and key benefits. The step-by-step guide helps businesses navigate the core elements of OSHA’s Recommended Practices for Safety and Health Programs.
Several forces are nudging OSHA to address a number of workplace hazards and high-hazard industries. This comes from other agencies, safety organizations, watchdogs, legislative proposals, and persistent injury/fatality data. Among the hazards are combustible dust; first aid; personal protective equipment; and workplace violence. How all this translates into new regulations, guidance, programmed inspections, or other initiatives remains to be seen.
Turning to environmental news, EPA issued a proposed rule to require waste handlers to use electronic manifests to track all RCRA hazardous waste shipments. Stakeholders have until May 4 to comment on the proposal.
On March 10, EPA finalized stronger emission limits for new and existing large municipal waste combustors and made other changes to related standards.
And finally, EPA temporarily extended coverage under the 2021 Multi-Sector General Permit for industrial stormwater discharges until the agency issues a new general permit. The permit expired February 28 and remains in effect for facilities previously covered. EPA won’t take enforcement action against new facilities for unpermitted stormwater discharges if the facilities meet specific conditions.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
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2026-05-26T05:00:00Z
OSHA packs new HazCom directive with enforcement clues
The first compliance date for the amended Hazard Communication (HazCom) standard has arrived, and OSHA finally issued its updated directive. The CPL instructs OSHA officers on how to conduct inspections and issue citations under the standard. However, it also provides chemical manufacturers, importers, distributors, and employers with insight into what officers will be assessing.
In effect, this CPL translates regulatory text into inspector expectations. It shows what adherence to the standard looks like in practice. That makes it a critical resource given recent and upcoming dates at 29 CFR 1910.1200(j).
CPL rewritten for the 2024 standard
On May 19, 2026, OSHA posted a revised CPL 02-02-079, “Inspection Procedures for the Hazard Communication Standard (HCS 2024),” replacing the July 9, 2015, version. The 132-page document reflects the reconfigured HazCom standard published May 20, 2024, effective on July 19, 2024, along with corrections issued through early 2026.
The agency designed this enforcement playbook to maintain uniform inspections during the transition period and after full implementation. Because of the extensive regulatory changes to definitions, hazard classification, labeling, safety data sheets, and trade secrets, the CPL is not a light refresh.
For those familiar with the rulemaking, the new CPL edits will not be surprising. Still, the directive should provide more clarity than the regulatory text.
Front matter and appendices
Updates to Sections I to IX are typical of a CPL, including:
- Cancellation of the 2015 CPL;
- A modified title and references to the 2024 final rule and corrections;
- Alignment with revisions 7 and 8 of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS); and
- A new summary of changes, historical background, and compliance dates.
OSHA also modernized appendices for dates, hazard lists, pictogram hazards, SDS review guidance, chemical resources, and related directives.
Reworked inspection guidelines
Section X outlines inspector instructions for paragraphs (b) through (j) of the standard. The latest modifications impact most sections:
- Scope, applicability, and exemptions — The directive offers new examples and expanded explanations, such as:
- A formaldehyde hazard example for hair smoothing products;
- An overview of pesticide labeling requirements and exemptions;
- Discussion of the EPA Agricultural Worker Protection standard preemption; and
- Greater detail about biological hazards from plants.
- Definitions — The document introduces terms and explains bulk shipment, immediate outer package, physical hazard, released for shipment, and more. It also revisits the terms combustible dust and manufacturer. Lithium-ion batteries are now referenced in the distributor context.
- Hazard classification — The directive instructs OSHA officers to consider the classification of:
- Hazards associated with a chemical’s intrinsic properties, including changes in physical form and reactions from known or reasonably anticipated uses; and
- Impurities, additives, and individual constituents.
- Written plan — The directive clarifies:
- Employers must revise programs by the compliance dates when new information is received from suppliers;
- The use of computers and third-party administrators of safety data sheets (SDSs); and
- The written program must describe how employees will be trained in a language and at a literacy level they understand.
- Labeling — The directive broadens the sections on Department of Transportation labeling, bulk shipments, and small container labeling. It incorporates final rule flexibility too:
- Phased-in compliance dates for labeling;
- Hazards not otherwise classified (HNOCs) and hazards identified and classified under 1910.1200(d)(1)(ii) don’t need to be addressed on the container;
- The exclamation mark pictogram is permitted (but not required) for HNOCs, under certain conditions;
- Minor textual variations for precautionary statements are allowed; and
- OSHA offers alternatives for chemical containers released for shipment.
- Safety data sheets (SDSs) — Amended text focuses on U.S. jurisdiction and technical provisions, such as:
- Phased-in compliance dates for SDSs;
- Importer SDS responsibilities;
- Using a U.S. address and phone number;
- The hazard class and category reflecting intrinsic properties;
- Required Chemical Abstracts Service (CAS) number or other unique identifiers; and
- No need to obtain updated SDSs to replace already received SDSs.
- Employee information/training — The directive references a temporary workers bulletin. It also emphasizes:
- Phased-in compliance dates for necessary training adjustments; and
- Delivering training in a language employees understand.
- Trade secrets — The instruction aligns with the 2024 rule:
- Allows the exact percentage, exact concentration range, or CAS number to be withheld if certain criteria are met; and
- Addresses the use of confidentiality agreements.
- Dates — The directive overhauls compliance timelines and discusses documentation of due diligence and good faith efforts.
In addition, the directive softens citation language with phrases like “should normally cite” instead of “shall cite.” This shift suggests inspectors may have greater discretion based on case-specific circumstances.
Key to remember
While 1910.1200 remains the baseline for employers and chemical manufacturers, importers, and distributors, the revised CPL 02-02-079 provides an enforcement lens. With implementation underway, regulated entities can use the CPL to steer their efforts and conform with how OSHA will inspect them in the field.
NewsIndustry NewsSafety & HealthGeneral Industry SafetyIndoor Air QualityIndustrial HygieneCAA ComplianceEnvironmentalIn-Depth ArticleEnglishFocus AreaUSA
2026-05-22T05:00:00Z
Where workplace exposure meets air permitting: Bridging OSHA industrial hygiene and EPA air programs
Air quality inside a facility and emissions leaving a stack are closely linked. The same chemicals that drive occupational exposure limits under the Occupational Safety and Health Administration (OSHA) often form the basis of regulated air pollutants under the Environmental Protection Agency's (EPA's) programs.
When industrial hygiene (IH) and environmental compliance teams work together, they can spot risks sooner, strengthen controls, and avoid surprises in permits or inspections. The overlap is practical. Worker exposure data can inform stack testing, and permit conditions can signal where IH monitoring should focus.
Shared chemistry, different lenses
Both programs start with the same substances, such as solvents, metals, acids, and combustion byproducts. IH focuses on what workers breathe in the workplace. It uses exposure limits such as OSHA permissible exposure limits or more protective guidelines from the National Institute for Occupational Safety and Health (NIOSH) and the American Conference of Governmental Industrial Hygienists (ACGIH). Environmental air programs focus on what leaves the property. They regulate criteria pollutants, hazardous air pollutants (HAPs), and toxics using emission limits, control requirements, and reporting rules.
The data tools look similar. IH uses personal and area sampling, direct-reading instruments, and task-based assessments. Environmental programs use emission factors, mass balance, continuous monitoring, and periodic stack testing. Both require documentation, quality control, and records.
Key differences that matter
The point of exposure is the biggest difference. IH evaluates the breathing zone of a worker during a task or shift. Environmental programs measure emissions at a release point, such as a stack, or estimate them across the site.
The time frame also differs. IH often looks at short-term peaks and full-shift averages to protect health during work. Air permits may set hourly, daily, or annual limits, and they may cap total emissions per year. Control strategies follow these goals. IH may rely on local exhaust ventilation, enclosure, or work practice changes. Air permits may require add-on controls such as thermal oxidizers, scrubbers, or filters.
Practical crossover: Using IH to inform permitting
IH data can reveal which tasks generate the highest concentrations and which compounds dominate exposure. That insight can refine emission estimates. For example, if wipe cleaning with a solvent produces the highest worker exposure, the same solvent may drive facility-wide volatile organic compound (VOC) emissions. The environmental team can use that knowledge to prioritize accurate emission factors, refine mass balance, or plan stack testing during peak operations.
IH data also helps define realistic operating scenarios for compliance testing. Stack tests that occur only at typical loads may miss worst-case conditions. Pairing test timing with identified peak tasks can provide a more representative test and reduce the risk of later noncompliance.
Practical crossover: Using permits to inform IH
Air permits define regulated compounds, control devices, and operating limits. These details can guide IH planning. If a permit lists specific HAPs or requires a control device for a process, there's a clear signal that exposure to those compounds is possible near the source. IH can target those areas for baseline sampling, validate control performance, and confirm that capture systems are effective where workers are present.
Permit conditions also flag upset and startup modes. These periods can increase emissions. IH can align monitoring during these windows to assess short-term exposures and ensure that work practices and protective measures are adequate.
