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DEPARTMENT OF TRANSPORTATION

Office of the Secretary

49 CFR Part 40

Pipeline and Hazardous Materials Safety Administration

49 CFR Part 199

[Docket DOT-OST-2022-0027]

RIN 2105-AF01

Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records

AGENCY: Office of the Secretary, Department of Transportation (DOT).

ACTION: Notice of proposed rulemaking (NPRM).

SUMMARY: The Department of Transportation (DOT or Department) proposes to amend its regulations for conducting workplace drug and alcohol testing for the federally regulated transportation industry to allow, but not require, electronic signatures on documents required to be created and utilized under the regulations, the use of electronic versions of forms, and the electronic storage of forms and data. The regulatory changes would apply to DOT-regulated employers and their contractors (“service agents”) who administer their DOT-regulated drug and alcohol testing programs. Currently, employers and their service agents must use, sign and store paper documents exclusively, unless the employer is utilizing a laboratory's electronic Federal Drug Testing Custody and Control Form (electronic CCF) system that has been approved by the Department of Health and Human Services (HHS). DOT is required by statute to amend its regulations to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms. This rulemaking also responds to an April 2, 2020, petition for rulemaking from DISA Global Solutions, Inc. (DISA), requesting that DOT regulations be amended to allow the use of an electronic version of the alcohol testing form (ATF) for DOT-authorized alcohol testing. The proposed regulatory amendments are expected to provide additional flexibility and reduced costs for the industry while maintaining the integrity and confidentiality requirements of the drug and alcohol testing regulations. In addition, DOT proposes to amend the Pipeline and Hazardous Materials Safety Administration (PHMSA) regulation for conformity and to make other miscellaneous technical changes and corrections.

DATES: Comments on this NPRM must be received on or before December 16, 2024.

ADDRESSES: You may submit comments identified by Docket Number DOT-OST-2022-0027 using any of the following methods:

Federal eRulemaking Portal: Go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document. Follow the online instructions for submitting comments.

Mail: Docket Management Facility, U.S. Department of Transportation, 1200 New Jersey Avenue SE, West Building, Ground Floor, Room W12-140, Washington, DC 20590-0001.

Hand Delivery or Courier: West Building, Ground Floor, Room W12-140, 1200 New Jersey Avenue SE, Washington, DC, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting Dockets Operations.

Fax: 202-493-2251.

To avoid duplication, please use only one of these methods. See the “Public Participation and Request for Comments” portion of the SUPPLEMENTARY INFORMATION section for instructions on submitting comments, including collection of information comments for the Office of Information and Regulatory Affairs, Office of Management and Budget (OMB).

FOR FURTHER INFORMATION CONTACT:

Mike Huntley, Office of Drug and Alcohol Policy and Compliance, 1200 New Jersey Avenue SE, Washington, DC 20590; telephone number 202-366-3784; ODAPCwebmail@dot.gov. If you have questions on viewing or submitting material to the docket, contact Docket Services, telephone (202) 366-9826.

SUPPLEMENTARY INFORMATION:

This NPRM is organized as follows:

I. Executive Summary

II. Public Participation and Request for Comments

A. Submitting Comments

B. Viewing Comments and Documents

C. Privacy Act

III. Legal Basis for the Rulemaking

IV. Background

V. Advance Notice of Proposed Rulemaking (ANPRM) Overview

VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures

VII. Amending Part 40 To Permit Electronic Documents and Signatures

VIII. Electronic ATF

IX. Section-by-Section Analysis

X. Regulatory Analyses and Notices

I. Executive Summary

Purpose and Summary of the Major Provisions

This proposed rule would establish parity between paper and electronic documents and signatures and expand businesses' and individuals' ability to use electronic methods to comply with the Department's drug and alcohol testing regulation, 49 CFR part 40, “Procedures for Transportation Workplace Drug and Alcohol Testing Programs” (part 40). Businesses and individuals subject to part 40 would continue to have the choice to use paper documents and traditional “wet” signatures. This proposed rule would also modify references to recordkeeping and reporting methods throughout part 40 to make them technologically neutral.

This proposed rulemaking responds to a statutory mandate set forth in section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271 (see 49 U.S.C. 322 note). The proposed rulemaking would take action consistent with the Government Paperwork Elimination Act (GPEA) (division C, title XVII, secs. 1701-1710, Pub. L. 105-277) and the Electronic Signatures in Global and National Commerce Act (E-SIGN) (Pub. L. 106-229) with regard to DOT's part 40 regulations.

II. Public Participation and Request for Comments

A. Submitting Comments

If you submit a comment, please include the docket number for this NPRM (Docket No. DOT-OST-2022-0027), indicate the specific section of this document to which each comment applies, and provide a reason for each suggestion or recommendation. You may submit your comments and material online or by fax, mail, or hand delivery, but please use only one of these means. The Office of the Secretary (OST) recommends that you include your name and a mailing address, an email address, or a phone number in a cover letter or an email so that OST can contact you if there are questions regarding your submission.

To submit your comment online, go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document, click on this NPRM, click “Comment,” and type your comment into the text box on the following screen.

If you submit your comments by mail or hand delivery, submit them in an unbound format, no larger than 8 1/2 by 11 inches, suitable for copying and electronic filing. If you submit comments by mail and would like to know that they reached the facility, please enclose a stamped, self-addressed postcard or envelope.

OST will consider all comments and material received during the comment period in determining how to proceed with any final rule.

B. Viewing Comments and Documents

To view comments, as well as any documents mentioned in this preamble as available in the docket, go to https://www.regulations.gov. Insert the docket number, DOT-OST-2022-0027, in the keyword box, and click “Search.” Next, click the “Open Docket Folder” button and choose the document to review. If you do not have access to the internet, you may view the docket online by visiting the Docket Management Facility in Room W12-140 on the ground floor of the DOT West Building, 1200 New Jersey Avenue SE, Washington, DC 20590-0001, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting the Docket Management Facility.

C. Privacy Act

In accordance with 5 U.S.C. 553(c), DOT solicits comments from the public to better inform its rulemaking process. DOT posts these comments, without edit, including any personal information the commenter provides, to www.regulations.gov, as described in the system of records notice (DOT/ALL-14 FDMS), which can be reviewed at https://www.transportation.gov/individuals/privacy/privacy-act-system-records-notices under the heading of “Department-Wide System of Records Notices”.

III. Legal Basis for the Rulemaking

This rulemaking is promulgated under the authority enacted in the Omnibus Transportation Employee Testing Act of 1991 (OTETA) (Pub. L. 102-143, tit. V, 105 Stat. 952) and codified at 49 U.S.C. 45102 (aviation), 49 U.S.C. 20140 (rail), 49 U.S.C. 31306 (motor carrier), and 49 U.S.C. 5331 (public transportation), as well as the Department's authority in 49 U.S.C. 322 and the PHMSA authorities specified in the proposed regulatory text for this action.

According to Public Law 115-271, the Secretary of Transportation is required to “issue a final rule revising part 40 of title 49, Code of Federal Regulations, to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms.” (49 U.S.C. 322 note) The statute set the deadline for this action as not later than 18 months after HHS establishes a deadline for a certified laboratory to request approval for fully electronic CCFs ( Id. ) On April 7, 2022, HHS set that deadline as August 31, 2023 (87 FR 20528). HHS has extended the deadline to August 31, 2026, to enable sufficient time for all HHS-certified laboratories to identify and contract with an electronic CCF supplier or to develop an electronic CCF. The deadline for DOT's regulatory amendments would therefore be February 29, 2028.

There are two additional Federal statutes relevant to the implementation of electronic document and signature requirements.

The Government Paperwork Elimination Act (GPEA), codified at 44 U.S.C. 3504 note, 1 was enacted to improve customer service and governmental efficiency through the use of information technology. The GPEA defines an electronic signature as a method of signing an electronic communication that: (a) identifies and authenticates a particular person as the source of the electronic communication; and (b) indicates such person's approval of the information contained in the electronic communication. Id. It also requires OMB to ensure Federal agencies provide for: (a) the option of maintaining, submitting; or disclosing information electronically, when practicable; and (b) the use and acceptance of electronic signatures when practicable. The GPEA states that electronic records submitted pursuant to procedures developed under title XVII for the submission of records to Federal agencies and electronic signatures used in accordance with those procedures shall not be denied legal effect, validity, or enforceability merely because they are in electronic form. Id.

1 Division C, title XVII (sec. 1701-1710) of Public Law 105-277, 112 Stat. 2681-749, enacted on October 21, 1998.

The Electronic Signatures in Global and National Commerce Act (E-SIGN), codified at 15 U.S.C. 7001-7031, 2 was designed to promote the use of electronic contract formation, signatures, and recordkeeping in private commerce by establishing legal equivalence between traditional paper-based methods and electronic methods. The E-SIGN Act allows the use of electronic records to satisfy any statute, regulation, or rule of law requiring that such information be provided in writing if the consumer has affirmatively consented to such use and has not withdrawn consent. Specifically, the statute establishes the legal equivalence of the following types of documents with respect to any transaction in or affecting interstate or foreign commerce, whether in traditional paper or electronic form: (a) contracts, (b) signatures, and (c) other records (15 U.S.C. 7001(a)(1)).

2 Public Law 106-229, 114 Stat. 464, enacted on June 30, 2000.

IV. Background

The Department's drug and alcohol testing regulations were promulgated at a time when the ability to sign and retain official records electronically—now commonplace in many business segments—was not available. Over the course of several years, we have adopted measures that have reduced the paper documentation associated with the drug and alcohol testing program without compromising the integrity and confidentiality requirements of the program. In 2003, we standardized the form for employers to report their Management Information System (MIS) aggregate drug and alcohol testing data, as well as the specific data collected. 3 When creating a ONE-DOT MIS Form, we then authorized employers to submit a single standardized form via a web portal. In 2015, we issued a final rule to allow employers, collectors, laboratories, and medical review officers (MROs) to use the electronic version of the Federal Drug Testing CCF in the DOT-regulated drug testing program. 4 That final rule also incorporated into the regulations the requirement to establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons when using the electronic CCF. We also included language protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form when using the electronic CCF.

3 68 FR 43946 (July 25, 2003).

4 80 FR 19551 (Apr. 13, 2015).

Consistent with the statutory mandate in 49 U.S.C. 322 note, we propose amendments to part 40 to permit the use of electronic signatures, forms, and records storage for drug and alcohol testing records throughout the regulation, including the use of an electronic ATF for DOT-authorized alcohol testing. We emphasize that electronic signatures, forms, and records would not be required; we would continue to allow paper, or hard-copy use with traditional “wet signatures.”

These proposed amendments would establish parity between paper and electronic collection and submission of information required under our regulations (and remain compatible with applicable OMB guidance on implementing electronic signatures 5 ) by allowing further use of electronic means and methods to comply with part 40 requirements. Many employers and their service agents have already instituted the use of electronic signatures, forms, and records storage for the non-DOT regulated testing that they conduct. DOT supports this transition to a paperless system and is committed to ensuring that the movement to a partially or fully electronic part 40 is done to maximize program efficiencies and reduce costs, while maintaining the integrity and confidentiality requirements of the program.

5https://www.whitehouse.gov/wp-content/uploads/2017/11/2000-M-00-15-OMB-Guidance-on-Implementing-the-Electronic-Signatures-in-Global-and-National-Commerce-Act.pdf.

Electronic documents would have a high degree of forensic defensibility as long as any changes made to the document are in the document's electronic footprint, which shows when the document or signature, as applicable, was created; when, and if, changes were made; who made the changes; and when, as applicable, a document was transmitted to and received by the receiving entity. The use of electronic forms and signatures in part 40 would help DOT-regulated employers and their service agents improve their workflow efficiency through faster turnaround times for required documents. Cost savings would result through reduced printing and delivery/shipping costs, and expedited transmission of information allowing for more timely decisions. We believe this proposed rule, if adopted, would also mitigate the longstanding problems ( e.g., delays in processing times of test results, cancelling of test results, etc.) associated with illegible and lost copies of paper documents.

