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NewsFleet SafetyPipeline and Hazardous Materials Safety Administration (PHMSA), DOTDrug testing - Motor CarrierDrug and Alcohol Testing - DOTOffice of the Secretary of TransportationHazmat SafetyRulemakingFocus AreaProposed RuleEnglishTransportationUSA
89 FR 82957 Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records
2024-10-15T05:00:00Z
DEPARTMENT OF TRANSPORTATION
Office of the Secretary
49 CFR Part 40
Pipeline and Hazardous Materials Safety Administration
49 CFR Part 199
[Docket DOT-OST-2022-0027]
RIN 2105-AF01
Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records
AGENCY: Office of the Secretary, Department of Transportation (DOT).
ACTION: Notice of proposed rulemaking (NPRM).
SUMMARY: The Department of Transportation (DOT or Department) proposes to amend its regulations for conducting workplace drug and alcohol testing for the federally regulated transportation industry to allow, but not require, electronic signatures on documents required to be created and utilized under the regulations, the use of electronic versions of forms, and the electronic storage of forms and data. The regulatory changes would apply to DOT-regulated employers and their contractors (“service agents”) who administer their DOT-regulated drug and alcohol testing programs. Currently, employers and their service agents must use, sign and store paper documents exclusively, unless the employer is utilizing a laboratory's electronic Federal Drug Testing Custody and Control Form (electronic CCF) system that has been approved by the Department of Health and Human Services (HHS). DOT is required by statute to amend its regulations to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms. This rulemaking also responds to an April 2, 2020, petition for rulemaking from DISA Global Solutions, Inc. (DISA), requesting that DOT regulations be amended to allow the use of an electronic version of the alcohol testing form (ATF) for DOT-authorized alcohol testing. The proposed regulatory amendments are expected to provide additional flexibility and reduced costs for the industry while maintaining the integrity and confidentiality requirements of the drug and alcohol testing regulations. In addition, DOT proposes to amend the Pipeline and Hazardous Materials Safety Administration (PHMSA) regulation for conformity and to make other miscellaneous technical changes and corrections.
DATES: Comments on this NPRM must be received on or before December 16, 2024.
ADDRESSES: You may submit comments identified by Docket Number DOT-OST-2022-0027 using any of the following methods:
• Federal eRulemaking Portal: Go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document. Follow the online instructions for submitting comments.
• Mail: Docket Management Facility, U.S. Department of Transportation, 1200 New Jersey Avenue SE, West Building, Ground Floor, Room W12-140, Washington, DC 20590-0001.
• Hand Delivery or Courier: West Building, Ground Floor, Room W12-140, 1200 New Jersey Avenue SE, Washington, DC, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting Dockets Operations.
• Fax: 202-493-2251.
To avoid duplication, please use only one of these methods. See the “Public Participation and Request for Comments” portion of the SUPPLEMENTARY INFORMATION section for instructions on submitting comments, including collection of information comments for the Office of Information and Regulatory Affairs, Office of Management and Budget (OMB).
FOR FURTHER INFORMATION CONTACT:
Mike Huntley, Office of Drug and Alcohol Policy and Compliance, 1200 New Jersey Avenue SE, Washington, DC 20590; telephone number 202-366-3784; ODAPCwebmail@dot.gov. If you have questions on viewing or submitting material to the docket, contact Docket Services, telephone (202) 366-9826.
SUPPLEMENTARY INFORMATION:
This NPRM is organized as follows:
I. Executive Summary
II. Public Participation and Request for Comments
A. Submitting Comments
B. Viewing Comments and Documents
C. Privacy Act
III. Legal Basis for the Rulemaking
IV. Background
V. Advance Notice of Proposed Rulemaking (ANPRM) Overview
VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures
VII. Amending Part 40 To Permit Electronic Documents and Signatures
VIII. Electronic ATF
IX. Section-by-Section Analysis
X. Regulatory Analyses and Notices
I. Executive Summary
Purpose and Summary of the Major Provisions
This proposed rule would establish parity between paper and electronic documents and signatures and expand businesses' and individuals' ability to use electronic methods to comply with the Department's drug and alcohol testing regulation, 49 CFR part 40, “Procedures for Transportation Workplace Drug and Alcohol Testing Programs” (part 40). Businesses and individuals subject to part 40 would continue to have the choice to use paper documents and traditional “wet” signatures. This proposed rule would also modify references to recordkeeping and reporting methods throughout part 40 to make them technologically neutral.
This proposed rulemaking responds to a statutory mandate set forth in section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271 (see 49 U.S.C. 322 note). The proposed rulemaking would take action consistent with the Government Paperwork Elimination Act (GPEA) (division C, title XVII, secs. 1701-1710, Pub. L. 105-277) and the Electronic Signatures in Global and National Commerce Act (E-SIGN) (Pub. L. 106-229) with regard to DOT's part 40 regulations.
II. Public Participation and Request for Comments
A. Submitting Comments
If you submit a comment, please include the docket number for this NPRM (Docket No. DOT-OST-2022-0027), indicate the specific section of this document to which each comment applies, and provide a reason for each suggestion or recommendation. You may submit your comments and material online or by fax, mail, or hand delivery, but please use only one of these means. The Office of the Secretary (OST) recommends that you include your name and a mailing address, an email address, or a phone number in a cover letter or an email so that OST can contact you if there are questions regarding your submission.
To submit your comment online, go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document, click on this NPRM, click “Comment,” and type your comment into the text box on the following screen.
If you submit your comments by mail or hand delivery, submit them in an unbound format, no larger than 8 1/2 by 11 inches, suitable for copying and electronic filing. If you submit comments by mail and would like to know that they reached the facility, please enclose a stamped, self-addressed postcard or envelope.
OST will consider all comments and material received during the comment period in determining how to proceed with any final rule.
B. Viewing Comments and Documents
To view comments, as well as any documents mentioned in this preamble as available in the docket, go to https://www.regulations.gov. Insert the docket number, DOT-OST-2022-0027, in the keyword box, and click “Search.” Next, click the “Open Docket Folder” button and choose the document to review. If you do not have access to the internet, you may view the docket online by visiting the Docket Management Facility in Room W12-140 on the ground floor of the DOT West Building, 1200 New Jersey Avenue SE, Washington, DC 20590-0001, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting the Docket Management Facility.
C. Privacy Act
In accordance with 5 U.S.C. 553(c), DOT solicits comments from the public to better inform its rulemaking process. DOT posts these comments, without edit, including any personal information the commenter provides, to www.regulations.gov, as described in the system of records notice (DOT/ALL-14 FDMS), which can be reviewed at https://www.transportation.gov/individuals/privacy/privacy-act-system-records-notices under the heading of “Department-Wide System of Records Notices”.
III. Legal Basis for the Rulemaking
This rulemaking is promulgated under the authority enacted in the Omnibus Transportation Employee Testing Act of 1991 (OTETA) (Pub. L. 102-143, tit. V, 105 Stat. 952) and codified at 49 U.S.C. 45102 (aviation), 49 U.S.C. 20140 (rail), 49 U.S.C. 31306 (motor carrier), and 49 U.S.C. 5331 (public transportation), as well as the Department's authority in 49 U.S.C. 322 and the PHMSA authorities specified in the proposed regulatory text for this action.
According to Public Law 115-271, the Secretary of Transportation is required to “issue a final rule revising part 40 of title 49, Code of Federal Regulations, to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms.” (49 U.S.C. 322 note) The statute set the deadline for this action as not later than 18 months after HHS establishes a deadline for a certified laboratory to request approval for fully electronic CCFs ( Id. ) On April 7, 2022, HHS set that deadline as August 31, 2023 (87 FR 20528). HHS has extended the deadline to August 31, 2026, to enable sufficient time for all HHS-certified laboratories to identify and contract with an electronic CCF supplier or to develop an electronic CCF. The deadline for DOT's regulatory amendments would therefore be February 29, 2028.
There are two additional Federal statutes relevant to the implementation of electronic document and signature requirements.
The Government Paperwork Elimination Act (GPEA), codified at 44 U.S.C. 3504 note, 1 was enacted to improve customer service and governmental efficiency through the use of information technology. The GPEA defines an electronic signature as a method of signing an electronic communication that: (a) identifies and authenticates a particular person as the source of the electronic communication; and (b) indicates such person's approval of the information contained in the electronic communication. Id. It also requires OMB to ensure Federal agencies provide for: (a) the option of maintaining, submitting; or disclosing information electronically, when practicable; and (b) the use and acceptance of electronic signatures when practicable. The GPEA states that electronic records submitted pursuant to procedures developed under title XVII for the submission of records to Federal agencies and electronic signatures used in accordance with those procedures shall not be denied legal effect, validity, or enforceability merely because they are in electronic form. Id.
1 Division C, title XVII (sec. 1701-1710) of Public Law 105-277, 112 Stat. 2681-749, enacted on October 21, 1998.
The Electronic Signatures in Global and National Commerce Act (E-SIGN), codified at 15 U.S.C. 7001-7031, 2 was designed to promote the use of electronic contract formation, signatures, and recordkeeping in private commerce by establishing legal equivalence between traditional paper-based methods and electronic methods. The E-SIGN Act allows the use of electronic records to satisfy any statute, regulation, or rule of law requiring that such information be provided in writing if the consumer has affirmatively consented to such use and has not withdrawn consent. Specifically, the statute establishes the legal equivalence of the following types of documents with respect to any transaction in or affecting interstate or foreign commerce, whether in traditional paper or electronic form: (a) contracts, (b) signatures, and (c) other records (15 U.S.C. 7001(a)(1)).
2 Public Law 106-229, 114 Stat. 464, enacted on June 30, 2000.
IV. Background
The Department's drug and alcohol testing regulations were promulgated at a time when the ability to sign and retain official records electronically—now commonplace in many business segments—was not available. Over the course of several years, we have adopted measures that have reduced the paper documentation associated with the drug and alcohol testing program without compromising the integrity and confidentiality requirements of the program. In 2003, we standardized the form for employers to report their Management Information System (MIS) aggregate drug and alcohol testing data, as well as the specific data collected. 3 When creating a ONE-DOT MIS Form, we then authorized employers to submit a single standardized form via a web portal. In 2015, we issued a final rule to allow employers, collectors, laboratories, and medical review officers (MROs) to use the electronic version of the Federal Drug Testing CCF in the DOT-regulated drug testing program. 4 That final rule also incorporated into the regulations the requirement to establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons when using the electronic CCF. We also included language protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form when using the electronic CCF.
3 68 FR 43946 (July 25, 2003).
4 80 FR 19551 (Apr. 13, 2015).
Consistent with the statutory mandate in 49 U.S.C. 322 note, we propose amendments to part 40 to permit the use of electronic signatures, forms, and records storage for drug and alcohol testing records throughout the regulation, including the use of an electronic ATF for DOT-authorized alcohol testing. We emphasize that electronic signatures, forms, and records would not be required; we would continue to allow paper, or hard-copy use with traditional “wet signatures.”
These proposed amendments would establish parity between paper and electronic collection and submission of information required under our regulations (and remain compatible with applicable OMB guidance on implementing electronic signatures 5 ) by allowing further use of electronic means and methods to comply with part 40 requirements. Many employers and their service agents have already instituted the use of electronic signatures, forms, and records storage for the non-DOT regulated testing that they conduct. DOT supports this transition to a paperless system and is committed to ensuring that the movement to a partially or fully electronic part 40 is done to maximize program efficiencies and reduce costs, while maintaining the integrity and confidentiality requirements of the program.
5https://www.whitehouse.gov/wp-content/uploads/2017/11/2000-M-00-15-OMB-Guidance-on-Implementing-the-Electronic-Signatures-in-Global-and-National-Commerce-Act.pdf.
Electronic documents would have a high degree of forensic defensibility as long as any changes made to the document are in the document's electronic footprint, which shows when the document or signature, as applicable, was created; when, and if, changes were made; who made the changes; and when, as applicable, a document was transmitted to and received by the receiving entity. The use of electronic forms and signatures in part 40 would help DOT-regulated employers and their service agents improve their workflow efficiency through faster turnaround times for required documents. Cost savings would result through reduced printing and delivery/shipping costs, and expedited transmission of information allowing for more timely decisions. We believe this proposed rule, if adopted, would also mitigate the longstanding problems ( e.g., delays in processing times of test results, cancelling of test results, etc.) associated with illegible and lost copies of paper documents.
V. Advance Notice of Proposed Rulemaking (ANPRM) Overview
On August 5, 2022, we published an ANPRM requesting public comment on how part 40 could be amended, as required by the statute, to allow electronic signatures, forms, and recordkeeping (87 FR 47951). We requested information from DOT-regulated employers and their service agents regarding if and how they are already handling electronic signatures, records transmission, and records storage in their non-DOT testing programs. In addition, we requested comments and information on appropriate performance standards, and on whether particular methods or performance standards have been successful or unsuccessful. We also asked a number of general questions on the potential advantages, risks, ramifications, and required safeguards associated with the use of electronic signatures, forms, and records in the DOT drug and alcohol testing program. We asked questions about specific sections of part 40 that we anticipated would be affected by prospective changes to implement electronic signatures, forms, and records. Finally, we asked a number of questions regarding the use of an electronic ATF for DOT-regulated alcohol tests.
We received 72 comments in response to the ANPRM, including comments from individuals, testing laboratories, MROs, and MRO organizations, substance abuse professionals (SAP) and SAP organizations, and various associations representing DOT-regulated transportation workers subject to mandatory drug and alcohol testing under part 40.
A few individuals expressed opposition to the adoption of electronic signatures, forms, and recordkeeping, citing concerns about the need for the rulemaking, risk to personal information from hackers or mismanaged electronic processes and procedures, and misuse of electronic forms and signatures. To meet our statutory mandate and in consideration of concerns about safeguarding personal information and appropriate use of the information in developing the NPRM, DOT proposes to require security measures for electronic forms and signatures used under part 40 that are the same as those currently in place for the electronic CCF specified in 49 CFR 40.40(c)(5).
Most commenters were supportive of changes to amend part 40 that would permit, but not require, the use of electronic signatures, forms, and recordkeeping. Commenters supporting revisions to part 40 noted that electronic signatures, forms, and recordkeeping are used in virtually every industry today—including but not limited to the banking, insurance, medical, and legal industries. Commenters supported the use of performance standards instead of technology-specific standards to ensure that, once established, standards do not become obsolete given the rapidly evolving nature of information technology standards and practices. Commenters stated that allowing electronic signatures, forms, and recordkeeping would make the drug testing process much more efficient and would result in cost savings. Commenters also stated that it would be safer to store records electronically since records could be backed-up, secured, and protected from tampering and unauthorized access and use.
VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures
In developing this NPRM, we looked to a rule promulgated by DOT's FMCSA that permits the use of electronic methods to generate, certify, sign, maintain, or exchange records so long as the documents accurately reflect the required information and can be used for their intended purpose. (83 FR 16210, Apr. 16, 2018) The rule applies to documents that FMCSA requires entities or individuals to retain. FMCSA permits, but does not require, anyone to satisfy FMCSA requirements by using electronic methods to generate, maintain, or exchange documents. The substance of the document must otherwise comply with applicable Federal laws and FMCSA rules. FMCSA also permits, but does not require, anyone required to sign or certify a document to do so using electronic signatures, defined, as in the GPEA, as a method of signing an electronic communication that: (1) identifies and authenticates a particular person as the source of the electronic communication; and (2) indicates such person's approval of the information contained in the electronic communication. FMCSA allows for the use any available technology for electronic signatures, so long as the signature otherwise complies with FMCSA's requirements.
FMCSA adopted broad performance standards for electronic documents and signatures—as specified in GPEA and E-SIGN—rather than detailed, technology specific standards that would likely become obsolete with inevitable changes in information technology standards and practices. FMCSA's April 2018 rule has been in effect for more than five years, and the definitions and requirements established in that rule have stood the test of time despite the many changes that have occurred with respect to electronic documents and signatures. We are unaware of any FMCSA-regulated entities that have reported issues to FMCSA regarding the use of electronic documents or signatures to meet the requirements of the FMCSRs since the rule became effective in 2018.
VII. Amending Part 40 To Permit Electronic Documents and Signatures
In this NPRM, we propose to permit but not require electronic documents, signatures, and recordkeeping in part 40. Additionally, we propose a performance standard approach as opposed to establishing technology-specific standards. Where it is possible to do so, establishing the same or substantively similar regulatory requirements for common issues across DOT modal agencies—such as the use of electronic documents and signatures—helps the Department maintain a consistent regulatory approach for those common issues.
There are currently more than 60 references to the term “written” in part 40, and more than 20 additional references to the term “in writing.” We propose to add a definition of “written or in writing” in part 40, to eliminate any distinction between paper and electronic documentation and establish technological neutrality throughout the entirety of part 40.
FMCSA's rule does not apply to documents that individuals or entities are required to file directly with FMCSA. In its April 2018 final rule, FMCSA explained that while industry could use electronic signatures and submit information directly to the FMCSA in certain situations, 6 adapting all FMCSA systems to allow for use of electronic signatures and submissions would significantly delay the implementation of the rule for use by third parties as it would require FMCSA to develop and implement technology systems to allow for direct submission to FMCSA from regulated parties. FMCSA noted that development of such systems could take several years, and therefore saw no reason to make private parties' use of electronic signatures and records retention contingent upon FMCSA's ability to receive submissions electronically because doing so would delay potential benefits to be gained by third parties.
6 As an example, Certified Medical Examiners may use electronic signatures, if they choose to do so, to sign medical forms, certificates, and a new driver medication report. If FMCSA requests these forms, they are uploaded in portable document format (PDF) to the Medical Examiner's account associated with the National Registry of Certified Medical Examiners for FMCSA to access.
In contrast to FMCSA's regulations, part 40 does not require entities or individuals to submit documents directly to the Department except for MIS aggregate drug and alcohol testing data that employers subject to DOT or U.S. Coast Guard (USCG) drug and alcohol testing regulations must submit annually. Each of the various documents required and used as part of the DOT drug and alcohol testing program under part 40 ( e.g., employee drug and alcohol testing records, MRO reports and records, SAP reports and records) are documents that are created by, exchanged between, and maintained by a person or entity involved in the testing process—but are not required to be submitted directly to DOT.
As noted earlier, and specifically with respect to the required MIS data, we standardized the form for employers to report their aggregate drug and alcohol testing data, as well as the specific data collected, more than 20 years ago. At that time, we authorized employers to submit the ONE-DOT MIS form via a web portal. Today, the Federal Aviation Administration, FMCSA, Federal Railroad Administration, and Federal Transit Administration permit employers to submit that same drug and alcohol testing data via the internet, and PHMSA requires that the data be submitted electronically. If employers submit the data electronically via the internet, they are not required to submit a hard copy. DOT recommends that employers have a copy of their data available (either hard copy or in electronic format) in the event an auditor or inspector requests a copy.
From the above, and because the only documents that part 40 requires to be submitted directly to the Department are already permitted to be, and in some cases required to be, submitted electronically, there is no need for us to limit the applicability of our proposal as FMCSA did in its 2018 final rule.
Several commenters noted that they already use electronic signatures and documents for their non-DOT drug and alcohol testing program, and in some cases, have done so for many years. In doing so, these commenters have had to establish appropriate confidentiality and security measures to ensure that confidential employee records cannot be accessed by unauthorized persons, including protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The same general requirements were added to the current §40.40(c)(5) when we approved the use of the electronic CCF for use in DOT drug testing in 2015, 7 and we propose the same requirements in this NPRM for the use of electronic signatures, documents, and recordkeeping throughout the entirety of part 40.
7 The 2015 revisions amended then §40.45(c)(5), which was redesignated as §40.40(c)(5) in the May 2023 final rule to include oral fluid testing in the DOT drug testing program (88 FR 27596, May 2, 2023).
Ensuring that confidential employee records are not available to unauthorized persons is an important element of part 40's protections for employees that are subject to DOT's drug and alcohol testing rules. We believe that the failure of a service agent to provide or maintain a secure/confidential electronic system should constitute the basis for the Department to start a public interest exclusion (PIE) proceeding, and propose to add this to the list of examples provided in §40.365(b).
Throughout part 40, information and documents are required to be transmitted and/or communicated between service agents ( e.g., collectors, screening test technicians (STTs) and breath alcohol technicians (BATs), laboratories, MROs, SAPs, and consortium/third party administrators (C/TPAs)), employers, and employees). Although part 40 does not currently require the party receiving these communications and/or documents to affirmatively confirm receipt of such from the sender, in some instances, regardless of whether the document is electronic or a hard copy, we believe that it may be important for the receiving party to verify that those required communications and/or documents were received.
For example, under §40.25, an employer intending to use an employee to perform safety-sensitive functions must, after obtaining an employee's written consent, request information about the employee's drug and alcohol testing record from previous DOT-regulated employers. After receiving a copy of the employee's written consent, the previous employer must immediately provide the requested information to the employer making the inquiry. If an employer is subsequently investigated/audited by the appropriate DOT mode, it may be beneficial for both the gaining employer and the previous employer to be able to affirmatively demonstrate that the employee's written consent and previous testing record were sent and received as required.
Sections 40.191(d) and 40.261(c)(1) require a collector or MRO (for drug tests) or a BAT, STT, or a physician evaluating a “shy lung” situation (for alcohol tests), respectively, to—when an employee refuses to participate in a part of the testing process—terminate the testing process, document the refusal, and immediately and directly notify the employer's designated employer representative (DER) by any means that ensures the refusal notification is immediately received. Because this notification of a refusal to an employer is of an urgent nature, it may be advisable to require the DER to affirmatively confirm receipt of the required notification from the collector, MRO, BAT, STT, or physician. For example, §§40.191(d) and 40.261(c)(1) could be amended to read “. . . immediately notify the DER by any means and ensure that the refusal notification is immediately received”.
While we are not proposing new requirements in this NPRM regarding confirmation of receipt in the sections discussed above (or in other part 40 requirements), we seek comment regarding whether it may be beneficial or advisable to do so, and if so, for which specific sections of part 40.