Aligning controls for dual benefit
Engineering controls can serve both goals when designed as a system. Capture at the source reduces worker exposure and lowers emissions to the stack. Good enclosure and balanced ventilation improve control efficiency and reduce fugitive releases. Preventive maintenance on control devices supports permit limits and keeps workplace air clean.
Administrative controls can align as well. Standard operating procedures can link production rates, control device settings, and ventilation checks. Change management should include both an IH review and an air permitting check to see if a modification triggers a permit update.
Communication and workflows
Successful crossover depends on routine communication. Regular meetings enable safety and environmental staff to share results, plan sampling, and coordinate testing windows. Shared inventories of chemicals and processes reduce duplication and errors. A common data platform, or at least a consistent file structure, makes it easier to compare IH results with emission estimates and permit limits.
Clear triggers help teams act. Examples include a new chemical introduction, a process change, a spike in IH results, or a deviation in control device performance. Each trigger should prompt both an IH review and an environmental compliance check.
Key to remember: When teams connect their data and plans, they gain a clearer picture of risk. The results are stronger compliance, better worker protection, and more efficient operations.
NewsWater PermittingChange NoticesChange NoticeWater ProgramsWater QualityWater ReportingFloridaEnvironmentalWater ProgramsEnglishFocus AreaCWA Compliance
2025-12-02T06:00:00Z
Florida allows reciprocity for water system operator licensing
Effective date: November 6, 2025
This rule applies to: Out-of-state licensed treatment plant operators and distribution system operators
Description of change: The Florida Department of Environmental Protection adopted rules to:
- Implement licensure reciprocity, allowing the department to issue licenses by reciprocity to water treatment, domestic water treatment, and water distribution system operators with out-of-state licenses; and
- Allow the department to issue temporary operator licenses during a declared state of emergency to out-of-state licensed treatment plant and distribution system operators during a declared state of emergency.
NewsIndustry NewsIndustry NewsToxic Substances Control Act - EPAToxic Subtances Control Act - EPATSCA ComplianceToxic Substances - EPAEnvironmental Protection Agency (EPA)EnvironmentalEnglishFocus AreaUSA
2025-08-15T05:00:00Z
EPA releases July 2025 TSCA Inventory
On August 14, 2025, the Environmental Protection Agency (EPA) released the biannual update to the nonconfidential Toxic Substances Control Act (TSCA) Chemical Substance Inventory (TSCA Inventory). The inventory includes all TSCA-regulated chemical substances manufactured, processed, or imported in the U.S.
The July 2025 TSCA Inventory contains 86,862 chemicals, adding 15 chemical substances since the last update. Nearly half of the substances (42,578) are active (i.e., in use). EPA also updated:
- Commercial activity data,
- Unique identifier data, and
- Regulatory flags (which identify substances with manufacturing or use restrictions as well as substances with full or partial reporting exemptions).
Further, the agency updated the TSCA Master Inventory File. It includes chemical identity information claimed as confidential that’s excluded from the nonconfidential TSCA Inventory. The TSCA Master Inventory File is the only list with comprehensive, authoritative information about which chemical substances are on the inventory.
The agency plans to make the next inventory update in Winter 2026.
How do I access the inventory?
View the TSCA Inventory by:
- Downloading the Microsoft Access or CSV text version of the data from EPA’s website, or
- Using EPA’s Substance Registry Services (SRS).
How does this impact my business?
The TSCA Inventory helps facilities determine compliance requirements for chemicals they (a) manufacture or use or (b) plan to manufacture or use. Chemicals that are on the TSCA Inventory are likely subject to rules, like manufacturing limits and reporting requirements. Chemicals that aren’t on the list must meet notification and review requirements before they can be used.
Key to remember: EPA released the July 2025 nonconfidential TSCA Inventory of chemical substances manufactured, processed, or imported in the U.S.
NewsIndustry NewsTSCA ComplianceCAA ComplianceSustainabilityIn-Depth ArticleCWA ComplianceEnvironmentalEnglishSustainabilityESG (Environmental, Social, and Governance)Focus AreaUSA
2025-12-05T06:00:00Z
EPA’s 2026 regulatory shift: How environmental managers can stay ahead
The clock is ticking for environmental teams. By 2026, several new EPA regulations will reshape compliance obligations for U.S. companies. Organizations that act now will avoid costly penalties and operational disruptions.
What’s changing and why it matters
Although EPA has been deregulating or loosening some requirements, there are still some standards being tightened across multiple fronts in the coming year:
- Renewable fuel standards (RFS): The EPA proposed higher volume requirements for 2026, including 24.02 billion renewable identification numbers (RINs), up nearly 8% from 2025. This increase pushes stricter expectations on fuel producers and organizations purchasing renewable fuels.
- Stormwater multi-sector general permit (MSGP): A new MSGP set to take effect by February 2026 will require quarterly PFAS indicator monitoring, expanded benchmark sampling, and resiliency measures in stormwater control designs.
- PFAS Reporting under the Toxic Substances Control Act (TSCA): TSCA Section 8(a)(7) mandates PFAS manufacturing and import data collection beginning in April 2026, through October 2026, with extended deadlines for certain small manufacturers.
Failure to prepare could lead to fines, reputational damage, supply chain disruptions, and permit delays. Companies that weave compliance planning into their 2026 strategy will be positioned not just to meet legal deadlines but to sustain operations smoothly.
Key areas of impact
- Renewable fuel standards (RFS) and air emissions The proposed increase in 2026 Renewable Identification Numbers (RIN) volumes, from 24.02 billion to 24.46 billion for 2027, signals tightening air and fuels policy that affects fuel use and emissions accounting.
- Stormwater management The upcoming 2026 MSGP requires expanded quarterly PFAS monitoring, new benchmark triggers, corrective action plans, and integration of climate resilience in design standards.
- PFAS disclosure (TSCA Section 8(a)(7)) Manufacturers and importers of PFAS must submit electronic reporting of usage, volumes, disposal, and exposure data between April and October 2026, with extensions available for smaller operations.
Steps to take now
- Audit compliance programs: Cross-check operations against RIN inventory, stormwater permits, and TSCA reporting duties.
- Upgrade monitoring and recordkeeping: Implement robust electronic systems to track PFAS, stormwater quality, fuel volumes, and emissions.
- Staff training: Educate teams on PFAS obligations, new stormwater protocols, and RFS structures.
- Engage regulators early: Comment on proposed rules, consult during permit drafting, and flag issues during the notice-and-comment period.
Looking ahead
The EPA’s 2026 updates reflect a trend toward increased transparency and environmental accountability. Companies that treat compliance as strategic will not only avoid enforcement but also gain resilience and stakeholder trust.
Key to remember: Start planning now. Early action on EPA rule changes will save time, money, and headaches when enforcement begins.
NewsAir QualityIndustry NewsEnvironmental Protection Agency (EPA)CAA ComplianceEnvironmentalIn-Depth ArticleFocus AreaEnglishAir PermittingAir ProgramsStationary Emission SourcesUSA
2025-09-25T05:00:00Z
Pre-preconstruction permits: Can building begin without one?
Just like blueprints, hard hats, and scaffolding, permits are synonymous with construction. Most businesses have to get permits before breaking ground on a project. However, recent federal guidance on preconstruction permits for air emissions indicates that some construction activities may be able to start without a permit.
The Environmental Protection Agency (EPA) requires businesses to obtain a preconstruction permit for a new facility or major modifications to an existing facility before starting construction. It ensures that new or modified facilities will be able to comply with air emissions requirements. In September 2025, the agency published guidance (in the form of a response letter), determining that a company may start construction activities on parts of a new facility unrelated to air emissions before obtaining a permit.
Let’s take a look at the preconstruction permit regulations, the facts of the case in the guidance, and EPA’s plans to clarify which construction activities can begin before obtaining a preconstruction permit.
What are the preconstruction permit requirements?
Under the New Source Review (NSR) regulations (40 CFR Part 51 Subpart I and Part 52 Subpart A), businesses that build a new facility or make major modifications to an existing one have to obtain a preconstruction permit to “begin actual construction.” EPA defines “begin actual construction” as “physical on-site construction activities on an emissions unit which are of a permanent nature.” It covers activities including (but not limited to) installing building supports and foundations, laying underground pipework, and constructing permanent storage structures.
There are three types of preconstruction permits: Prevention of Significant Deterioration (PSD) permits, nonattainment NSR permits, and minor source permits. The permits define:
- What construction is allowed,
- Emissions limits, and
- How the source must be operated (if applicable).
It’s important to note that most preconstruction permits are issued at the state or local levels. The requirements must be at least as stringent as EPA’s.
What’s the case?
A county air quality district in Arizona asked EPA to assess whether it may allow a company to start the first phase of construction on a semiconductor manufacturing facility before obtaining an NSR permit if no emissions units are involved.
EPA answered the request with TSMC Arizona Begin Actual Construction — EPA Response Letter (September 2, 2025) and published the letter as new guidance.
Facts of the case
The company builds its facilities in three phases and doesn’t install the semiconductor manufacturing equipment until all phases are complete.
The first phase of construction consists of building the core and shell of the facility, which includes the foundation, a steel superstructure, and external walls. The building will eventually house emissions units (semiconductor manufacturing equipment). However, the company stated that the first phase of construction doesn’t involve any air pollution control devices, emissions units, or foundations for emissions units.