V. Advance Notice of Proposed Rulemaking (ANPRM) Overview

On August 5, 2022, we published an ANPRM requesting public comment on how part 40 could be amended, as required by the statute, to allow electronic signatures, forms, and recordkeeping (87 FR 47951). We requested information from DOT-regulated employers and their service agents regarding if and how they are already handling electronic signatures, records transmission, and records storage in their non-DOT testing programs. In addition, we requested comments and information on appropriate performance standards, and on whether particular methods or performance standards have been successful or unsuccessful. We also asked a number of general questions on the potential advantages, risks, ramifications, and required safeguards associated with the use of electronic signatures, forms, and records in the DOT drug and alcohol testing program. We asked questions about specific sections of part 40 that we anticipated would be affected by prospective changes to implement electronic signatures, forms, and records. Finally, we asked a number of questions regarding the use of an electronic ATF for DOT-regulated alcohol tests.

We received 72 comments in response to the ANPRM, including comments from individuals, testing laboratories, MROs, and MRO organizations, substance abuse professionals (SAP) and SAP organizations, and various associations representing DOT-regulated transportation workers subject to mandatory drug and alcohol testing under part 40.

A few individuals expressed opposition to the adoption of electronic signatures, forms, and recordkeeping, citing concerns about the need for the rulemaking, risk to personal information from hackers or mismanaged electronic processes and procedures, and misuse of electronic forms and signatures. To meet our statutory mandate and in consideration of concerns about safeguarding personal information and appropriate use of the information in developing the NPRM, DOT proposes to require security measures for electronic forms and signatures used under part 40 that are the same as those currently in place for the electronic CCF specified in 49 CFR 40.40(c)(5).

Most commenters were supportive of changes to amend part 40 that would permit, but not require, the use of electronic signatures, forms, and recordkeeping. Commenters supporting revisions to part 40 noted that electronic signatures, forms, and recordkeeping are used in virtually every industry today—including but not limited to the banking, insurance, medical, and legal industries. Commenters supported the use of performance standards instead of technology-specific standards to ensure that, once established, standards do not become obsolete given the rapidly evolving nature of information technology standards and practices. Commenters stated that allowing electronic signatures, forms, and recordkeeping would make the drug testing process much more efficient and would result in cost savings. Commenters also stated that it would be safer to store records electronically since records could be backed-up, secured, and protected from tampering and unauthorized access and use.

VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures

In developing this NPRM, we looked to a rule promulgated by DOT's FMCSA that permits the use of electronic methods to generate, certify, sign, maintain, or exchange records so long as the documents accurately reflect the required information and can be used for their intended purpose. (83 FR 16210, Apr. 16, 2018) The rule applies to documents that FMCSA requires entities or individuals to retain. FMCSA permits, but does not require, anyone to satisfy FMCSA requirements by using electronic methods to generate, maintain, or exchange documents. The substance of the document must otherwise comply with applicable Federal laws and FMCSA rules. FMCSA also permits, but does not require, anyone required to sign or certify a document to do so using electronic signatures, defined, as in the GPEA, as a method of signing an electronic communication that: (1) identifies and authenticates a particular person as the source of the electronic communication; and (2) indicates such person's approval of the information contained in the electronic communication. FMCSA allows for the use any available technology for electronic signatures, so long as the signature otherwise complies with FMCSA's requirements.

FMCSA adopted broad performance standards for electronic documents and signatures—as specified in GPEA and E-SIGN—rather than detailed, technology specific standards that would likely become obsolete with inevitable changes in information technology standards and practices. FMCSA's April 2018 rule has been in effect for more than five years, and the definitions and requirements established in that rule have stood the test of time despite the many changes that have occurred with respect to electronic documents and signatures. We are unaware of any FMCSA-regulated entities that have reported issues to FMCSA regarding the use of electronic documents or signatures to meet the requirements of the FMCSRs since the rule became effective in 2018.

VII. Amending Part 40 To Permit Electronic Documents and Signatures

In this NPRM, we propose to permit but not require electronic documents, signatures, and recordkeeping in part 40. Additionally, we propose a performance standard approach as opposed to establishing technology-specific standards. Where it is possible to do so, establishing the same or substantively similar regulatory requirements for common issues across DOT modal agencies—such as the use of electronic documents and signatures—helps the Department maintain a consistent regulatory approach for those common issues.

There are currently more than 60 references to the term “written” in part 40, and more than 20 additional references to the term “in writing.” We propose to add a definition of “written or in writing” in part 40, to eliminate any distinction between paper and electronic documentation and establish technological neutrality throughout the entirety of part 40.

FMCSA's rule does not apply to documents that individuals or entities are required to file directly with FMCSA. In its April 2018 final rule, FMCSA explained that while industry could use electronic signatures and submit information directly to the FMCSA in certain situations, 6 adapting all FMCSA systems to allow for use of electronic signatures and submissions would significantly delay the implementation of the rule for use by third parties as it would require FMCSA to develop and implement technology systems to allow for direct submission to FMCSA from regulated parties. FMCSA noted that development of such systems could take several years, and therefore saw no reason to make private parties' use of electronic signatures and records retention contingent upon FMCSA's ability to receive submissions electronically because doing so would delay potential benefits to be gained by third parties.

6 As an example, Certified Medical Examiners may use electronic signatures, if they choose to do so, to sign medical forms, certificates, and a new driver medication report. If FMCSA requests these forms, they are uploaded in portable document format (PDF) to the Medical Examiner's account associated with the National Registry of Certified Medical Examiners for FMCSA to access.

In contrast to FMCSA's regulations, part 40 does not require entities or individuals to submit documents directly to the Department except for MIS aggregate drug and alcohol testing data that employers subject to DOT or U.S. Coast Guard (USCG) drug and alcohol testing regulations must submit annually. Each of the various documents required and used as part of the DOT drug and alcohol testing program under part 40 ( e.g., employee drug and alcohol testing records, MRO reports and records, SAP reports and records) are documents that are created by, exchanged between, and maintained by a person or entity involved in the testing process—but are not required to be submitted directly to DOT.

As noted earlier, and specifically with respect to the required MIS data, we standardized the form for employers to report their aggregate drug and alcohol testing data, as well as the specific data collected, more than 20 years ago. At that time, we authorized employers to submit the ONE-DOT MIS form via a web portal. Today, the Federal Aviation Administration, FMCSA, Federal Railroad Administration, and Federal Transit Administration permit employers to submit that same drug and alcohol testing data via the internet, and PHMSA requires that the data be submitted electronically. If employers submit the data electronically via the internet, they are not required to submit a hard copy. DOT recommends that employers have a copy of their data available (either hard copy or in electronic format) in the event an auditor or inspector requests a copy.

From the above, and because the only documents that part 40 requires to be submitted directly to the Department are already permitted to be, and in some cases required to be, submitted electronically, there is no need for us to limit the applicability of our proposal as FMCSA did in its 2018 final rule.

Several commenters noted that they already use electronic signatures and documents for their non-DOT drug and alcohol testing program, and in some cases, have done so for many years. In doing so, these commenters have had to establish appropriate confidentiality and security measures to ensure that confidential employee records cannot be accessed by unauthorized persons, including protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The same general requirements were added to the current §40.40(c)(5) when we approved the use of the electronic CCF for use in DOT drug testing in 2015, 7 and we propose the same requirements in this NPRM for the use of electronic signatures, documents, and recordkeeping throughout the entirety of part 40.

7 The 2015 revisions amended then §40.45(c)(5), which was redesignated as §40.40(c)(5) in the May 2023 final rule to include oral fluid testing in the DOT drug testing program (88 FR 27596, May 2, 2023).

Ensuring that confidential employee records are not available to unauthorized persons is an important element of part 40's protections for employees that are subject to DOT's drug and alcohol testing rules. We believe that the failure of a service agent to provide or maintain a secure/confidential electronic system should constitute the basis for the Department to start a public interest exclusion (PIE) proceeding, and propose to add this to the list of examples provided in §40.365(b).

Throughout part 40, information and documents are required to be transmitted and/or communicated between service agents ( e.g., collectors, screening test technicians (STTs) and breath alcohol technicians (BATs), laboratories, MROs, SAPs, and consortium/third party administrators (C/TPAs)), employers, and employees). Although part 40 does not currently require the party receiving these communications and/or documents to affirmatively confirm receipt of such from the sender, in some instances, regardless of whether the document is electronic or a hard copy, we believe that it may be important for the receiving party to verify that those required communications and/or documents were received.

For example, under §40.25, an employer intending to use an employee to perform safety-sensitive functions must, after obtaining an employee's written consent, request information about the employee's drug and alcohol testing record from previous DOT-regulated employers. After receiving a copy of the employee's written consent, the previous employer must immediately provide the requested information to the employer making the inquiry. If an employer is subsequently investigated/audited by the appropriate DOT mode, it may be beneficial for both the gaining employer and the previous employer to be able to affirmatively demonstrate that the employee's written consent and previous testing record were sent and received as required.

Sections 40.191(d) and 40.261(c)(1) require a collector or MRO (for drug tests) or a BAT, STT, or a physician evaluating a “shy lung” situation (for alcohol tests), respectively, to—when an employee refuses to participate in a part of the testing process—terminate the testing process, document the refusal, and immediately and directly notify the employer's designated employer representative (DER) by any means that ensures the refusal notification is immediately received. Because this notification of a refusal to an employer is of an urgent nature, it may be advisable to require the DER to affirmatively confirm receipt of the required notification from the collector, MRO, BAT, STT, or physician. For example, §§40.191(d) and 40.261(c)(1) could be amended to read “. . . immediately notify the DER by any means and ensure that the refusal notification is immediately received”.

While we are not proposing new requirements in this NPRM regarding confirmation of receipt in the sections discussed above (or in other part 40 requirements), we seek comment regarding whether it may be beneficial or advisable to do so, and if so, for which specific sections of part 40.

VIII. Electronic ATF

The ATF has been in use in the DOT alcohol testing program since 1994 (see 59 FR 7349, Feb. 15, 1994). The ATF must be used to document every DOT alcohol test. DOT regulations at 49 CFR 40.225 set forth the requirements for use of the form, and 49 CFR part 40, appendix G, contains a facsimile (reference copy) of the form. The ATF is a three-part carbonless manifold form used by DOT-regulated employers to document the testing event when testing employees subject to DOT alcohol testing. When the employee is tested, both the employee and the STT and/or the BAT will complete the ATF in various sections. The STT/BAT documents the result(s) by either writing in the screening result or attaching the screening and/or confirmation result printed by the evidential breath testing devices (EBT) onto the ATF, and then sends Copy 1 to the employer, provides Copy 2 to the employee, and retains Copy 3 for their records.

On April 2, 2020, DISA petitioned the Department to amend part 40 to allow for the use of an electronic version of the ATF for DOT mandated alcohol testing. In support of its petition, DISA stated that “The requested amendment to 49 CFR part 40 will enable a parallel process for the documentation of DOT-mandated alcohol tests aligned with the similarly situated amendment previously approved for drug testing.” DISA believes that allowing the use of an electronic ATF will result in several benefits to the industry, including “increased efficiency, security and accuracy in documentation of DOT alcohol tests; paperwork reduction; improved process for conducting a DOT alcohol test in conjunction with a DOT drug test when an electronic version of the federal CCF is used for the drug test; reduction of errors and omissions in the completion of the ATF; and improved efficiency and efficacy in the transmission and record retention of alcohol test results.”

DISA noted that non-DOT workplace breath alcohol testing has been conducted using electronic versions of an alcohol testing form that mirrors the DOT ATF for more than five years. Based on experience using those electronic forms for non-DOT testing, DISA cites improved efficiency and accuracy of documentation because: (1) employer and employee information is entered via computer and thus not dependent on reading and deciphering hand-written entries, (2) date time stamps of the testing are automated and not subject to fluctuation or error, (3) transmission of documentation on completed tests is more secure using databases accessed only via protected password and personal identification number (PIN) to authorized employers or their designated agents, and (4) transmission of test result information is faster and more secure than existing transmission options of scanning and emailing attachments or facsimile.

DISA also noted that permitting use of an electronic ATF for DOT-regulated alcohol testing “will substantially reduce cost, by eliminating the requirement for the printing and distribution of carbonless three-ply paper ATFs. The proposed electronic ATF option would still provide for printed paper images to be made available to the employee, the employer, and the alcohol technician, [but] eliminates the requirement for the more expensive carbonless 3 ply paper ATF.”