VIII. Electronic ATF
The ATF has been in use in the DOT alcohol testing program since 1994 (see 59 FR 7349, Feb. 15, 1994). The ATF must be used to document every DOT alcohol test. DOT regulations at 49 CFR 40.225 set forth the requirements for use of the form, and 49 CFR part 40, appendix G, contains a facsimile (reference copy) of the form. The ATF is a three-part carbonless manifold form used by DOT-regulated employers to document the testing event when testing employees subject to DOT alcohol testing. When the employee is tested, both the employee and the STT and/or the BAT will complete the ATF in various sections. The STT/BAT documents the result(s) by either writing in the screening result or attaching the screening and/or confirmation result printed by the evidential breath testing devices (EBT) onto the ATF, and then sends Copy 1 to the employer, provides Copy 2 to the employee, and retains Copy 3 for their records.
On April 2, 2020, DISA petitioned the Department to amend part 40 to allow for the use of an electronic version of the ATF for DOT mandated alcohol testing. In support of its petition, DISA stated that “The requested amendment to 49 CFR part 40 will enable a parallel process for the documentation of DOT-mandated alcohol tests aligned with the similarly situated amendment previously approved for drug testing.” DISA believes that allowing the use of an electronic ATF will result in several benefits to the industry, including “increased efficiency, security and accuracy in documentation of DOT alcohol tests; paperwork reduction; improved process for conducting a DOT alcohol test in conjunction with a DOT drug test when an electronic version of the federal CCF is used for the drug test; reduction of errors and omissions in the completion of the ATF; and improved efficiency and efficacy in the transmission and record retention of alcohol test results.”
DISA noted that non-DOT workplace breath alcohol testing has been conducted using electronic versions of an alcohol testing form that mirrors the DOT ATF for more than five years. Based on experience using those electronic forms for non-DOT testing, DISA cites improved efficiency and accuracy of documentation because: (1) employer and employee information is entered via computer and thus not dependent on reading and deciphering hand-written entries, (2) date time stamps of the testing are automated and not subject to fluctuation or error, (3) transmission of documentation on completed tests is more secure using databases accessed only via protected password and personal identification number (PIN) to authorized employers or their designated agents, and (4) transmission of test result information is faster and more secure than existing transmission options of scanning and emailing attachments or facsimile.
DISA also noted that permitting use of an electronic ATF for DOT-regulated alcohol testing “will substantially reduce cost, by eliminating the requirement for the printing and distribution of carbonless three-ply paper ATFs. The proposed electronic ATF option would still provide for printed paper images to be made available to the employee, the employer, and the alcohol technician, [but] eliminates the requirement for the more expensive carbonless 3 ply paper ATF.”
For the reasons described by DISA in its petition, and recognizing that significant benefits and cost reductions have resulted from use of the electronic CCF for drug testing, we believe that it is likewise appropriate to permit the use of electronic ATFs in part 40 for DOT-regulated testing. Permitting but not requiring the use of an electronic ATF would be consistent with our proposal to permit, but not require, the use of electronic documents and signatures throughout the entirety of part 40 as discussed above. As several commenters noted, the use of an electronic ATF has been used in non-DOT testing for 5-10 years, and the same developers of the electronic CCFs have developed the electronic ATFs. Any electronic ATF used under part 40 for DOT-regulated employees would have to be identical in form and content to the DOT ATF in appendix I to part 40. 8 Just as we imposed general confidentiality and security requirements when electronic CCFs were permitted to be used under part 40, we believe that it is necessary to include the same general requirements relating to the use of electronic ATFs to ensure that confidential employee records cannot be accessed by unauthorized persons.
8 The ATF form was redesignated from appendix G to appendix I as part of the rulemaking process culminating in the May 2023 final rule. During that process, the form was reviewed by the public and DOT received no comment on the form.
Manufacturers of EBTs and alcohol screening devices (ASD) used in DOT alcohol tests must obtain approval from the National Highway Traffic Safety Administration (NHTSA) and then be listed on the Office of Drug and Alcohol Policy and Compliance's (ODAPC) website before those devices may be used in DOT alcohol testing.
IX. PHMSA Proposed Changes
PHMSA is proposing to amend §§199.3, 199.117, and 199.227 and to add §199.4 to conform to the proposed changes in part 40 and to clarify that the proposed changes in part 40 apply to part 199. These changes will help the readers of part 199 find the applicable regulations in part 40 with regards to the definition of terms and record keeping requirements. We also propose to amend §§199.119 and 199.229 by changing the reference of “appendix H” to “appendix J” to conform to the amendment of part 40 published on May 2, 2023.
X. Section-by-Section Analysis
Section 40.3 What do the terms used in this regulation mean?
We propose to add a definition of “electronic signature.” The rule would define an electronic signature as a method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 44 U.S.C. 3504 note, 112 Stat. 2681-749). Including the specific cross reference to GPEA would ensure that regulated entities know that we are using GPEA's performance standard for allowing use of electronic signatures.
We propose to add a definition of “written or in writing.” The rule would define written or in writing as printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of 49 CFR 40.4. This definition would eliminate any distinction between paper and electronic methods of communication/documentation.
Section 40.4 May electronic documents and signatures be used?
We propose to add a new §40.4 that would prescribe the requirements pertaining to electronic documents and signatures throughout part 40.
Paragraph (a) would specify that §40.4 would apply to all documents required by part 40, except for the CCF, as an electronic CCF may only be used when approved by HHS and in compliance with §40.40(c)(5). As background, before an HHS-certified laboratory can use a Federal electronic CCF for regulated specimens, the test facility must submit a detailed plan and proposed standard operating procedures for the electronic CCF system for HHS review and approval through the National Laboratory Certification Program. At the current time, several HHS-certified laboratories have received approval to use a combination electronic/paper CCF, while four laboratories have received approval to use a fully electronic CCF. As noted earlier, and in a separate section of the SUPPORT Act, HHS was required to set a deadline for certified laboratories to request approval for use of fully electronic CCFs. That deadline is now August 31, 2026.
Paragraph (b) would permit, but not require, any person or entity to use electronic methods to comply with any provision in part 40 that requires a document to be signed, certified, generated, maintained, or transmitted between parties. It would apply to all forms of written documentation, including forms, records, notations, and other documents. The substance of the document would otherwise have to comply with part 40 requirements. This would establish parity between paper and electronic documents and signatures, greatly expanding interested parties' ability to use electronic methods to comply with the requirements of part 40.
Paragraph (c) would permit, but not require, any entity required to sign or certify a document to do so using electronic signatures as defined in §40.3. The rule specifies that a person may use any available technology so long as the signature otherwise complies with the requirements of part 40.
Paragraph (d) would establish the minimum requirements for electronic documents and signatures. Any electronic document or signature would be considered the legal equivalent of a paper document or signature if it is the functional equivalent with respect to integrity, accuracy, and accessibility. In other words, the electronic documents or signatures need to accurately and reliably reflect the information in the record. They must remain accessible in a form that could be accurately viewed or reproduced according to Agency rules. As with any documents, paper or electronic, documents that are not legible—for any reason—do not satisfy the Department's requirements.
Electronic documents are not to be considered the legal equivalent of traditional paper documents if they (1) are not capable of being retained, (2) are not used for the purpose for which they were created, or (3) cannot be accurately reproduced for reference by any entity entitled to access by law, for the period of time required by the Department's recordkeeping requirements.
Paragraph (d) would also require that any electronically signed documents must incorporate or otherwise include evidence that both parties to the document have consented to the use of electronic signatures, as required by the E-SIGN Act (15 U.S.C. 7001(c)).
Paragraph (e) would require that when using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records cannot be accessed by unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The proposed requirements are analogous to those established in the current §40.40(c)(5) when we approved use of the electronic CCF in part 40.
Section 40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?
Currently, paragraph (g) makes it clear that the release of information under this section must be in any written form, and the parenthetical clarifies that this can be paper-based (written, fax) or electronic (email). Under the proposed definition of “written or in writing,” there is no distinction between paper-based and electronic communications. Because “written or in writing” would mean either paper or electronic communications, we propose to remove parenthetical reference to “fax, email, letter” to eliminate redundancy and confusion. All parties can conduct their business using either paper or electronic means of documentation and communication.
Section 40.79 How is the collection process completed?
Currently, paragraph (a)(9) of this section requires the collector to “fax or otherwise transmit” Copy 2 of the CCF to the MRO and Copy 4 to the DER within 24 hours or during the next business day. We propose to amend this section by removing reference to the methods of transmitting receipts, so parties can choose their own medium of communication.
Section 40.97 What do laboratories report and how do they report it?
For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraphs (c)(1) and (2) of this section.
Section 40.111 When and how must a laboratory disclose statistical summaries and other information it maintains?
For the same reasons explained in the discussion of §40.79, we propose to amend paragraph (b) of this section to remove the references to the methods of transmitting the summary or report required by this section. Because the summary or report can be transmitted via hard copy or electronically, there is no need to specify how it must be transmitted. As such, we propose to amend the title of this section accordingly.
Section 40.127 What are the MRO's functions in reviewing negative test results?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (c)(2) of this section.
Section 40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative test results?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (b)(2) of this section.
Section 40.163 How does the MRO report drug test results?
For the same reasons explained in the discussion of §40.25, we propose to remove the reference to a “letter” in paragraph (c) of this section. In paragraph (e) of this section, we propose to replace the term “letter” with “written report” for consistency with paragraph (c).
Section 40.167 How are MRO reports of drug results transmitted to the employer?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (c)(1) of this section.
Section 40.185 Through what methods and to whom must a laboratory report split specimen results?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (b) of this section. In addition, because Copy 1 of the CCF can be transmitted in writing or electronically, there is no need to specify the methods through which it must be transmitted. As such, we propose to amend the title of this section accordingly.
Section 40.187 What does the MRO do with split specimen laboratory results?
For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraph (c)(2)(iv)(C) of this section.
Section 40.191 What is a refusal to take a DOT drug test, and what are the consequences?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (d) of this section as means of transmitting notification that an employee has refused to participate in part of the testing process from the collector or MRO to the DER.
Section 40.193 What happens when an employee does not provide a sufficient amount of urine for a drug test?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “send or fax” as the means for the collector to transmit copies of the CCF to the MRO and the DER in paragraph (b)(3) of this section.
Section 40.205 How are drug test problems corrected?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a collector, laboratory, MRO, employer, or other person to supply signed statements regarding correctable problems in a drug test in paragraphs (b)(1) and (2) of this section.
Section 40.225 What form is used for an alcohol test?
We propose to amend this section to permit, but not require, the use of an electronic version of the DOT ATF that is identical in form and content to the form provided in appendix I to part 40. The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT, and if an EBT provides a separate printout of confirmation test results pursuant to §40.253(g), the electronic ATF must include that separate printout. This section would also be amended to specify the same general confidentiality and security measures in §40.45 relating to electronic CCFs to ensure that confidential employee records cannot be accessed by unauthorized persons.
Section 40.255 What happens next after the alcohol confirmation test result?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (a)(5)(i) of this section as means of transmitting results of the alcohol confirmation test from the BAT to the DER. Similarly, there is no need to specify that Copy 1 of the ATF may be transmitted “in person, by telephone, or by electronic means.”
Section 40.261 What is a refusal to take an alcohol test, and what are the consequences?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (c) of this section as means of transmitting a refusal notification from a BAT, STT, or referral physician to the DER.
Section 40.271 How are alcohol testing problems corrected?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a STT, BAT, employer, or other service agent to supply a signed statement regarding correctable flaws in an alcohol test in paragraph (b)(2) of this section.
Section 40.365 What is the Department's policy concerning starting a PIE proceeding?
We propose to amend this section by adding a new paragraph (b)(15) that would identify the failure of a service agent to provide or maintain a secure/confidential electronic system as appropriate grounds for starting a PIE proceeding.
X. Regulatory Analyses and Notices
Executive Orders 12866, 13563, and 14094 (Regulatory Planning and Review)
The Secretary has examined the impact of the proposed part 40 amendments under Executive Order 12866 (“Regulatory Planning and Review”), as supplemented by Executive Order 13563 (“Improving Regulation and Regulatory Review”) and amended by Executive Order 14094 (“Modernizing Regulatory Review”), which directs Federal agencies to assess all costs and benefits of available regulatory alternatives and, when regulation is necessary, to select regulatory approaches that maximize net benefits (including potential economic, environmental, public health and safety, and other advantages; distributive impacts; and equity).
According to these Executive orders, a regulatory action is “significant” if it meets any one of a number of specified conditions, including having an annual effect on the economy of $200 million or more, as adjusted every three years by the Office of Information and Regulatory Affairs (OIRA); adversely affecting in a material way a sector of the economy, competition, or jobs; or if it raises novel legal or policy issues. The proposed amendments, which would allow the use of electronic documents and signatures, do not meet the Executive order's criteria for being a significant rule. Consequently, OMB has determined that the rulemaking action is not significant under the Executive order.
The proposed rule responds to the statutory mandate set forth in Section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271. The proposed rule would not impose new requirements on the industry; rather, it would simply permit—but not require—regulated entities to use electronic signatures, forms, and recordkeeping, and remove outdated and obsolete references in the regulatory text. The proposed rule would not impose new costs on the industry because regulated entities would be allowed to choose to continue to use paper-based documents as they had before. The benefits of the rule would stem from savings in paper and printing expense and other efficiency gains. Examples of documents affected by this rule include, but are not limited to, records of a prospective employee's drug and alcohol testing history that employers must obtain prior to permitting that employee to perform safety-sensitive duties, MRO records and reports, SAP records and reports, and ATFs. While there is no way to estimate how many entities or individuals would change their practices given the new options, or how many documents would be affected, several commenters to the ANPRM stated that they have been using electronic documents and signatures in their non-DOT drug and alcohol testing programs for many years. While neither the benefits nor the costs of this rule can be reliably estimated, we expect this proposed rule to provide flexibility to the industry. Under this proposed rule, regulated entities would have the flexibility to conduct business using either electronic or traditional paper-based methods. We also expect regulated entities to choose technologies that would maximize benefits in accordance with their individual needs and circumstances.
Regulatory Flexibility Act and Small Business Regulatory Enforcement Fairness Act (SBREFA)
The Regulatory Flexibility Act of 1980 (5 U.S.C. 601 et seq. ) requires Federal agencies to consider the effects of their regulatory actions on small businesses and other small entities and minimize any significant economic impact. The term “small entities” comprises small businesses and not-for-profit organizations that are independently owned and operated and are not dominant in their fields, and governmental jurisdictions with a population of less than 50,000. For this rulemaking, potentially affected small entities include drug testing companies (U.S. Small Business Administration (SBA) North American Industry Classification System (NAICS) Sector 54 (Professional, Scientific and Technical Services), Code 541380 (Testing Laboratories and Services)) as well as DOT-regulated entities (SBA NAICS Sectors 48-49 (Transportation and Warehousing)).
The Department does not expect that the proposed rule would have a significant economic impact on a substantial number of small entities. The proposed rule, if adopted, would increase flexibility for all small-entity transportation employers and their service agents by allowing them to use electronic documents, signatures, and recordkeeping to meet part 40 requirements. Use of electronic documents, electronic signatures, and electronic recordkeeping would be voluntary for affected small entities, which will provide added flexibility to these entities in meeting the part 40 requirements. For these reasons, and as explained in more detail in the preamble to this proposed rule, the Secretary certifies that the proposed rule would not have a significant economic impact on a substantial number of small entities within the meaning of the Regulatory Flexibility Act. Consequently, an initial regulatory flexibility analysis is not required for this proposed rule.
Unfunded Mandates
The Secretary has examined the impact of the final rule under the Unfunded Mandates Reform Act (UMRA) of 1995 (Pub. L. 104-4). This NPRM does not trigger the requirement for a written statement under sec. 202(a) of the UMRA because this rulemaking does not impose a mandate that results in an expenditure of $100 million (adjusted annually for inflation) or more by either State, local, and tribal governments in the aggregate or by the private sector in any one year. In fact, by providing an alternative to traditional paper-based records, the proposed rule would be expected to reduce costs to regulated parties, including State and local entities ( e.g., public transit authorities, and public works departments) whose employees are subject to testing and that choose to use electronic documents as opposed to paper-based documents.
Environmental Impact
The DOT has analyzed the environmental impacts of this action pursuant to the National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321 et seq. ) and has determined that it is categorically excluded pursuant to DOT Order 5610.1C, “Procedures for Considering Environmental Impacts” (44 FR 56420, October 1, 1979). Categorical exclusions are actions identified in an agency's NEPA implementing procedures that do not normally have a significant impact on the environment and therefore do not require either an environmental assessment (EA) or environmental impact statement (EIS). This proposed rule would amend the transportation industry drug testing program procedures regulation to permit the use of electronic documents, signatures, and recordkeeping. This action is covered by the categorical exclusion listed at 23 CFR 771.118(c)(4), “[p]lanning and administrative activities that do not involve or lead directly to construction, such as: . . . promulgation of rules, regulations, directives . . .” The Department does not anticipate any environmental impacts, and there are no extraordinary circumstances present in connection with this rulemaking.
Executive Order 13132: Federalism
The Secretary has analyzed the final rule in accordance with Executive Order 13132: Federalism. Executive Order 13132 requires Federal agencies to carefully examine actions to determine if they contain policies that have federalism implications or that preempt State law. As defined in the order, “policies that have federalism implications” refer to regulations, legislative comments or proposed legislation, and other policy statements or actions that have substantial direct effects on the States, on the relationship between the National Government and the States, or on the distribution of power and responsibilities among the various levels of government.
Most of the regulated parties under the Department's drug testing program are private entities. Some regulated entities are public entities ( e.g., transit authorities and public works departments); however, as noted above, this proposal would reduce costs of the Department's drug testing program and provide additional flexibility for regulated parties. Accordingly, the Secretary has determined that the proposed rule, which would allow but not require use of electronic signatures and recordkeeping, does not contain policies that have federalism implications.
Executive Order 13175: Consultation and Coordination With Indian Tribal Governments
Executive Order 13175 (65 FR 67249, November 6, 2000) requires Federal agencies to develop an accountable process to ensure “meaningful and timely input by tribal officials in the development of regulatory policies that have tribal implications.” “Policies that have tribal implications” as defined in the Executive order, include regulations that have “substantial direct effects on one or more Indian tribes, on the relationship between the Federal government and the Indian tribes, or on the distribution of power and responsibilities between the Federal government and Indian tribes.” This proposed rule does not have tribal implications. The proposed rule will also not have substantial direct effects on tribal governments, on the relationship between the Federal Government and Indian tribes, or on the distribution of power and responsibilities between the Federal Government and Indian tribes, as specified in Executive Order 13175.
Paperwork Reduction Act
The Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520) (PRA) requires that DOT consider the impact of paperwork and other information collection burdens imposed on the public. This proposed rule would call for no new collection of information under the PRA. Instead, there would likely be a significant reduction in the burden hours required for information collection 2105-0529, Procedures for Transportation Drug and Alcohol Testing Program, due to the ability to use electronic signatures and forms, and largely due to the ability to use an electronic ATF for DOT-regulated alcohol testing under part 40. We request comments on this issue. Notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information subject to the PRA that does not display a currently valid OMB control number.
Privacy Act
Anyone is able to search the electronic form of all comments received in any of our dockets by the name of the individual submitting the comment (or signing the comment, if submitted on behalf of an association, business, labor union, etc.) For information on DOT's compliance with the Privacy Act, please visit https://www.transportation.gov/privacy.
5 U.S.C. 553(b)(4)
As required by 5 U.S.C. 553(b)(4), a summary of this proposed rule can be found at the entry for RIN 2105-AF01 in the Department's Portion of the Unified Agenda of Regulatory and Deregulatory Affairs, available at https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202404&RIN=2105-AF01 .
Pay-As-You-Go Act of 2023
In accordance with Compliance with Pay-As-You-Go Act of 2023 (Fiscal Responsibility Act of 2023, Pub. L. 118-5, div. B, title III) and OMB Memorandum (M-23-21) dated September 1, 2023, the Department has determined that this proposed rule is not subject to the Pay-As-You-Go Act of 2023 because it will not increase direct spending beyond specified thresholds.
List of Subjects
49 CFR Part 40
Administrative practice and procedures, Alcohol abuse, Alcohol testing, Drug abuse, Drug testing, Laboratories, Reporting and recordkeeping requirements, Safety, Transportation.
49 CFR Part 199
Alcohol testing, Drug testing, Pipeline safety, Reporting and recordkeeping requirements, Safety, Transportation.
For the reasons stated in the preamble, the Department proposes to amend 49 CFR parts 40 and 199 as follows:
PART 40—PROCEDURES FOR TRANSPORTATION WORKPLACE DRUG AND ALCOHOL TESTING PROGRAMS
1. The authority for part 40 continues to read as follows:
Authority:
49 U.S.C. 102, 301, 322, 5331, 20140, 31306, and 54101 et seq.
2. In §40.3, add the definitions of “Electronic signature” and “Written or in writing” in alphabetical order to read as follows:
§40.3 What do the terms used in this part mean?
* * * * *
Electronic signature. A method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 112 Stat. 2681-749, 44 U.S.C. 3504 note).
* * * * *
Written or in writing. Printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of §40.4.
3. Add §40.4 to read as follows:
§40.4 May electronic documents and signatures be used?
(a) Applicability. This section applies to all documents required by this part, except for the CCF. An electronic CCF may be used only if it has been approved for use by the Department of Health and Human Services and is used in compliance with §40.40(c)(5).
(b) Electronic records or documents. Any person or entity required to generate, maintain, or exchange and/or transmit documents to satisfy requirements in this part may use electronic methods to satisfy those requirements.
(c) Electronic signatures. (1) Any person or entity required to sign or certify a document to satisfy the requirements of this part may use an electronic signature, as defined in §40.3.
(2) Any available technology may be used that satisfies the requirements of an electronic signature as defined in §40.3.
(d) Electronic document requirements. Any person or entity may use documents signed, certified, generated, maintained, or exchanged using electronic methods, as long as the documents accurately reflect the information otherwise required to be contained in them.