The county air quality district agreed that if a structure contains no emissions unit, it’s not subject to NSR permitting because it doesn’t emit or have the potential to emit pollutants.
EPA response to the case
In the September 2025 response letter, EPA recognized that the definition of “begin actual construction” prohibits on-site construction of an emissions unit without a permit, but it doesn’t prohibit on-site construction of the parts of a facility that don’t qualify as an emissions unit.
The agency determined that the county air quality district may allow the company to start the first phase of construction (even if it’s of a permanent nature) before it obtains an NSR permit as long as it doesn’t involve construction on an emissions unit.
What are EPA’s regulatory plans?
The agency will conduct rulemaking to clarify what construction activities need an NSR permit and what construction activities can proceed without one. It plans to amend the NSR regulations in 2026 by:
- Revising the definition of “begin actual construction," and
- Establishing how permitting authorities may distinguish parts of a facility that are and aren’t emissions units or parts of emissions units.
Until then, EPA will address preconstruction permitting issues on a case-by-case basis.
How should facilities respond?
If you’re planning to build a new facility or make a major modification to one, consider these tips to help you comply with the NSR regulations:
- Check whether the state and local requirements are the same as or stricter than federal rules. The state environmental department’s website is a good place to start.
- Contact the permit-issuing agency (likely the state or local air pollution control agency) for direct help with your specific project.
- Watch EPA news announcements for updates on rulemaking. You can also track the Federal Register, where the agency publishes proposed and final rules.
Key to remember: EPA plans to conduct rulemaking to help distinguish which construction activities need a preconstruction permit for air emissions and which activities don’t.
Most Popular Highlights In Transportation
NewsIndustry NewsFleet SafetyTrainingTrainingTraining & DevelopmentFocus AreaIn-Depth ArticleUSAEnglishTransportationHuman Resources
2026-05-26T05:00:00Z
From orientation to on-road excellence: Build a training program that delivers results
Effective driver training programs are not built on ride-alongs alone. They are built on structure, consistency, and measurable outcomes. Carriers that develop a formal, written approach to training create a program that is repeatable, defensible in an audit, and capable of producing safe, professional drivers over time. Here’s how they do it.
Start with written policies that define the trainers’ roles and goals
Every trainer should operate from a clear policy that outlines expectations. This includes the trainer’s responsibility to model compliant behavior, document progress, and coach drivers. Goals should be specific and measurable, such as ensuring learners demonstrate proficiency in pre-trip inspections, hours-of-service (HOS) compliance, backing maneuvers, and defensive driving techniques. When trainer expectations are written and standardized, the carrier reduces inconsistency and ensures every learner receives the same level of instruction.
Build written program guidelines that define how training is delivered
A strong program includes documented procedures for each phase of training. This should cover classroom instruction, yard skills, and on-road driving. Guidelines should define required skills demonstrations, and the sequence in which training occurs. They should also clearly distinguish between observation, supervised practice, and independent performance. This structure ensures that training is not rushed and that drivers build skills progressively rather than being pushed through to fill seats.
Establish clear written criteria for driver certification
Certification should not be based on time alone. It should require demonstrated competency. Written guidelines should define what a driver must do to be released, such as completing a compliant pre-trip inspection without assistance, maintaining lane control and proper following distance, executing safe backing maneuvers, and adhering to company policies. Documentation should support each certification decision, creating a record that the driver met objective standards.
Adapt training as hiring criteria evolve
As hiring standards shift, training must be adjusted accordingly. Less experienced drivers require more foundational instruction, longer training periods, and greater emphasis on basic vehicle control and compliance habits. Experienced hires may need shorter programs focused on company-specific policies and correcting bad habits. A training program will fail if it does not reflect the actual skill level of incoming drivers.
Measure results beyond program completion
Completing training does not equal success. Carriers need a system to evaluate whether training is effective in the real world. This includes tracking key performance indicators such as preventable accidents, roadside inspection violations, HOS compliance errors, and telematics data (speeding, hard braking, lane control). These metrics should be tied back to individual drivers and training to identify trends.
Define what “good” looks like and measure behavior in the field
Drivers need clear expectations. Define “good” in observable terms such as consistent mirror usage, proper following distance, smooth braking, accurate log entries, and thorough inspections. Follow-alongs or ride-alongs can then be used to verify these behaviors in real operating conditions. These evaluations should be structured with scorecards or checklists to ensure consistency and provide objective feedback.
Continuously improve trainers and the program itself
Trainer development is just as important as driver development. Trainer certifications should be reviewed and updated regularly, ensuring trainers stay current on regulations, company policies, and coaching techniques. Additionally, data gathered from driver performance should be fed back into the training program. If certain violations or risky behaviors appear repeatedly, the program should be updated to address those gaps directly.
Key to remember: With written standards, measurable outcomes, and continuous improvement, carriers can move beyond basic compliance and build a program that truly reduces risk and develops professional drivers.
NewsIndustry NewsFleet SafetyRisk Management TransportationRisk Management - Motor CarrierFocus AreaIn-Depth ArticleFleet OperationsEnglishTransportationUSA
2026-05-28T05:00:00Z
5 keys to being a defendable motor carrier
Becoming a defendable motor carrier requires disciplined execution in a few critical areas:
- Accident response,
- Documentation,
- Driver performance management, and
- Compliance.
The goal is simple—reduce risk and clearly demonstrate that your company takes safety seriously. This starts with the top leadership in the organization.
1. Create a strong accident response and investigation
The first step after a crash is getting the right information — fast. After a crash, safety comes first, followed immediately by collecting accurate, unbiased data. Engage legal counsel immediately if the crash severity indicates potential litigation.
Capture photos, vehicle positions, roadway conditions, and witness statements while details are fresh. Preserve electronic data like dash cam footage, electronic logging device (ELD) records, and telematics immediately.
Also, ensure someone qualified gathers scene data—whether that’s the driver, a safety employee, or preferably an insurance adjuster or accident reconstructionist. Without timely evidence, later investigation becomes guesswork.
2. Build a complete evidence file
A defendable carrier backs up its position with documentation. Also, examining all evidence provides a complete picture of potential liability, even if the facts show carrier or driver actions or inaction contributed to the crash.
After the crash, gather:
- Police and inspection reports,
- Dash cam footage from the carrier’s vehicle and other vehicles,
- Traffic or other structure camera footage,
- Driver logs and communication records,
- Maintenance and inspection records,
- Electronic control module data, and
- DOT drug/alcohol test results.
Just as important as collecting the data is protecting it. Maintain secure storage and a clear chain of custody to avoid questions about data integrity. As appropriate, place items like a driver’s cell phone under attorney-client privilege.
3. Focus on avoiding crashes and unsafe or illegal behavior
As an ongoing part of the safety program, reduce unsafe or illegal driver behavior through proactive coaching, retraining, or discipline. At the same time, evaluate company policies, procedures, and operational pressures that may contribute to crashes or unsafe behavior. Make appropriate adjustments to enhance safety management controls.
Consistency in following a progressive discipline and training policies is critical. If a policy says a violation leads to termination, failing to follow through can create major retention risk. Document decisions and follow the established processes. Exceptions to policies weakens a carrier’s defense.
Use data from dash cams and telematics to identify high-risk behaviors like speeding, distraction/cell phone use, lack of seat belt use, or following too closely. Focus coaching on illegal behavior or those most likely to result in crashes or injuries.
Equally important—balance correction with recognition. Reinforcing positive behavior builds driver buy-in and strengthens a carrier's safety culture.
4. Establish clear policies and enforce them
Policies are where you define expectations and prove your commitment to safety.
Strong policies should:
- Define acceptable and unacceptable behaviors,
- Outline training and corrective action processes,
- Ensure consistent enforcement with minimal exceptions, and
- Address privacy and data use (especially with cameras).
Regularly review, update, and document all policy changes and training.
5. Ensure leadership support
A defendable carrier starts with the top leadership who must prioritize safety over productivity and support it with resources, technology, and accountability.
Every department’s leadership—not just the safety director—must share responsibility for safe operations.
Keys to remember: A defendable carrier isn’t defined by whether accidents happen, but by how the company prepares, responds, and improves. Strong processes to collect evidence and demonstrate consistent actions to avoid crashes make all the difference.
NewsIndustry NewsHazmat PlacardingHazmat SafetyExpert InsightsFocus AreaHazmat markings, Placards, and LabelsEnglishTransportationUSA
2026-05-22T05:00:00Z
Expert Insights: Common hazmat placarding mistakes
Placards are one of the most visible parts of hazmat compliance. Anyone on the road can see them, including drivers, enforcement officials, and emergency responders. Because of that visibility, most people I talk to assume that placarding is simple. In reality, it’s one of the areas where small oversights show up fast and can create major compliance issues.
In my experience, most violations don’t come from a lack of effort. They usually come from assumptions, habits, or misunderstandings about how the rules apply in real-world operations. When I take a closer look at placarding issues, the same patterns tend to show up. Once you start recognizing those patterns, it becomes a lot easier to catch issues early and avoid problems during inspections or incidents.