For the reasons described by DISA in its petition, and recognizing that significant benefits and cost reductions have resulted from use of the electronic CCF for drug testing, we believe that it is likewise appropriate to permit the use of electronic ATFs in part 40 for DOT-regulated testing. Permitting but not requiring the use of an electronic ATF would be consistent with our proposal to permit, but not require, the use of electronic documents and signatures throughout the entirety of part 40 as discussed above. As several commenters noted, the use of an electronic ATF has been used in non-DOT testing for 5-10 years, and the same developers of the electronic CCFs have developed the electronic ATFs. Any electronic ATF used under part 40 for DOT-regulated employees would have to be identical in form and content to the DOT ATF in appendix I to part 40. 8 Just as we imposed general confidentiality and security requirements when electronic CCFs were permitted to be used under part 40, we believe that it is necessary to include the same general requirements relating to the use of electronic ATFs to ensure that confidential employee records cannot be accessed by unauthorized persons.

8 The ATF form was redesignated from appendix G to appendix I as part of the rulemaking process culminating in the May 2023 final rule. During that process, the form was reviewed by the public and DOT received no comment on the form.

Manufacturers of EBTs and alcohol screening devices (ASD) used in DOT alcohol tests must obtain approval from the National Highway Traffic Safety Administration (NHTSA) and then be listed on the Office of Drug and Alcohol Policy and Compliance's (ODAPC) website before those devices may be used in DOT alcohol testing.

IX. PHMSA Proposed Changes

PHMSA is proposing to amend §§199.3, 199.117, and 199.227 and to add §199.4 to conform to the proposed changes in part 40 and to clarify that the proposed changes in part 40 apply to part 199. These changes will help the readers of part 199 find the applicable regulations in part 40 with regards to the definition of terms and record keeping requirements. We also propose to amend §§199.119 and 199.229 by changing the reference of “appendix H” to “appendix J” to conform to the amendment of part 40 published on May 2, 2023.

X. Section-by-Section Analysis

Section 40.3 What do the terms used in this regulation mean?

We propose to add a definition of “electronic signature.” The rule would define an electronic signature as a method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 44 U.S.C. 3504 note, 112 Stat. 2681-749). Including the specific cross reference to GPEA would ensure that regulated entities know that we are using GPEA's performance standard for allowing use of electronic signatures.

We propose to add a definition of “written or in writing.” The rule would define written or in writing as printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of 49 CFR 40.4. This definition would eliminate any distinction between paper and electronic methods of communication/documentation.

Section 40.4 May electronic documents and signatures be used?

We propose to add a new §40.4 that would prescribe the requirements pertaining to electronic documents and signatures throughout part 40.

Paragraph (a) would specify that §40.4 would apply to all documents required by part 40, except for the CCF, as an electronic CCF may only be used when approved by HHS and in compliance with §40.40(c)(5). As background, before an HHS-certified laboratory can use a Federal electronic CCF for regulated specimens, the test facility must submit a detailed plan and proposed standard operating procedures for the electronic CCF system for HHS review and approval through the National Laboratory Certification Program. At the current time, several HHS-certified laboratories have received approval to use a combination electronic/paper CCF, while four laboratories have received approval to use a fully electronic CCF. As noted earlier, and in a separate section of the SUPPORT Act, HHS was required to set a deadline for certified laboratories to request approval for use of fully electronic CCFs. That deadline is now August 31, 2026.

Paragraph (b) would permit, but not require, any person or entity to use electronic methods to comply with any provision in part 40 that requires a document to be signed, certified, generated, maintained, or transmitted between parties. It would apply to all forms of written documentation, including forms, records, notations, and other documents. The substance of the document would otherwise have to comply with part 40 requirements. This would establish parity between paper and electronic documents and signatures, greatly expanding interested parties' ability to use electronic methods to comply with the requirements of part 40.

Paragraph (c) would permit, but not require, any entity required to sign or certify a document to do so using electronic signatures as defined in §40.3. The rule specifies that a person may use any available technology so long as the signature otherwise complies with the requirements of part 40.

Paragraph (d) would establish the minimum requirements for electronic documents and signatures. Any electronic document or signature would be considered the legal equivalent of a paper document or signature if it is the functional equivalent with respect to integrity, accuracy, and accessibility. In other words, the electronic documents or signatures need to accurately and reliably reflect the information in the record. They must remain accessible in a form that could be accurately viewed or reproduced according to Agency rules. As with any documents, paper or electronic, documents that are not legible—for any reason—do not satisfy the Department's requirements.

Electronic documents are not to be considered the legal equivalent of traditional paper documents if they (1) are not capable of being retained, (2) are not used for the purpose for which they were created, or (3) cannot be accurately reproduced for reference by any entity entitled to access by law, for the period of time required by the Department's recordkeeping requirements.

Paragraph (d) would also require that any electronically signed documents must incorporate or otherwise include evidence that both parties to the document have consented to the use of electronic signatures, as required by the E-SIGN Act (15 U.S.C. 7001(c)).

Paragraph (e) would require that when using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records cannot be accessed by unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The proposed requirements are analogous to those established in the current §40.40(c)(5) when we approved use of the electronic CCF in part 40.

Section 40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?

Currently, paragraph (g) makes it clear that the release of information under this section must be in any written form, and the parenthetical clarifies that this can be paper-based (written, fax) or electronic (email). Under the proposed definition of “written or in writing,” there is no distinction between paper-based and electronic communications. Because “written or in writing” would mean either paper or electronic communications, we propose to remove parenthetical reference to “fax, email, letter” to eliminate redundancy and confusion. All parties can conduct their business using either paper or electronic means of documentation and communication.

Section 40.79 How is the collection process completed?

Currently, paragraph (a)(9) of this section requires the collector to “fax or otherwise transmit” Copy 2 of the CCF to the MRO and Copy 4 to the DER within 24 hours or during the next business day. We propose to amend this section by removing reference to the methods of transmitting receipts, so parties can choose their own medium of communication.

Section 40.97 What do laboratories report and how do they report it?

For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraphs (c)(1) and (2) of this section.

Section 40.111 When and how must a laboratory disclose statistical summaries and other information it maintains?

For the same reasons explained in the discussion of §40.79, we propose to amend paragraph (b) of this section to remove the references to the methods of transmitting the summary or report required by this section. Because the summary or report can be transmitted via hard copy or electronically, there is no need to specify how it must be transmitted. As such, we propose to amend the title of this section accordingly.

Section 40.127 What are the MRO's functions in reviewing negative test results?

For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (c)(2) of this section.

Section 40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative test results?

For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (b)(2) of this section.

Section 40.163 How does the MRO report drug test results?

For the same reasons explained in the discussion of §40.25, we propose to remove the reference to a “letter” in paragraph (c) of this section. In paragraph (e) of this section, we propose to replace the term “letter” with “written report” for consistency with paragraph (c).

Section 40.167 How are MRO reports of drug results transmitted to the employer?

For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (c)(1) of this section.

Section 40.185 Through what methods and to whom must a laboratory report split specimen results?

For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (b) of this section. In addition, because Copy 1 of the CCF can be transmitted in writing or electronically, there is no need to specify the methods through which it must be transmitted. As such, we propose to amend the title of this section accordingly.

Section 40.187 What does the MRO do with split specimen laboratory results?

For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraph (c)(2)(iv)(C) of this section.

Section 40.191 What is a refusal to take a DOT drug test, and what are the consequences?

For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (d) of this section as means of transmitting notification that an employee has refused to participate in part of the testing process from the collector or MRO to the DER.

Section 40.193 What happens when an employee does not provide a sufficient amount of urine for a drug test?

For the same reasons explained in the discussion of §40.25, we propose to delete the references to “send or fax” as the means for the collector to transmit copies of the CCF to the MRO and the DER in paragraph (b)(3) of this section.

Section 40.205 How are drug test problems corrected?

For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a collector, laboratory, MRO, employer, or other person to supply signed statements regarding correctable problems in a drug test in paragraphs (b)(1) and (2) of this section.

Section 40.225 What form is used for an alcohol test?

We propose to amend this section to permit, but not require, the use of an electronic version of the DOT ATF that is identical in form and content to the form provided in appendix I to part 40. The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT, and if an EBT provides a separate printout of confirmation test results pursuant to §40.253(g), the electronic ATF must include that separate printout. This section would also be amended to specify the same general confidentiality and security measures in §40.45 relating to electronic CCFs to ensure that confidential employee records cannot be accessed by unauthorized persons.

Section 40.255 What happens next after the alcohol confirmation test result?

For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (a)(5)(i) of this section as means of transmitting results of the alcohol confirmation test from the BAT to the DER. Similarly, there is no need to specify that Copy 1 of the ATF may be transmitted “in person, by telephone, or by electronic means.”

Section 40.261 What is a refusal to take an alcohol test, and what are the consequences?

For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (c) of this section as means of transmitting a refusal notification from a BAT, STT, or referral physician to the DER.

Section 40.271 How are alcohol testing problems corrected?

For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a STT, BAT, employer, or other service agent to supply a signed statement regarding correctable flaws in an alcohol test in paragraph (b)(2) of this section.

Section 40.365 What is the Department's policy concerning starting a PIE proceeding?

We propose to amend this section by adding a new paragraph (b)(15) that would identify the failure of a service agent to provide or maintain a secure/confidential electronic system as appropriate grounds for starting a PIE proceeding.

X. Regulatory Analyses and Notices

Executive Orders 12866, 13563, and 14094 (Regulatory Planning and Review)

The Secretary has examined the impact of the proposed part 40 amendments under Executive Order 12866 (“Regulatory Planning and Review”), as supplemented by Executive Order 13563 (“Improving Regulation and Regulatory Review”) and amended by Executive Order 14094 (“Modernizing Regulatory Review”), which directs Federal agencies to assess all costs and benefits of available regulatory alternatives and, when regulation is necessary, to select regulatory approaches that maximize net benefits (including potential economic, environmental, public health and safety, and other advantages; distributive impacts; and equity).

According to these Executive orders, a regulatory action is “significant” if it meets any one of a number of specified conditions, including having an annual effect on the economy of $200 million or more, as adjusted every three years by the Office of Information and Regulatory Affairs (OIRA); adversely affecting in a material way a sector of the economy, competition, or jobs; or if it raises novel legal or policy issues. The proposed amendments, which would allow the use of electronic documents and signatures, do not meet the Executive order's criteria for being a significant rule. Consequently, OMB has determined that the rulemaking action is not significant under the Executive order.

The proposed rule responds to the statutory mandate set forth in Section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271. The proposed rule would not impose new requirements on the industry; rather, it would simply permit—but not require—regulated entities to use electronic signatures, forms, and recordkeeping, and remove outdated and obsolete references in the regulatory text. The proposed rule would not impose new costs on the industry because regulated entities would be allowed to choose to continue to use paper-based documents as they had before. The benefits of the rule would stem from savings in paper and printing expense and other efficiency gains. Examples of documents affected by this rule include, but are not limited to, records of a prospective employee's drug and alcohol testing history that employers must obtain prior to permitting that employee to perform safety-sensitive duties, MRO records and reports, SAP records and reports, and ATFs. While there is no way to estimate how many entities or individuals would change their practices given the new options, or how many documents would be affected, several commenters to the ANPRM stated that they have been using electronic documents and signatures in their non-DOT drug and alcohol testing programs for many years. While neither the benefits nor the costs of this rule can be reliably estimated, we expect this proposed rule to provide flexibility to the industry. Under this proposed rule, regulated entities would have the flexibility to conduct business using either electronic or traditional paper-based methods. We also expect regulated entities to choose technologies that would maximize benefits in accordance with their individual needs and circumstances.

Regulatory Flexibility Act and Small Business Regulatory Enforcement Fairness Act (SBREFA)

The Regulatory Flexibility Act of 1980 (5 U.S.C. 601 et seq. ) requires Federal agencies to consider the effects of their regulatory actions on small businesses and other small entities and minimize any significant economic impact. The term “small entities” comprises small businesses and not-for-profit organizations that are independently owned and operated and are not dominant in their fields, and governmental jurisdictions with a population of less than 50,000. For this rulemaking, potentially affected small entities include drug testing companies (U.S. Small Business Administration (SBA) North American Industry Classification System (NAICS) Sector 54 (Professional, Scientific and Technical Services), Code 541380 (Testing Laboratories and Services)) as well as DOT-regulated entities (SBA NAICS Sectors 48-49 (Transportation and Warehousing)).