(1) Records, documents, or signatures generated, maintained, or exchanged using electronic methods satisfy the requirements of this section if they are capable of being retained, are used for the purpose for which they were created, and can be accurately reproduced within required timeframes for reference by any party entitled to access.
(2) Records or documents generated electronically satisfy the requirements of this section if they include proof of consent to use electronically generated records or documents, as required by 15 U.S.C. 7001(c).
(e) Confidentiality and security. When using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form to include protecting against destruction, deterioration, and data corruption.
4. In §40.25, revise paragraph (g) to read as follows:
§40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?
* * * * *
(g) The release of information under this section must be in any written form that ensures confidentiality. As the previous employer, you must maintain a written record of the information released, including the date, the party to whom it was released, and a summary of the information provided.
* * * * *
5. In §40.79, revise paragraph (a)(9) to read as follows:
§40.79 How is the collection process completed?
(a) * * *
(9) Send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or during the next business day. Keep Copy 3 for at least 30 days, unless otherwise specified by applicable DOT agency regulations.
* * * * *
6. In §40.97, revise paragraphs (c) introductory text, (c)(1) introductory text, and (c)(2) to read as follows:
§40. 97 What do laboratories report and how do they report it?
* * * * *
(c) As a laboratory, you must report laboratory results directly, and only, to the MRO at his or her place of business. You must not report results to or through the DER or a service agent ( e.g., C/TPA).
(1) Negative results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF which has been signed by the certifying scientist, or you may provide the laboratory results report electronically.
* * * * *
(2) Non-negative and rejected for testing results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF that has been signed by the certifying scientist. In addition, you may provide the laboratory results report following the format and procedures set forth in paragraphs (c)(1)(i) and (ii) of this section.
* * * * *
7. In §40.111, revise the section heading and paragraph (b) to read as follows:
§40.111 When must a laboratory disclose statistical summaries and other information it maintains?
* * * * *
(b) When the employer requests a summary in response to an inspection, audit, or review by a DOT agency, you must provide it unless the employer had fewer than five aggregate test results. In that case, you must send the employer a report indicating that not enough testing was conducted to warrant a summary.
* * * * *
8. In §40.127, revise paragraph (c)(2) to read as follows:
§40.127 What are the MRO's functions in reviewing negative test results?
* * * * *
(c) * * *
(2) A legible copy of Copy 1 of the CCF or the electronic laboratory results report that conveys the negative laboratory test result.
* * * * *
9. In §40.129, revise paragraphs (b) introductory text and (b)(2) to read as follows:
§40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative drug test results?
* * * * *
(b) Before you report a verified negative, positive, test cancelled, refusal to test because of adulteration or substitution, you must have in your possession the following documents:
* * * * *
(2) A legible copy of Copy 1 of the CCF, containing the certifying scientist's signature.
* * * * *
10. In §40.163, revise paragraphs (c) introductory text and (e) to read as follows:
§40.163 How does the MRO report drug test results?
* * * * *
(c) If you do not report test results using Copy 2 of the CCF for the purposes of this section, you must provide a written report for each test result. This report must, as a minimum, include the following information:
* * * * *
(e) You must retain a signed or stamped and dated copy of Copy 2 of the CCF in your records. If you do not use Copy 2 for reporting results, you must maintain a copy of the signed or stamped and dated written report in addition to the signed or stamped and dated Copy 2. If you use the electronic data file to report negatives, you must maintain a retrievable copy of that report in a format suitable for inspection and auditing by a DOT representative.
* * * * *
11. In §40.167, revise paragraph (c)(1) to read as follows:
§40.167 How are MRO reports of drug test results transmitted to the employer?
* * * * *
(c) * * *
(1) You must transmit a legible image or copy of either the signed or stamped and dated Copy 2 or the written report (see §40.163(b) and (c)).
* * * * *
12. In §40.185, revise the section heading and paragraph (b) to read as follows:
§40.185 What and to whom must a laboratory report split specimen results?
* * * * *
(b) You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF, which has been signed by the certifying scientist.
* * * * *
13. In §40.187, revise paragraph (c)(2)(iv)(C) to read as follows:
§40.187 What does the MRO do with split specimen laboratory results?
* * * * *
(c) * * *
(2) * * *
(iv) * * *
(C) As the laboratory that tests the primary specimen to reconfirm the presence of the adulterant found in the split specimen and/or to determine that the primary specimen meets appropriate substitution criteria, report your result to the MRO using a copy of Copy 1 of the CCF.
* * * * *
14. In §40.191, revise paragraph (d) introductory text to read as follows:
§40.191 What is a refusal to take a DOT drug test, and what are the consequences?
* * * * *
(d) As a collector or an MRO, when an employee refuses to participate in the part of the testing process in which you are involved, you must terminate the portion of the testing process in which you are involved, document the refusal on the CCF (including, in the case of the collector, printing the employee's name on Copy 2 of the CCF), immediately notify the DER by any means that ensures that the refusal notification is immediately received. As a referral physician ( e.g., physician evaluating a “shy bladder” condition or a claim of a legitimate medical explanation in a validity testing situation), you must notify the MRO, who in turn will notify the DER.
* * * * *
15. In §40.193, revise paragraph (b)(3) to read as follows:
§40.193 What happens when an employee does not provide a sufficient amount of specimen for a drug test?
* * * * *
(b) * * *
(3) As the collector, you must send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or the next business day.
* * * * *
16. In §40.205, revise paragraphs (b)(1) and (2) to read as follows:
§40.205 How are drug test problems corrected?
* * * * *
(b) * * *
(1) If the problem resulted from the omission of required information, you must, as the person responsible for providing that information, supply in writing the missing information and a statement that it is true and accurate. For example, suppose you are a collector, and you forgot to make a notation on the “Remarks” line of the CCF that the employee did not sign the certification. You would, when the problem is called to your attention, supply a signed statement that the employee failed or refused to sign the certification and that your statement is true and accurate. You must supply this information on the same business day on which you are notified of the problem.
(2) If the problem is the use of a non-Federal form or an expired Federal form, you must provide a signed statement ( i.e., a memorandum for the record). It must state that the incorrect form contains all the information needed for a valid DOT drug test, and that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control. The statement must also list the steps you have taken to prevent future use of non-Federal forms or expired Federal forms for DOT tests. For this flaw to be corrected, the test of the specimen must have occurred at an HHS-certified laboratory where it was tested consistent with the requirements of this part. You must supply this information on the same business day on which you are notified of the problem.
* * * * *
17. In §40.225, revise paragraph (a) and add paragraphs (d) and (e) to read as follows:
§40.225 What form is used for an alcohol test?
(a) The DOT Alcohol Testing Form (ATF) must be used for every DOT alcohol test. The ATF must be a three-part carbonless manifold form or an electronic ATF that meets the requirements of paragraph (d) of this section. The ATF is found in appendix G to this part. You may view this form on the ODAPC website ( https://www.transportation.gov/odapc ).
* * * * *
(d) As an employer, you may use an electronic ATF that meets the following requirements:
(1) The electronic ATF must be identical in form and content to the ATF found in appendix G to this part.
(2) The electronic ATF must meet the requirements of §40.4(d).
(3) The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT.
(4) If an EBT provides a separate printout of confirmation test results (see §40.253(g)), the electronic ATF must include that separate printout.
(e) As an employer, BAT, or STT using an electronic ATF, you must establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form.
18. In §40.255, revise paragraph (a)(5)(i) to read as follows:
§40.255 What happens next after the alcohol confirmation test result?
(a) * * *
(5) * * *
(i) You may transmit the results using Copy 1 of the ATF, in person, by telephone, or by electronic means. In any case, you must immediately notify the DER of any result of 0.02 or greater by any means that ensures the result is immediately received by the DER. You must not transmit these results through C/TPAs or other service agents.
* * * * *
19. In §40.261, revise paragraph (c)(1) to read as follows:
§40.261 What is a refusal to take an alcohol test, and what are the consequences?
* * * * *
(c)(1) As a BAT or an STT, or as the physician evaluating a “shy lung” situation, when an employee refuses to test as provided in paragraph (a) of this section, you must terminate the portion of the testing process in which you are involved, document the refusal on the ATF (or in a separate document which you cause to be attached to the form), immediately notify the DER by any means that ensures the refusal notification is immediately received. You must make this notification directly to the DER (not using a C/TPA as an intermediary).
* * * * *
20. In §40.271, revise paragraph (b)(2) to read as follows:
§40.271 How are alcohol testing problems corrected?
* * * * *
(b) * * *
(2) If the problem is the use of a non-DOT form, you must, as the person responsible for the use of the incorrect form, certify in writing that the incorrect form contains all the information needed for a valid DOT alcohol test. You must also provide a signed statement that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control, and the steps you have taken to prevent future use of non-DOT forms for DOT tests. You must supply this information on the same business day on which you are notified of the problem.
* * * * *
21. In §40.365, revise paragraphs (b)(13) and (14) and add paragraph (b)(15) to read as follows:
§40.365 What is the Department's policy concerning starting a PIE proceeding?
* * * * *
(b) * * *
(13) For any service agent, directing or recommending that an employer fail or refuse to implement any provision of this part;
(14) With respect to noncompliance with a DOT agency regulation, conduct that affects important provisions of Department-wide concern ( e.g., failure to properly conduct the selection process for random testing); or
(15) For a service agent, failing to provide or maintain a secure/confidential electronic system. PART 199—DRUG AND ALCOHOL TESTING
22. The authority citation for part 199 continues to read as follows:
Authority:
49 U.S.C. 5103, 60102, 60104, 60108, 60117, and 60118; 49 CFR 1.53.
23. In §199.3:
a. Designate the introductory text as paragraph (b); and
b. Add paragraph (a).
The addition reads as follows:
§199.3 Definitions.
(a) Terms used in this part have the same meaning as in 49 CFR 40.3.
* * * * *
24. Add §199.4 to read as follows:
§199.4 Electronic documents, records, and signatures.
Electronic documents, records, and signatures may be used to comply with this part provided they meet the requirements specified in 49 CFR part 40.
25. In §199.117, revise paragraph (a) introductory text to read as follows:
§199.117 Recordkeeping.
(a) Each operator shall keep the records in paragraphs (a)(1) through (5) of this section for the periods specified by this section or for the periods specified by 49 CFR part 40, whichever is greater; and will permit access to the records as provided by §190.203.
* * * * *
26. In §199.119, revise paragraph (a) to read as follows:
§199.119 Reporting of anti-drug testing results.
(a) Each large operator (having more than 50 covered employees) must submit an annual Management Information System (MIS) report to PHMSA of its anti-drug testing using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.
* * * * *
27. In §199.227, revise paragraph (b) introductory text to read as follows:
§199.227 Retention of records.
* * * * *
(b) Period of retention. Each operator shall maintain the records in accordance with the following schedule or for the periods specified by 49 CFR part 40, whichever is greater:
* * * * *
28. In §199.229, revise paragraph (a) to read as follows:
§199.229 Reporting of alcohol testing results.
(a) Each large operator (having more than 50 covered employees) must submit an annual MIS report to PHMSA of its alcohol testing results using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.
* * * * *
Signed on: Thursday, October 3, 2024.
Pete Buttigieg,
Secretary of Transportation.
[FR Doc. 2024-23427 Filed 10-11-24; 8:45 am]
BILLING CODE 4910-9X-P
NewsFleet SafetyPipeline and Hazardous Materials Safety Administration (PHMSA), DOTDrug testing - Motor CarrierDrug and Alcohol Testing - DOTOffice of the Secretary of TransportationHazmat SafetyRulemakingFocus AreaProposed RuleEnglishTransportationUSA
89 FR 82957 Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records
2024-10-15T05:00:00Z
DEPARTMENT OF TRANSPORTATION
Office of the Secretary
49 CFR Part 40
Pipeline and Hazardous Materials Safety Administration
49 CFR Part 199
[Docket DOT-OST-2022-0027]
RIN 2105-AF01
Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records
AGENCY: Office of the Secretary, Department of Transportation (DOT).
ACTION: Notice of proposed rulemaking (NPRM).
SUMMARY: The Department of Transportation (DOT or Department) proposes to amend its regulations for conducting workplace drug and alcohol testing for the federally regulated transportation industry to allow, but not require, electronic signatures on documents required to be created and utilized under the regulations, the use of electronic versions of forms, and the electronic storage of forms and data. The regulatory changes would apply to DOT-regulated employers and their contractors (“service agents”) who administer their DOT-regulated drug and alcohol testing programs. Currently, employers and their service agents must use, sign and store paper documents exclusively, unless the employer is utilizing a laboratory's electronic Federal Drug Testing Custody and Control Form (electronic CCF) system that has been approved by the Department of Health and Human Services (HHS). DOT is required by statute to amend its regulations to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms. This rulemaking also responds to an April 2, 2020, petition for rulemaking from DISA Global Solutions, Inc. (DISA), requesting that DOT regulations be amended to allow the use of an electronic version of the alcohol testing form (ATF) for DOT-authorized alcohol testing. The proposed regulatory amendments are expected to provide additional flexibility and reduced costs for the industry while maintaining the integrity and confidentiality requirements of the drug and alcohol testing regulations. In addition, DOT proposes to amend the Pipeline and Hazardous Materials Safety Administration (PHMSA) regulation for conformity and to make other miscellaneous technical changes and corrections.
DATES: Comments on this NPRM must be received on or before December 16, 2024.
ADDRESSES: You may submit comments identified by Docket Number DOT-OST-2022-0027 using any of the following methods:
• Federal eRulemaking Portal: Go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document. Follow the online instructions for submitting comments.
• Mail: Docket Management Facility, U.S. Department of Transportation, 1200 New Jersey Avenue SE, West Building, Ground Floor, Room W12-140, Washington, DC 20590-0001.
• Hand Delivery or Courier: West Building, Ground Floor, Room W12-140, 1200 New Jersey Avenue SE, Washington, DC, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting Dockets Operations.
• Fax: 202-493-2251.
To avoid duplication, please use only one of these methods. See the “Public Participation and Request for Comments” portion of the SUPPLEMENTARY INFORMATION section for instructions on submitting comments, including collection of information comments for the Office of Information and Regulatory Affairs, Office of Management and Budget (OMB).
FOR FURTHER INFORMATION CONTACT:
Mike Huntley, Office of Drug and Alcohol Policy and Compliance, 1200 New Jersey Avenue SE, Washington, DC 20590; telephone number 202-366-3784; ODAPCwebmail@dot.gov. If you have questions on viewing or submitting material to the docket, contact Docket Services, telephone (202) 366-9826.
SUPPLEMENTARY INFORMATION:
This NPRM is organized as follows:
I. Executive Summary
II. Public Participation and Request for Comments
A. Submitting Comments
B. Viewing Comments and Documents
C. Privacy Act
III. Legal Basis for the Rulemaking
IV. Background
V. Advance Notice of Proposed Rulemaking (ANPRM) Overview
VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures
VII. Amending Part 40 To Permit Electronic Documents and Signatures
VIII. Electronic ATF
IX. Section-by-Section Analysis
X. Regulatory Analyses and Notices
I. Executive Summary
Purpose and Summary of the Major Provisions
This proposed rule would establish parity between paper and electronic documents and signatures and expand businesses' and individuals' ability to use electronic methods to comply with the Department's drug and alcohol testing regulation, 49 CFR part 40, “Procedures for Transportation Workplace Drug and Alcohol Testing Programs” (part 40). Businesses and individuals subject to part 40 would continue to have the choice to use paper documents and traditional “wet” signatures. This proposed rule would also modify references to recordkeeping and reporting methods throughout part 40 to make them technologically neutral.
This proposed rulemaking responds to a statutory mandate set forth in section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271 (see 49 U.S.C. 322 note). The proposed rulemaking would take action consistent with the Government Paperwork Elimination Act (GPEA) (division C, title XVII, secs. 1701-1710, Pub. L. 105-277) and the Electronic Signatures in Global and National Commerce Act (E-SIGN) (Pub. L. 106-229) with regard to DOT's part 40 regulations.
II. Public Participation and Request for Comments
A. Submitting Comments
If you submit a comment, please include the docket number for this NPRM (Docket No. DOT-OST-2022-0027), indicate the specific section of this document to which each comment applies, and provide a reason for each suggestion or recommendation. You may submit your comments and material online or by fax, mail, or hand delivery, but please use only one of these means. The Office of the Secretary (OST) recommends that you include your name and a mailing address, an email address, or a phone number in a cover letter or an email so that OST can contact you if there are questions regarding your submission.
To submit your comment online, go to https://www.regulations.gov/docket/DOT-OST-2022-0027/document, click on this NPRM, click “Comment,” and type your comment into the text box on the following screen.
If you submit your comments by mail or hand delivery, submit them in an unbound format, no larger than 8 1/2 by 11 inches, suitable for copying and electronic filing. If you submit comments by mail and would like to know that they reached the facility, please enclose a stamped, self-addressed postcard or envelope.
OST will consider all comments and material received during the comment period in determining how to proceed with any final rule.
B. Viewing Comments and Documents
To view comments, as well as any documents mentioned in this preamble as available in the docket, go to https://www.regulations.gov. Insert the docket number, DOT-OST-2022-0027, in the keyword box, and click “Search.” Next, click the “Open Docket Folder” button and choose the document to review. If you do not have access to the internet, you may view the docket online by visiting the Docket Management Facility in Room W12-140 on the ground floor of the DOT West Building, 1200 New Jersey Avenue SE, Washington, DC 20590-0001, between 9 a.m. and 5 p.m. ET, Monday through Friday, except Federal holidays. To be sure someone is there to help you, please call (202) 366-9317 or (202) 366-9826 before visiting the Docket Management Facility.
C. Privacy Act
In accordance with 5 U.S.C. 553(c), DOT solicits comments from the public to better inform its rulemaking process. DOT posts these comments, without edit, including any personal information the commenter provides, to www.regulations.gov, as described in the system of records notice (DOT/ALL-14 FDMS), which can be reviewed at https://www.transportation.gov/individuals/privacy/privacy-act-system-records-notices under the heading of “Department-Wide System of Records Notices”.
III. Legal Basis for the Rulemaking
This rulemaking is promulgated under the authority enacted in the Omnibus Transportation Employee Testing Act of 1991 (OTETA) (Pub. L. 102-143, tit. V, 105 Stat. 952) and codified at 49 U.S.C. 45102 (aviation), 49 U.S.C. 20140 (rail), 49 U.S.C. 31306 (motor carrier), and 49 U.S.C. 5331 (public transportation), as well as the Department's authority in 49 U.S.C. 322 and the PHMSA authorities specified in the proposed regulatory text for this action.
According to Public Law 115-271, the Secretary of Transportation is required to “issue a final rule revising part 40 of title 49, Code of Federal Regulations, to authorize, to the extent practicable, the use of electronic signatures or digital signatures executed to electronic forms instead of traditional handwritten signatures executed on paper forms.” (49 U.S.C. 322 note) The statute set the deadline for this action as not later than 18 months after HHS establishes a deadline for a certified laboratory to request approval for fully electronic CCFs ( Id. ) On April 7, 2022, HHS set that deadline as August 31, 2023 (87 FR 20528). HHS has extended the deadline to August 31, 2026, to enable sufficient time for all HHS-certified laboratories to identify and contract with an electronic CCF supplier or to develop an electronic CCF. The deadline for DOT's regulatory amendments would therefore be February 29, 2028.
There are two additional Federal statutes relevant to the implementation of electronic document and signature requirements.
The Government Paperwork Elimination Act (GPEA), codified at 44 U.S.C. 3504 note, 1 was enacted to improve customer service and governmental efficiency through the use of information technology. The GPEA defines an electronic signature as a method of signing an electronic communication that: (a) identifies and authenticates a particular person as the source of the electronic communication; and (b) indicates such person's approval of the information contained in the electronic communication. Id. It also requires OMB to ensure Federal agencies provide for: (a) the option of maintaining, submitting; or disclosing information electronically, when practicable; and (b) the use and acceptance of electronic signatures when practicable. The GPEA states that electronic records submitted pursuant to procedures developed under title XVII for the submission of records to Federal agencies and electronic signatures used in accordance with those procedures shall not be denied legal effect, validity, or enforceability merely because they are in electronic form. Id.
1 Division C, title XVII (sec. 1701-1710) of Public Law 105-277, 112 Stat. 2681-749, enacted on October 21, 1998.
The Electronic Signatures in Global and National Commerce Act (E-SIGN), codified at 15 U.S.C. 7001-7031, 2 was designed to promote the use of electronic contract formation, signatures, and recordkeeping in private commerce by establishing legal equivalence between traditional paper-based methods and electronic methods. The E-SIGN Act allows the use of electronic records to satisfy any statute, regulation, or rule of law requiring that such information be provided in writing if the consumer has affirmatively consented to such use and has not withdrawn consent. Specifically, the statute establishes the legal equivalence of the following types of documents with respect to any transaction in or affecting interstate or foreign commerce, whether in traditional paper or electronic form: (a) contracts, (b) signatures, and (c) other records (15 U.S.C. 7001(a)(1)).
2 Public Law 106-229, 114 Stat. 464, enacted on June 30, 2000.
IV. Background
The Department's drug and alcohol testing regulations were promulgated at a time when the ability to sign and retain official records electronically—now commonplace in many business segments—was not available. Over the course of several years, we have adopted measures that have reduced the paper documentation associated with the drug and alcohol testing program without compromising the integrity and confidentiality requirements of the program. In 2003, we standardized the form for employers to report their Management Information System (MIS) aggregate drug and alcohol testing data, as well as the specific data collected. 3 When creating a ONE-DOT MIS Form, we then authorized employers to submit a single standardized form via a web portal. In 2015, we issued a final rule to allow employers, collectors, laboratories, and medical review officers (MROs) to use the electronic version of the Federal Drug Testing CCF in the DOT-regulated drug testing program. 4 That final rule also incorporated into the regulations the requirement to establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons when using the electronic CCF. We also included language protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form when using the electronic CCF.
3 68 FR 43946 (July 25, 2003).
4 80 FR 19551 (Apr. 13, 2015).