Using the wrong placard or using it at the wrong time
One of the most common mistakes I see is using a placard that doesn’t match the material being transported. This usually happens when someone relies on memory instead of verifying the hazard class, or when subsidiary risks get overlooked. Even experienced employees fall into this habit when things start moving too fast.
I also see situations where the placard is technically correct but used at the wrong time. A placard might be left on from a previous load or put on in anticipation of a future shipment. Placards aren’t general warnings. They need to reflect exactly what’s in the vehicle at that moment.
Failing to remove placards
Another issue I run into a lot is failing to remove placards when the hazard is no longer present. This tends to happen when equipment is reused frequently or when operations are trying to keep things moving. It may seem like a small detail, but it creates real risk.
If a placard is displayed, responders are going to assume the hazard is there. That can impact how they respond in an emergency and lead to unnecessary precautions. From a compliance perspective, displaying a placard that doesn’t match the contents of the vehicle is a violation and usually draws unwanted attention during inspections.
Misunderstanding when placards are required
Placarding decisions aren’t always straightforward, especially when packaging types and quantities vary. I usually see teams assume that placards are always required any time hazmat is present. That approach can lead to over-placarding and send the wrong message.
On the other side, I also see required placards get missed because quantities aren’t evaluated correctly. Smaller packages can still trigger placarding when they’re combined. Taking a few extra minutes to verify packaging type and total quantity can make all the difference.
Placement and visibility issues
Even when the right placards are selected, they’re not always displayed properly. Placards need to be clearly visible and in good condition, but this is something I see get overlooked in day-to-day operations. Dirt, damage, and equipment can all block or reduce visibility.
If a placard can’t be easily seen, it’s not doing its job. I always recommend building placement and condition checks into routine inspections, not just focusing on whether the correct placard was chosen. This becomes even more important in environments where equipment sees heavy use.
What this means in the real world
When I look at placarding overall, I don’t see it as just a basic requirement. It’s a real-time communication tool that people rely on to make decisions. Every incorrect, missing, or unnecessary placard sends the wrong message and increases risk.
The good news is that most of these mistakes are preventable. Clear procedures, consistent training, and routine checks go a long way. When teams start treating placarding as an active part of hazard communication instead of just another requirement, I see better decisions and fewer mistakes.
NewsIndustry NewsOn-duty time - Motor CarrierFleet SafetyHours of ServiceRisk Management TransportationRisk Management - Motor CarrierFocus AreaIn-Depth ArticleFleet OperationsEnglishTransportationUSA
2022-12-15T06:00:00Z
6 Yard Move FAQs – Need-to-know answers for carriers and drivers
A “yard move” (YM) is an electronic logging device (ELD) special driving category, which carriers have the option to authorize. Putting an ELD in the YM status can give a yard or road driver added flexibility or another avenue for falsification.
To avoid violations and increased risk, ensure that your drivers, dispatchers, and safety personnel know the answers to these frequently asked questions (FAQs).
1. What falls under the definition of a “yard”?
The Federal Motor Carrier Safety Administration (FMCSA) does not officially define a yard. Still, it is generally accepted an area that is not open to public travel due to being restricted by signs or gates.
A carrier’s terminal, a customer’s facility, or a rail yard can be a yard if the area cannot be defined as a highway per 390.5. A driver may also cross a public road to reach another part of private property under yard-move time if traffic controls (i.e., flagger) for the public are in place.
Malls, truck stops, and parking lots the public can access, however, are all examples of places that cannot be a yard for ELD and on-duty (not driving) purposes.
2. Is a yard driver subject to federal regulations?
Commercial motor vehicles (CMVs) are federally regulated at 10,001 pounds or greater — rated or actual, alone or in combination with a trailer. State definitions of a CMV vary.
Suppose a yard truck met the definition of a CMV and operates in an area open to public travel in interstate commerce. In that case, the yard driver must be qualified under Part 391 and is subject to all other applicable federal regulations. If the yard truck and trailer meet the definition of a CDL vehicle in 383.5 as most do, the driver is also subject to drug and alcohol testing and CDL requirements.
Yard drivers might not be required by their carrier to use an ELD to create a log. They are stillsubject to the hours-of-service limits in 395.3 and the same rules for on-duty (not driving) time in a yard or on-duty driving (Line-3) on a public roadway.
A carrier may allow the use of a time record instead of an ELD to track a yard driver’s time under the 150 air-mile exception in 395.1(e). If the yard driver uses an ELD, the carrier can designate the driver as “Exempt” (exempt from grid logs only) in the ELD back-office system.
3. How is a yard move recorded on an ELD?
YM time is visible in the ELD grid as driving time with a dashed or dotted line. Before using YM time, the driver must select the “YM” special driving category and annotate the ELD record describing the reason for the activity.
According to federal hours-of-service rules, a driver cannot use “Line-3” or on-duty driving time after 14 consecutive hours from the start of on-duty time for the day. However, yard moves are recorded as “Line-4 time” or on-duty not (driving) time. Therefore, YM time doesn’t stop the 14-hour clock, but can be appropriately used beyond the 14-hour or other driving limits.
4. Does a yard move count toward the 30-minute break from eight total hours of on-duty driving?
Yes. Because a YM is on-duty (not driving), it counts toward the 30-consecutive minute break from on-duty driving required after eight total hours of on-duty driving. (see 395.3(a)(3))However, if a driver is involved in a fatigue-related crash, driving in a yard to satisfy a break from driving requirement will not look prudent to a jury.
5. What if a driver forgets to change the driving status, and the ELD remains in YM-status after they leave the yard?
The time will be incorrectly captured as Yard Move (on-duty yard time rather than on-duty driving time) and could be considered a false log. To address this, the driver should attach a comment to the log explaining the error as soon as safely possible.
The driver’s log must be manually edited to the correct driving time if the ELD system allows the off-yard time to be changed to on-duty driving time. Otherwise, an annotation must be made noting the correct on-duty (not driving) and on-duty driving time.
6. How are yard moves audited?
Verify the location at the time of the YM with the location description or the longitude and latitude data from the ELD or vehicle tracking device. If the driver was not in a yard at the time of the YM, the driver falsified the record.
A driver using a public road in YM status to get fuel or take the truck in for maintenance is considered falsification. If the driver was over the 11-hour driving limit, 14-consecutive on-duty period, or the 60- or 70-hour limit, they now have an out-of-service violation and a false log.
Carriers can define a geo-fence or virtual boundary of the yard if the system allows that feature to indicate a departure from the yard.
Keys to remember:
Carriers must train their team to understand when the Yard Move status or on-duty (not driving) can and can’t be used when operating a CMV. Audit yard moves to ensure this ELD special driving category, or duty status for drivers on time records, is not used to falsify logs.
NewsIndustry NewsEnglishFleet SafetyDriver qualificationsDriving RecordsFocus AreaIn-Depth ArticleEnforcement - DOTRoadside InspectionsTransportationUSA
2024-01-12T06:00:00Z
Answers to 3 key questions to keep commercial drivers compliant after vision surgery
Options for corrective vision surgery have significantly increased over the past 25 years. Commercial drivers who meet vision standards post-surgery must update their licensing and medical certifications. They must also understand the consequences of inaction.
During a roadside inspection after vision surgery, if the driver's license or medical card states that corrective lenses are required, the driver must prove they are wearing them. If the driver is not wearing glasses or contacts, but the driver's license or medical card still lists them as required, the driver will be cited and placed out of service.
Three key questions
Below are three questions and the answers to which can help avoid citations and out-of-service orders relating to vision requirements.
1. What must a driver do after vision surgery if they no longer require corrective lenses?
Answer: The driver must:
- Take a vision test at the motor vehicle department to have the corrective lenses restriction removed from their license, and
- Contact a certified medical examiner (CME) from the National Registry for an exam to remove the corrective lenses requirement from their medical certification.
The driver may also need to undergo an eye exam from an optometrist or ophthalmologist if requested by the CME.
2. If a medical certification says corrective lenses are required, but the license does not, or vice versa, is this a violation in a roadside inspection?
Answer: Yes. If the driver is not wearing corrective lenses, it is a medical qualification violation per Federal Motor Carrier Safety Administration Regulations (FMCSRs) §391.11(b)(4), and the driver must be placed out of service.
Alternatively, if the license says corrective lenses are required, and the driver is not wearing them, then the citation is written as a licensing violation (§391.11(b)(5) or §383.21(a)(2)), and the driver must also be placed out of service.
3. Is the discrepancy a violation if the driver wears corrective lenses as specified by their medical certification but not on their license?
Answer: No. The violation only exists if the license or the medical certification requires corrective lenses and the driver is not wearing them.
Some states do not use the same criteria for requiring corrective lenses as are specified in the FMCSRs vision standard in §391.41(b)(10), so there's a difference it's not a violation. In many states, it is possible to have a license without the corrective lens restriction and not be able to pass the federal vision standard.
Drivers are usually licensed for more than five years. Vision can change during periods far longer than the maximum two-year medical certification.