The Department does not expect that the proposed rule would have a significant economic impact on a substantial number of small entities. The proposed rule, if adopted, would increase flexibility for all small-entity transportation employers and their service agents by allowing them to use electronic documents, signatures, and recordkeeping to meet part 40 requirements. Use of electronic documents, electronic signatures, and electronic recordkeeping would be voluntary for affected small entities, which will provide added flexibility to these entities in meeting the part 40 requirements. For these reasons, and as explained in more detail in the preamble to this proposed rule, the Secretary certifies that the proposed rule would not have a significant economic impact on a substantial number of small entities within the meaning of the Regulatory Flexibility Act. Consequently, an initial regulatory flexibility analysis is not required for this proposed rule.

Unfunded Mandates

The Secretary has examined the impact of the final rule under the Unfunded Mandates Reform Act (UMRA) of 1995 (Pub. L. 104-4). This NPRM does not trigger the requirement for a written statement under sec. 202(a) of the UMRA because this rulemaking does not impose a mandate that results in an expenditure of $100 million (adjusted annually for inflation) or more by either State, local, and tribal governments in the aggregate or by the private sector in any one year. In fact, by providing an alternative to traditional paper-based records, the proposed rule would be expected to reduce costs to regulated parties, including State and local entities ( e.g., public transit authorities, and public works departments) whose employees are subject to testing and that choose to use electronic documents as opposed to paper-based documents.

Environmental Impact

The DOT has analyzed the environmental impacts of this action pursuant to the National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321 et seq. ) and has determined that it is categorically excluded pursuant to DOT Order 5610.1C, “Procedures for Considering Environmental Impacts” (44 FR 56420, October 1, 1979). Categorical exclusions are actions identified in an agency's NEPA implementing procedures that do not normally have a significant impact on the environment and therefore do not require either an environmental assessment (EA) or environmental impact statement (EIS). This proposed rule would amend the transportation industry drug testing program procedures regulation to permit the use of electronic documents, signatures, and recordkeeping. This action is covered by the categorical exclusion listed at 23 CFR 771.118(c)(4), “[p]lanning and administrative activities that do not involve or lead directly to construction, such as: . . . promulgation of rules, regulations, directives . . .” The Department does not anticipate any environmental impacts, and there are no extraordinary circumstances present in connection with this rulemaking.

Executive Order 13132: Federalism

The Secretary has analyzed the final rule in accordance with Executive Order 13132: Federalism. Executive Order 13132 requires Federal agencies to carefully examine actions to determine if they contain policies that have federalism implications or that preempt State law. As defined in the order, “policies that have federalism implications” refer to regulations, legislative comments or proposed legislation, and other policy statements or actions that have substantial direct effects on the States, on the relationship between the National Government and the States, or on the distribution of power and responsibilities among the various levels of government.

Most of the regulated parties under the Department's drug testing program are private entities. Some regulated entities are public entities ( e.g., transit authorities and public works departments); however, as noted above, this proposal would reduce costs of the Department's drug testing program and provide additional flexibility for regulated parties. Accordingly, the Secretary has determined that the proposed rule, which would allow but not require use of electronic signatures and recordkeeping, does not contain policies that have federalism implications.

Executive Order 13175: Consultation and Coordination With Indian Tribal Governments

Executive Order 13175 (65 FR 67249, November 6, 2000) requires Federal agencies to develop an accountable process to ensure “meaningful and timely input by tribal officials in the development of regulatory policies that have tribal implications.” “Policies that have tribal implications” as defined in the Executive order, include regulations that have “substantial direct effects on one or more Indian tribes, on the relationship between the Federal government and the Indian tribes, or on the distribution of power and responsibilities between the Federal government and Indian tribes.” This proposed rule does not have tribal implications. The proposed rule will also not have substantial direct effects on tribal governments, on the relationship between the Federal Government and Indian tribes, or on the distribution of power and responsibilities between the Federal Government and Indian tribes, as specified in Executive Order 13175.

Paperwork Reduction Act

The Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520) (PRA) requires that DOT consider the impact of paperwork and other information collection burdens imposed on the public. This proposed rule would call for no new collection of information under the PRA. Instead, there would likely be a significant reduction in the burden hours required for information collection 2105-0529, Procedures for Transportation Drug and Alcohol Testing Program, due to the ability to use electronic signatures and forms, and largely due to the ability to use an electronic ATF for DOT-regulated alcohol testing under part 40. We request comments on this issue. Notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information subject to the PRA that does not display a currently valid OMB control number.

Privacy Act

Anyone is able to search the electronic form of all comments received in any of our dockets by the name of the individual submitting the comment (or signing the comment, if submitted on behalf of an association, business, labor union, etc.) For information on DOT's compliance with the Privacy Act, please visit https://www.transportation.gov/privacy.

5 U.S.C. 553(b)(4)

As required by 5 U.S.C. 553(b)(4), a summary of this proposed rule can be found at the entry for RIN 2105-AF01 in the Department's Portion of the Unified Agenda of Regulatory and Deregulatory Affairs, available at https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202404&RIN=2105-AF01 .

Pay-As-You-Go Act of 2023

In accordance with Compliance with Pay-As-You-Go Act of 2023 (Fiscal Responsibility Act of 2023, Pub. L. 118-5, div. B, title III) and OMB Memorandum (M-23-21) dated September 1, 2023, the Department has determined that this proposed rule is not subject to the Pay-As-You-Go Act of 2023 because it will not increase direct spending beyond specified thresholds.

List of Subjects

49 CFR Part 40

Administrative practice and procedures, Alcohol abuse, Alcohol testing, Drug abuse, Drug testing, Laboratories, Reporting and recordkeeping requirements, Safety, Transportation.

49 CFR Part 199

Alcohol testing, Drug testing, Pipeline safety, Reporting and recordkeeping requirements, Safety, Transportation.

For the reasons stated in the preamble, the Department proposes to amend 49 CFR parts 40 and 199 as follows:

PART 40—PROCEDURES FOR TRANSPORTATION WORKPLACE DRUG AND ALCOHOL TESTING PROGRAMS

1. The authority for part 40 continues to read as follows:

Authority:

49 U.S.C. 102, 301, 322, 5331, 20140, 31306, and 54101 et seq.

2. In §40.3, add the definitions of “Electronic signature” and “Written or in writing” in alphabetical order to read as follows:

§40.3 What do the terms used in this part mean?

* * * * *

Electronic signature. A method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 112 Stat. 2681-749, 44 U.S.C. 3504 note).

* * * * *

Written or in writing. Printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of §40.4.

3. Add §40.4 to read as follows:

§40.4 May electronic documents and signatures be used?

(a) Applicability. This section applies to all documents required by this part, except for the CCF. An electronic CCF may be used only if it has been approved for use by the Department of Health and Human Services and is used in compliance with §40.40(c)(5).

(b) Electronic records or documents. Any person or entity required to generate, maintain, or exchange and/or transmit documents to satisfy requirements in this part may use electronic methods to satisfy those requirements.

(c) Electronic signatures. (1) Any person or entity required to sign or certify a document to satisfy the requirements of this part may use an electronic signature, as defined in §40.3.

(2) Any available technology may be used that satisfies the requirements of an electronic signature as defined in §40.3.

(d) Electronic document requirements. Any person or entity may use documents signed, certified, generated, maintained, or exchanged using electronic methods, as long as the documents accurately reflect the information otherwise required to be contained in them.

(1) Records, documents, or signatures generated, maintained, or exchanged using electronic methods satisfy the requirements of this section if they are capable of being retained, are used for the purpose for which they were created, and can be accurately reproduced within required timeframes for reference by any party entitled to access.

(2) Records or documents generated electronically satisfy the requirements of this section if they include proof of consent to use electronically generated records or documents, as required by 15 U.S.C. 7001(c).

(e) Confidentiality and security. When using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form to include protecting against destruction, deterioration, and data corruption.

4. In §40.25, revise paragraph (g) to read as follows:

§40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?

* * * * *

(g) The release of information under this section must be in any written form that ensures confidentiality. As the previous employer, you must maintain a written record of the information released, including the date, the party to whom it was released, and a summary of the information provided.

* * * * *

5. In §40.79, revise paragraph (a)(9) to read as follows:

§40.79 How is the collection process completed?

(a) * * *

(9) Send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or during the next business day. Keep Copy 3 for at least 30 days, unless otherwise specified by applicable DOT agency regulations.

* * * * *

6. In §40.97, revise paragraphs (c) introductory text, (c)(1) introductory text, and (c)(2) to read as follows:

§40. 97 What do laboratories report and how do they report it?

* * * * *

(c) As a laboratory, you must report laboratory results directly, and only, to the MRO at his or her place of business. You must not report results to or through the DER or a service agent ( e.g., C/TPA).

(1) Negative results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF which has been signed by the certifying scientist, or you may provide the laboratory results report electronically.

* * * * *

(2) Non-negative and rejected for testing results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF that has been signed by the certifying scientist. In addition, you may provide the laboratory results report following the format and procedures set forth in paragraphs (c)(1)(i) and (ii) of this section.

* * * * *

7. In §40.111, revise the section heading and paragraph (b) to read as follows:

§40.111 When must a laboratory disclose statistical summaries and other information it maintains?

* * * * *

(b) When the employer requests a summary in response to an inspection, audit, or review by a DOT agency, you must provide it unless the employer had fewer than five aggregate test results. In that case, you must send the employer a report indicating that not enough testing was conducted to warrant a summary.

* * * * *

8. In §40.127, revise paragraph (c)(2) to read as follows:

§40.127 What are the MRO's functions in reviewing negative test results?

* * * * *

(c) * * *

(2) A legible copy of Copy 1 of the CCF or the electronic laboratory results report that conveys the negative laboratory test result.

* * * * *

9. In §40.129, revise paragraphs (b) introductory text and (b)(2) to read as follows:

§40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative drug test results?

* * * * *

(b) Before you report a verified negative, positive, test cancelled, refusal to test because of adulteration or substitution, you must have in your possession the following documents:

* * * * *

(2) A legible copy of Copy 1 of the CCF, containing the certifying scientist's signature.

* * * * *

10. In §40.163, revise paragraphs (c) introductory text and (e) to read as follows:

§40.163 How does the MRO report drug test results?

* * * * *

(c) If you do not report test results using Copy 2 of the CCF for the purposes of this section, you must provide a written report for each test result. This report must, as a minimum, include the following information:

* * * * *

(e) You must retain a signed or stamped and dated copy of Copy 2 of the CCF in your records. If you do not use Copy 2 for reporting results, you must maintain a copy of the signed or stamped and dated written report in addition to the signed or stamped and dated Copy 2. If you use the electronic data file to report negatives, you must maintain a retrievable copy of that report in a format suitable for inspection and auditing by a DOT representative.

* * * * *

11. In §40.167, revise paragraph (c)(1) to read as follows:

§40.167 How are MRO reports of drug test results transmitted to the employer?

* * * * *

(c) * * *

(1) You must transmit a legible image or copy of either the signed or stamped and dated Copy 2 or the written report (see §40.163(b) and (c)).

* * * * *

12. In §40.185, revise the section heading and paragraph (b) to read as follows:

§40.185 What and to whom must a laboratory report split specimen results?

* * * * *

(b) You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF, which has been signed by the certifying scientist.

* * * * *

13. In §40.187, revise paragraph (c)(2)(iv)(C) to read as follows:

§40.187 What does the MRO do with split specimen laboratory results?

* * * * *

(c) * * *

(2) * * *

(iv) * * *

(C) As the laboratory that tests the primary specimen to reconfirm the presence of the adulterant found in the split specimen and/or to determine that the primary specimen meets appropriate substitution criteria, report your result to the MRO using a copy of Copy 1 of the CCF.

* * * * *

14. In §40.191, revise paragraph (d) introductory text to read as follows:

§40.191 What is a refusal to take a DOT drug test, and what are the consequences?