Consistent with the statutory mandate in 49 U.S.C. 322 note, we propose amendments to part 40 to permit the use of electronic signatures, forms, and records storage for drug and alcohol testing records throughout the regulation, including the use of an electronic ATF for DOT-authorized alcohol testing. We emphasize that electronic signatures, forms, and records would not be required; we would continue to allow paper, or hard-copy use with traditional “wet signatures.”
These proposed amendments would establish parity between paper and electronic collection and submission of information required under our regulations (and remain compatible with applicable OMB guidance on implementing electronic signatures 5 ) by allowing further use of electronic means and methods to comply with part 40 requirements. Many employers and their service agents have already instituted the use of electronic signatures, forms, and records storage for the non-DOT regulated testing that they conduct. DOT supports this transition to a paperless system and is committed to ensuring that the movement to a partially or fully electronic part 40 is done to maximize program efficiencies and reduce costs, while maintaining the integrity and confidentiality requirements of the program.
5https://www.whitehouse.gov/wp-content/uploads/2017/11/2000-M-00-15-OMB-Guidance-on-Implementing-the-Electronic-Signatures-in-Global-and-National-Commerce-Act.pdf.
Electronic documents would have a high degree of forensic defensibility as long as any changes made to the document are in the document's electronic footprint, which shows when the document or signature, as applicable, was created; when, and if, changes were made; who made the changes; and when, as applicable, a document was transmitted to and received by the receiving entity. The use of electronic forms and signatures in part 40 would help DOT-regulated employers and their service agents improve their workflow efficiency through faster turnaround times for required documents. Cost savings would result through reduced printing and delivery/shipping costs, and expedited transmission of information allowing for more timely decisions. We believe this proposed rule, if adopted, would also mitigate the longstanding problems ( e.g., delays in processing times of test results, cancelling of test results, etc.) associated with illegible and lost copies of paper documents.
V. Advance Notice of Proposed Rulemaking (ANPRM) Overview
On August 5, 2022, we published an ANPRM requesting public comment on how part 40 could be amended, as required by the statute, to allow electronic signatures, forms, and recordkeeping (87 FR 47951). We requested information from DOT-regulated employers and their service agents regarding if and how they are already handling electronic signatures, records transmission, and records storage in their non-DOT testing programs. In addition, we requested comments and information on appropriate performance standards, and on whether particular methods or performance standards have been successful or unsuccessful. We also asked a number of general questions on the potential advantages, risks, ramifications, and required safeguards associated with the use of electronic signatures, forms, and records in the DOT drug and alcohol testing program. We asked questions about specific sections of part 40 that we anticipated would be affected by prospective changes to implement electronic signatures, forms, and records. Finally, we asked a number of questions regarding the use of an electronic ATF for DOT-regulated alcohol tests.
We received 72 comments in response to the ANPRM, including comments from individuals, testing laboratories, MROs, and MRO organizations, substance abuse professionals (SAP) and SAP organizations, and various associations representing DOT-regulated transportation workers subject to mandatory drug and alcohol testing under part 40.
A few individuals expressed opposition to the adoption of electronic signatures, forms, and recordkeeping, citing concerns about the need for the rulemaking, risk to personal information from hackers or mismanaged electronic processes and procedures, and misuse of electronic forms and signatures. To meet our statutory mandate and in consideration of concerns about safeguarding personal information and appropriate use of the information in developing the NPRM, DOT proposes to require security measures for electronic forms and signatures used under part 40 that are the same as those currently in place for the electronic CCF specified in 49 CFR 40.40(c)(5).
Most commenters were supportive of changes to amend part 40 that would permit, but not require, the use of electronic signatures, forms, and recordkeeping. Commenters supporting revisions to part 40 noted that electronic signatures, forms, and recordkeeping are used in virtually every industry today—including but not limited to the banking, insurance, medical, and legal industries. Commenters supported the use of performance standards instead of technology-specific standards to ensure that, once established, standards do not become obsolete given the rapidly evolving nature of information technology standards and practices. Commenters stated that allowing electronic signatures, forms, and recordkeeping would make the drug testing process much more efficient and would result in cost savings. Commenters also stated that it would be safer to store records electronically since records could be backed-up, secured, and protected from tampering and unauthorized access and use.
VI. Federal Motor Carrier Safety Administration (FMCSA) Rulemaking on Electronic Documents and Signatures
In developing this NPRM, we looked to a rule promulgated by DOT's FMCSA that permits the use of electronic methods to generate, certify, sign, maintain, or exchange records so long as the documents accurately reflect the required information and can be used for their intended purpose. (83 FR 16210, Apr. 16, 2018) The rule applies to documents that FMCSA requires entities or individuals to retain. FMCSA permits, but does not require, anyone to satisfy FMCSA requirements by using electronic methods to generate, maintain, or exchange documents. The substance of the document must otherwise comply with applicable Federal laws and FMCSA rules. FMCSA also permits, but does not require, anyone required to sign or certify a document to do so using electronic signatures, defined, as in the GPEA, as a method of signing an electronic communication that: (1) identifies and authenticates a particular person as the source of the electronic communication; and (2) indicates such person's approval of the information contained in the electronic communication. FMCSA allows for the use any available technology for electronic signatures, so long as the signature otherwise complies with FMCSA's requirements.
FMCSA adopted broad performance standards for electronic documents and signatures—as specified in GPEA and E-SIGN—rather than detailed, technology specific standards that would likely become obsolete with inevitable changes in information technology standards and practices. FMCSA's April 2018 rule has been in effect for more than five years, and the definitions and requirements established in that rule have stood the test of time despite the many changes that have occurred with respect to electronic documents and signatures. We are unaware of any FMCSA-regulated entities that have reported issues to FMCSA regarding the use of electronic documents or signatures to meet the requirements of the FMCSRs since the rule became effective in 2018.
VII. Amending Part 40 To Permit Electronic Documents and Signatures
In this NPRM, we propose to permit but not require electronic documents, signatures, and recordkeeping in part 40. Additionally, we propose a performance standard approach as opposed to establishing technology-specific standards. Where it is possible to do so, establishing the same or substantively similar regulatory requirements for common issues across DOT modal agencies—such as the use of electronic documents and signatures—helps the Department maintain a consistent regulatory approach for those common issues.
There are currently more than 60 references to the term “written” in part 40, and more than 20 additional references to the term “in writing.” We propose to add a definition of “written or in writing” in part 40, to eliminate any distinction between paper and electronic documentation and establish technological neutrality throughout the entirety of part 40.
FMCSA's rule does not apply to documents that individuals or entities are required to file directly with FMCSA. In its April 2018 final rule, FMCSA explained that while industry could use electronic signatures and submit information directly to the FMCSA in certain situations, 6 adapting all FMCSA systems to allow for use of electronic signatures and submissions would significantly delay the implementation of the rule for use by third parties as it would require FMCSA to develop and implement technology systems to allow for direct submission to FMCSA from regulated parties. FMCSA noted that development of such systems could take several years, and therefore saw no reason to make private parties' use of electronic signatures and records retention contingent upon FMCSA's ability to receive submissions electronically because doing so would delay potential benefits to be gained by third parties.
6 As an example, Certified Medical Examiners may use electronic signatures, if they choose to do so, to sign medical forms, certificates, and a new driver medication report. If FMCSA requests these forms, they are uploaded in portable document format (PDF) to the Medical Examiner's account associated with the National Registry of Certified Medical Examiners for FMCSA to access.
In contrast to FMCSA's regulations, part 40 does not require entities or individuals to submit documents directly to the Department except for MIS aggregate drug and alcohol testing data that employers subject to DOT or U.S. Coast Guard (USCG) drug and alcohol testing regulations must submit annually. Each of the various documents required and used as part of the DOT drug and alcohol testing program under part 40 ( e.g., employee drug and alcohol testing records, MRO reports and records, SAP reports and records) are documents that are created by, exchanged between, and maintained by a person or entity involved in the testing process—but are not required to be submitted directly to DOT.
As noted earlier, and specifically with respect to the required MIS data, we standardized the form for employers to report their aggregate drug and alcohol testing data, as well as the specific data collected, more than 20 years ago. At that time, we authorized employers to submit the ONE-DOT MIS form via a web portal. Today, the Federal Aviation Administration, FMCSA, Federal Railroad Administration, and Federal Transit Administration permit employers to submit that same drug and alcohol testing data via the internet, and PHMSA requires that the data be submitted electronically. If employers submit the data electronically via the internet, they are not required to submit a hard copy. DOT recommends that employers have a copy of their data available (either hard copy or in electronic format) in the event an auditor or inspector requests a copy.
From the above, and because the only documents that part 40 requires to be submitted directly to the Department are already permitted to be, and in some cases required to be, submitted electronically, there is no need for us to limit the applicability of our proposal as FMCSA did in its 2018 final rule.
Several commenters noted that they already use electronic signatures and documents for their non-DOT drug and alcohol testing program, and in some cases, have done so for many years. In doing so, these commenters have had to establish appropriate confidentiality and security measures to ensure that confidential employee records cannot be accessed by unauthorized persons, including protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The same general requirements were added to the current §40.40(c)(5) when we approved the use of the electronic CCF for use in DOT drug testing in 2015, 7 and we propose the same requirements in this NPRM for the use of electronic signatures, documents, and recordkeeping throughout the entirety of part 40.
7 The 2015 revisions amended then §40.45(c)(5), which was redesignated as §40.40(c)(5) in the May 2023 final rule to include oral fluid testing in the DOT drug testing program (88 FR 27596, May 2, 2023).
Ensuring that confidential employee records are not available to unauthorized persons is an important element of part 40's protections for employees that are subject to DOT's drug and alcohol testing rules. We believe that the failure of a service agent to provide or maintain a secure/confidential electronic system should constitute the basis for the Department to start a public interest exclusion (PIE) proceeding, and propose to add this to the list of examples provided in §40.365(b).
Throughout part 40, information and documents are required to be transmitted and/or communicated between service agents ( e.g., collectors, screening test technicians (STTs) and breath alcohol technicians (BATs), laboratories, MROs, SAPs, and consortium/third party administrators (C/TPAs)), employers, and employees). Although part 40 does not currently require the party receiving these communications and/or documents to affirmatively confirm receipt of such from the sender, in some instances, regardless of whether the document is electronic or a hard copy, we believe that it may be important for the receiving party to verify that those required communications and/or documents were received.
For example, under §40.25, an employer intending to use an employee to perform safety-sensitive functions must, after obtaining an employee's written consent, request information about the employee's drug and alcohol testing record from previous DOT-regulated employers. After receiving a copy of the employee's written consent, the previous employer must immediately provide the requested information to the employer making the inquiry. If an employer is subsequently investigated/audited by the appropriate DOT mode, it may be beneficial for both the gaining employer and the previous employer to be able to affirmatively demonstrate that the employee's written consent and previous testing record were sent and received as required.
Sections 40.191(d) and 40.261(c)(1) require a collector or MRO (for drug tests) or a BAT, STT, or a physician evaluating a “shy lung” situation (for alcohol tests), respectively, to—when an employee refuses to participate in a part of the testing process—terminate the testing process, document the refusal, and immediately and directly notify the employer's designated employer representative (DER) by any means that ensures the refusal notification is immediately received. Because this notification of a refusal to an employer is of an urgent nature, it may be advisable to require the DER to affirmatively confirm receipt of the required notification from the collector, MRO, BAT, STT, or physician. For example, §§40.191(d) and 40.261(c)(1) could be amended to read “. . . immediately notify the DER by any means and ensure that the refusal notification is immediately received”.
While we are not proposing new requirements in this NPRM regarding confirmation of receipt in the sections discussed above (or in other part 40 requirements), we seek comment regarding whether it may be beneficial or advisable to do so, and if so, for which specific sections of part 40.
VIII. Electronic ATF
The ATF has been in use in the DOT alcohol testing program since 1994 (see 59 FR 7349, Feb. 15, 1994). The ATF must be used to document every DOT alcohol test. DOT regulations at 49 CFR 40.225 set forth the requirements for use of the form, and 49 CFR part 40, appendix G, contains a facsimile (reference copy) of the form. The ATF is a three-part carbonless manifold form used by DOT-regulated employers to document the testing event when testing employees subject to DOT alcohol testing. When the employee is tested, both the employee and the STT and/or the BAT will complete the ATF in various sections. The STT/BAT documents the result(s) by either writing in the screening result or attaching the screening and/or confirmation result printed by the evidential breath testing devices (EBT) onto the ATF, and then sends Copy 1 to the employer, provides Copy 2 to the employee, and retains Copy 3 for their records.
On April 2, 2020, DISA petitioned the Department to amend part 40 to allow for the use of an electronic version of the ATF for DOT mandated alcohol testing. In support of its petition, DISA stated that “The requested amendment to 49 CFR part 40 will enable a parallel process for the documentation of DOT-mandated alcohol tests aligned with the similarly situated amendment previously approved for drug testing.” DISA believes that allowing the use of an electronic ATF will result in several benefits to the industry, including “increased efficiency, security and accuracy in documentation of DOT alcohol tests; paperwork reduction; improved process for conducting a DOT alcohol test in conjunction with a DOT drug test when an electronic version of the federal CCF is used for the drug test; reduction of errors and omissions in the completion of the ATF; and improved efficiency and efficacy in the transmission and record retention of alcohol test results.”
DISA noted that non-DOT workplace breath alcohol testing has been conducted using electronic versions of an alcohol testing form that mirrors the DOT ATF for more than five years. Based on experience using those electronic forms for non-DOT testing, DISA cites improved efficiency and accuracy of documentation because: (1) employer and employee information is entered via computer and thus not dependent on reading and deciphering hand-written entries, (2) date time stamps of the testing are automated and not subject to fluctuation or error, (3) transmission of documentation on completed tests is more secure using databases accessed only via protected password and personal identification number (PIN) to authorized employers or their designated agents, and (4) transmission of test result information is faster and more secure than existing transmission options of scanning and emailing attachments or facsimile.
DISA also noted that permitting use of an electronic ATF for DOT-regulated alcohol testing “will substantially reduce cost, by eliminating the requirement for the printing and distribution of carbonless three-ply paper ATFs. The proposed electronic ATF option would still provide for printed paper images to be made available to the employee, the employer, and the alcohol technician, [but] eliminates the requirement for the more expensive carbonless 3 ply paper ATF.”
For the reasons described by DISA in its petition, and recognizing that significant benefits and cost reductions have resulted from use of the electronic CCF for drug testing, we believe that it is likewise appropriate to permit the use of electronic ATFs in part 40 for DOT-regulated testing. Permitting but not requiring the use of an electronic ATF would be consistent with our proposal to permit, but not require, the use of electronic documents and signatures throughout the entirety of part 40 as discussed above. As several commenters noted, the use of an electronic ATF has been used in non-DOT testing for 5-10 years, and the same developers of the electronic CCFs have developed the electronic ATFs. Any electronic ATF used under part 40 for DOT-regulated employees would have to be identical in form and content to the DOT ATF in appendix I to part 40. 8 Just as we imposed general confidentiality and security requirements when electronic CCFs were permitted to be used under part 40, we believe that it is necessary to include the same general requirements relating to the use of electronic ATFs to ensure that confidential employee records cannot be accessed by unauthorized persons.
8 The ATF form was redesignated from appendix G to appendix I as part of the rulemaking process culminating in the May 2023 final rule. During that process, the form was reviewed by the public and DOT received no comment on the form.
Manufacturers of EBTs and alcohol screening devices (ASD) used in DOT alcohol tests must obtain approval from the National Highway Traffic Safety Administration (NHTSA) and then be listed on the Office of Drug and Alcohol Policy and Compliance's (ODAPC) website before those devices may be used in DOT alcohol testing.
IX. PHMSA Proposed Changes
PHMSA is proposing to amend §§199.3, 199.117, and 199.227 and to add §199.4 to conform to the proposed changes in part 40 and to clarify that the proposed changes in part 40 apply to part 199. These changes will help the readers of part 199 find the applicable regulations in part 40 with regards to the definition of terms and record keeping requirements. We also propose to amend §§199.119 and 199.229 by changing the reference of “appendix H” to “appendix J” to conform to the amendment of part 40 published on May 2, 2023.
X. Section-by-Section Analysis
Section 40.3 What do the terms used in this regulation mean?
We propose to add a definition of “electronic signature.” The rule would define an electronic signature as a method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 44 U.S.C. 3504 note, 112 Stat. 2681-749). Including the specific cross reference to GPEA would ensure that regulated entities know that we are using GPEA's performance standard for allowing use of electronic signatures.
We propose to add a definition of “written or in writing.” The rule would define written or in writing as printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of 49 CFR 40.4. This definition would eliminate any distinction between paper and electronic methods of communication/documentation.
Section 40.4 May electronic documents and signatures be used?
We propose to add a new §40.4 that would prescribe the requirements pertaining to electronic documents and signatures throughout part 40.
Paragraph (a) would specify that §40.4 would apply to all documents required by part 40, except for the CCF, as an electronic CCF may only be used when approved by HHS and in compliance with §40.40(c)(5). As background, before an HHS-certified laboratory can use a Federal electronic CCF for regulated specimens, the test facility must submit a detailed plan and proposed standard operating procedures for the electronic CCF system for HHS review and approval through the National Laboratory Certification Program. At the current time, several HHS-certified laboratories have received approval to use a combination electronic/paper CCF, while four laboratories have received approval to use a fully electronic CCF. As noted earlier, and in a separate section of the SUPPORT Act, HHS was required to set a deadline for certified laboratories to request approval for use of fully electronic CCFs. That deadline is now August 31, 2026.
Paragraph (b) would permit, but not require, any person or entity to use electronic methods to comply with any provision in part 40 that requires a document to be signed, certified, generated, maintained, or transmitted between parties. It would apply to all forms of written documentation, including forms, records, notations, and other documents. The substance of the document would otherwise have to comply with part 40 requirements. This would establish parity between paper and electronic documents and signatures, greatly expanding interested parties' ability to use electronic methods to comply with the requirements of part 40.
Paragraph (c) would permit, but not require, any entity required to sign or certify a document to do so using electronic signatures as defined in §40.3. The rule specifies that a person may use any available technology so long as the signature otherwise complies with the requirements of part 40.
Paragraph (d) would establish the minimum requirements for electronic documents and signatures. Any electronic document or signature would be considered the legal equivalent of a paper document or signature if it is the functional equivalent with respect to integrity, accuracy, and accessibility. In other words, the electronic documents or signatures need to accurately and reliably reflect the information in the record. They must remain accessible in a form that could be accurately viewed or reproduced according to Agency rules. As with any documents, paper or electronic, documents that are not legible—for any reason—do not satisfy the Department's requirements.
Electronic documents are not to be considered the legal equivalent of traditional paper documents if they (1) are not capable of being retained, (2) are not used for the purpose for which they were created, or (3) cannot be accurately reproduced for reference by any entity entitled to access by law, for the period of time required by the Department's recordkeeping requirements.
Paragraph (d) would also require that any electronically signed documents must incorporate or otherwise include evidence that both parties to the document have consented to the use of electronic signatures, as required by the E-SIGN Act (15 U.S.C. 7001(c)).
Paragraph (e) would require that when using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records cannot be accessed by unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form. The proposed requirements are analogous to those established in the current §40.40(c)(5) when we approved use of the electronic CCF in part 40.
Section 40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?
Currently, paragraph (g) makes it clear that the release of information under this section must be in any written form, and the parenthetical clarifies that this can be paper-based (written, fax) or electronic (email). Under the proposed definition of “written or in writing,” there is no distinction between paper-based and electronic communications. Because “written or in writing” would mean either paper or electronic communications, we propose to remove parenthetical reference to “fax, email, letter” to eliminate redundancy and confusion. All parties can conduct their business using either paper or electronic means of documentation and communication.
Section 40.79 How is the collection process completed?
Currently, paragraph (a)(9) of this section requires the collector to “fax or otherwise transmit” Copy 2 of the CCF to the MRO and Copy 4 to the DER within 24 hours or during the next business day. We propose to amend this section by removing reference to the methods of transmitting receipts, so parties can choose their own medium of communication.
Section 40.97 What do laboratories report and how do they report it?
For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraphs (c)(1) and (2) of this section.
Section 40.111 When and how must a laboratory disclose statistical summaries and other information it maintains?
For the same reasons explained in the discussion of §40.79, we propose to amend paragraph (b) of this section to remove the references to the methods of transmitting the summary or report required by this section. Because the summary or report can be transmitted via hard copy or electronically, there is no need to specify how it must be transmitted. As such, we propose to amend the title of this section accordingly.
Section 40.127 What are the MRO's functions in reviewing negative test results?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (c)(2) of this section.
Section 40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative test results?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “fax, photocopy, image” for Copy 1 of the CCF in paragraph (b)(2) of this section.
Section 40.163 How does the MRO report drug test results?
For the same reasons explained in the discussion of §40.25, we propose to remove the reference to a “letter” in paragraph (c) of this section. In paragraph (e) of this section, we propose to replace the term “letter” with “written report” for consistency with paragraph (c).
Section 40.167 How are MRO reports of drug results transmitted to the employer?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (c)(1) of this section.
Section 40.185 Through what methods and to whom must a laboratory report split specimen results?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “fax, courier, mail, or electronically” in paragraph (b) of this section. In addition, because Copy 1 of the CCF can be transmitted in writing or electronically, there is no need to specify the methods through which it must be transmitted. As such, we propose to amend the title of this section accordingly.
Section 40.187 What does the MRO do with split specimen laboratory results?
For the same reasons explained in the discussion of §40.79, we propose to remove the references to the methods of transmitting Copy 1 of the CCF from the laboratory to the MRO in paragraph (c)(2)(iv)(C) of this section.
Section 40.191 What is a refusal to take a DOT drug test, and what are the consequences?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (d) of this section as means of transmitting notification that an employee has refused to participate in part of the testing process from the collector or MRO to the DER.
Section 40.193 What happens when an employee does not provide a sufficient amount of urine for a drug test?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “send or fax” as the means for the collector to transmit copies of the CCF to the MRO and the DER in paragraph (b)(3) of this section.