Keep in mind, a medical qualification violation cannot be challenged in the FMCSA's DataQs system because "the driver didn't need corrective lenses anymore." Post-surgery, the medical certification, and license must reflect that no corrective lenses are needed, or the driver will face consequences.
Key to remember: Educate drivers on the requirement to update their license and medical certification after corrective vision surgery to keep them compliant.
NewsIndustry NewsIn-Depth ArticleExempt Carrier AuthorityFocus AreaOperating AuthorityFleet OperationsEnglishTransportationUSA
2022-08-31T05:00:00Z
What are exempt for-hire carriers exempt from?
With carriers looking for additional revenue streams, many otherwise private and new carriers wonder whether they can become “exempt” for-hire carriers.
The “exempt for hire” designation is for property carriers that carry certain “exempt commodities,” but do so for compensation. The designation is a holdover from the Interstate Commerce Commission (ICC). Most of the commodities are minimally processed agriculture items, but there’s a fair number of surprises – both in what’s included and what’s not.
The Federal Motor Carrier Safety Administration (FMCSA) provides a relatively short list of items that are not exempt in 49 CFR 372.115. The agency provides a much more robust list of both exempt and non-exempt commodities in Administrative Rule 119.
Exempt carriers are not required to have a motor carrier or MC number designating for-hire authority. However, exempt carriers are required to have a USDOT number. In order to maintain an exempt for-hire status, the carrier must never haul a commodity that is not exempt for compensation.
Do exempt carriers need to have proof of insurance?
Carriers that haul exempt commodities are required to have the minimum level of financial responsibility required by 49 CFR 387, and their insurance provider must provide the carrier with an MCS-90 endorsement. However, the insurance need not be on file with the FMCSA. Many states have insurance requirements both for the amount required and the need to carry proof of coverage in the vehicle. Federally exempt for-hire carriers are not exempted from any state requirement.
Are exempt for-hire carriers required to name process agents?
Currently, exempt-for hire carriers are not required to name process agents for each state of operation as other for-hire carriers are required to do so on the BOC-3 form. That may change when the FMCSA fully implements their Unified Registration System, or URS. The system was introduced with a final rule in the summer of 2013 and included a provision requiring exempt carriers to have process agents. Much of the rule was suspended at the beginning of 2017. At some point, the agency would like to get the URS ball rolling again.
Are exempt carriers exempt from IFTA, IRP, HVUT, and UCR?
Exempt for-hire carriers are not exempt from the alphabet soup of revenue generating programs of the International Fuel Tax Agreement (IFTA) allowing for the sharing of fuel tax revenue, the International Registration Plan (IRP) allowing for the sharing of vehicle registration fees, the Internal Revenue Service’s (IRS) tax for heavy vehicles that weight 55,000 pounds or more, or for the Unified Carrier Registration (UCR) revenue generating program.
Are exempt carriers exempt from the Federal Motor Carrier Safety Regulations (FMCSRs)?
Exempt carriers are not automatically exempt from the safety regulations such as driver qualifications, drug and alcohol testing, commercial driver licenses, vehicle inspections, or the hours-of-service rules. Although livestock and agriculture commodity carriers may qualify for the hours-of-service agriculture exemption.
Key to remember: “Exempt” commodity haulers are exempt from very little. Primarily they are exempt from needing for-hire authority and designating process agents.
Most Popular Highlights In Human Resources
NewsIndustry NewsIndustry NewsHR GeneralistFamily and Medical Leave Act (FMLA)Family and Medical Leave Act (FMLA)USAHR ManagementEnglishFocus AreaHuman Resources
2023-09-06T05:00:00Z
Appellate court sided with employee's (almost) 3-year-delayed FMLA claim
Back in October 2018, Laffon had a medical emergency and needed some time off under the federal Family and Medical Leave Act (FMLA).
Her leave lasted until November 15. Ten days after she returned to work, on November 26, her employer terminated her.
She sued, arguing that the employer retaliated against her because of her FMLA leave.
The catch? She didn't bring the suit until almost three years later.
No link between leave and termination
In court, the employer argued that there was no causal link between Laffon taking FMLA leave and her termination. Although the court documents aren't robust, they do reveal that the employer indicated that Laffon's allegations didn't show that her taking FMLA leave was a factor in the decision to terminate her. The documents showed only that the termination chronologically followed her leave.
The court agreed with the employer. It also agreed that Laffon failed to allege a willful violation of the FMLA, which would allow her to benefit from the FMLA's three-year statute of limitations.
Laffon appealed the case to the Ninth Circuit.
Statute of limitations
Under the FMLA, employees have two years from the date of the last event constituting the alleged violation for which they can bring a claim.
Those two years are extended to three years if the employer's actions were "willful." This means that an employee must show that the employer either knew or showed reckless disregard for whether its conduct violated the FMLA.
Ruling overturned
Fast forward to August 2023, when the Ninth Circuit reversed the lower court's decision. It indicated that, based on Laffon's amended complaint and liberally construing the law, her allegations establish that her leave was causally connected to her termination and that the employer's action (her termination) was willful.
Glymph v. CT Corporation Systems, No. 22-35735, Ninth Circuit Court of Appeals, August 22, 2023.
Key to remember: Terminating an employee soon after returning from FMLA leave is risky, unless there is a clear, well-documented, non-leave-related reason. Case documents did not show such a clear reason, which can also increase the risk of a willful finding. Employees have time to file claims, even years.
NewsIn-Depth ArticleHR ManagementEnglishHuman ResourcesAssociate Benefits & CompensationIndustry NewsEmployee BenefitsConsumer-driven health plansEmployee BenefitsBenefits communicationHR GeneralistFlexible BenefitsAssociate RelationsFocus AreaUSA
2026-05-28T05:00:00Z
Your employees are lost! Help them better navigate their benefits
There’s a growing gap between the benefits employers offer and the benefits employees use, according to the 2026 Employer Health Benefits Experience survey by the health care navigation platform Castlight Health.
Even though employers are investing in digital health and well-being programs, many workers are skipping employer-sponsored options. Instead, they’re creating their own mix of apps, devices, and online tools, and are often paying for these options themselves.
While most of the 2,000 U.S. employees surveyed have access to multiple benefits, only about one-third understand what’s available to them or even use those benefits.
The survey results indicate that more than half are using at least one consumer health or wellness app, with 46 percent paying with their own money — sometimes hundreds of dollars — for easier tools they find more useful.
This data shows that employees are willing to invest their own money when employer-provided benefits seem too complex or inflexible. It also indicates that employers may not be getting the full return from the benefits they offer.
How employers should respond
- Give employees more benefit flexibility. Employers looking to increase retention should move benefit flexibility to the top of their “to-do” list. When employees have choices, they’re more likely to stay at a company. The survey showed that 80 percent of surveyed employees feel that wellness flexibility would mean they’d be more likely to stay.
- Communicate often about benefits. To encourage employees to make use of company benefits before seeking help on their own, employers must keep benefit messaging in the forefront of employees’ minds. This could be done by sending out regular emails, posting information on the company’s intranet, sending text alerts, etc. Top-of-mind awareness is key!
- Roll with the changes. Employees’ lives are in a constant state of flux, and benefit options need to keep up with that pace to support them no matter what they’re juggling in their personal lives.
- Think beyond open enrollment. The survey revealed that only 7 percent of employees said that the open enrollment period made them think about using their benefits. They’re much more likely to think about what benefits they have when they’re at a doctor’s appointment, or an unexpected need pops up. If employers want their employees to engage with company-sponsored benefits, they should make tools easy to use and available when employees need them the most.
Key to remember: If navigating benefit options is too hard, employees are less likely to make use of their company-sponsored offerings, and might spend their own money on easier-to-use tools.
NewsIndustry NewsIndustry NewsWage and HourWage and HourAssociate Benefits & CompensationAssociate RelationsHR GeneralistFair Labor Standards Act (FLSA)OvertimeHR ManagementEnglishFocus AreaHuman ResourcesUSA
2026-05-21T05:00:00Z
Federal overtime threshold rule gone, for now
On May 15, members of Congress introduced a bill that would gradually increase the overtime salary threshold for determining whether employees may be classified as exempt under the federal Fair Labor Standards Act (FLSA).
This news came on the heels of the U.S. Department of Labor's official rescission of the 2024 rule that increased the threshold. That rule was challenged in federal court, and employers didn’t have to comply with it since it was vacated in November 2024.
Employers may now comfortably continue to follow the 2019 rule, where the minimum salary threshold is $684 per week ($35,568 per year) for executive, administrative, and professional employees, and $107,432 for highly compensated employees.
Potential future increases
The bill, The Restoring Overtime Pay Act of 2026 (HR 8868), would increase the federal minimum salary level as follows:
- 2026 — $45,000
- 2027 — $55,000
- 2028 — $65,000
- 2029 — $75,000
- 2030 — 55th percentile of full-time salaried workers nationally*, updated annually
*The current 55th percentile of full-time salaried workers nationally is $89,440 and could increase to $98,000 by 2030.
The measure would allow the Secretary of Labor to establish a higher salary threshold through notice and comment rulemaking, as long as it can be updated annually.