* * * * *

(d) As a collector or an MRO, when an employee refuses to participate in the part of the testing process in which you are involved, you must terminate the portion of the testing process in which you are involved, document the refusal on the CCF (including, in the case of the collector, printing the employee's name on Copy 2 of the CCF), immediately notify the DER by any means that ensures that the refusal notification is immediately received. As a referral physician ( e.g., physician evaluating a “shy bladder” condition or a claim of a legitimate medical explanation in a validity testing situation), you must notify the MRO, who in turn will notify the DER.

* * * * *

15. In §40.193, revise paragraph (b)(3) to read as follows:

§40.193 What happens when an employee does not provide a sufficient amount of specimen for a drug test?

* * * * *

(b) * * *

(3) As the collector, you must send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or the next business day.

* * * * *

16. In §40.205, revise paragraphs (b)(1) and (2) to read as follows:

§40.205 How are drug test problems corrected?

* * * * *

(b) * * *

(1) If the problem resulted from the omission of required information, you must, as the person responsible for providing that information, supply in writing the missing information and a statement that it is true and accurate. For example, suppose you are a collector, and you forgot to make a notation on the “Remarks” line of the CCF that the employee did not sign the certification. You would, when the problem is called to your attention, supply a signed statement that the employee failed or refused to sign the certification and that your statement is true and accurate. You must supply this information on the same business day on which you are notified of the problem.

(2) If the problem is the use of a non-Federal form or an expired Federal form, you must provide a signed statement ( i.e., a memorandum for the record). It must state that the incorrect form contains all the information needed for a valid DOT drug test, and that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control. The statement must also list the steps you have taken to prevent future use of non-Federal forms or expired Federal forms for DOT tests. For this flaw to be corrected, the test of the specimen must have occurred at an HHS-certified laboratory where it was tested consistent with the requirements of this part. You must supply this information on the same business day on which you are notified of the problem.

* * * * *

17. In §40.225, revise paragraph (a) and add paragraphs (d) and (e) to read as follows:

§40.225 What form is used for an alcohol test?

(a) The DOT Alcohol Testing Form (ATF) must be used for every DOT alcohol test. The ATF must be a three-part carbonless manifold form or an electronic ATF that meets the requirements of paragraph (d) of this section. The ATF is found in appendix G to this part. You may view this form on the ODAPC website ( https://www.transportation.gov/odapc ).

* * * * *

(d) As an employer, you may use an electronic ATF that meets the following requirements:

(1) The electronic ATF must be identical in form and content to the ATF found in appendix G to this part.

(2) The electronic ATF must meet the requirements of §40.4(d).

(3) The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT.

(4) If an EBT provides a separate printout of confirmation test results (see §40.253(g)), the electronic ATF must include that separate printout.

(e) As an employer, BAT, or STT using an electronic ATF, you must establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form.

18. In §40.255, revise paragraph (a)(5)(i) to read as follows:

§40.255 What happens next after the alcohol confirmation test result?

(a) * * *

(5) * * *

(i) You may transmit the results using Copy 1 of the ATF, in person, by telephone, or by electronic means. In any case, you must immediately notify the DER of any result of 0.02 or greater by any means that ensures the result is immediately received by the DER. You must not transmit these results through C/TPAs or other service agents.

* * * * *

19. In §40.261, revise paragraph (c)(1) to read as follows:

§40.261 What is a refusal to take an alcohol test, and what are the consequences?

* * * * *

(c)(1) As a BAT or an STT, or as the physician evaluating a “shy lung” situation, when an employee refuses to test as provided in paragraph (a) of this section, you must terminate the portion of the testing process in which you are involved, document the refusal on the ATF (or in a separate document which you cause to be attached to the form), immediately notify the DER by any means that ensures the refusal notification is immediately received. You must make this notification directly to the DER (not using a C/TPA as an intermediary).

* * * * *

20. In §40.271, revise paragraph (b)(2) to read as follows:

§40.271 How are alcohol testing problems corrected?

* * * * *

(b) * * *

(2) If the problem is the use of a non-DOT form, you must, as the person responsible for the use of the incorrect form, certify in writing that the incorrect form contains all the information needed for a valid DOT alcohol test. You must also provide a signed statement that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control, and the steps you have taken to prevent future use of non-DOT forms for DOT tests. You must supply this information on the same business day on which you are notified of the problem.

* * * * *

21. In §40.365, revise paragraphs (b)(13) and (14) and add paragraph (b)(15) to read as follows:

§40.365 What is the Department's policy concerning starting a PIE proceeding?

* * * * *

(b) * * *

(13) For any service agent, directing or recommending that an employer fail or refuse to implement any provision of this part;

(14) With respect to noncompliance with a DOT agency regulation, conduct that affects important provisions of Department-wide concern ( e.g., failure to properly conduct the selection process for random testing); or

(15) For a service agent, failing to provide or maintain a secure/confidential electronic system. PART 199—DRUG AND ALCOHOL TESTING

22. The authority citation for part 199 continues to read as follows:

Authority:

49 U.S.C. 5103, 60102, 60104, 60108, 60117, and 60118; 49 CFR 1.53.

23. In §199.3:

a. Designate the introductory text as paragraph (b); and

b. Add paragraph (a).

The addition reads as follows:

§199.3 Definitions.

(a) Terms used in this part have the same meaning as in 49 CFR 40.3.

* * * * *

24. Add §199.4 to read as follows:

§199.4 Electronic documents, records, and signatures.

Electronic documents, records, and signatures may be used to comply with this part provided they meet the requirements specified in 49 CFR part 40.

25. In §199.117, revise paragraph (a) introductory text to read as follows:

§199.117 Recordkeeping.

(a) Each operator shall keep the records in paragraphs (a)(1) through (5) of this section for the periods specified by this section or for the periods specified by 49 CFR part 40, whichever is greater; and will permit access to the records as provided by §190.203.

* * * * *

26. In §199.119, revise paragraph (a) to read as follows:

§199.119 Reporting of anti-drug testing results.

(a) Each large operator (having more than 50 covered employees) must submit an annual Management Information System (MIS) report to PHMSA of its anti-drug testing using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.

* * * * *

27. In §199.227, revise paragraph (b) introductory text to read as follows:

§199.227 Retention of records.

* * * * *

(b) Period of retention. Each operator shall maintain the records in accordance with the following schedule or for the periods specified by 49 CFR part 40, whichever is greater:

* * * * *

28. In §199.229, revise paragraph (a) to read as follows:

§199.229 Reporting of alcohol testing results.

(a) Each large operator (having more than 50 covered employees) must submit an annual MIS report to PHMSA of its alcohol testing results using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.

* * * * *

Signed on: Thursday, October 3, 2024.

Pete Buttigieg,

Secretary of Transportation.

[FR Doc. 2024-23427 Filed 10-11-24; 8:45 am]

BILLING CODE 4910-9X-P

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Most Recent Highlights In Environmental

EPA updates preconstruction permitting guidance: What are the impacts on major sources?
2026-07-29T05:00:00Z

EPA updates preconstruction permitting guidance: What are the impacts on major sources?

Where there’s construction, there are permits, and where there are permits, there are usually delays. For major construction projects in areas with poor air quality, the delay could be due to emission credits. New federal guidance, however, may help reduce those delays.

The Environmental Protection Agency (EPA) recently released guidance clarifying that Nonattainment New Source Review (NNSR) preconstruction permits may be issued to applicants before they obtain the required offsetting emission reduction credits (ERCs) if certain conditions are met.

The new guidance for permitting authorities (usually state or local air agencies) is a change in the agency’s recommended approach, designed to help prevent preconstruction permitting delays for applicants that haven’t yet formally secured ERCs. So, what does this mean for facilities? Let’s take a look!

Which construction projects could be affected?

EPA’s new guidance impacts construction projects in nonattainment areas. These are areas where emissions exceed the National Ambient Air Quality Standards (NAAQS) for any of the six regulated criteria air pollutants.

You need an NNSR permit to build a new major stationary source or make major modifications to an existing major stationary source if:

  • The new or modified source is located in a nonattainment area, and
  • The new or modified source emits or has the potential to emit a regulated pollutant in amounts that meet the applicable major source or major modification thresholds.

You must obtain an NNSR permit before construction begins. NNSR permits can be issued only if the applicant meets certain conditions, one of which is meeting emission offset requirements.

What are emission offsets?

Emission offsets are reductions in emissions from existing sources that can be used to compensate for emissions from a new or modified source. The Clean Air Act requires new and modified major sources to offset emissions by obtaining sufficient ERCs from existing sources located in the same nonattainment area.

In other words, a new or modified major source must get enough credits from existing nearby sources to cover the total amount of emissions that the facility will add to the area.

How does the guidance impact permitting?

EPA’s previous guidance recommended that NNSR permits generally shouldn’t be issued until ERCs are actually secured. As a result, permitting agencies require applicants to obtain ERCs before issuing an NNSR permit to start construction on a facility, even if the facility won’t immediately begin operations.

Guidance on Clean Air Act Nonattainment New Source Review Emissions Offsets (ERC guidance), issued by EPA on July 1, 2026, changes the agency’s recommended approach. It clarifies that permitting authorities may issue NNSR permits before applicants specifically secure the required ERCs if the permit contains:

  • A federally enforceable commitment by the permit applicant to obtain the needed ERCs before starting operations, and
  • An express ban on starting operations until the required ERCs are obtained with appropriate permit restrictions on the sources providing the ERCs.

What’s the possible impact on facilities?

Permitting authorities that apply ERC guidance to permitting decisions can issue NNSR permits to qualifying sources before they secure ERCs. This would allow applicants to start construction on or modifications to a major source without delay, provided the enforceable permit conditions are met.

Here's an example:

A business is ready to build a manufacturing plant in a nonattainment area, but operations at the new facility won’t begin until a year after construction is complete.

Under previous guidance, the business couldn’t begin construction on the manufacturing plant until it formally secured the required ERCs upfront for operations that won’t start until a year after the facility is complete.

EPA’s ERC guidance would allow the permitting authority to issue the business an NNSR permit before it obtains the ERCs. That means the business could build the manufacturing plant right away and then secure the ERCs later, closer to the time the facility starts operating.

Keep these points in mind!

Consider the following when determining how EPA’s updated NNSR policy may impact your construction project:

  • The ERC guidance is nonbinding, meaning that permitting authorities aren’t required to implement the guidance. Permitting authorities can still require applicants to secure ERCs before issuing NNSR permits.
  • Facilities may be able to start construction without first securing ERCs, but facilities can’t begin operating until they secure the required ERCs.
  • Most NNSR permits are issued on a state or local level. Confirm the specific requirements that apply to your major source construction project with the relevant state or local permitting authority.

Key to remember: EPA’s guidance allows permitting authorities to issue preconstruction permits for new major sources and major modifications in nonattainment areas before the sources secure emission reduction credits.

EPA extends PCE and CTC compliance deadlines
2026-07-28T05:00:00Z

EPA extends PCE and CTC compliance deadlines

The Environmental Protection Agency (EPA) has extended the compliance dates of certain Workplace Chemical Protection Program (WCPP) requirements for perchloroethylene (PCE) and carbon tetrachloride (CTC) established under the Toxic Substances Control Act (TSCA).

Published on July 28, 2026, EPA’s final rule changes specific compliance dates but doesn’t alter the underlying WCPP requirements or the agency’s determination that PCE and CTC present unreasonable risks.

Who’s impacted?

The revised deadlines affect facilities subject to the TSCA PCE and CTC risk management rules finalized in 2024. These include entities that manufacture (including import), process, distribute in commerce, use, or dispose of:

  • PCE,
  • CTC, or
  • Products containing PCE or CTC.

What are the new PCE and CTC compliance dates?

EPA’s final rule extends compliance deadlines for various WCPP requirements, including:

  • Conducting initial monitoring,
  • Meeting the existing chemical exposure limit (ECEL),
  • Establishing a regulated area,
  • Providing any required respiratory personal protective equipment (PPE) and establishing a respiratory PPE program,
  • Implementing a workplace information and training program, and
  • Establishing and implementing an exposure control plan (ECP).

Below is a summary of the new compliance deadlines.