Section 40.205 How are drug test problems corrected?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a collector, laboratory, MRO, employer, or other person to supply signed statements regarding correctable problems in a drug test in paragraphs (b)(1) and (2) of this section.
Section 40.225 What form is used for an alcohol test?
We propose to amend this section to permit, but not require, the use of an electronic version of the DOT ATF that is identical in form and content to the form provided in appendix I to part 40. The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT, and if an EBT provides a separate printout of confirmation test results pursuant to §40.253(g), the electronic ATF must include that separate printout. This section would also be amended to specify the same general confidentiality and security measures in §40.45 relating to electronic CCFs to ensure that confidential employee records cannot be accessed by unauthorized persons.
Section 40.255 What happens next after the alcohol confirmation test result?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (a)(5)(i) of this section as means of transmitting results of the alcohol confirmation test from the BAT to the DER. Similarly, there is no need to specify that Copy 1 of the ATF may be transmitted “in person, by telephone, or by electronic means.”
Section 40.261 What is a refusal to take an alcohol test, and what are the consequences?
For the same reasons explained in the discussion of §40.25, we propose to delete the parenthetical references to “telephone or secure fax machine” in paragraph (c) of this section as means of transmitting a refusal notification from a BAT, STT, or referral physician to the DER.
Section 40.271 How are alcohol testing problems corrected?
For the same reasons explained in the discussion of §40.25, we propose to delete the references to “by fax or courier” as the means for a STT, BAT, employer, or other service agent to supply a signed statement regarding correctable flaws in an alcohol test in paragraph (b)(2) of this section.
Section 40.365 What is the Department's policy concerning starting a PIE proceeding?
We propose to amend this section by adding a new paragraph (b)(15) that would identify the failure of a service agent to provide or maintain a secure/confidential electronic system as appropriate grounds for starting a PIE proceeding.
X. Regulatory Analyses and Notices
Executive Orders 12866, 13563, and 14094 (Regulatory Planning and Review)
The Secretary has examined the impact of the proposed part 40 amendments under Executive Order 12866 (“Regulatory Planning and Review”), as supplemented by Executive Order 13563 (“Improving Regulation and Regulatory Review”) and amended by Executive Order 14094 (“Modernizing Regulatory Review”), which directs Federal agencies to assess all costs and benefits of available regulatory alternatives and, when regulation is necessary, to select regulatory approaches that maximize net benefits (including potential economic, environmental, public health and safety, and other advantages; distributive impacts; and equity).
According to these Executive orders, a regulatory action is “significant” if it meets any one of a number of specified conditions, including having an annual effect on the economy of $200 million or more, as adjusted every three years by the Office of Information and Regulatory Affairs (OIRA); adversely affecting in a material way a sector of the economy, competition, or jobs; or if it raises novel legal or policy issues. The proposed amendments, which would allow the use of electronic documents and signatures, do not meet the Executive order's criteria for being a significant rule. Consequently, OMB has determined that the rulemaking action is not significant under the Executive order.
The proposed rule responds to the statutory mandate set forth in Section 8108 of the Fighting Opioid Abuse in Transportation Act, part of the SUPPORT for Patients and Communities Act, Public Law 115-271. The proposed rule would not impose new requirements on the industry; rather, it would simply permit—but not require—regulated entities to use electronic signatures, forms, and recordkeeping, and remove outdated and obsolete references in the regulatory text. The proposed rule would not impose new costs on the industry because regulated entities would be allowed to choose to continue to use paper-based documents as they had before. The benefits of the rule would stem from savings in paper and printing expense and other efficiency gains. Examples of documents affected by this rule include, but are not limited to, records of a prospective employee's drug and alcohol testing history that employers must obtain prior to permitting that employee to perform safety-sensitive duties, MRO records and reports, SAP records and reports, and ATFs. While there is no way to estimate how many entities or individuals would change their practices given the new options, or how many documents would be affected, several commenters to the ANPRM stated that they have been using electronic documents and signatures in their non-DOT drug and alcohol testing programs for many years. While neither the benefits nor the costs of this rule can be reliably estimated, we expect this proposed rule to provide flexibility to the industry. Under this proposed rule, regulated entities would have the flexibility to conduct business using either electronic or traditional paper-based methods. We also expect regulated entities to choose technologies that would maximize benefits in accordance with their individual needs and circumstances.
Regulatory Flexibility Act and Small Business Regulatory Enforcement Fairness Act (SBREFA)
The Regulatory Flexibility Act of 1980 (5 U.S.C. 601 et seq. ) requires Federal agencies to consider the effects of their regulatory actions on small businesses and other small entities and minimize any significant economic impact. The term “small entities” comprises small businesses and not-for-profit organizations that are independently owned and operated and are not dominant in their fields, and governmental jurisdictions with a population of less than 50,000. For this rulemaking, potentially affected small entities include drug testing companies (U.S. Small Business Administration (SBA) North American Industry Classification System (NAICS) Sector 54 (Professional, Scientific and Technical Services), Code 541380 (Testing Laboratories and Services)) as well as DOT-regulated entities (SBA NAICS Sectors 48-49 (Transportation and Warehousing)).
The Department does not expect that the proposed rule would have a significant economic impact on a substantial number of small entities. The proposed rule, if adopted, would increase flexibility for all small-entity transportation employers and their service agents by allowing them to use electronic documents, signatures, and recordkeeping to meet part 40 requirements. Use of electronic documents, electronic signatures, and electronic recordkeeping would be voluntary for affected small entities, which will provide added flexibility to these entities in meeting the part 40 requirements. For these reasons, and as explained in more detail in the preamble to this proposed rule, the Secretary certifies that the proposed rule would not have a significant economic impact on a substantial number of small entities within the meaning of the Regulatory Flexibility Act. Consequently, an initial regulatory flexibility analysis is not required for this proposed rule.
Unfunded Mandates
The Secretary has examined the impact of the final rule under the Unfunded Mandates Reform Act (UMRA) of 1995 (Pub. L. 104-4). This NPRM does not trigger the requirement for a written statement under sec. 202(a) of the UMRA because this rulemaking does not impose a mandate that results in an expenditure of $100 million (adjusted annually for inflation) or more by either State, local, and tribal governments in the aggregate or by the private sector in any one year. In fact, by providing an alternative to traditional paper-based records, the proposed rule would be expected to reduce costs to regulated parties, including State and local entities ( e.g., public transit authorities, and public works departments) whose employees are subject to testing and that choose to use electronic documents as opposed to paper-based documents.
Environmental Impact
The DOT has analyzed the environmental impacts of this action pursuant to the National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321 et seq. ) and has determined that it is categorically excluded pursuant to DOT Order 5610.1C, “Procedures for Considering Environmental Impacts” (44 FR 56420, October 1, 1979). Categorical exclusions are actions identified in an agency's NEPA implementing procedures that do not normally have a significant impact on the environment and therefore do not require either an environmental assessment (EA) or environmental impact statement (EIS). This proposed rule would amend the transportation industry drug testing program procedures regulation to permit the use of electronic documents, signatures, and recordkeeping. This action is covered by the categorical exclusion listed at 23 CFR 771.118(c)(4), “[p]lanning and administrative activities that do not involve or lead directly to construction, such as: . . . promulgation of rules, regulations, directives . . .” The Department does not anticipate any environmental impacts, and there are no extraordinary circumstances present in connection with this rulemaking.
Executive Order 13132: Federalism
The Secretary has analyzed the final rule in accordance with Executive Order 13132: Federalism. Executive Order 13132 requires Federal agencies to carefully examine actions to determine if they contain policies that have federalism implications or that preempt State law. As defined in the order, “policies that have federalism implications” refer to regulations, legislative comments or proposed legislation, and other policy statements or actions that have substantial direct effects on the States, on the relationship between the National Government and the States, or on the distribution of power and responsibilities among the various levels of government.
Most of the regulated parties under the Department's drug testing program are private entities. Some regulated entities are public entities ( e.g., transit authorities and public works departments); however, as noted above, this proposal would reduce costs of the Department's drug testing program and provide additional flexibility for regulated parties. Accordingly, the Secretary has determined that the proposed rule, which would allow but not require use of electronic signatures and recordkeeping, does not contain policies that have federalism implications.
Executive Order 13175: Consultation and Coordination With Indian Tribal Governments
Executive Order 13175 (65 FR 67249, November 6, 2000) requires Federal agencies to develop an accountable process to ensure “meaningful and timely input by tribal officials in the development of regulatory policies that have tribal implications.” “Policies that have tribal implications” as defined in the Executive order, include regulations that have “substantial direct effects on one or more Indian tribes, on the relationship between the Federal government and the Indian tribes, or on the distribution of power and responsibilities between the Federal government and Indian tribes.” This proposed rule does not have tribal implications. The proposed rule will also not have substantial direct effects on tribal governments, on the relationship between the Federal Government and Indian tribes, or on the distribution of power and responsibilities between the Federal Government and Indian tribes, as specified in Executive Order 13175.
Paperwork Reduction Act
The Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520) (PRA) requires that DOT consider the impact of paperwork and other information collection burdens imposed on the public. This proposed rule would call for no new collection of information under the PRA. Instead, there would likely be a significant reduction in the burden hours required for information collection 2105-0529, Procedures for Transportation Drug and Alcohol Testing Program, due to the ability to use electronic signatures and forms, and largely due to the ability to use an electronic ATF for DOT-regulated alcohol testing under part 40. We request comments on this issue. Notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information subject to the PRA that does not display a currently valid OMB control number.
Privacy Act
Anyone is able to search the electronic form of all comments received in any of our dockets by the name of the individual submitting the comment (or signing the comment, if submitted on behalf of an association, business, labor union, etc.) For information on DOT's compliance with the Privacy Act, please visit https://www.transportation.gov/privacy.
5 U.S.C. 553(b)(4)
As required by 5 U.S.C. 553(b)(4), a summary of this proposed rule can be found at the entry for RIN 2105-AF01 in the Department's Portion of the Unified Agenda of Regulatory and Deregulatory Affairs, available at https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202404&RIN=2105-AF01 .
Pay-As-You-Go Act of 2023
In accordance with Compliance with Pay-As-You-Go Act of 2023 (Fiscal Responsibility Act of 2023, Pub. L. 118-5, div. B, title III) and OMB Memorandum (M-23-21) dated September 1, 2023, the Department has determined that this proposed rule is not subject to the Pay-As-You-Go Act of 2023 because it will not increase direct spending beyond specified thresholds.
List of Subjects
49 CFR Part 40
Administrative practice and procedures, Alcohol abuse, Alcohol testing, Drug abuse, Drug testing, Laboratories, Reporting and recordkeeping requirements, Safety, Transportation.
49 CFR Part 199
Alcohol testing, Drug testing, Pipeline safety, Reporting and recordkeeping requirements, Safety, Transportation.
For the reasons stated in the preamble, the Department proposes to amend 49 CFR parts 40 and 199 as follows:
PART 40—PROCEDURES FOR TRANSPORTATION WORKPLACE DRUG AND ALCOHOL TESTING PROGRAMS
1. The authority for part 40 continues to read as follows:
Authority:
49 U.S.C. 102, 301, 322, 5331, 20140, 31306, and 54101 et seq.
2. In §40.3, add the definitions of “Electronic signature” and “Written or in writing” in alphabetical order to read as follows:
§40.3 What do the terms used in this part mean?
* * * * *
Electronic signature. A method of signing an electronic communication that identifies and authenticates a particular person as the source of the electronic communication and indicates such person's approval of the information contained in the electronic communication, in accordance with the Government Paperwork Elimination Act (Pub. L. 105-277, title XVII, secs. 1701-1710, 112 Stat. 2681-749, 44 U.S.C. 3504 note).
* * * * *
Written or in writing. Printed, handwritten, or typewritten either on paper or other tangible medium, or by any method of electronic documentation that meets the requirements of §40.4.
3. Add §40.4 to read as follows:
§40.4 May electronic documents and signatures be used?
(a) Applicability. This section applies to all documents required by this part, except for the CCF. An electronic CCF may be used only if it has been approved for use by the Department of Health and Human Services and is used in compliance with §40.40(c)(5).
(b) Electronic records or documents. Any person or entity required to generate, maintain, or exchange and/or transmit documents to satisfy requirements in this part may use electronic methods to satisfy those requirements.
(c) Electronic signatures. (1) Any person or entity required to sign or certify a document to satisfy the requirements of this part may use an electronic signature, as defined in §40.3.
(2) Any available technology may be used that satisfies the requirements of an electronic signature as defined in §40.3.
(d) Electronic document requirements. Any person or entity may use documents signed, certified, generated, maintained, or exchanged using electronic methods, as long as the documents accurately reflect the information otherwise required to be contained in them.
(1) Records, documents, or signatures generated, maintained, or exchanged using electronic methods satisfy the requirements of this section if they are capable of being retained, are used for the purpose for which they were created, and can be accurately reproduced within required timeframes for reference by any party entitled to access.
(2) Records or documents generated electronically satisfy the requirements of this section if they include proof of consent to use electronically generated records or documents, as required by 15 U.S.C. 7001(c).
(e) Confidentiality and security. When using electronic documents and signatures, adequate confidentiality and security measures must be established to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form to include protecting against destruction, deterioration, and data corruption.
4. In §40.25, revise paragraph (g) to read as follows:
§40.25 Must an employer check on the drug and alcohol testing record of employees it is intending to use to perform safety-sensitive duties?
* * * * *
(g) The release of information under this section must be in any written form that ensures confidentiality. As the previous employer, you must maintain a written record of the information released, including the date, the party to whom it was released, and a summary of the information provided.
* * * * *
5. In §40.79, revise paragraph (a)(9) to read as follows:
§40.79 How is the collection process completed?
(a) * * *
(9) Send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or during the next business day. Keep Copy 3 for at least 30 days, unless otherwise specified by applicable DOT agency regulations.
* * * * *
6. In §40.97, revise paragraphs (c) introductory text, (c)(1) introductory text, and (c)(2) to read as follows:
§40. 97 What do laboratories report and how do they report it?
* * * * *
(c) As a laboratory, you must report laboratory results directly, and only, to the MRO at his or her place of business. You must not report results to or through the DER or a service agent ( e.g., C/TPA).
(1) Negative results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF which has been signed by the certifying scientist, or you may provide the laboratory results report electronically.
* * * * *
(2) Non-negative and rejected for testing results. You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF that has been signed by the certifying scientist. In addition, you may provide the laboratory results report following the format and procedures set forth in paragraphs (c)(1)(i) and (ii) of this section.
* * * * *
7. In §40.111, revise the section heading and paragraph (b) to read as follows:
§40.111 When must a laboratory disclose statistical summaries and other information it maintains?
* * * * *
(b) When the employer requests a summary in response to an inspection, audit, or review by a DOT agency, you must provide it unless the employer had fewer than five aggregate test results. In that case, you must send the employer a report indicating that not enough testing was conducted to warrant a summary.
* * * * *
8. In §40.127, revise paragraph (c)(2) to read as follows:
§40.127 What are the MRO's functions in reviewing negative test results?
* * * * *
(c) * * *
(2) A legible copy of Copy 1 of the CCF or the electronic laboratory results report that conveys the negative laboratory test result.
* * * * *
9. In §40.129, revise paragraphs (b) introductory text and (b)(2) to read as follows:
§40.129 What are the MRO's functions in reviewing laboratory confirmed non-negative drug test results?
* * * * *
(b) Before you report a verified negative, positive, test cancelled, refusal to test because of adulteration or substitution, you must have in your possession the following documents:
* * * * *
(2) A legible copy of Copy 1 of the CCF, containing the certifying scientist's signature.
* * * * *
10. In §40.163, revise paragraphs (c) introductory text and (e) to read as follows:
§40.163 How does the MRO report drug test results?
* * * * *
(c) If you do not report test results using Copy 2 of the CCF for the purposes of this section, you must provide a written report for each test result. This report must, as a minimum, include the following information:
* * * * *
(e) You must retain a signed or stamped and dated copy of Copy 2 of the CCF in your records. If you do not use Copy 2 for reporting results, you must maintain a copy of the signed or stamped and dated written report in addition to the signed or stamped and dated Copy 2. If you use the electronic data file to report negatives, you must maintain a retrievable copy of that report in a format suitable for inspection and auditing by a DOT representative.
* * * * *
11. In §40.167, revise paragraph (c)(1) to read as follows:
§40.167 How are MRO reports of drug test results transmitted to the employer?
* * * * *
(c) * * *
(1) You must transmit a legible image or copy of either the signed or stamped and dated Copy 2 or the written report (see §40.163(b) and (c)).
* * * * *
12. In §40.185, revise the section heading and paragraph (b) to read as follows:
§40.185 What and to whom must a laboratory report split specimen results?
* * * * *
(b) You must transmit a legible image or copy of the fully-completed Copy 1 of the CCF, which has been signed by the certifying scientist.
* * * * *
13. In §40.187, revise paragraph (c)(2)(iv)(C) to read as follows:
§40.187 What does the MRO do with split specimen laboratory results?
* * * * *
(c) * * *
(2) * * *
(iv) * * *
(C) As the laboratory that tests the primary specimen to reconfirm the presence of the adulterant found in the split specimen and/or to determine that the primary specimen meets appropriate substitution criteria, report your result to the MRO using a copy of Copy 1 of the CCF.
* * * * *
14. In §40.191, revise paragraph (d) introductory text to read as follows:
§40.191 What is a refusal to take a DOT drug test, and what are the consequences?
* * * * *
(d) As a collector or an MRO, when an employee refuses to participate in the part of the testing process in which you are involved, you must terminate the portion of the testing process in which you are involved, document the refusal on the CCF (including, in the case of the collector, printing the employee's name on Copy 2 of the CCF), immediately notify the DER by any means that ensures that the refusal notification is immediately received. As a referral physician ( e.g., physician evaluating a “shy bladder” condition or a claim of a legitimate medical explanation in a validity testing situation), you must notify the MRO, who in turn will notify the DER.
* * * * *
15. In §40.193, revise paragraph (b)(3) to read as follows:
§40.193 What happens when an employee does not provide a sufficient amount of specimen for a drug test?
* * * * *
(b) * * *
(3) As the collector, you must send Copy 2 of the CCF to the MRO and Copy 4 to the DER. You must transmit these copies to the MRO and DER within 24 hours or the next business day.
* * * * *
16. In §40.205, revise paragraphs (b)(1) and (2) to read as follows:
§40.205 How are drug test problems corrected?
* * * * *
(b) * * *
(1) If the problem resulted from the omission of required information, you must, as the person responsible for providing that information, supply in writing the missing information and a statement that it is true and accurate. For example, suppose you are a collector, and you forgot to make a notation on the “Remarks” line of the CCF that the employee did not sign the certification. You would, when the problem is called to your attention, supply a signed statement that the employee failed or refused to sign the certification and that your statement is true and accurate. You must supply this information on the same business day on which you are notified of the problem.
(2) If the problem is the use of a non-Federal form or an expired Federal form, you must provide a signed statement ( i.e., a memorandum for the record). It must state that the incorrect form contains all the information needed for a valid DOT drug test, and that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control. The statement must also list the steps you have taken to prevent future use of non-Federal forms or expired Federal forms for DOT tests. For this flaw to be corrected, the test of the specimen must have occurred at an HHS-certified laboratory where it was tested consistent with the requirements of this part. You must supply this information on the same business day on which you are notified of the problem.
* * * * *
17. In §40.225, revise paragraph (a) and add paragraphs (d) and (e) to read as follows:
§40.225 What form is used for an alcohol test?
(a) The DOT Alcohol Testing Form (ATF) must be used for every DOT alcohol test. The ATF must be a three-part carbonless manifold form or an electronic ATF that meets the requirements of paragraph (d) of this section. The ATF is found in appendix G to this part. You may view this form on the ODAPC website ( https://www.transportation.gov/odapc ).
* * * * *
(d) As an employer, you may use an electronic ATF that meets the following requirements:
(1) The electronic ATF must be identical in form and content to the ATF found in appendix G to this part.
(2) The electronic ATF must meet the requirements of §40.4(d).
(3) The electronic ATF must be capable of capturing the electronic signatures of the employee and the BAT and/or STT.
(4) If an EBT provides a separate printout of confirmation test results (see §40.253(g)), the electronic ATF must include that separate printout.
(e) As an employer, BAT, or STT using an electronic ATF, you must establish adequate confidentiality and security measures to ensure that confidential employee records are not available to unauthorized persons. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic form.
18. In §40.255, revise paragraph (a)(5)(i) to read as follows:
§40.255 What happens next after the alcohol confirmation test result?
(a) * * *
(5) * * *
(i) You may transmit the results using Copy 1 of the ATF, in person, by telephone, or by electronic means. In any case, you must immediately notify the DER of any result of 0.02 or greater by any means that ensures the result is immediately received by the DER. You must not transmit these results through C/TPAs or other service agents.
* * * * *
19. In §40.261, revise paragraph (c)(1) to read as follows:
§40.261 What is a refusal to take an alcohol test, and what are the consequences?
* * * * *
(c)(1) As a BAT or an STT, or as the physician evaluating a “shy lung” situation, when an employee refuses to test as provided in paragraph (a) of this section, you must terminate the portion of the testing process in which you are involved, document the refusal on the ATF (or in a separate document which you cause to be attached to the form), immediately notify the DER by any means that ensures the refusal notification is immediately received. You must make this notification directly to the DER (not using a C/TPA as an intermediary).
* * * * *
20. In §40.271, revise paragraph (b)(2) to read as follows:
§40.271 How are alcohol testing problems corrected?
* * * * *
(b) * * *
(2) If the problem is the use of a non-DOT form, you must, as the person responsible for the use of the incorrect form, certify in writing that the incorrect form contains all the information needed for a valid DOT alcohol test. You must also provide a signed statement that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control, and the steps you have taken to prevent future use of non-DOT forms for DOT tests. You must supply this information on the same business day on which you are notified of the problem.
* * * * *
21. In §40.365, revise paragraphs (b)(13) and (14) and add paragraph (b)(15) to read as follows:
§40.365 What is the Department's policy concerning starting a PIE proceeding?