The bill would also require the following:
- The Secretary of Labor would need to provide annual, automatic updates to the overtime threshold of at least the 55th percentile of weekly earnings of full-time salaried workers.
- If the Secretary doesn’t establish an increased salary threshold, the 55th percentile of weekly earnings of full-time salaried workers nationally would take effect, based on the Bureau of Labor Statistics (BLS) from the second quarter of the preceding calendar year.
- The Secretary would need to publish a notice announcing the revised salary threshold no later than 60 days before the revised threshold takes effect.
- The BLS would need to publicly publish data on its website for each week of each quarter and data on weekly earnings by census region.
The bill is in the first stage of the legislative process. It was referred to the House Committee on Education and Workforce. While it has a small chance of being enacted at this time, it does show that some members of Congress are interested in this topic.
Key to remember: Congress members introduced a bill increasing the federal salary threshold level. But for now, employers can use the 2019 federal salary threshold to determine whether they may classify an employee as exempt.
NewsIndustry NewsAssociate Benefits & CompensationHR GeneralistFamily and Medical Leave Act (FMLA)In-Depth ArticleFamily and Medical Leave Act (FMLA)Associate RelationsEnglishHR ManagementFocus AreaHuman ResourcesUSA
2025-03-27T05:00:00Z
Who can fill out FMLA forms? The answer might surprise you
One of the most common questions involving the federal Family and Medical Leave Act (FMLA) that we see is: “Can ________ fill out the medical certification?”
This question stumps a lot of HR people and can be a little confusing.
It might be easier to start with who CAN’T fill out an FMLA certification. That includes your coworker, best friend, neighbor, or pet.
Jokes aside, often (but not always) a doctor fills out the FMLA certification, and since March 30 is “Doctors’ Day,” this is a great time to discuss this topic.
FMLA certification basics
Employers aren’t required to use certifications, but if they do, the U.S. Department of Labor (DOL) has five different certification forms to use for various FMLA leave situations.
The forms are as follows:
- Certification of Health Care Provider for Employee's Serious Health Condition,
- Certification of Health Care Provider for Family Member's Serious Health Condition,
- Certification of Qualifying Exigency for Military Family Leave,
- Certification for Serious Injury or Illness of a Current Servicemember for Military Family Leave, and
- Certification for Serious Injury or Illness of a Veteran for Military Family Leave.
Let’s focus on the first two, as these are the most common ones HR administrators use.
Who can fill out an FMLA certification?
The FMLA regulations describe the person who has the authority to fill out a certification as a “health care provider.” The good news is, the regulations include a lengthy list of medical professionals who fit this role.
Under the FMLA, a health care provider includes:
- A doctor of medicine or osteopathy,
- A podiatrist,
- A dentist,
- A clinical psychologist,
- An optometrist,
- A chiropractor (limited to manual manipulation of the spine as demonstrated by X-ray),
- A nurse practitioner,
- A nurse midwife,
- A clinical social worker,
- A physician assistant,
- A Christian Science practitioner, and
- Any health care provider from whom the employer or the employer's group health plan's benefits manager will accept a medical certification to substantiate a claim for benefits.
To be qualified to fill out FMLA forms, medical professionals must be authorized to practice in the state and perform within the scope of their practice. This means that the provider must be authorized to diagnose and treat physical or mental health conditions.
What about doctors in a foreign country?
If an employee or an employee's family member is visiting another country, or a family member resides in another country, and a serious health condition develops, the employer must accept a medical certification from a health care provider who practices in that country. This includes second and third opinions.
If a medical certification from a foreign health care provider is not in English, the employee may be required to provide a written translation of the certification.
Key to remember: The FMLA regulations spell out which medical professionals can fill out certification forms.
NewsIndustry NewsHR GeneralistFamily and Medical Leave Act (FMLA)In-Depth ArticleFamily and Medical Leave Act (FMLA)HR ManagementEnglishFocus AreaHuman ResourcesUSA
2025-03-18T05:00:00Z
FMLA leave triggered? Employees don’t have to miss three days of work
Employees may take leave under the federal Family and Medical Leave Act (FMLA) for several reasons, and one of those reasons is to care for their own or a family member’s medical condition. There’s no list of qualifying medical conditions, so employers have to gather all the facts to see if FMLA applies.
FMLA-related medical conditions can be short- or long-term. Some employers believe that their FMLA obligations aren’t triggered unless and until an employee misses three days of work. That’s just not true in many situations, and here’s why.
The FMLA defines a serious health condition as an illness, injury, impairment, or physical or mental condition that involves inpatient care or continuing treatment by a health care provider.
Inpatient care explained
Inpatient care is an overnight stay in a health care facility. If the employee or family member had an overnight stay, it’s an FMLA serious health condition regardless of how many days of work the employee missed.
If the employee or family member did not have an overnight stay, employers move on to the continuing treatment part of the definition.
Continuing treatment defined
A serious health condition involving continuing treatment includes the following:
- A period of incapacity of more than three, consecutive, full calendar days, and any subsequent treatment that also involves:
- Treatment two or more times within 30 days of the first day of incapacity by a health care provider, or
- Treatment at least once, resulting in a regimen of continuing treatment.
- Any period of incapacity due to pregnancy or for prenatal care.
- Any period of incapacity (or treatment for) a chronic serious health condition requiring treatments at least twice per year and continuing over an extended period of time. These may cause episodic rather than continuing periods of incapacity.
- A period of incapacity for a permanent or long-term condition in which treatment may not be effective.
- Any period of absence to receive multiple treatments (i.e., chemotherapy, radiation, physical therapy, dialysis), for restorative surgery, or for a condition that would likely result in a period of incapacity of more than three consecutive, full, calendar days if treatment isn’t received.
Not all parts of the definition above will apply to a particular situation. The only part of the continuing treatment segment that involves three days, for example, falls under the first bullet. For all the other parts, any period of incapacity would be FMLA leave. An employee doesn’t need to miss three days of work.
Focus on incapacity not absence when applying FMLA leave
The period of more than three days applies to how long the individual is incapacitated, not how many days of work the employee missed. If, for example, an employee who normally works Monday through Friday suffers a serious health condition on Friday evening and is incapacitated until Wednesday, the period of incapacity is more than three days. The employee missed only two days of work, but those two days would be FMLA leave.
Failure to designate an absence as FMLA leave when it is called for risks a claim that the employer interfered with the employee’s FMLA rights.
Key to remember: Employees don’t have to miss three days of work to trigger an employer’s FMLA obligations.
NewsIndustry NewsHR GeneralistFamily and Medical Leave Act (FMLA)In-Depth ArticleFamily and Medical Leave Act (FMLA)Associate RelationsEnglishUSAHR ManagementFocus AreaHuman Resources
2023-09-13T05:00:00Z
Navigating FMLA for lifelong conditions
If you’re reading this, you’ve likely seen certifications that indicate an employee needs leave under the Family and Medical Leave Act (FMLA) for a condition that lasts for the employee’s (or a family member’s) lifetime.
Many health conditions linger for years. Until medical science advances to eliminate long-lasting illnesses, you can expect to continue seeing such certifications.
These lifelong conditions might be chronic ones, such as asthma, or one that is permanent or long-term where treatment might not be effective, such as Alzheimer’s disease.
Lifelong conditions often involve flare-ups and intermittent FMLA leave for your employees who are managing symptoms, doctor appointments, etc. A certification should provide you with an idea as to when an employee might be absent. Remember, however, that this is just an estimate, so you might need to be flexible.
The certification could state that it is valid for 12 months. Such an indication, however, does not mean that you need to wait 12 months before asking for updated information.
Situations change, so you might want to get fresh information regarding a lifelong condition and continuing need for leave. Enter recertifications.
Recertifications
You may request a recertification no more often than every 30 days in connection with an employee’s absence unless the condition will last for more than 30 days — which would be the case for lifelong conditions.
For conditions certified as having a minimum duration of more than 30 days, you must wait to request a recertification until the specified period has passed.
In all cases, including those where the condition is indefinite or lifelong, you may request recertification every six months in connection with an employee’s absence.
Employee example
If Joe Employee requests and takes eight weeks of FMLA leave for a back operation and gives you a medical certification listing an eight-week absence, you can assume he will be back by that time.
At the end of the eight-week period, what if Joe tells you he needs more leave? Now he needs three days of FMLA leave per month for an indefinite period for additional therapy. You may request a recertification at that time, as Joe has asked for an extension of the original leave.
Six months later, and in connection with an absence for the same reason, you may ask Joe to recertify the need for FMLA leave. From that recertification, you learn that Joe will continue to need time off every now and then for his back condition.
Summary
Lifelong conditions don’t usually change much in 30 days, so it makes sense to request updated information only every six months. Of course, when the employee requests leave for the first time in a new 12-month period, you may request a new certification.
In some situations, a condition could change in less than six months. Therefore, you may request a recertification sooner than six months if any of the following occurs:
- The employee requests an extension of leave;
- Circumstances described in the current certification change significantly (e.g., the duration or frequency of the absence, the nature or severity of the condition, complications); or
- You receive information that casts doubt upon the employee’s stated reason for leave.