WCPP requirementNew compliance deadlinePCE applicabilityCTC applicability
  • Initial monitoring for inhalation exposure
June 21, 2027Non-federal facilitiesNon-federal facilities
  • Meet ECEL
  • Establish regulated area
  • Provide respiratory PPE
  • Establish respiratory PPE program
September 20, 2027Non-federal facilitiesNon-federal facilities
  • Institute workplace information and training program
September 20, 2027Federal and non-federal facilitiesNon-federal facilities
  • Establish and implement ECP*
December 20, 2027Non-federal facilities

* EPA maintains the CTC rule’s WCPP compliance date of December 3, 2027, for federal and non-federal facilities to establish and implement an ECP.

Key to remember: EPA has extended compliance dates for certain PCE and CTC Workplace Chemical Protection Program requirements into 2027.

2026-07-24T05:00:00Z

New Mexico classifies AFFF as hazardous waste

Effective date: August 1, 2026

This applies to: Entities regulated by the New Mexico hazardous waste regulations

Description of change: The New Mexico Hazardous Waste Bureau adopted amendments and a new rule to regulate aqueous film-forming foam (AFFF) containing intentionally added per- and polyfluoroalkyl substances (PFAS).

Changes include:

  • Classifying AFFF with intentionally added PFAS as a hazardous waste (subject to New Mexico’s hazardous waste regulations); and
  • Establishing regulations for AFFF with intentionally added PFAS, including:
    • A periodic inventory of the substance,
    • Restricting the use of AFFF to emergency purposes only, and
    • Requiring cleanup of discarded AFFF according to the New Mexico Hazardous Waste Act regulations.

Note that the operational restrictions (20.13.3 NMAC) take effect on August 1, 2026, and the disposal and cleanup rules (20.4.1) take effect on December 1, 2026.

Related state info: Hazardous waste generators — New Mexico

2026-07-24T05:00:00Z

Colorado revises annual emissions reporting requirements

Effective date: July 15, 2026

This applies to: Sources subject to Regulations 3 and 7 annual reporting requirements

Description of change: The Colorado Air Quality Control Commission amended Regulation Numbers 3 and 7. The revisions:

  • Remove the duplicate greenhouse gas (GHG) air pollutant emission notice (APEN) reporting requirement for sources required by Regulation Number 22 to report GHG emissions annually;
  • Streamline reporting requirements for annual estimated emissions reports required by Regulation Numbers 3 and 7 (for certain non-oil and gas sector sources and for upstream and midstream oil and gas sector sources, respectively) by specifying that their Emissions Reporting Notices (ERNs) will satisfy the requirements to submit revised APENs due to a change in actual emissions or solely before expiration;
  • Increase existing fees for APEN submissions, annual emissions, and application processing required by Regulation Number 3; and
  • Add a fee for filing ERNs required by Regulation 7 on a per-emission-point basis (with plans to require fees from all annual reporters eventually).

Streamlined reporting begins in 2027 for Regulation Number 7 annual emissions reports for calendar year 2026 emissions. The ERN filing fee for Regulation Number 7 reporters starts with the ERN filed in 2027 for calendar year 2026 emissions.

Related state info: Clean air operating permits state comparison

2026-07-24T05:00:00Z

Nevada revises hazardous waste recycling rules

Effective date: July 1, 2026

This applies to: Facilities and mobile units that manage recyclable materials classified as hazardous waste or hazardous secondary materials

Description of change: The Nevada State Environmental Commission adopted amendments to the hazardous waste recycling program regulations. Changes include:

  • Establishing one regulatory regime for facilities managing recyclable materials classified as either hazardous waste or hazardous secondary materials;
  • Exempting certain facilities or mobile units from the requirement to obtain a written determination from the Department of Conservation and Natural Resources before construction and providing that such facilities must comply with certain federal requirements, local zoning requirements if applicable, reporting and notification requirements, and other regulations;
  • Exempting certain facilities (if they’re subject to local zoning requirements) from prohibitions on the locations where new or expanding stationary facilities that manage hazardous waste may be built; and
  • Establishing an annual $5,000 fee for:
    • A written determination issued to new facilities or mobile units that the facilities or units will operate for recycling hazardous waste; and
    • Existing facilities that recycle certain hazardous waste and are subject to specific federal recycling requirements.
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Most Recent Highlights In Transportation

2026-07-24T05:00:00Z

Michigan updates fertilizer bulk storage requirements

Effective date: July 2, 2026

This applies to: Commercial bulk fertilizer storage facilities

Description of change: The amendments increase requirements related to physical and structural redundancy, maintenance, and recordkeeping. The rules align with the standards of the Association of American Plant Food Control Officials (AAPFCO) and the regulations established by similarly situated states. Some of the changes include:

  • Requiring every storage container to have a liquid level gauging device;
  • Requiring storage containers and appurtenances to be fenced, locked, or otherwise secured to protect against vandalism or unauthorized access that could result in a discharge; and
  • Allowing alternative diking for large storage tanks that use double steel wall systems.

Further, the rules require the Michigan Department of Agriculture and Rural Development to preapprove the construction of new or the modification of existing containment systems and operational areas.

ISO 14001:2026 arrives: Key changes for environmental management systems
2026-07-14T05:00:00Z

ISO 14001:2026 arrives: Key changes for environmental management systems

Environmental management has changed significantly since ISO 14001 was last revised in 2015. Climate-related risks, resource constraints, supply chain challenges, and stakeholder expectations have reshaped how organizations manage environmental issues. In response, the International Organization for Standardization (ISO) released ISO 14001:2026, the first major update to the environmental management system (EMS) standard in over a decade.

The revised standard doesn't change the purpose of ISO 14001. Organizations will continue to use an EMS to identify environmental aspects, meet compliance obligations, manage environmental risks, and improve environmental performance. However, the new edition clarifies requirements and places greater emphasis on measurable environmental results. ISO says the revision is intended to better align EMS programs with today's environmental challenges. Organizations certified to ISO 14001 may need to update procedures, documentation, audits, and management reviews.

Why was the standard updated?

When ISO published ISO 14001:2015, many organizations focused primarily on regulatory compliance. While compliance remains a core component of an EMS, environmental managers today face a broader range of issues. Climate impacts, resource availability, supply chain disruptions, and stakeholder expectations can all affect environmental planning and performance. Rather than creating an entirely new framework, the 2026 version largely builds on concepts that already existed in the 2015 edition while expanding and clarifying expectations.

Environmental context receives greater attention

A major theme of the revision is a stronger focus on organizational context. Organizations are expected to look beyond day-to-day compliance activities when identifying environmental risks and opportunities.

The revised standard emphasizes consideration of environmental conditions that may affect the EMS, including climate-related concerns, biodiversity, ecosystem impacts, and natural resource availability. Organizations are expected to evaluate how external issues and stakeholder expectations may influence environmental objectives and planning.

For environmental managers, this may mean expanding annual EMS reviews to evaluate emerging environmental issues that could affect operations, compliance obligations, permit conditions, or environmental objectives.

Change management moves into the spotlight

The revised standard also introduces a more structured approach to managing change. Many organizations already evaluate environmental impacts when making operational changes, but those reviews are often informal.

ISO 14001:2026 expects organizations to plan, manage, and evaluate changes that may affect environmental performance. Examples include:

  • Installing new equipment,
  • Expanding production capacity,
  • Changing raw materials,
  • Modifying waste management practices,
  • Switching suppliers, and
  • Adding new products or processes.

This requirement should sound familiar to many environmental professionals. Operational changes can affect air emissions, waste generation, wastewater discharges, stormwater exposure, and permit applicability. A structured review process can help identify environmental impacts before changes are implemented.

Lifecycle thinking and supply chains gain importance

Lifecycle thinking was already part of ISO 14001:2015, but the revised standard places greater emphasis on it. Organizations are expected to consider environmental impacts throughout the lifecycle of products and services, including activities involving suppliers, contractors, and externally provided products and services.

This requirement doesn't mean organizations are responsible for every environmental impact within their supply chain. Rather, it encourages organizations to understand how purchasing decisions, outsourced activities, and supplier relationships may affect environmental performance.

For some organizations, this could mean greater emphasis on supplier evaluations, procurement procedures, contractor oversight, or product stewardship initiatives.

Leadership involvement becomes more visible

ISO 14001:2026 also strengthens expectations related to leadership accountability. Environmental management is no longer viewed solely as the responsibility of the environmental department.

The revised standard emphasizes visible leadership involvement and broader organizational participation. Environmental responsibilities may extend beyond EHS personnel to departments such as operations, purchasing, engineering, and management. Organizations will need to demonstrate that leadership is actively engaged in environmental planning, resource allocation, and performance evaluation activities.

What should organizations do now?

Although organizations have time to prepare for the transition, environmental managers may want to begin evaluating their programs now. Early reviews can help identify gaps and reduce the likelihood of surprises during future audits.

Questions organizations may want to consider include:

  • Does the EMS adequately address climate, resources, and other emerging environmental issues?
  • Is there a documented process for evaluating environmental impacts before operational changes are made?
  • Are lifecycle considerations incorporated into purchasing and contractor management activities?
  • Can leadership involvement be demonstrated through documented actions and decisions?
  • Do environmental objectives show measurable performance improvements?

While ISO 14001:2026 is an evolution of the existing standard rather than a complete overhaul, organizations shouldn't assume existing EMS procedures will meet the revised expectations. Environmental managers may want to review how their systems address organizational context, change management, lifecycle considerations, and leadership involvement before their next audit.

Key to remember: For environmental professionals, the revised standard provides an opportunity to strengthen that connection and demonstrate the value that effective environmental management brings to the organization.

EPA releases 2026 regulatory agenda
2026-07-09T05:00:00Z

EPA releases 2026 regulatory agenda

The Environmental Protection Agency (EPA) published the 2026 Agenda of Regulatory and Deregulatory Actions on July 3, 2026. The agenda outlines the agency’s upcoming regulatory actions and their status in the rulemaking process. Many of the proposed and final rules support EPA’s continued deregulatory efforts.

Significant rulemaking on EPA’s docket includes the following:

  • Proposing risk management regulations under the Toxic Substances Control Act (TSCA) for various chemical substances, such as formaldehyde, diisodecyl phthalate (DIDP), and diisononyl phthalate (DINP);
  • Aligning the definition of “waters of the United States” with the Supreme Court’s Sackett v. Environmental Protection Agency (2023) decision, which narrowed the definition under the Clean Water Act;
  • Finalizing the part 2 risk management regulations for asbestos, including use and associated disposal requirements for legacy asbestos, asbestos-containing talc, and asbestos fibers other than chrysotile;
  • Repealing the Carbon Pollution Standards (CPS) that limit greenhouse gas emissions from fossil fuel-fired plants (or repealing a narrower set of requirements under the CPS); and
  • Establishing a federal permitting program under the Resource Conservation and Recovery Act (RCRA) for the disposal of coal combustion residuals (CCR).

Additionally, EPA continues to conduct rulemaking related to per- and polyfluoroalkyl substances (PFAS), such as:

  • Revising existing effluent limitations guidelines and standards (ELGs) to address PFAS discharges from PFAS manufacturing facilities and chromium electroplating facilities;
  • Extending the compliance deadlines for Maximum Contaminant Levels established by the National Primary Drinking Water Regulations (NPDWRs) for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS); and
  • Rescinding the NPDWRs for four PFAS.

This article highlights some of the major rules we’re monitoring closely. You can review the entire agenda to learn about all the rulemakings EPA plans to review, propose, and finalize. Please note that the agenda dates are tentative, indicating when the agency seeks to publish the rulemakings in the Federal Register.

Final Rule Stage
Projected publication dateTitle
July 2026Reconsideration of the Greenhouse Gas Reporting Program
August 20261-Bromopropane (1-BP); Regulation Under the Toxic Substances Control Act (TSCA)
October 2026Revisions to Standards for the Open Burning/Open Detonation of Waste Explosives
October 2026Secondary Lead Smelting: National Emissions Standard for Hazardous Air Pollutants (NESHAP) Technology Review and Reconsideration
January 2027Listing of Specific PFAS as Hazardous Constituents
Proposed Rule Stage
Projected publication date of notice of proposed rulemaking
Title
August 2026Improving Recycling and Management of Renewable Energy Wastes: Universal Waste Regulations for Solar Panels and Lithium Batteries
September 2026Effluent Limitations Guidelines and Standards for the Oil and Gas Extraction Category (40 CFR 435 Subpart E)
October 2026Effluent Limitations Guidelines and Standards for the Centralized Waste Treatment Category (40 CFR 437)
December 2026Clean Water Act Hazardous Substance Facility Response Plans; Amendment Reconsideration
December 2026National Emission Standards for Hazardous Air Pollutants: Stationary Combustion Turbines; Amendments
Pre-Rule Stage
Projected publication date or other actionTitle
January 2027 (final rule)Risk Management Program, CAA Section 112(r)(7) (Section 610 Review)
August 2026 (begin review)Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources (Section 610 Review)
Key to remember: EPA's planned rulemakings may impact regulatory compliance with air, land, and water rules.