* * * * *
(b) * * *
(13) For any service agent, directing or recommending that an employer fail or refuse to implement any provision of this part;
(14) With respect to noncompliance with a DOT agency regulation, conduct that affects important provisions of Department-wide concern ( e.g., failure to properly conduct the selection process for random testing); or
(15) For a service agent, failing to provide or maintain a secure/confidential electronic system. PART 199—DRUG AND ALCOHOL TESTING
22. The authority citation for part 199 continues to read as follows:
Authority:
49 U.S.C. 5103, 60102, 60104, 60108, 60117, and 60118; 49 CFR 1.53.
23. In §199.3:
a. Designate the introductory text as paragraph (b); and
b. Add paragraph (a).
The addition reads as follows:
§199.3 Definitions.
(a) Terms used in this part have the same meaning as in 49 CFR 40.3.
* * * * *
24. Add §199.4 to read as follows:
§199.4 Electronic documents, records, and signatures.
Electronic documents, records, and signatures may be used to comply with this part provided they meet the requirements specified in 49 CFR part 40.
25. In §199.117, revise paragraph (a) introductory text to read as follows:
§199.117 Recordkeeping.
(a) Each operator shall keep the records in paragraphs (a)(1) through (5) of this section for the periods specified by this section or for the periods specified by 49 CFR part 40, whichever is greater; and will permit access to the records as provided by §190.203.
* * * * *
26. In §199.119, revise paragraph (a) to read as follows:
§199.119 Reporting of anti-drug testing results.
(a) Each large operator (having more than 50 covered employees) must submit an annual Management Information System (MIS) report to PHMSA of its anti-drug testing using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.
* * * * *
27. In §199.227, revise paragraph (b) introductory text to read as follows:
§199.227 Retention of records.
* * * * *
(b) Period of retention. Each operator shall maintain the records in accordance with the following schedule or for the periods specified by 49 CFR part 40, whichever is greater:
* * * * *
28. In §199.229, revise paragraph (a) to read as follows:
§199.229 Reporting of alcohol testing results.
(a) Each large operator (having more than 50 covered employees) must submit an annual MIS report to PHMSA of its alcohol testing results using the MIS form and instructions as required by 49 CFR part 40 (at §40.26 and appendix J to part 40), not later than March 15 of each year for the prior calendar year (January 1 through December 31). The Administrator may require by notice in the PHMSA Portal ( https://portal.phmsa.dot.gov/phmsaportallanding ) that small operators (50 or fewer covered employees), not otherwise required to submit annual MIS reports, to prepare and submit such reports to PHMSA.
* * * * *
Signed on: Thursday, October 3, 2024.
Pete Buttigieg,
Secretary of Transportation.
[FR Doc. 2024-23427 Filed 10-11-24; 8:45 am]
BILLING CODE 4910-9X-P
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Most Recent Highlights In Environmental
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2026-05-20T05:00:00Z
EPA floats major changes to current PFAS drinking water rules
The Environmental Protection Agency (EPA) has released two proposed rules that, if finalized, would have major impacts on drinking water regulations for per- and polyfluoroalkyl substances (PFAS), specifically, the 2024 National Primary Drinking Water Regulation (NPDWR) for PFAS (2024 PFAS NPDWR).
Proposed rule: MCL compliance extension
The first rule proposes to establish a federal exemption that allows public water systems (PWSs) to request an extension of the deadline to comply with the Maximum Contaminant Levels (MCLs) for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) from April 26, 2029, to April 26, 2031.
The rule would require PWSs that meet the eligibility requirements to submit a request to EPA for the federal exemption within 180 days of the date a final rule is published. PWSs would have to provide specific information in the request (such as recent water sample results and a certified statement that the system can’t comply with the original MCL deadline).
Additionally, EPA’s proposed rule would require:
- All PWSs with the federal exemption to notify customers of the exemption, and
- PWSs with PFOA or PFOS levels at or above 12 parts per trillion to implement two control measures (from six options) during the exemption period.
Who would be impacted?
The proposed federal exemption would apply to PWSs:
- Regulated by the 2024 PFAS NPDWR for PFOA and PFOS;
- In operation on or before June 25, 2024;
- Not under a variance for small systems for the PFOA and PFOS MCLs; and
- In a state that doesn’t have primacy for the 2024 PFAS NPDWR.
PWSs in states with primacy for the 2024 PFAS NPDWR may request an exemption from the primacy agency.
Proposed rule: Rescinding PFAS NPDWRs
The second rule proposes to rescind EPA’s determinations to regulate:
- Perfluorohexane sulfonic acid (PFHxS);
- Perfluorononanoic acid (PFNA);
- Hexafluoropropylene oxide dimer acid and its ammonium salt (HFPO-DA, called GenX chemicals); and
- Perfluorobutane sulfonic acid (PFBS).
It also proposes to remove the related 2024 PFAS NPDWR provisions from 40 CFR Parts 141 and 142, including:
- The MCLs and MCL Goals (MCLGs) for PFHxS, PFNA, and HFPO-DA;
- The MCL and MCLG for mixtures with two or more of PFHxS, PFNA, HFPO-DA, and PFBS (referred to as the Index PFAS); and
- All other compliance requirements.
The proposed rule would maintain the 2024 PFAS NPDWR requirements for PFOA and PFOS.
Who would be impacted?
The rule would impact PWSs, including community water systems (CWSs) and non-transient non-CWSs, subject to the 2024 PFAS NPDWR standards for PFHxS, PFNA, HFPO-DA, or the Index PFAS.
How do I give feedback?
EPA will hold a virtual public hearing for verbal comments on the proposed rules on July 7, 2026. Written comments for the proposed compliance extension rule (Docket ID No. EPA-HQ-OW-2025-1742) and proposed rescission rule (Docket ID No. EPA-HQ-OW-2025-0654) are due by July 20, 2026.
Key to remember: EPA has proposed major changes to the national drinking water regulations for PFAS.
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California approves plastic packaging regulations
Effective date: May 1, 2026
This applies to: Producers of single-use packaging and plastic single-use food service ware
Description of change: CalRecycle approved permanent regulations to implement the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54). The regulations require producers of covered materials (single-use packaging and plastic single-use food service ware) to administer an extended producer responsibility program.
Producers must meet minimum recycled content requirements for covered materials and pay fees (including annual mitigation surcharges for all producers and fees to producers participating in a producer responsibility organization (PRO) plan).
By June 1, 2026, producers must:
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New Mexico adopts PFAS product phaseout regulations
Effective date: July 1, 2026
This applies to: Manufacturers, distributors, and retailers that sell, offer for sale, distribute, or distribute for sale products that contain intentionally added per- and polyfluoroalkyl substances (PFAS) in New Mexico
Description of change: The New Mexico Environment Department adopted regulations implementing the PFAS Protection Act (HB212), which phases out consumer products with intentionally added PFAS. The regulations contain:
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The regulations establish three phaseout deadlines:
- The first group of products must be phased out by January 1, 2027.
- The second group of products must be phased out by January 1, 2028.
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California adopts risk-based water quality standards for nonpotable water
Effective date: April 22, 2026
This applies to: Owners and operators of on-site treated nonpotable water systems (OTNWS)
Description of change: The California State Water Resources Control Board adopted risk-based water quality standards that apply to OTNWS for the on-site treatment and reuse of nonpotable water for nonpotable end uses in:
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- Mixed-use buildings.
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- Stormwater, and
- Roof runoff.
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EPA proposes major changes to multiple rules
The Environmental Protection Agency (EPA) has been on a rulemaking roll! In recent weeks, the agency has published significant proposed rules in the Federal Register that affect coal-fired power plant wastewater, pre-construction air permits, and vehicle emission requirements.
Coal-fired power plants: Unmanaged CRL discharges
EPA proposes to revise the wastewater requirements established by a 2024 final rule (2024 Rule) for unmanaged combustion residual leachate (CRL) from coal-fired power plants.
Unmanaged CRL (a type of waste stream) is water that contains coal combustion residuals and leaks from landfills or surface impoundments (i.e., waste management units). Unmanaged CRL includes:
- Pumped unmanaged CRL (leached CRL that’s captured, pumped to the surface, and discharged directly to waters of the United States); and
- The functional equivalent of an unmanaged CRL direct discharge (determined by the permitting authority).
The proposed rule applies to coal-fired power plants with unmanaged CRL that are subject to the 2024 Rule’s technology-based effluent limitations guidelines and standards.
The agency proposes three options to revise the unmanaged CRL requirements:
- Option 1 (preferred by EPA) would maintain the 2024 rule’s mercury and arsenic numeric limits for pumped unmanaged CRL discharges, but it would delay the compliance deadline from December 31, 2029, to December 31, 2034. Additionally, the permitting authorities would determine best available technology economically achievable (BAT) limits for functional equivalents on a case-by-case basis.
- Option 2 would maintain the 2024 rule’s mercury and arsenic numeric limits for pumped unmanaged CRL discharges and functional equivalents. It would also maintain the original compliance timeline of December 31, 2029.
- Option 3 would impose zero-discharge limits for all pollutants in pumped unmanaged CRL discharges and functional equivalents. It would also establish interim BAT limits for mercury and arsenic. Facilities would have to meet the zero-discharge limits by December 31, 2034.
Public comments are due by June 17, 2026 (Docket ID No. EPA–HQ–OW–2009–0819).
Pre-construction air permits: Begin actual construction
EPA proposes to allow construction-related activities on components or structures that don’t emit air pollutants to start before obtaining a New Source Review (NSR) pre-construction permit to build or modify a stationary source. The proposed rule:
- Redefines “begin actual construction," and
- Adds “pollutant-emitting activities” to the regulatory definitions.
Both definitions list equipment, components, and processes that are excluded, meaning that construction on these activities may begin before obtaining an NSR permit. Examples of exempt activities include compacting and stabilizing soil, paving surfaces, and installing concrete pads.
If finalized, the proposed rule will distinguish between construction on stationary sources and construction on non-emitting components (e.g., utility infrastructure, certain building foundations) and codify that on-site construction of non-emitting components or structures can begin before getting an NSR permit.
Public comments are due by June 29, 2026 (Docket ID No. EPA-HQ-OAR-2025-0618).
Light- and medium-duty vehicle regulations: Tier 4 standards
EPA published Part 1 of a two-part rulemaking effort to revise the Tier 4 criteria air pollutant standards set in 2024 (Tier 4 Rule) for light- and medium-duty vehicles (LMDVs), which include:
- Light-duty vehicles and trucks,
- Medium-duty passenger vehicles, and
- Medium-duty vehicles.
In Part 1, EPA proposes to amend the phase-in schedule for Tier 4 criteria air pollutant requirements by:
- Extending the Tier 3 standards set in 2014 (Tier 3 Rule) for LMDVs to model years (MYs) 2027 and 2028,
- Delaying the start of phasing in Tier 4 standards for LMDVs from MY 2027 to MY 2029, and
- Removing the optional early phase-in of Tier 4 standards for LMDVs with a gross vehicle weight rating of more than 6,000 pounds from MYs 2027 and 2028.
The agency also proposes to delay changes to the test protocols for emissions performance certification evaluations to MY 2029.
In Part 2, EPA will reconsider the Tier 4 Rule for LMDVs, which may include changing emission standards, lead time and phase-in schedules, and test procedures.
Public comments are due by July 6, 2026 (Docket ID No. EPA–HQ–OAR–2025–3297).
Key to remember: EPA has issued a series of proposed rules that, if finalized, may have significant regulatory impacts on power plant wastewater, pre-construction air permits, and vehicle emission requirements.
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2026-05-14T05:00:00Z
MACT emission standards: 7 questions answered
Standards are more than just suggestions when it comes to environmental regulations; they define the minimum level of performance that must be achieved and, as a result, determine who complies and who doesn’t. For industrial facilities that release air toxics, emission standards are foundational to compliance.
The Environmental Protection Agency (EPA) controls the release of more than 180 air toxics, known as hazardous air pollutants (HAPs), from industrial sources (such as factories and refineries) through the National Emission Standards for Hazardous Air Pollutants (NESHAP) program. For major sources, EPA develops maximum achievable control technology (MACT) standards to reduce HAP emissions.
Understanding the basics of MACT standards can help you navigate the requirements specific to your facility. Here’s what you need to know.
What’s a MACT standard?
A MACT standard refers to the specific technology-based requirements set by EPA to control HAP emissions from major sources in a specific industrial source category. The agency bases the standards on the emission levels already being achieved with existing control technologies by the best-controlled and lowest-emitting facilities in an industry.
What’s a MACT floor?
MACT floors are the minimum control levels that regulated facilities must meet. EPA sets MACT floors differently for new and existing facilities:
- The MACT floors for new facilities must be at least as stringent as the emission control achieved by the best-controlled similar source.
- The MACT floors for existing facilities (which may be less stringent than the floors for new sources) have to be at least as strict as the average emission limitation achieved by either:
- The top-performing 12 percent of sources in a category or subcategory with 30 or more sources, or
- The top-performing 5 sources in a category or subcategory with fewer than 30 sources.
Keep in mind that EPA may establish requirements stricter than the MACT floor, known as “beyond-the-floor” standards.
What types of facilities are subject to MACT standards?
MACT standards generally apply to major sources of HAP emissions. A facility is considered a major source if it emits or has the potential to emit:
- 10 tons per year (tpy) of any one HAP, or
- 25 tpy of any combination of HAPs.
How are MACT standards organized?
EPA develops MACT standards by industry sector and publishes them as part of the NESHAP regulations. Most of the rules appear under 40 CFR Part 63, organized by subparts based on source category. Facilities must identify their source category to determine which NESHAP subpart applies.
A limited number of the rules are found under Part 61, organized by subparts based on specific HAPs (such as vinyl chloride) or activities (like asbestos demolition). Facilities need to confirm whether any of the NESHAPs for specific HAPs or activities apply.
How are MACT standards enforced?
The air permitting authority (usually a state or local air agency) incorporates applicable NESHAP requirements, including MACT standards, into a facility’s Title V operating permit.
What do MACT standards cover?
MACT standards can include a combination of measures, methods, processes, systems, and techniques to reduce or eliminate HAP emissions. Examples include:
- Conducting process changes;
- Substituting materials;
- Enclosing systems or processes; and
- Collecting, capturing, and/or treating HAP releases from emission points.
MACT standards may also contain design, equipment, work practice, and operation requirements.
Can MACT standards change?
Yes. The Clean Air Act requires EPA to evaluate MACT standards every 8 years (known as a risk and technology review). The agency will revise MACT standards when it determines improvements in technologies, practices, processes, or other emission-reduction methods warrant revisions.
Real-world example
Let’s take a look at the NESHAP for Polyether Polyols (PEPO) Production (PEPO NESHAP), recently updated in March 2026.
The MACT standards that apply to the PEPO NESHAP (Part 63 Subpart PPP) include:
- Emission limits for process vents;
- Equipment and work practice requirements for storage vessels, wastewater, and equipment leaks; and
- Work practice standards for heat exchange systems.
EPA concluded that improvements in controls warranted updates to specific MACT standards in the PEPO NESHAP, including for heat exchange systems. Specifically, the revised rule requires owners and operators of existing and new heat exchange systems in organic HAP service to:
- Conduct quarterly monitoring using the Modified El Paso Method (also known as the Air Stripping Method), and
- Repair leaks of total strippable hydrocarbon concentration (as methane) in the stripping gas of 6.2 parts per million by volume or greater.
The agency found that the Modified El Paso Method is more effective at identifying leaks, and it measures more compounds than previously required methods. As a result, this revised MACT standard will further reduce HAP emissions from heat exchange systems.
Key to remember: EPA controls hazardous air pollutant emissions from major sources through MACT standards based on the emission levels already achieved by the best-controlled facilities in an industry.
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EHS Monthly Round Up - April 2026
In this April 2026 roundup video, we’ll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
OSHA revised its National Emphasis Program on heat-related hazards. Going forward, the agency will prioritize inspections in 55 high-risk industries in indoor and outdoor work settings. The program remains in effect for 5 years from its April 10 effective date.
An OSHA proposed rule seeks to eliminate the November 18, 2036, deadline in the Walking-Working Surfaces standard that would require all fixed ladders extending more than 24 feet above a lower level to be equipped with personal fall arrest systems or ladder safety systems. OSHA also seeks feedback on nine specific questions related to the proposal, with comments due on June 5.
On April 17, OSHA revoked its House Falls in Marine Terminals standard at 1917.41. The agency said that because most cargo has been containerized and is moved by cranes, the standard is no longer necessary to protect employees.
Turning to environmental news, an EPA final rule further delays the submission period for the one-time PFAS report required of manufacturers. It pushes the start of the submission period to either 60 days after the effective date of a future final rule updating the PFAS Reporting Rule or January 31, 2027, whichever comes first.
An EPA final rule makes technical changes to the emission standards established in March 2024 for crude oil and natural gas facilities. The changes take effect June 8.
EPA published the draft 6th Contaminant Candidate List for the next group of contaminants to be considered for regulation under the Safe Drinking Water Act. The proposed list designates microplastics and pharmaceuticals as priority contaminant groups for the first time.
And finally, EPA plans to make significant changes to coal combustion residuals requirements. A proposed rule published April 13 would revise the regulations governing the disposal of coal combustion residuals in landfills and surface impoundments, as well as the beneficial use of coal combustion residuals.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
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EHS Monthly Round Up - February 2026
In this Februrary 2026 roundup video, we'll discuss the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
Fatal work injuries fell 4 percent in 2024, largely due to a decline in workplace drug- and alcohol-related overdoses. According to the Bureau of Labor Statistics, overdose fatalities fell from 512 in 2023 to 410 in 2024. Across all types of workplace incidents, there were 5,070 fatal work injuries in 2024, compared to 5,283 in 2023. Transportation incidents continue to be the most frequent type of fatal event, accounting for over 38 percent of all occupational fatalities in 2024.
OSHA is fast-tracking a proposal to remove the 2036 obligation to upgrade fall protection systems on fixed ladders that extend over 24 feet. This follows an industry petition from major chemical and petroleum industry groups, which argue the provision is unjustified, costly, and not supported by the rulemaking record. OSHA frames the upcoming proposed action as deregulatory, allowing employers to update fixed ladders at the end of their service lives. We’ll provide updates as more information becomes available.
As OSHA leans into “deregulatory” actions, lawmakers are moving to pressure the agency to issue “regulatory” rulemaking to protect American workers. The latest legislative wave of bills aims to fill regulatory gaps, tackle emerging hazards, expand OSHA authority, and raise penalties. Topics addressed by these bills include musculoskeletal disorders, heat stress, infectious diseases, wildfire smoke, and workplace violence.
In a recently issued letter of interpretation, OSHA states that a burn injury caused by a personal lithium-ion battery fire is work related if it occurs in the workplace during assigned working hours. The letter details an incident where an employee was burned when their rechargeable lithium-ion batteries for e-cigarettes sparked a fire after coming into contact with a key used for work.
A new report from the Department of Labor Office of Inspector General concludes that OSHA struggles to meet its mission, particularly in high-risk industries like healthcare, construction, and manufacturing. Several pages point to OSHA’s difficulties in effectively enforcing annual injury and illness reporting requirements, reaching the nation’s high-risk worksites for inspection, and addressing workplace violence by regulatory or other action.
Turning to environmental news, EPA extended the deadlines for Facility Evaluation Reports and related requirements for coal combustion residuals facilities. In most instances, the deadlines have been moved one or two years out.
And finally, EPA announced a final rule eliminating the 2009 Endangerment Finding and related greenhouse gas emission requirements for on-highway vehicles and vehicle engines. When the final rule takes effect, manufacturers and importers of new motor vehicles and motor vehicle engines will no longer have to measure, report, certify, or comply with federal greenhouse gas emission standards.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
NewsWaste ManifestsEnforcement and Audits - OSHAWaste/HazWasteWater ProgramsMonthly Roundup VideoCAA ComplianceUSACWA ComplianceStormwaterEnglishAir ProgramsIndustry NewsEnforcement and Audits - OSHAMunicipal WastewaterSafety & HealthGeneral Industry SafetyWasteEnvironmentalFocus AreaAir ProgramsVideo
EHS Monthly Round Up - March 2026
In this March 2026 roundup video, we'll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
OSHA released an updated Job Safety and Health poster. Employers can use either the revised version or the older one, but the poster must be displayed in a conspicuous place where workers can easily see it.
OSHA recently removed a link from its Data topic webpage that displayed a list of “high-penalty cases” at or over $40,000 since 2015. The agency says it discontinued and removed it in December. The data is frozen and archived elsewhere.
OSHA published two new resources as part of its newly launched Safety Champions Program. The fact sheet provides an overview of how the program works, eligibility criteria, and key benefits. The step-by-step guide helps businesses navigate the core elements of OSHA’s Recommended Practices for Safety and Health Programs.
Several forces are nudging OSHA to address a number of workplace hazards and high-hazard industries. This comes from other agencies, safety organizations, watchdogs, legislative proposals, and persistent injury/fatality data. Among the hazards are combustible dust; first aid; personal protective equipment; and workplace violence. How all this translates into new regulations, guidance, programmed inspections, or other initiatives remains to be seen.
Turning to environmental news, EPA issued a proposed rule to require waste handlers to use electronic manifests to track all RCRA hazardous waste shipments. Stakeholders have until May 4 to comment on the proposal.
On March 10, EPA finalized stronger emission limits for new and existing large municipal waste combustors and made other changes to related standards.
And finally, EPA temporarily extended coverage under the 2021 Multi-Sector General Permit for industrial stormwater discharges until the agency issues a new general permit. The permit expired February 28 and remains in effect for facilities previously covered. EPA won’t take enforcement action against new facilities for unpermitted stormwater discharges if the facilities meet specific conditions.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
NewsCERCLA, SARA, EPCRA CERCLA, SARA, EPCRASafety and Health Programs and TrainingElectronic Reporting of Injury and Illness RecordsWater ProgramsMonthly Roundup VideoSafety and Health Programs and TrainingUSAWater ProgramsHazard CommunicationInjury and Illness RecordkeepingEnglishTier II Inventory ReportingIndustry NewsSafety & HealthInjury and Illness RecordkeepingWater ReportingGeneral Industry SafetyEnvironmentalHazard CommunicationSARA ComplianceFocus AreaVideo
EHS Monthly Round Up - January 2026
In this January 2026 roundup video, we'll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
Chemical manufacturers, importers, distributors, and employers will have an extra four months to comply with the provisions of OSHA’s revised Hazard Communication standard. When the rule was revised in 2024, it contained staggered compliance dates for those who classify or use chemical substances and mixtures. The first compliance date is now May 19 rather than January 19 of 2026.