Key to remember: Certifications and recertifications are great tools to help keep you informed regarding lifelong conditions. The FMLA does, however, put limits on when you may request such information.
Most Popular Highlights In Safety & Health
NewsIndustry NewsMaterials Handling and StorageSafety & HealthConstruction SafetyGeneral Industry SafetyMaterials Handling and StorageIn-Depth ArticleEnglishFocus AreaUSA
2026-05-28T05:00:00Z
Material handling, when handling without care
Powered industrial truck regulations consistently rank among OSHA’s most cited. Many of these events don’t involve unusual conditions. They happen during routine work, in spaces employees navigate every day.
Injury and enforcement trends repeatedly point to struck by and caught between hazards that develop during normal operations. These are not rare events. They are recurring outcomes tied to how material is moved, stored, and managed.
Movement multiplies risk
Material handling means motion, equipment in travel lanes, loads shifting as they move, and workers crossing forklift paths. Every movement adds exposure, and it can escalate fast when tasks overlap or the area gets congested.
Moving pallets, operating forklifts, stacking materials, and stocking shelves are normal tasks, but each one can affect movement, storage, and load stability. OSHA data and enforcement trends continue to show serious injuries and fatalities tied to these types of activities. Material handling risks are more likely when:
- Forklifts and pedestrians share the same travel paths;
- Loads are lifted, carried, or stacked beyond stable limits;
- Visibility is reduced due to product, layout, or speed;
- Aisles become obstructed or narrowed during operations; or
- Tasks overlap without clear coordination of movement.
Stack safe, store smart
Safe storage practices reduce the chance that routine handling turns into a collapse, spill, or struck-by event. A slightly uneven stack, an overloaded pallet, or a rack pushed beyond capacity can fail quickly under normal workplace conditions. Strong storage practices can greatly reduce risk by:
- Maintaining pallet loads that are even, stable, and securely stacked;
- Verifying stacks stay within rack and pallet ratings;
- Keeping materials within designated storage boundaries; and
- Removing damaged pallets or containers from service.
Control, not complacency
Serious incidents are often less about equipment failure and more about familiar work being performed without enough attention to current conditions. Operators rely on experience instead of staying alert to the situation in front of them, pedestrians assume they have been seen, and routine tasks continue even when aisles tighten, loads change, or travel paths become less controlled.
Exposure to risks quickly rise when assumptions replace attention and routine replace active hazard recognition. Real control means staying actively engaged, maintaining awareness, checking conditions, verifying paths, and recognizing when conditions change.
Expect inspections
For both managers and workers, consistent inspections are one of the best ways to catch changing conditions before they lead to injury. Strong inspection practices can include:
- Checking travel paths and pedestrian separation throughout the shift;
- Removing damaged pallets, racks, or equipment from service;
- Identifying congestion points before they disrupt workflow; and
- Reinforcing that inspections support safe operations.
Training smart, work safe
Training for material handling is often centered on equipment operation. However, effective training focuses on recognizing changing conditions, understanding interaction between people and equipment, and reinforcing when to stop, reassess, and adjust.
To minimize the risks from constant movement in material handling environments, employers should implement clear traffic management strategies, such as designated pedestrian walkways and marked forklift lanes. Strong training reinforces decisions such as:
- Identifying when pedestrian separation is no longer maintained,
- Recognizing unstable loads before movement begins,
- Understanding when speed or congestion increases exposure,
- Stopping work when conditions no longer support safe handling, or
- Recognizing when a different method is the safer option.
Key to remember: When loads stay stable, travel paths stay clear, and workers stay alert to changing conditions, routine material handling activities stay productive, controlled, and far less likely to become a serious incident.
NewsIndustry NewsEnglishSafety & HealthConstruction SafetyGeneral Industry SafetyIn-Depth ArticleHazard CommunicationHazard CommunicationHazcom LabelingUSAFocus AreaHazCom Written ProgramHazCom Information and Training
2026-05-28T05:00:00Z
November's HazCom GHS 7 Deadline: What employers need to know
OSHA’s updated Hazard Communication Standard, now aligned with the 7th revised edition of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS 7), is being rolled out in phases. One deadline passed in May, and the next arrives in November. For employers, this means now is the time to start making updates. This revision introduces enough meaningful changes that relying on an old hazard communication checklist will not be enough.
First, a Quick Refresher on What HazCom Actually Is
At its core, OSHA’s Hazard Communication Standard is designed to make sure workers know what chemicals they are working with and what hazards those chemicals present. It covers the labels on chemical containers, the Safety Data Sheets (SDSs) that provide detailed hazard information, and the training employees need so they can understand and use that information effectively.
HazCom is tied to the Globally Harmonized System, or GHS, an international framework developed by the United Nations to create a more consistent approach to classifying and communicating chemical hazards. When the UN updates the GHS, OSHA eventually updates HazCom to better align with it. That is what is happening now with GHS 7, and those updates are beginning to work their way into supplier documents and workplace compliance expectations.
What’s Actually Changing in GHS 7
So what is different this time? GHS 7 includes several substantive changes that affect how chemicals are classified, how SDSs are written, and how labels are presented. These are not just wording updates. In some cases, they can change how hazards are described and how information is communicated to workers. The changes are:
- New and Revised Hazard Categories: GHS 7 expands classification for certain health and physical hazards. Desensitized explosives, for example, now have their own hazard class. Some existing categories have been refined with new subcategories that require different labeling and SDS language.
- Updated SDS Requirements: Section formatting and content requirements are being revised in several areas. Employers and chemical manufacturers will need to review existing SDS documents to ensure they reflect the updated classification criteria and language. If you’re an employer who receives SDS from suppliers, you’ll need to verify that incoming documents meet the new standard.
- Label Changes: Some products will require updated pictograms, signal words, or hazard statements based on reclassification under GHS 7. That means physical labels on containers may need to be reprinted and replaced.
- Exposure Limits and Inhalation Hazards: GHS 7 brings more specificity to how inhalation hazards are communicated, particularly for aerosols and mixtures.
What the May Deadline Covered
OSHA’s GHS 7 update was not designed as a single cutoff date. Instead, it was rolled out in phases, with different obligations applying at different points in time. The May 2026 deadline primarily affected chemical manufacturers, importers, and distributors. By then, those upstream parties were expected to update chemical classifications and begin issuing labels and SDSs that align with the revised standard.
For employers, that phase matters because it marks the point when updated information should begin flowing into the workplace. If you receive hazardous chemicals from suppliers, the SDSs and shipped labels you get should increasingly reflect the new classification language and formatting requirements.
That does not mean employers can treat compliance as only a supplier issue. You are still responsible for making sure the SDSs in your workplace are current, your labels reflect the hazards of the chemicals in use, and employees are trained on the information they rely on. If a supplier is slow to update documentation, that gap can quickly become your problem during an inspection.
That is why now is the time to start reaching out to chemical vendors and reviewing your own program. Ask suppliers whether their SDSs have been updated to GHS 7 standards, track what you receive, and follow up on anything that is missing or unclear. November will arrive quickly, and employers that wait too long may find themselves rushing through updates that should have been planned in advance.
Roadmap for November Update
The best way to approach the November deadline is as a practical compliance project rather than a last-minute document review.
- Chemical inventory audit: You cannot update what you have not identified, so pull together a complete inventory of every chemical in the workplace, including cleaning products, maintenance supplies, and production materials. That inventory becomes the baseline for everything that follows.
- Review and update your SDS library: Contact suppliers and request GHS 7-compliant SDSs for each product on your inventory. Do not assume existing files are already current. Create a simple tracking system so you know which documents have been updated, which are still pending, and where follow-up is needed.
- Audit your physical labels: Walk the facility and compare container labels to the updated hazard information you are receiving. If products have been reclassified or now use different pictograms, signal words, or hazard statements, your in-house labels may also need to change. Starting early is important, especially for larger facilities where relabeling can take time.
- Revise your written HazCom program: This should be treated as a living document that reflects current practice. Review it carefully and update language, procedures, and responsibilities so they align with the revised standard and with the way your facility actually manages chemical hazards.
- Retrain your workforce and brief supervisors: Employees need to understand what changed, what updated labels and SDSs mean, and how those changes affect handling, storage, and response expectations. Supervisors should receive deeper guidance so they can answer questions, recognize compliance gaps, and reinforce the updated program in day-to-day operations.
Key to remember: Now is the time to prepare for November's Hazard Communication Standard deadline.
NewsIndustry NewsSafety & HealthGeneral Industry SafetyExpert InsightsFire Protection and PreventionEnglishFire Protection and PreventionFocus AreaUSA
2026-05-29T05:00:00Z
Expert Insights: Safety often born of tragedy
The more I understand OSHA’s regulations and answer questions from safety professionals, the more I keep an eye out for safety wherever I go, whether it’s being alert to where the exits are or whether workers are using personal protective equipment while on a roof in my neighborhood.
Working in the safety field also has meant becoming familiar with tragic events like the 1911 Triangle Shirtwaist Factory Fire, in which 146 workers died. More recently, during a walk along Boston’s historic Freedom Trail and surrounding areas, I discovered the Boston Fire Museum and a tragedy I hadn’t heard of.