EHS Monthly Round Up - June 2026

EHS Monthly Round Up - June 2026

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

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

OSHA won’t increase its penalty amounts in 2026. The agency is required to annually adjust its penalties for inflation, based specifically on the October Consumer Price Index data released by the Bureau of Labor Statistics. Due to a lapse in funding, BLS did not release the October 2025 data. Because no alternative calculation is allowed, OSHA penalties will remain at the 2025 amounts.

OSHA updated its inspection guidance for the Hazard Communication standard. While the document is geared towards OSHA inspectors, it provides insights for chemical manufacturers, importers, distributors, and employers as to what the agency will look for during an inspection.

OSHA will hold a series of informal, virtual hearings on multiple proposed rules beginning August 19th. The majority relate to respiratory protection requirements for different chemical substances. All of the proposed rules were originally published in the Federal Register on July 1, 2025.

Nevada OSHA published a list of frequently asked questions related to its recently adopted heat illness rule. The state’s rule took effect April 29.

Turning to environmental news, EPA restored emergency-related affirmative defense provisions for Title V operating permits. This allows stationary sources to assert a regulatory affirmative defense for certain air emission violations caused by events beyond their control.

EPA released two proposed rules that would have major impacts on drinking water regulations for PFAS. The agency will accept comments on the proposals until July 20.

And finally, EPA now allows facilities to submit PCB annual reports electronically. Facilities can start with the upcoming report that’s due July 15.

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

EPA sets MyPeST compliance reporting deadlines for bilingual pesticide labeling requirements
2026-07-01T05:00:00Z

EPA sets MyPeST compliance reporting deadlines for bilingual pesticide labeling requirements

The Environmental Protection Agency (EPA) published instructions and deadlines for pesticide registrants to report compliance with bilingual labeling requirements in the MyPeST application. The first compliance reporting deadline is July 31, 2026, for pesticide products with the highest toxicity.

Who’s impacted?

Compliance reporting applies to registrants of pesticide products subject to the bilingual labeling requirements established by the Pesticide Registration Improvement Act of 2022 (PRIA 5) amendments to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

PRIA 5 requires all end-use pesticide product labels to provide Spanish translations of the human health and safety sections by including the translated sections directly on the label or providing a link via scannable technology or other readily accessible electronic methods to the translated sections. EPA allows certain antimicrobial and non-agricultural pesticide products to comply by providing access to Spanish-language Safety Data Sheets instead of direct label translations.

Compliance timelines are based on the type of pesticide and its toxicity category.

What’s required?

Pesticide registrants must report compliance with the PRIA 5 bilingual labeling requirements using EPA’s MyPeST app. The agency recently published detailed reporting instructions in the MyPeST Application User Guide (accessible in the MyPeST app).

EPA also established the following deadlines for reporting compliance in MyPeST:

Pesticide product typeBilingual labeling deadlineCompliance reporting deadline
Restricted use pesticides (RUPs)December 29, 2025July 31, 2026
Non-RUP agricultural products
Acute Toxicity Category IDecember 29, 2025July 31, 2026
Acute Toxicity Category IIDecember 29, 2027 January 28, 2028
Antimicrobials and non-agricultural products
Acute Toxicity Category IDecember 29, 2026January 28, 2027
Acute Toxicity Category IIDecember 29, 2028January 28, 2029
All other pesticide productsDecember 29, 2030January 28, 2031
Key to remember: EPA released detailed instructions and deadlines for pesticide registrants to report compliance with the bilingual labeling requirements in the MyPeST application.

See More

Most Recent Highlights In Safety & Health

Secondary containment alternative: Does your oil-filled operational equipment qualify?
2026-06-30T05:00:00Z

Secondary containment alternative: Does your oil-filled operational equipment qualify?

Facilities that run like a well-oiled machine often rely on just that — operational equipment that stores and uses oil to function (like hydraulic systems). But wherever oil is stored, there’s always the possibility of a leak, and spilled oil can do serious harm, especially if it reaches water.

That’s where the Environmental Protection Agency’s (EPA’s) Spill Prevention, Control, and Countermeasure (SPCC) rule comes in. Usually, regulated facilities must equip oil-filled operational equipment with general secondary containment, which is designed to temporarily hold discharged oil until it can be properly cleaned up. However, some facilities may have another compliance option available.

EPA offers an alternative to secondary containment for qualified oil-filled operational equipment. Let’s take a look at the eligibility criteria and what the other method of compliance requires.

What’s oil-filled operational equipment?

EPA defines “oil-filled operational equipment” at 40 CFR 112.2. Generally, it refers to equipment that has one or more oil storage containers with oil that’s used solely to operate the equipment. Common examples are lubrication systems for pumps and compressors, machining coolant systems, circuit breakers, and electrical switches.

Does your facility have qualified equipment?

Only qualified oil-filled operational equipment is eligible for the alternative requirements to general secondary containment.

The SPCC rule considers oil-filled operational equipment to be qualified if it hasn’t had one discharge of oil exceeding 1,000 gallons or two discharges of oil exceeding 42 gallons each over the following time periods:

  • If the facility has operated for at least 3 years, within any 12-month period in the 3 years before the SPCC Plan’s certification date; or
  • If the facility has operated for less than 3 years, since becoming subject to the SPCC regulations.

Take note! When determining whether your facility’s oil-filled operational equipment is eligible under federal standards:

  • Don’t count oil discharges caused by natural disasters, acts of war, or terrorism; and
  • Don’t count the total amount of oil spilled, only the amount that reaches navigable waters or adjoining shorelines.

What about oil-filled manufacturing equipment?

The SPCC rule distinguishes between oil-filled manufacturing equipment and oil-filled operational equipment. Oil-filled manufacturing equipment stores oil only as a supporting element for conducting a mechanical or chemical operation to create or modify a product. It typically involves a flow-through process in which oil continuously moves through the equipment. Examples of this type of equipment include reaction vessels, mixing tanks, and distillation columns.

Because it’s defined independently under the SPCC rule, oil-filled manufacturing equipment isn’t eligible for the alternative compliance option available to qualified oil-filled operational equipment.

What are the alternative measures?

Instead of providing secondary containment for qualified oil-filled operational equipment, facilities may choose to comply with the alternative requirements at 112.7(k), which include:

  • Establishing and documenting an inspection or a monitoring program to detect equipment failures and discharges; and
  • Adding to the SPCC Plan:
    • An oil spill contingency plan according to the requirements of Part 109; and
    • A written commitment of the resources (manpower, equipment, and materials) needed to quickly control and remove any potentially harmful quantities of discharged oil.

Take note! If your business must submit a facility response plan (FRP) under 112.20, the oil spill contingency plan and written commitment requirements don’t apply since your FRP already contains these elements.

Why should my facility consider the alternative compliance option?

The alternative requirements to general secondary containment don’t require facilities to prepare an impracticability determination for qualified oil-filled operational equipment.

The impracticability determination provisions at 112.7(d) impose more requirements for facilities that use alternative measures to secondary containment for unqualified equipment. In addition to meeting the same requirements for qualified oil-filled operational equipment, facilities must have the oil spill contingency plan certified by a Professional Engineer (unless self-certifying as a qualified facility). They also must:

  • Describe in the SPCC Plan the reasons such measures aren’t practicable, and
  • Conduct periodic integrity tests of bulk storage containers and periodic integrity and leak tests of valves and piping.

Key to remember: The SPCC rule offers an alternative to general secondary containment requirements for qualified oil-filled operational equipment.

EHS Monthly Round Up - August 2025

EHS Monthly Round Up - August 2025

In this August 2025 roundup video, we'll review the most impactful environmental health and safety news.

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

OSHA extended the comment period for multiple proposed rules it published on July 1. Stakeholders now have an extra 60 days, until November 1, to comment. Impacted rules include those for respiratory protection, construction illumination, COVID-19, and the General Duty Clause.

OSHA is expanding its Voluntary Protection Programs to help employers develop strong safety programs and lower injury rates. To participate, employers must submit an application to OSHA and undergo an onsite evaluation by a team of safety and health professionals.

Following a series of recent trench collapses, OSHA urges employers to take steps to protect workers. Trench collapses can be prevented by sloping or benching trench walls at an angle, shoring trench walls with supports, and shielding walls with trench boxes. More information can be found on OSHA’s website.

The Mine Safety and Health Administration launched a webpage for its new Compliance Assistance in Safety and Health, or CASH, program. The agency anticipates a surge in domestic mining productivity and seeks to proactively provide miners and mine operators with compliance assistance materials.

Turning to environmental news, EPA proposes challenges to California’s Clean Truck Check program. The program aims to reduce emissions of nitrogen oxides and particulate matter for heavy-duty vehicles. EPA supports the regulation as it applies to California-registered vehicles but disapproves the regulation as it applies to out of state and out of country vehicles. Stakeholders have until September 25 to comment on the proposal.

On August 14, EPA released the July 2025 nonconfidential TSCA Inventory of chemical substances manufactured, processed, or imported in the U.S. The Inventory contains over 86 thousand chemicals, nearly half of which are in active use. The next inventory update is planned for late 2026.

And finally, EPA proposes to rescind the 2009 Endangerment Finding and repeal greenhouse gas emissions for new motor vehicles and vehicle engines. The agency will accept comments on the proposal through September 15.

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

EHS Monthly Round Up - September 2025

EHS Monthly Round Up - September 2025

In this September 2025 roundup video, we'll review the most impactful environmental health and safety news.

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

OSHA released its Spring 2025 regulatory agenda on September 4. Many rulemakings have been pushed into the fourth quarter of 2025 and the first half of 2026, while a few have been removed from the agenda altogether. These include Infectious Diseases, Blood Lead Level for Medical Removal, and the Musculoskeletal Disorders Column on the OSHA 300 log.

Three rules moved into the long-term actions category – Workplace Violence in Health Care and Social Assistance, Cranes and Derricks in Construction, and Process Safety Management and Prevention of Major Chemical Accidents. The proposed rule stage saw an influx of new entries, most of which were published in the July 1 Federal Register.

The Standards Improvement Project, slated for proposal in May 2026, intends to “remove, modernize, or narrow duplicative, unnecessary, or overly burdensome regulatory provisions.”

OSHA renewed its alliance with the National Waste and Recycling Association and the Solid Waste Association of North America. The partnership will focus on safety issues such as transportation hazards; slips, trips, and falls; needlestick and musculoskeletal injuries; and health issues associated with lithium battery hazards in waste/recycling collection and processing.

For the 15th year in a row, fall protection for construction topped OSHA’s list of top 10 violations. In fiscal year 2024, there were 5,914 recorded fall protection violations, down from 7,271 in fiscal year 2023. The standards that round out the top 10 remain unchanged, with a shift in some of the rankings.

Turning to environmental news, EPA proposes to eliminate the Greenhouse Gas Reporting Program requirements for all source categories except the petroleum and natural gas systems category. The agency also proposes to suspend compliance obligations for covered facilities until 2034. A public hearing was held October 1 and stakeholders have until November 3 to comment on the proposal.

Hazardous waste handlers may continue to use 5-paper copy manifest forms. EPA announced it will accept these forms from entities regulated by the Resource Conservation and Recovery Act, or RCRA, until further notice. The agency will give a 90-day notice before it plans to stop accepting the 5-copy forms.

And finally, EPA published its Spring 2025 regulatory agenda on September 4. The agenda outlines the agency’s upcoming regulatory actions and their status in the rulemaking process. Major updates on the docket include those for greenhouse gases, risk management rules, and the Renewable Fuel Standards for 2026 and 2027.

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

EHS Monthly Round Up - January 2025

EHS Monthly Round Up - January 2025

In this January 2025 monthly roundup video, we'll review the most impactful environmental health and safety news.

Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. There’s a lot going on, so let’s get started!