On January 8, OSHA issued further technical corrections to its Hazard Communication final rule. An initial set of corrections was published in October 2024, and OSHA continued to review the standard for errors. The agency said these corrections should reduce confusion during the chemical classification process and prevent errors on labels and safety data sheets.
In 2024, private industry employers reported 2.5 million nonfatal workplace injuries and illnesses, according to the Bureau of Labor Statistics. This is down 3.1 percent from 2023 and largely due to a decrease in respiratory illnesses. The greatest number of cases involving days away from work, job restriction, or transfer were caused by overexertion, repetitive motion, and bodily conditions, followed by contact incidents.
Registration is open for OSHA’s Safety Champions Program, which is designed to help employers develop and implement effective safety and health programs. Participants can work at their own pace through Introductory, Intermediate, and Advanced levels.
Turning to environmental news, on January 9, EPA withdrew its direct final rule on SDS/Tier II reporting tied to OSHA HazCom, before it had a chance to take effect. The direct final rule was published back on November 17, 2025, and was intended to relax the Tier II and safety data sheet reporting requirements and align with OSHA’s HazCom standard. EPA said it plans to write a new rule addressing all public comments.
And finally, EPA published a final rule that changes certain requirements for wastewater discharges from coal-fired steam electric power plants. It applies to the deadlines established by the preceding rule finalized in 2024.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
Most Recent Highlights In Safety & Health
NewsIndustry NewsIndustry NewsToxic Substances Control Act - EPAToxic Subtances Control Act - EPATSCA ComplianceToxic Substances - EPAEnvironmental Protection Agency (EPA)EnvironmentalEnglishFocus AreaUSA
2026-05-07T05:00:00Z
EPA postpones compliance for TCE uses with TSCA Section 6(g) exemptions
On May 5, 2026, the Environmental Protection Agency (EPA) published a final rule postponing the effective date of compliance requirements for trichloroethylene (TCE) uses with Toxic Substances Control Act (TSCA) Section 6(g) exemptions until pending judicial review is concluded.
Who’s impacted?
The delay applies to the conditions imposed on each TSCA Section 6(g) exemption at 40 CFR 751.325, including the Workplace Chemical Protection Program requirements at 751.315.
Since the compliance requirements haven’t taken effect, facilities that use TCE with TSCA Section 6(g) exemptions don’t have to comply with the provisions yet.
Why the delay?
In December 2024, EPA released the final TCE rule (2024 TCE rule). The rule ultimately bans all uses of TCE, but it allows uses with TSCA Section 6(g) exemptions to continue for a limited time as long as facilities comply with strict workplace controls. Currently, the 2024 TCE rule is under judicial review. EPA has delayed the effective date of the requirements for TCE uses with TSCA Section 6(g) exemptions until the judicial challenges to the 2024 TCE rule are resolved.
If you have a sense of déjà vu, it’s for a good reason. This is the fifth time the agency has delayed the compliance requirements for TSCA Section 6(g) exemptions. However, EPA’s previous postponements established specific dates for the provisions to take effect, but this rule doesn’t.
Key to remember: EPA has delayed the compliance requirements for TCE uses with TSCA Section 6(g) exemptions until pending judicial review is concluded.
NewsSafe Drinking WaterChange NoticesChange NoticeWater ProgramsEnvironmentalCWA ComplianceEnglishWisconsinFocus Area
2026-05-04T05:00:00Z
Wisconsin adds requirements to federal lead and copper drinking water rule
Effective date: May 1, 2026
This applies to: Public water systems
Description of change: The Wisconsin Department of Natural Resources (department) finalized amendments to align state regulations with the Environmental Protection Agency’s (EPA’s) updated lead and copper control requirements for drinking water. While most of the amendments conform to federal standards, the state has additional standards. The department also:
- Requires community water systems to make four contact attempts (two more than federal requirements) by two different means for elementary schools and childcare facilities to schedule lead monitoring,
- Requires public water systems on reduced annual monitoring to analyze and report the same number of sample results for copper and lead (instead of the federal requirements that only half of the copper samples are analyzed),
- Requires public water systems undergoing temporary treatment or source water changes (unregulated by EPA) for more than 30 days to notify the department 10 days before the planned change or as soon as possible for an unplanned emergency change,
- Requires groundwater system water suppliers that request to limit their entry point sampling to obtain prior approval from the department,
- Requires water suppliers that provide point-of-use treatment devices for the corrosion control treatment compliance flexibility option to submit a written plan to the department (not required by the federal rule),
- Grants the department the authority to require analysis of total and dissolved lead during distribution system and site assessments where the federal rule doesn’t provide this authority to the state,
- Requires water suppliers that request to invalidate a reported sample result to provide substantial evidence that the sample meets one of the invalidation criteria in the rule, and
- Combines the lead and copper monitoring waivers into one waiver and requires public water systems to complete at least two 6-month rounds of standard tap water monitoring (for which the federal rule only requires one 6-month round).
NewsDistrict of ColumbiaChange NoticesChange NoticeCAA ComplianceEnvironmentalAir PermittingFocus AreaEnglishAir Programs
2026-05-04T05:00:00Z
District of Columbia updates odor control permit rules
Effective date: April 10, 2026
This applies to: Entities required to obtain an operating air permit under Nuisance Odor Regulations
Description of change: The District of Columbia’s Department of Energy and Environment (DOEE) finalized a rulemaking that allows sources of nuisance odors to implement odor controls before obtaining an operating air permit under 20 DCMR Section 200.
To qualify, an entity must obtain from the DOEE written approval of the controls in the Odor Control Plan (OCP) decision letter. Additionally, the source must apply for an operating permit under 200.2 within 60 days of receiving an OCP decision letter.
Related state info: Clean air operating permits state comparison
NewsChange NoticesChange NoticeCaliforniaMobile Emission SourcesCAA ComplianceEnvironmentalFocus AreaEnglishAir Programs
2026-05-04T05:00:00Z
California permanently adopts emergency vehicle rules
Effective date: April 1, 2026
This applies to: New vehicle and engine manufacturers
Description of change: The California Air Resources Board (CARB) permanently adopted the Emergency Vehicle Emissions Regulations, which CARB adopted in 2025 as a temporary measure.
The rule reverts the emission standards and requirements for vehicle and engine manufacturers to the regulations in effect before the adoption of:
- Advanced Clean Cars II (ACC II), and
- Heavy-Duty Engine and Vehicle Omnibus Low NOx (Omnibus).
CARB allows manufacturers to comply with ACC II and Omnibus requirements voluntarily.
In 2025, the Environmental Protection Agency revoked CARB’s waivers to implement the ACC II, Omnibus, and Advanced Clean Trucks rules.
NewsHazardous WasteIndustry NewsWaste GeneratorsWaste ManifestsWaste/HazWasteWaste HandlersWasteEnvironmental Protection Agency (EPA)TSD FacilitiesEnvironmentalIn-Depth ArticleEnglishFocus AreaUSA
2026-04-28T05:00:00Z
Hazardous waste manifests: Hybrid vs. fully electronic
More industries are embracing the exclusive use of electronic platforms. For example, digital payments are replacing cash, news sites are going fully online, and cloud storage is eclipsing external computer storage. And, based on recent proposed rulemaking, hazardous waste manifests may join the list.
The Environmental Protection Agency (EPA) proposed the Paper Manifest Sunset Rule in March 2026, planning to shift to electronic-only manifests for tracking hazardous waste that’s regulated by the Resource Conservation and Recovery Act (RCRA).
If the proposed rule is finalized, regulated entities will have to track all hazardous waste shipments electronically. Specifically, generators, transporters, and receiving facilities could only use hybrid or fully electronic manifests on the Hazardous Waste Electronic Manifest System (e-Manifest).
So, what are the differences between hybrid and fully electronic manifests? Let’s compare the distinctions and explore some of the benefits that electronic manifests can offer.
What’s a hybrid manifest?
EPA initially established the hybrid manifest for generators that couldn’t fully participate in electronic manifests when the e-Manifest launched in 2018. The hybrid manifest combines paper and electronic manifests, allowing generators that aren’t registered in e-Manifest or don’t have an EPA identification (ID) number to sign printed copies of electronic manifests.
Here’s the general hybrid manifest process:
- The first transporter initiates an electronic manifest in e-Manifest. A hard copy of the electronic manifest is printed out, and the generator and initial transporter sign the paper copy.
- The generator keeps a signed paper copy on-site. The transporter keeps a signed paper copy with the shipment until it’s delivered to the receiving facility.
- From that point forward, the initial transporter and all subsequent waste handlers track the shipment in e-Manifest (using electronic signatures and electronic transmissions).
- The manifest is complete when the receiving facility or exporter electronically signs it on e-Manifest.
What’s a fully electronic manifest?
The fully electronic manifest is tracked completely online. All handlers — generators, transporters, and receiving facilities or exporters — must have an EPA ID number and be registered in e-Manifest to use the fully electronic manifest.
The entire process is conducted on e-Manifest:
- The manifest is created electronically in e-Manifest.
- All handlers electronically sign the manifest in e-Manifest.
- The manifest is complete when the receiving facility or exporter electronically signs it on e-Manifest.
What benefits do electronic manifests offer?
Regardless of whether EPA’s rule is finalized as is, electronic manifests offer hazardous waste handlers a range of benefits. Consider the following potential perks.
Compliance with existing regulations
Many handlers are already required to embrace electronic manifesting. In July 2024, EPA finalized the e-Manifest Third Rule, which requires:
- Large quantity generators and small quantity generators to register for e-Manifest,
- Exporters to submit manifests and continuation sheets to e-Manifest (and pay the associated fees), and
- Waste handlers to submit manifest-related reports and data corrections to e-Manifest.
Streamlined recordkeeping for generators
Hazardous waste handlers using e-Manifest automatically meet the recordkeeping requirements to maintain records of manifests (paper or electronic) since the manifests are retained electronically in the system.
This eliminates the need to keep hard copies. It also provides a centralized place where handlers can access these documents at any time.
However, the provision doesn’t apply to generators using hybrid manifests; they must keep the initial paper copies of the electronic manifest for 3 years.
Reduced costs
Embracing electronic manifesting removes the costs associated with printing paper manifests from EPA-approved sources.
Keep in mind, there’s an unavoidable cost for receiving facilities and exporters. These entities have to pay user fees for each manifest they submit to e-Manifest.
Proactive preparation
EPA’s proposed Paper Manifest Sunset Rule would prohibit the use of paper manifests 2 years after the publication of a final rule. Hazardous waste handlers who transition to using only electronic manifests now will be better prepared to comply with future regulations. It gives businesses time to coordinate resources and address any unexpected issues.
Key to remember: Do you know the differences between hybrid and fully electronic hazardous waste manifests? The distinctions could be the difference between compliance and noncompliance.
Most Recent Highlights In Human Resources
NewsIndustry NewsIndustry NewsToxic Substances Control Act - EPAToxic Subtances Control Act - EPATSCA ComplianceEnvironmental Protection Agency (EPA)EnvironmentalEnglishFocus AreaUSA
2026-04-27T05:00:00Z
EPA publishes first round of expiring TSCA CBI claims
The Environmental Protection Agency (EPA) published the first list of expiring Confidential Business Information (CBI) claims for information submitted under the Toxic Substances Control Act (TSCA). The list covers CBI claims that expire from June 22, 2026, to July 31, 2026.
What are expiring CBI claims?
The Frank R. Lautenberg Chemical Safety for the 21st Century Act (which became law in June 2016) set an automatic 10-year expiration for most CBI claims made under TSCA. The first round of expiring claims starts in June 2026.
EPA allows businesses to request extensions of CBI protection for up to another 10 years.
How do I know if my CBI claims are expiring?
EPA will notify businesses of expiring CBI claims directly through the Central Data Exchange (CDX).
The agency will also release public lists of upcoming expiring CBI claims monthly on the “CBI Claim Expiration” webpage. The agency encourages businesses to review the lists to verify whether any of their claims are included.
How do I request an extension of expiring CBI claims?
Businesses seeking to extend a CBI claim beyond its expiration date must submit an extension request at least 30 days before the claim expires using the newly launched TSCA Section 14(e) CBI Claim Extension Request application in EPA’s CDX.
Here’s the general process:
- EPA notifies the business of an expiring CBI claim directly through CDX and via the public lists on the “CBI Claim Expiration” webpage.
- The business submits a request for extension through EPA’s CDX at least 30 days before the CBI claim expires. Requests must comply with the substantiation requirements at 40 CFR 703.5(a) and (b).
- EPA reviews the submission and either grants or denies the request.
What are the possible results?
If EPA approves the extension request, the information in the CBI claim will remain protected for up to another 10 years.
If EPA denies the extension request, the agency can publicize the information in the claim 30 days after notifying the submitter in CDX. Further, if a business doesn’t submit an extension request at least 30 days before the expiration date, EPA may publicize the information without notifying the submitter.
Key to remember: EPA published the first round of expiring CBI claims for information submitted under TSCA. Businesses must submit extension requests to keep the information protected.
NewsChange NoticesAboveground Storage TanksChange NoticeEnvironmentalStorage TanksFocus AreaEnglishNorth DakotaTank Systems
2026-04-24T05:00:00Z
North Dakota establishes AST regulations
Effective date: April 1, 2026
This applies to: Owners and operators of aboveground storage tanks (ASTs) and liquid fuel storage tanks
Description of change: The Department of Environmental Quality adopted technical standards and corrective action requirements for ASTs. The department also approved amendments to the registration dates and fee categories of the Petroleum Tank Release Compensation Fund for liquid fuels storage tanks.
Related state info: Aboveground storage tanks (ASTs) state comparison — ASTs
NewsWater PermittingPublicly Owned Treatment WorksChange NoticesChange NoticeOhioWater ProgramsEnvironmentalWater ProgramsEnglishFocus AreaCWA Compliance
2026-04-24T05:00:00Z
Ohio finalizes sewage sludge amendments
Effective date: March 1, 2026
This applies to: Facilities regulated by the sewage sludge program
Description of change: The Ohio Environmental Protection Agency finalized changes to the sewage sludge program through its 5-year review of the regulations. The approved amendments:
- Add professional operator of record requirements for privately owned treatment works;
- Increase and add isolation distances for facilities;
- Prohibit beneficial use of biosolids within a vulnerable hydrogeological setting;
- Remove dioxin monitoring requirements; and
- Add requirements for beneficial user certification (including the application and examination process, recordkeeping requirements, and reasons for suspending or revoking a certification).
NewsNew MexicoNew Mexico Environment Department (NMED)Change NoticesChange NoticeMobile Emission SourcesCAA ComplianceEnvironmentalFocus AreaEnglishAir Programs
2026-04-24T05:00:00Z
New Mexico adopts Clean Transportation Fuel Program rules
Effective date: April 1, 2026
This applies to: Transportation fuel produced in, imported into, or dispensed for use in New Mexico
Description of change: The New Mexico Environment Department finalized regulations to implement the Clean Transportation Fuel Program (CTFP) to reduce the carbon intensity of transportation fuel (including gasoline and diesel). The program covers transportation fuel producers, importers, and dispensers.
The CTFP:
- Establishes annual statewide carbon intensity standards that apply to transportation fuel (e.g., gasoline and diesel) produced, imported, and dispensed for use in New Mexico;
- Allocates credits and calculates deficits for regulated entities based on the fuel’s carbon intensity; and
- Sets up a marketplace for selling and purchasing credits to comply with the carbon intensity standards.
The first compliance period runs from April 1, 2026, to December 31, 2027. The first compliance period report is due by April 30, 2028. Annual compliance reports will be due by April 30 for the previous calendar year.
NewsRecyclingChange NoticesChange NoticeMaineSustainabilityProduct StewardshipSustainabilityWaste MinimizationEnvironmentalEnglishSustainabilityFocus Area
2026-04-24T05:00:00Z
Maine lists materials covered for packaging stewardship program
Effective date: March 3, 2026
This applies to: Entities subject to the Stewardship Program for Packaging Regulations
Description of change: The Maine Department of Environmental Protection’s amendments to the Stewardship Program for Packaging Regulations (06-096 C.M.R. Chapter 428) include:
- Aligning the rules with changes made by An Act to Improve Recycling by Updating the Stewardship Program for Packaging (L.D. 1423), and
- Adding Appendix A — The Packaging Material Types List to the Stewardship Program for Packaging Regulations.
L.D. 1423:
- Excludes certain commercial, cosmetic, medical, environmental, dangerous, hazardous, and flammable product packaging from the program requirements;
- Excludes packaging of products related to public health and water quality testing from the program requirements;
- Requires the department to adopt a process for approving a producer payment system; and
- Updates definitions for clarity.
Appendix A defines packaging material and designates the material types readily recyclable as applicable. It may also designate materials as compostable or reusable.
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NewsIndustry NewsWaste GeneratorsWaste IdentificationWaste/HazWasteWasteEnvironmentalIn-Depth ArticleSolid WasteEnglishFocus AreaUSA
2025-09-22T05:00:00Z
The new rules of waste: How 2025 legislation is reshaping corporate environmental compliance
In 2025, sweeping changes to waste laws across the U.S. are forcing companies to rethink packaging, disposal, and reporting practices. From statewide bans on single-use plastics to expanded Extended Producer Responsibility (EPR) programs and chemical recycling reclassification, these updates carry significant compliance implications for corporate Environmental Health and Safety (EHS) teams.
Single-use plastics: New bans and restrictions
Several states have enacted new bans on polystyrene foam containers, plastic straws, and produce bags:
- California SB 1046: As of January 1, 2025, expanded polystyrene (EPS) food containers are banned unless they meet a 25% recycling rate. Pre-checkout bags must be compostable or made of recycled paper.
- Delaware SB 51: Foam containers and plastic stirrers are banned unless requested by the customer.
- Oregon SB 543: Bans EPS containers and food packaging with intentionally added PFAS.
- Virginia: No food vendor may use EPS containers starting July 1, 2025.
Compliance tip: Audit your packaging inventory and supplier certifications. Ensure alternatives meet compostability or recyclability standards.
Extended producer responsibility (EPR): Expanding nationwide
EPR laws now apply in several states. These laws require companies to help pay for recycling and report packaging data.
- Maryland SB 901: Allows multiple Producer Responsibility Organizations (PROs) and mandates cost-sharing for recycling.
- Washington SB 5284: Targets consumer packaging with compliance deadlines starting in 2028.
- Colorado: Unregistered producers are banned from selling covered products as of July 1, 2025.
- California SB 54: Revised draft rules released in May 2025 include new compliance dates and exemptions.
Compliance tip: Register with your state’s PRO, submit packaging data, and prepare for fee schedules. Track deadlines and exemptions closely.
Chemical recycling: Regulatory reclassification and impacts
States like Texas and Pennsylvania now classify chemical recycling as manufacturing, not waste management. This shift encourages investment but also changes permitting and emissions reporting obligations.
Compliance tip: If your facility uses or contracts chemical recycling, review air and water permits. Ensure alignment with manufacturing regulations.
Per and polyfluoroalkyl substances (PFAS): Phase-outs and hazardous waste updates
More states are banning PFAS in packaging and cookware:
- Minnesota, Oregon, Rhode Island, and New Mexico have banned or phased out PFAS in consumer products.
- Illinois SB 727: Aligns PFAS limits with EPA standards.
Compliance tip: Update product safety data sheets (SDS) and conduct PFAS audits. Prepare for new reporting under TSCA Section 8(a)(7), including data on manufacture, use, and disposal.
Circular economy and composting: Recent mandates
States are setting zero-waste goals and requiring composting:
- Hawaii HB 750: Launches a statewide recycling needs assessment.
- Maine LD 1065: Requires large food waste generators to compost by 2030.
Compliance Tip: Evaluate organics diversion programs and infrastructure. Consider partnerships with composting facilities.
EHS teams: What to do now
- Map your regulatory exposure: Identify which state laws apply to your operations.
- Engage with PROs: Register, report, and participate in rulemaking.
- Train staff: Ensure procurement, operations, and legal teams understand new requirements.
- Audit packaging and waste streams: Replace banned materials and optimize recycling.
- Monitor emerging legislation: Stay ahead of new bills and compliance deadlines.
Key to remember: Staying compliant in 2025 means more than avoiding fines. EHS teams must lead efforts to meet new waste laws and support sustainability goals.
NewsGreenhouse GasesIndustry NewsIndustry NewsAir ProgramsEnvironmental Protection Agency (EPA)CAA ComplianceEnvironmentalFocus AreaEnglishVolatile Organic CompoundsAir ProgramsStationary Emission SourcesUSA
2026-04-10T05:00:00Z
EPA amends specific oil and gas emission standards
On April 9, 2026, the Environmental Protection Agency (EPA) published a final rule that makes technical changes to the emission standards established in March 2024 (2024 Final Rule) for crude oil and natural gas facilities. This rule (2026 Final Rule) amends the requirements for:
- Temporary flaring of associated gas, and
- Vent gas net heating value (NHV) monitoring provisions for flares and enclosed combustion devices (ECDs).
Who’s impacted?
The 2026 Final Rule affects new and existing oil and gas facilities. Specifically, it applies to the regulations for the Crude Oil and Natural Gas source category, including the:
- New Source Performance Standards at 40 CFR 60 Subpart OOOOb, and
- Emission guidelines at 60 Subpart OOOOc.
These emission standards are commonly referred to as OOOOb/c.
What are the changes?
The 2026 Final Rule implements technical changes to the temporary flaring and vent gas NHV monitoring requirements set by the 2024 Final Rule.