While exploring the fire trucks and memorabilia, a wall display caught my eye. Intrigued by a newspaper headline — “400 Dead in Hub Night Club Fire” — I read on and learned something new.
Just after Thanksgiving in 1942, nearly 500 people died when a fire broke out in the basement bar of the Cocoanut Grove supper club. It’s believed the fire ignited when a busboy lit a match to better see while fixing a lightbulb near an artificial palm tree.
Within minutes, decorations and furnishings caught fire, sending a fireball of flame and toxic gases racing toward the only exit — a four-foot-wide staircase leading to the first floor, which housed restrooms, coatrooms, and the main entrance. As people tried to escape, the revolving door jammed with panicked patrons.
Later, investigators determined that several alternative exits had been blocked or locked, the building was overcrowded, and flammable building materials and highly combustible decorations contributed to the rapid spread of the fire. A lack of sprinklers and smoke detectors also increased the scale of devastation.
The fire triggered significant reforms that continue to drive compliance, including:
- Exit design and egress requirements,
- Exit visibility and emergency lighting,
- Control of flammable materials such as interior decorations,
- Occupancy limits and enforcement,
- Fire protection systems, and
- Creation of fire safety oversight and codes.
Many safety laws and regulations exist today because of real tragedies, some predating OSHA by decades. The Cocoanut Grove fire is just one example.
NewsIndustry NewsIndustry NewsEnforcement and Audits - OSHASafety & HealthConstruction SafetyGeneral Industry SafetyAgriculture SafetyMaritime SafetyFocus AreaEnglishOSHA Violations and PenaltiesUSA
2026-05-28T05:00:00Z
OSHA penalty amounts won’t increase in 2026
OSHA won’t increase its penalty amounts in 2026. The agency is required to annually adjust its penalties for inflation, based specifically on the October Consumer Price Index for All Urban Consumers (CPI-U) data released by the Bureau of Labor Statistics (BLS). Due to a lapse in funding, BLS did not release the October 2025 data. Because no alternative calculation is allowed, OSHA penalties will remain at the 2025 amounts.
| Type of violation | Penalty |
| Serious Other-than-serious Posting requirements | $16,550 per violation |
| Failure to abate | $16,550 per day beyond the abatement date |
| Willful or repeated | $165,514 per violation |
NewsEmergency Planning - OSHAIndustry NewsSafety & HealthElectrical SafetyGeneral Industry SafetyEmergency ExitsFire Protection and PreventionIn-Depth ArticleFire ExtinguishersEnglishClearance DistancesFocus AreaUSA
2022-07-08T05:00:00Z
Locked/blocked exits prompt $580K in OSHA penalties
A national retailer, with what OSHA calls a long history of violations, was slapped with four willful citations after local fire officials sent a referral to the agency regarding a Wisconsin store. Once inside the store last December and January, OSHA inspectors found a:
- Locked exit — Emergency exit doors to the back receiving room were padlocked with a bike lock and a board placed through the handles. Employees were not able to open an exit route door from the inside at all times without keys, tools, or special knowledge. This violated 29 CFR 1910.36(d)(1). The violation was considered willful and serious because the retailer had previously been cited for the same violation three times elsewhere in the U.S. Now the store received the maximum penalty of $145,027.
- Blocked exit — Merchandise and carts blocked the exit in the receiving room, according to OSHA. The exit route was not kept free and unobstructed, and violated 1910.37(a)(3). This violation too was considered willful and serious because the retailer had been cited previously for the same violation 12 times in the U.S. This time the penalty was the maximum $145,027.
- Blocked extinguisher — A portable fire extinguisher in the back receiving room was obstructed with carts/containers. The extinguishers were not readily accessible per 1910.157(c)(1). OSHA found that the retailer previously violated this regulation twice in the U.S., so the violation was considered willful and serious and picked up another maximum $145,027 penalty.
- Blocked electrical panel — Adequate space around electrical panels was not provided says OSHA. Inspectors found that the employer obstructed the access and working space about electrical panels with carts/containers, in violation of 1910.303(g)(1). The citation explains that the retailer violated that regulation eight previous times in the U.S., and the violation was willful and serious, but OSHA did not propose a penalty amount.
While store managers explained that the doors needed repair to close properly, OSHA determined the doors were in disrepair for three months. The store has settled the case for $435,081 in penalties.
However, in January, a similar inspection was conducted at another one of the retailer’s stores in Ohio. That location was cited for barrel locks on the inside of a double-door emergency exit in the back room in violation of 1910.36(d)(1) . The Ohio store was cited for one willful violation and settled the case with $145,027 in penalties.
It is noteworthy that officials for the company had signed settlement agreements with OSHA in 2017, promising to resolve similar violations at its stores nationwide. However, OSHA officials say, based on the latest violations, the retailer continues to gamble with workers’ lives and must stop before tragedy strikes.
NewsPersonal Protective EquipmentIn-Depth ArticleUSAEnglishPersonal Protective EquipmentFoot ProtectionIndustry NewsHead ProtectionEye and Face ProtectionElectrical Protective EquipmentWeather-specific PPESafety & HealthConstruction SafetyGeneral Industry SafetyHand ProtectionHearing ProtectionRespiratory ProtectionFocus AreaSafety Vests
2024-02-02T06:00:00Z
Understanding PPE Exceptions: When and How to Accommodate Employees
Did you know there are situations where employees may need exceptions from wearing personal protective equipment (PPE) due to medical reasons or safety concerns? In these cases, employers must engage in an interactive process to determine if a reasonable accommodation can be made. Let's explore the guidelines and best practices for handling PPE exceptions and ensuring the safety of all employees.
OSHA's yearly list of the "Top 10 most frequently cited standards" consistently includes noncompliance with personal protective equipment (PPE) regulations. It's important to note that these violations are specific to OSHA citations and do not encompass the wide range of PPE challenges that safety professionals encounter daily, like exceptions.
Based on a 2023 study by the J. J. Keller Center for Market Insights, safety professionals feel training employees on most topics related to PPE usage is increasingly challenging. Getting employees to wear PPE continues to be challenging, with over 70% of participants saying they have employee PPE compliance issues. Employers must figure out if, in fact, compliance issues may instead be needs for accommodations or exceptions.
Free PPE or Not
OSHA (Occupational Safety and Health Administration) has rules requiring employers to give their employees protective gear, like hard hats, gloves, goggles, and safety shoes if needed to keep them safe at work. These rules are in place to prevent injuries and illnesses. However, it's worth noting that not all these rules say that the employer must provide the gear for free.
Right to Use PPE
OSHA's PPE standards do not allow employees to waive their right to use PPE. However, if an employee has a medical condition that would make them eligible for protection under the Americans with Disabilities Act, the employer would be expected to make reasonable accommodations that do not compromise safety.
OSHA also addresses the refusal to wear PPE due to religious beliefs in a specific directive. There is no indication that OSHA would accept a signed waiver from an employee who refuses to wear necessary PPE or follow other safety rules.
Medical Accommodations
When it comes to accommodating an employee who states they cannot wear personal protective equipment (PPE) due to a medical reason, employers must engage in an interactive process to determine if a reasonable accommodation can be made. The employer should work with the employee and, if necessary, consult with medical professionals to assess the situation.
The goal is to find a solution that allows the employee to perform their job safely while considering their medical condition. However, it's important to note that the accommodation must not pose an undue hardship on the employer or compromise the employee's or others' safety in the workplace. Each situation is unique, so employers should consult with legal counsel or compliance experts to ensure they follow the appropriate guidelines and regulations.
Allergies to PPE
When employees are allergic to the available materials for required personal protective equipment (PPE), employers should take the following steps to address the situation:
- Assess the Allergy: Employers should gather information about the specific allergy and its severity. This may involve consulting with medical professionals or requesting documentation from the employee's healthcare provider.
- Explore Alternative Options: Employers should work with the employee to identify alternative materials or PPE types suitable for their allergy. This could involve researching and sourcing different hypoallergenic PPE products or made from materials the employee is not allergic to.
- Test and Evaluate: Before implementing any alternative PPE, it's important to conduct testing and evaluation to ensure that the new materials do not cause an allergic reaction for the employee. This may involve conducting patch tests or having the employee try out different options under controlled conditions.
- Document Accommodation: If an alternative PPE solution is found, employers should document the accommodation process, including the steps taken, the alternative PPE selected, and any agreements reached with the employee. This documentation helps demonstrate compliance with regulations and records the accommodation made.
- Ongoing Monitoring: Employers should regularly monitor the employee's condition and the effectiveness of the alternative PPE. Any issues or changes should be addressed promptly to ensure the employee's safety and well-being.
Employers need to consult with legal counsel or compliance experts to ensure they are following the appropriate guidelines and regulations when accommodating employees with allergies to PPE materials.
Key to Remember
Getting employees to wear PPE continues to be challenging, with over 70% of participants saying they have employee PPE compliance issues. Employers must figure out if, in fact, compliance issues may instead be needs for accommodations or exceptions.
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