As happens at the start of most incoming presidential administrations, a freeze has been placed on all regulatory activity at the federal level, giving the new administration time to review agencies’ plans. The Office of Management and Budget, which must approve most rulemaking activities, has sent numerous pending rules back to the agencies for review. In addition, OSHA withdrew its infectious diseases proposed rule and its COVID-19 in healthcare rule prior to the inauguration.

OSHA’s penalties increased on January 15. The maximum penalty amounts for serious and other-than-serious violations increased to $16,550. For willful or repeated violations, the maximum penalty increased to $165,514 per violation.

OSHA updated its directive on injury and illness recordkeeping policies and procedures. While it’s intended for OSHA compliance officers, employers can use the information to help with recordkeeping compliance.

Fewer workers died on the job in 2023, as fatal work injuries decreased 3.7 percent from 2022. Transportation incidents remained the most frequent type of fatal event, accounting for over 36 percent of all occupational fatalities.

California’s Occupational Safety and Health Standards Board voted to adopt a permanent silica standard. If approved, it would extend and strengthen the state’s emergency temporary standard, which was put in place in December 2023.

The National Institute for Occupational Safety and Health updated its List of Hazardous Drugs in Healthcare Settings. This is a resource for employers and employees in identifying drugs that are hazardous to the health and safety of those who handle them.

Turning to environmental news, EPA released the biannual update of the nonconfidential TSCA inventory. The inventory helps facilities determine their regulatory requirements for the chemicals they use or plan to use.

And finally, EPA added new Management Method Codes to describe how hazardous waste will be managed after temporary storage and transfer. As of January 1st, hazardous waste handlers must use the codes on the Biennial Report Waste Generation and Management forms.

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

EHS Monthly Round-Up - August 2024

EHS Monthly Round-Up - August 2024

In this August 2024 roundup, we'll review the most impactful environmental, health, and safety news.

Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental, health, and safety news. Please view the content links in the transcript for more information about the topics I’ll be covering today. Let’s get started!

Two State Plan agencies allegedly provided advance notice of workplace inspections to employers, a practice that’s prohibited under the Occupational Safety and Health Act. Now, lawmakers have requested that the Department of Labor’s acting secretary address the allegations and explain what challenges OSHA faces when monitoring and enforcing State Plan compliance.

A recent study shows jobs in agriculture, forestry, fishing, and hunting are among California’s most dangerous, accounting for the highest number of fatalities among full-time workers. Transportation and utilities jobs ranked second and construction was third.

Remote isolation of process equipment can quickly stop the release of hazardous materials, which can help prevent fatalities and injuries, limit facility damage, and better protect communities and the environment. A U.S. Chemical Safety Board study explores their use and makes recommendations for their utilization in chemical facilities.

A National Safety Council report explores the role of diversity, equity, and inclusion on work-related musculoskeletal disorders, or MSDs. MSDs are the most common workplace injury and often lead to worker disability, early retirement, and employment limitations.

And finally, turning to environmental news, EPA published a final rule that revises its hazardous waste export manifest regulations. All hazardous waste shipments and manifest-related reports will be managed electronically through the agency’s e-Manifest program.

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

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Most Recent Highlights In Human Resources

2026-06-26T05:00:00Z

Multimedia inspections are back: How to prepare for comprehensive EPA and state audits

Regulators have returned to routine, in-person inspections, and many are no longer limited to a single program. The Environmental Protection Agency (EPA) and state agencies are again conducting multimedia inspections that review air, water, and hazardous waste compliance in one visit. For facilities, this shift raises the stakes. An issue in one program can quickly lead inspectors into others, especially when records or operations don't align.

Most inspectors now arrive with background data already reviewed. Electronic submissions, air reports, discharge monitoring reports, and hazardous waste filings are compared against what they see on-site. When numbers, dates, or practices don't match, the scope of the inspection often expands.

What inspectors are really evaluating

While documents are important, inspectors focus on whether procedures match actual operations. They will often start with a walk-through of the facility, tracing how materials move through production and become emissions, discharges, or wastes.

For example:

  • Air compliance may be checked by reviewing fuel use, hours of operation, or control device logs;
  • Stormwater compliance often involves visual checks for exposed materials and conditions of controls; and
  • Hazardous waste inspections typically focus on labeling, container condition, and accumulation practices.

The common thread is consistency. If a plan says one thing but operators do another, it's likely to result in a finding.

Common gaps seen during multimedia inspections

Across industries, several issues appear repeatedly:

  • Records that don't match across programs (e.g., waste logs versus manifests);
  • Missing or incomplete inspection logs for air or stormwater systems;
  • Assumptions about exemptions without supporting documentation;
  • Satellite accumulation areas managed informally outside environmental oversight; and
  • Housekeeping issues that create unintended stormwater exposure.

Many of these aren't complex violations. They're breakdowns in communication, training, or follow-through.

A practical way to prepare

Facilities can improve readiness by conducting an internal, cross-media review that mirrors an actual inspection. This is more effective than reviewing each program in isolation.

Start with a process-based walk-through:

  1. Identify where raw materials enter the facility.
  2. Follow how they're used, stored, and handled.
  3. Note where wastes, emissions, or discharges are generated.
  4. Confirm how each is managed and documented.

At each step, ask two questions:

  • Is this activity reflected accurately in our records and plans?
  • Would an operator explain it the same way it's written?

This approach often reveals gaps that aren't obvious during a desk review.

A recent case: How one issue expands the scope

At a mid-sized manufacturing facility, inspectors began with a routine hazardous waste review. They noticed that waste logs showed periodic disposal of solvent residues, but there were no related air records for emissions tied to cleaning operations.

This led inspectors to review the facility’s air permit assumptions. They found that solvent use had increased over time, but the facility hadn't updated its potential-to-emit calculations. What started as a simple waste review expanded into an air applicability concern.

The facility ultimately faced findings in both programs, not because of a single major violation, but because information didn't align across systems.

Strengthening compliance across programs

Preparation doesn't require building new systems. It requires making sure existing ones are aligned and consistently followed.

Focus on:

  • Clear ownership of compliance tasks across departments;
  • Regular cross-checks between records (air, water, waste);
  • Training staff on how their daily tasks affect compliance; and
  • Maintaining documentation that supports assumptions, exemptions, and limits.

Facilities that treat compliance as a connected system, not separate programs, are better positioned during inspections.

Key to remember: A multimedia inspection looks for consistency across air, water, and waste programs, not just isolated compliance. If your records and operations tell the same story, you're far less likely to face expanded scrutiny.

2026-06-25T05:00:00Z

Hazardous waste episodic events: What to do when a bad month happens

Every generator has that month. A tank clean-out gets scheduled; a forklift punctures a tote, and suddenly you've generated way more hazardous waste than you normally would. If you're a Very Small Quantity Generator (VSQG) or Small Quantity Generator (SQG), that one bad month could technically bump you into Large Quantity Generator (LQG) status, potentially subjecting the facility to LQG requirements such as contingency planning, personnel training, and biennial reporting.

The good news is that EPA built in an escape hatch. The 2016 Generator Improvements Rule added 40 CFR Part 262, Subpart L (the "episodic event" provision), which lets you keep your normal generator category for that month, if you follow the rules in 40 CFR 262.232 exactly.

Scenario 1: The planned tank clean-out

Picture a metal finishing shop that's normally an SQG, generating about 400 kg/month of spent plating solution. They finally get around to cleaning out an old process tank that's been sitting idle for three years. That clean-out produces about 1,800 kg of sludge in one shot and enough to push them into LQG numbers for the month.

Since this is something the facility planned and scheduled for, it's a planned episodic event. Here's what the employer would need to do:

  • Notify EPA (or the delegated state agency) at least 30 calendar days before the clean-out starts, using EPA Form 8700-12. Include the start/end dates, why the event is happening, estimated waste types and quantities, and a 24-hour emergency contact.
  • Double-check the facility's EPA ID number to make sure it is current.
  • Stage the waste properly with compliant containers or tanks and labeled with the episodic event start date.
  • Get it manifested and shipped off-site within 60 calendar days of the start date.
  • Hang onto every record including the notification, manifests for 3 years after the event ends.

Scenario 2: The unplanned spill

Next, picture a packaging plant. They are a VSQG generating around 80 kg/month. They have a forklift punch a hole in a 275-gallon tote of listed solvent and by the time cleanup is done, they're looking at about 900 kg of contaminated absorbent and solvent residue. Nobody planned this. It's not part of normal operations. That makes it an unplanned episodic event. Here is what they should do:

  • They have 72 hours to notify EPA or the state by phone, email, or fax. There will be no time to fill out paperwork first.
  • Follow that up by submitting EPA Form 8700-12 after the fact, documenting what happened since you couldn't give advance notice.
  • Keep the spill cleanup waste separate from your routine waste streams and label it with the episodic start date.
  • The same 60-day shipping window and 3-year recordkeeping requirement apply here too.

The things you can't skip

Whether the event is planned or unplanned, there are a handful of conditions that apply across the board and missing any one of them could cost you the episodic event relief entirely.

  • One event per year, period. Both VSQGs and SQGs get exactly one episodic event a year unless they petition the Regional Administrator under 40 CFR 262.233 for a second. That second one must be the opposite type, so if your first was planned, the next must be unplanned.
  • The clock doesn't wait. Exactly 30 days out for planned and 72 hours for unplanned are required. Miss either window or you lose the relief entirely, meaning full LQG status kicks in for that period.
  • The 60-day shipping clock starts on day one of the event, not when you send the notification, so make sure to track it immediately.
  • Manifest the waste properly. Episodic waste can ship under the standard Subpart B manifest rules, even in the same load as your regular waste.
  • Write everything down. Three years of solid records such as dates, causes of event, quantities, and where it went is what separates a clean inspection from an enforcement headache.

Keys to remember: The episodic event provision rewards generators who plan, classify the event correctly, notify on time, ship within 60 days, and document everything for three years.

2026-06-24T05:00:00Z

Virginia reinstates power plant CO2 budget program

Effective date: April 24, 2026

This applies to: Power plant owners

Description of change: The Virginia Department of Environmental Quality reinstated the Virginia CO2 Budget Trading Program Regulation, which implements the Regional Greenhouse Gas Initiative (RGGI). Participation in the RGGI was stopped in 2023, but the state will resume participation on July 1, 2026, the same date on which the compliance requirements take effect.

The regulation requires fossil fuel-fired units that serve an electricity generator with a capacity of 25 megawatts or more to obtain enough allowances to cover CO2 emissions, which they can purchase in the September and December RGGI auctions.

The department also adopted amendments to the regulations, including establishing a one-time 6-month control period from July 1, 2026, to December 31, 2026.

Related state info: Clean air operating permits state comparison

2026-06-24T05:00:00Z

North Carolina approved revisions to wastewater discharge rules

Effective date: May 1, 2026

This applies to: Facilities with domestic wastewater discharges up to 2 million gallons per day

Description of change: The North Carolina Department of Environmental Quality (DEQ) adopted a rule that adds a permitting option to the National Pollutant Discharge Elimination System (NPDES) program for facilities with domestic wastewater discharges of up to 2 million gallons per day.

DEQ removed the ban on new or expanded discharges of oxygen-consuming waste when the 7Q10 and 30Q2 flows are both 0 for these facilities. In other words, it allows systems to discharge domestic wastewater to zero-flow receiving streams, provided the system:

  • Meets qualifying criteria,
  • Complies with specific effluent limits, and
  • Uses low-energy methods before discharging wastewater to the receiving stream.

It’ll likely benefit areas where the cost of piping to a higher-flowing stream farther away is prohibitive.

2026-06-24T05:00:00Z

New Hampshire updates sludge management rules

Effective date: May 15, 2026

This applies to: Owners and operators of drinking water and wastewater treatment plants that generate sludge; land application sites; and facilities that treat, manage, or dispose of sludge

Description of change: The New Hampshire Department of Environmental Services amended sludge management rules. Major changes include:

  • Reinstating 5-year site and facility permit renewals (instead of 10 years),
  • Adding annual reporting requirements for sludge haulers (which already apply to septage haulers), and
  • Requiring all applications to be submitted electronically.

The rule also codifies per- and polyfluoroalkyl substances (PFAS) sampling (implemented in 2019 for the sludge quality certificate program).

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