Temporary flaring
The rule extends the baseline time limit for temporary flaring of associated gas at well sites in certain situations (like conducting repairs or maintenance) from 24 to 72 hours. Owners and operators must stop temporary flaring as soon as the situation is resolved or the temporary flaring limit is reached (whichever happens first).
It also grants allowances beyond the 72-hour limit if exigent circumstances occur (such as severe weather that prevents safe access to a well site to address an emergency or maintenance issue) and there’s a need to extend duration for repairs, maintenance, or safety issues. Owners and operators must keep records of exigent circumstances and include the information in their annual reports.
NHV monitoring
For new and existing sources, the 2026 Final Rule exempts all flare types (unassisted and assisted) and ECDs from monitoring due to high NHV content, except when inert gases are added to the process streams or for other scenarios that decrease the NHV content of the inlet stream gas. In these cases, EPA requires NHV monitoring via continuous monitoring or the alternative performance test (sampling demonstration) option for all flares and ECDs.
Other significant changes include:
- Replacing the general exemption from NHV monitoring for associated gas for any control device used at well site affected facilities with NHV monitoring requirements,
- Granting operational pauses during weekends and holidays for the consecutive 14-day sampling demonstration requirements (limiting it to no more than 3 operating days from the previous sampling day), and
- Permitting less than 1-hour sampling times for twice daily samples where low or intermittent flow makes it infeasible (as long as owners and operators report the sampling time used and the reason for the reduced time).
The 2026 Final Rule takes effect on June 8, 2026.
Key to remember: EPA’s technical changes to the emission standards for oil and gas facilities apply to temporary flaring provisions and vent gas NHV monitoring requirements.
NewsClosuresIndustry NewsIndustry NewsWaste/HazWasteWasteEnvironmental Protection Agency (EPA)Waste ManagementEnvironmentalSolid WasteEnglishFocus AreaUSA
2026-04-16T05:00:00Z
EPA proposes major changes to coal combustion residuals rules
The Environmental Protection Agency (EPA) published a proposed rule on April 13, 2026, to revise the existing regulations governing the disposal of coal combustion residuals (CCR) in landfills and surface impoundments as well as the beneficial use of CCR.
Who’s impacted?
The proposed rule affects coal-fired electric utilities and independent power producers subject to the CCR disposal and beneficial use regulations at 40 CFR Part 257.
What are the changes?
Significant changes the EPA proposes include:
- Adding an option for facilities to certify the closure of legacy CCR surface impoundments by CCR removal that were closed before November 8, 2024, under regulatory oversight;
- Expanding the eligibility criteria for facilities to defer CCR closure requirements until site-specific determinations are made for legacy surface impoundments that were closed before November 8, 2024, under regulatory oversight;
- Exempting CCR dewatering structures (used to dewater CCR waste for the disposal of CCR elsewhere) from federal CCR regulations (Part 257);
- Rescinding all CCR management unit (CCRMU) requirements or revising the existing CCRMU regulations;
- Allowing permit authorities to make site-specific determinations regarding certain requirements during permitting for CCR units complying with federal CCR groundwater monitoring, corrective action, and closure requirements under a federal or an approved-state CCR permit; and
- Revising the beneficial use requirements by:
- Removing the environmental demonstration requirement for non-roadway use of more than 12,400 tons of unencapsulated CCR; and
- Excluding these beneficial uses from federal CCR regulations (Part 257):
- CCR used in cement manufacturing at cement kilns,
- Flue gas desulfurization (FGD) gypsum used in agriculture, and
- FGD gypsum used in wallboard.
Key to remember: EPA plans to make significant amendments to the coal combustion residuals requirements.
NewsAir QualityIndustry NewsIndustry NewsAir ProgramsEnvironmental Protection Agency (EPA)Hazardous Air PollutantsCAA ComplianceEnvironmentalFocus AreaEnglishAir ProgramsStationary Emission SourcesUSA
2026-04-02T05:00:00Z
EPA releases final NESHAP for chemical manufacturing area sources
The Environmental Protection Agency (EPA) published a final rule on April 1, 2026, amending the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Chemical Manufacturing Area Sources (CMAS). The NESHAP controls hazardous air pollutant (HAP) emissions from facilities that manufacture a range of chemicals and products, such as inorganic chemicals, plastics, and synthetic rubber.
Who’s impacted?
The final rule applies to nine area source categories in the chemical manufacturing sector that are regulated by the CMAS NESHAP (40 CFR 63 Subpart VVVVVV).
What are the changes?
EPA’s final rule:
- Establishes leak detection and repair requirements for equipment leaks and heat exchange systems in organic HAP service,
- Adds detectable emissions monitoring standards for pressure vessels in organic HAP service and emission management practice standards for pressure relief devices (PRDs) in organic HAP service,
- Prohibits closed vent systems in organic HAP service from bypassing an air pollution control device (APCD), and
- Requires recurring performance testing of non-flare APCDs to demonstrate compliance with process vent and storage tank provisions.
The final rule also mandates electronic reporting for notifications of compliance status (NOCs), performance test reports, and periodic reports. Facilities must submit these reports through the Compliance and Emissions Data Reporting Interface (CEDRI) on EPA’s Central Data Exchange.
What didn’t change?
Significantly, the final rule doesn’t add previously proposed regulations for area sources that use ethylene oxide (EtO) to produce materials described by code 325 of the North American Industry Classification System (NAICS).
EPA states that it intends to address the regulation of EtO from area sources and major sources in one final action.
What are the compliance timelines?
Existing facilities must comply with the amendments by April 1, 2029.
New facilities (those that begin construction or reconstruction after January 22, 2025) have to comply with the changes by April 1, 2026, or upon startup, whichever is later.
Additionally, facilities must start electronically submitting:
- Performance tests by June 1, 2026;
- NOCs by August 31, 2026; and
- Periodic reports by April 1, 2029.
Key to remember: EPA’s final HAP emissions rule for chemical manufacturing area sources adds new requirements for certain processing equipment and systems.
NewsGreenhouse GasesWaste/HazWasteToxic Substances Control Act - EPASafe Drinking WaterWater AnalysisWater ProgramsWater QualityMaximum Contaminant LevelsWalking Working SurfacesMonthly Roundup VideoCAA ComplianceSolid WasteCWA ComplianceLaddersEnglishUSAHeat StressIndustry NewsHeat and Cold ExposureSafety & HealthGeneral Industry SafetyWasteMaritime SafetyEnvironmentalFocus AreaWater MonitoringVolatile Organic CompoundsAir ProgramsStationary Emission SourcesVideo
EHS Monthly Round Up - April 2026
In this April 2026 roundup video, we’ll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
OSHA revised its National Emphasis Program on heat-related hazards. Going forward, the agency will prioritize inspections in 55 high-risk industries in indoor and outdoor work settings. The program remains in effect for 5 years from its April 10 effective date.
An OSHA proposed rule seeks to eliminate the November 18, 2036, deadline in the Walking-Working Surfaces standard that would require all fixed ladders extending more than 24 feet above a lower level to be equipped with personal fall arrest systems or ladder safety systems. OSHA also seeks feedback on nine specific questions related to the proposal, with comments due on June 5.
On April 17, OSHA revoked its House Falls in Marine Terminals standard at 1917.41. The agency said that because most cargo has been containerized and is moved by cranes, the standard is no longer necessary to protect employees.
Turning to environmental news, an EPA final rule further delays the submission period for the one-time PFAS report required of manufacturers. It pushes the start of the submission period to either 60 days after the effective date of a future final rule updating the PFAS Reporting Rule or January 31, 2027, whichever comes first.
An EPA final rule makes technical changes to the emission standards established in March 2024 for crude oil and natural gas facilities. The changes take effect June 8.
EPA published the draft 6th Contaminant Candidate List for the next group of contaminants to be considered for regulation under the Safe Drinking Water Act. The proposed list designates microplastics and pharmaceuticals as priority contaminant groups for the first time.
And finally, EPA plans to make significant changes to coal combustion residuals requirements. A proposed rule published April 13 would revise the regulations governing the disposal of coal combustion residuals in landfills and surface impoundments, as well as the beneficial use of coal combustion residuals.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
NewsIndustry NewsIndustry NewsToxic Substances Control Act - EPAToxic Subtances Control Act - EPATSCA ComplianceToxic Substances - EPAEnvironmental Protection Agency (EPA)EnvironmentalEnglishFocus AreaUSA
2026-04-13T05:00:00Z
EPA delays TSCA Section 8(a)(7) PFAS reporting timeline again
On April 13, 2026, the Environmental Protection Agency (EPA) published a final rule that further delays the submission period for the one-time report required of manufacturers on per- and polyfluoroalkyl substances (PFAS) by the PFAS Reporting and Recordkeeping Rule (PFAS Reporting Rule).
This final rule pushes the starting submission period to either 60 days after the effective date of a future final rule updating the PFAS Reporting Rule or January 31, 2027, whichever is earlier.
Who’s impacted?
Established under Toxic Substances Control Act (TSCA) Section 8(a)(7), the PFAS Reporting Rule (40 CFR Part 705) requires any business that manufactured (including imported) any PFAS or PFAS-containing article between 2011 and 2022 to report. Covered manufacturers and importers must submit information on:
- Chemical identity, uses, and volumes made and processed;
- Byproducts;
- Environmental and health effects;
- Worker exposure; and
- Disposal.
What’s the new timeline?
The opening submission period was moved from April 13, 2026, to either 60 days after the effective date of a future final PFAS Reporting Rule or January 31, 2027, whichever is earlier.
Most manufacturers have 6 months to submit the report. Small manufacturers reporting only as importers of PFAS-containing articles have 1 year.
| TSCA Section 8(a)(7) PFAS Reporting Rule submission period | ||
|---|---|---|
| Start date | End date | |
| Most manufacturers | 60 days from effective date of final PFAS Reporting Rule or January 31, 2027 (whichever is earlier) | 6 months from start date or July 31, 2027 (whichever is earlier) |
| Small manufacturers reporting solely as PFAS article importers | 60 days from effective date of final PFAS Reporting Rule or January 31, 2027 (whichever is earlier) | 1 year from start date or January 31, 2028 (whichever is earlier) |
Why the delay?
In November 2025, the agency proposed updates to the PFAS Reporting Rule. EPA has delayed the reporting period to give the agency time to issue a final rule (expected later this year).
Key to remember: EPA has delayed the starting submission deadline for the TSCA Section 8(a)(7) PFAS Reporting Rule from April 2026 to no later than January 2027.
Most Popular Highlights In Transportation
NewsIndustry NewsMedical review officer (MRO) - Motor CarrierFleet SafetyDrug testing - Motor CarrierDrug and Alcohol Testing - DOTFocus AreaIn-Depth ArticleEnglishTransportationUSA
2026-05-14T05:00:00Z
Excuses that won’t make the cut for failed drug tests
Medical review officers (MROs) hear some wild excuses from drivers regarding failed DOT drug tests.
Some excuses may be valid and investigated by the MRO during the verification process. For example, a driver may refer the MRO to a family physician about a legally prescribed medication that showed up in the drug panel.
However, some explanations provided by drivers aren’t viewed as reasonable under the regulations. Consider the following commonly used excuses that MROs aren’t permitted to entertain.
Tested in error
- Drivers may claim that their employer initiated a test that shouldn’t have been done, such as: Requesting a post-accident test when the criteria in 382.303 weren’t met,
- Misidentifying a driver as the subject of a random test, or
- Sending a driver for a reasonable suspicion test without grounds.
MROs are told in 49 CFR 40.151(c) that it’s not their role to determine whether the test should have occurred. A positive test result stands for anyone holding a commercial driver’s license (CDL), even if the employer made a mistake in sending them for the collection.
Drugged by someone
In some instances, the driver doesn’t contest the lab result. They just claim they unknowingly were exposed to the drug, and it’s not their fault.
Stories might include:
- Someone slipped a drug into a drink at a party,
- The driver ingested a marijuana brownie without realizing it, or
- The driver traveled in a closed car with several people smoking drugs.
Stories of passive or unknowing ingestion can’t be verified. Even if true, they don’t present a legitimate medical explanation, so the MRO can’t deem the test negative.
Was set up
Drivers may claim that the specimen isn’t theirs, or someone tampered with it at the clinic.
For example, there may be allegations made by the driver that the collector left the area or left open specimen containers where others could access them.
The regulations are clear: It’s not the MRO’s role to investigate claims that collection procedures weren’t followed by the clinic. The MRO only works with what is reflected in the chain of custody form, and all other accusations will be dismissed.
Took a second test
Some drivers take it upon themselves to take a second drug test outside of DOT to prove their innocence. For example, a driver tells the MRO that a personal physician performed a urine drug test that was sent to a lab, and it came back negative. The MRO must ignore this second test result. It isn’t evidence to sway the result.
Exposed to a cleaning product
An adulterated test result is often the result of soap, bleach, or disinfectant used to tamper with a urine specimen. A driver might claim the chemicals wound up in the urine through exposure to cleaning products (e.g., absorbed through the skin or inhaled). According to the regulations, there are no physiological means through which these substances can enter a specimen.
Key to remember: MROs won’t consider tall tales when verifying failed drug tests. They are given specific instructions by DOT: Only consider valid medical explanations — no matter how convincing the driver’s story might be.
NewsIndustry NewsFleet SafetyWeights and dimensionsFocus AreaIn-Depth ArticleEnglishSize and Weight LimitsTransportationUSA
2024-01-29T06:00:00Z
Don’t drive high in Canada: Know the height of your load!
Knowing the height of the load being hauled seems straightforward enough for an enclosed trailer unit; however, what about flatbed load heights when the loading was done before your driver arrived to pick it up?
Ensuring your drivers are aware and familiar with height limits is very important; if a load is over-height, drivers are at risk of hitting awnings, overpasses, and bridges. This becomes even more critical to know if the driver wasn’t involved in loading. In addition, the vehicle height could easily change depending on what load is being carried and could change if your drivers are picking up multiple loads throughout their shift.
The consequences for having an over-height truck in Canada may vary depending on the province or territory where the violation occurs but could result in a fine, being ordered to unload excess cargo, or even being denied access to certain routes.
Are you too high?
Overhead clearance has become such a problem in Canada that some jurisdictions have started to report bridge strike incidents to the public.
The British Columbia Transportation Ministry for example made the announcement recently that fines will quadruple to $575 for drivers that have over-height loads and violations can be stacked to take that total much higher.
This could also include the cancellation of a carrier’s safety fitness certificate, which would effectively prevent the company from operating in the province.
The standard height of a semitrailer in Canada is 4.15 meters; however, the maximum height of a vehicle may vary depending on the jurisdiction and the type of load. Some bridges or overhead structures may have a lower clearance than the legal limit. Drivers should also check the signs on the edge of trailers or the labels on the equipment to verify the height of the vehicle. If drivers are unsure, they need to measure or get out and look before driving.
Knowing the low-down and what to do.
There are several possible reasons why trucks keep hitting overhead structures, bridges, etc., such as your drivers using unapproved transport routes or not following the signs for low clearances.
Perhaps your drivers are not measuring their loads or knowing the exact height of their vehicles in both metric and imperial units, especially if they cross the border between Canada and the U.S, or not receiving adequate guidance from the shippers, receivers, or regulators on how to safely transport over-sized loads.
Once finding that a vehicle/load is over-height, you or your drivers can obtain over-height permits for vehicles that exceed the maximum height limits; however, this does change the fact that the height of the load will still be restricted.
These restrictions vary by province and territory; be sure to check the specific regulations and your permits for your destination before you travel. Some of the common restrictions include:
- Road Safety. You may need to use escort vehicles, warning signs, flags, or lights to alert other drivers of your over sized load.
- Infrastructure Considerations. You may not be allowed to drive on certain roads, bridges, or tunnels that cannot support the height of your over sized load.
- Time of Day. You may only be allowed to drive during certain hours of the day, depending on the dimensions of your over sized load.
The stakes are high.
Height limits are in place to protect the safety of others on the road and to prevent damage to infrastructure and other property. Fines, safety fitness certification cancellation, and bad public perceptions are just a few of the major consequences of operating with over-height loads.
Key to remember: At the end of the day, your drivers are ultimately responsible and need to know how to properly measure loads, plan for trips (including permits if needed), and know whether loads will easily clear the height clearances on a route.
NewsEnglishFleet SafetyChange NoticesChange NoticeDrug and Alcohol Testing - DOTDrug testing - Motor CarrierOffice of the Secretary of TransportationFocus AreaAlcohol testing - Motor CarrierTransportationUSA
2026-05-11T05:00:00Z
DOT Final Rule: Procedures for Transportation Workplace Drug and Alcohol Testing Programs
The U.S. Department of Transportation revises its drug and alcohol testing procedures to require a directly observed urine collection in situations where oral fluid tests are currently required but cannot be conducted because oral fluid testing is not yet available. The rule also updates terminology in these procedures consistent with Executive Order (E.O.) 14168, Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government.
DATES: This rule is effective on June 10, 2026. Published in the Federal Register May 11, 2026, page 25507.
View final rule.
| §40.65 What does the collector check for when the employee presents a urine specimen? | ||
| (d) | Added | View text |
| §40.67 When and how is a directly observed urine collection conducted? | ||
| (g) | Revised | View text |
| (h) | Revised | View text |
| §40.69 How is a monitored urine collection conducted? | ||
| (c) | Revised | View text |
| (d) | Revised | View text |
| §40.145 [Amended] | ||
| (h)(1)(ii) | Revised | View text |
Previous text
§40.67 When and how is a directly observed urine collection conducted?
* * * *
(g) As the collector, you must ensure that the observer is the same gender as the employee.
(1) You must never permit an opposite gender person to act as the observer.
(2) The observer can be a different person from the collector and need not be a qualified collector.
(3) If a same gender collector cannot be found or in circumstances of nonbinary or transgender employees:
(i) If the employer has a standing order to allow oral fluid testing in such situations, the collector will follow that order;
(ii) If there is no standing order from the employer, the collector must contact the DER and either conduct an oral fluid test if the collection site is able to do so, or send the employee to a collection site acceptable to the employer for the oral fluid test.
(h) As the collector, if someone else is to observe the collection (e.g., in order to ensure a same gender observer), you must verbally instruct that person to follow procedures at paragraphs (i) and (j) of this section. If you, the collector, are the observer, you too must follow these procedures.
§40.69 How is a monitored urine collection conducted?
* * * *
(c) As the collector, you must ensure that the monitor is the same gender as the employee, unless the monitor is a medical professional (e.g., nurse, doctor, physician’s assistant, technologist, or technician licensed or certified to practice in the jurisdiction in which the collection takes place). The monitor can be a different person from the collector and need not be a qualified collector.
(d) As the collector, if someone else is to monitor the collection (e.g., in order to ensure a same gender monitor), you must verbally instruct that person to follow the procedures of paragraphs (d) and (e) of this section. If you, the collector, are the monitor, you must follow these procedures.
§40.145 On what basis does the MRO verify test results involving adulteration or substitution?
* * * *
(h)(1)(ii) Assertion by the employee that his or her personal characteristics (e.g., with respect to race, gender, weight, diet, working conditions) are responsible for the substituted result does not, in itself, constitute a legitimate medical explanation. To make a case that there is a legitimate medical explanation, the employee must present evidence showing that the cited personal characteristics actually result in the physiological production of urine meeting the creatinine and specific gravity criteria of §40.88(b).
NewsTransportationUSAHR ManagementEnglishDriver recruiting and retentionDriver recruiting and retentionTalent Management & RecruitingAssociate Benefits & CompensationDiscriminationGender DiscriminationDiscriminationIndustry NewsIndustry NewsRecruiting and hiringRecruiting and hiringHR GeneralistFleet OperationsApplications/ApplicantsAssociate RelationsFocus AreaHuman Resources
2026-05-18T05:00:00Z
Trucking company to pay $5.5M for not hiring qualified female drivers
A nationwide trucking company will pay $5.5 million to settle a sex discrimination claim for refusing to hire qualified female drivers for the past 10 years. The U.S. Equal Employment Opportunity Commission (EEOC) announced the resolution in a May 15 press release. The money will go to the four original complainants and a class of other qualified female truck drivers who applied but weren’t hired.
The EEOC lawsuit alleged that the trucking company, based in Michigan, repeatedly passed over qualified female truck driver applicants throughout the U.S. Instead, the company often hired male truck drivers, many of whom were less qualified or had less experience. Many female applicants reported that company personnel across the country subjected them to different hiring procedures than those used for male applicants.
Several female driver applicants also saw the trucking company throwing their job applications in the trash at local truck terminals, according to the lawsuit. Further, at a West Virginia truck terminal, the dispatcher informed a female applicant that corporate offices had instructed him not to hire any female truck drivers.
In addition to monetary relief, the company must allow affected applicants to apply for positions and take part in the company’s recruitment and hiring processes free from sex-based discrimination and retaliation for participating in the lawsuit.
The company will also:
- Hire an outside consultant to review its hiring policies, practices, and procedures to ensure full compliance with Title VII of the Civil Rights Act of 1964;
- Institute training on its anti-discrimination policies, including training on its recordkeeping obligations and the filing of EEO-1 reports as required by current law; and
- Appoint someone to review and verify the implementation of the settlement terms, and report on compliance to the EEOC.
Key to remember: It’s illegal for employers to reject qualified women for jobs based on their sex. A trucking company now owes steep fines because of such violations.
NewsIndustry NewsHazmat SafetyHazmatIn-Depth ArticleFocus AreaUSAEnglishTransportationHazmat Rulemaking procedures
2026-05-13T05:00:00Z
A close look at PHMSA's plans for class 9
If you’ve spent any time working with hazmat regulations, you know Class 9 has always been a bit of a mixed bag. It covers a wide range of materials, from lithium batteries and dry ice to environmentally hazardous substances and safety devices. At this year’s Council on Safe Transportation of Hazardous Articles (COSTHA) conference, PHMSA made it clear they think that grouping has run its course.
During their briefing, PHMSA shared early details on an idea they have been developing internationally. The proposal would keep Class 9 intact but divide it into four clearer subdivisions. Their goal is to improve hazard communication and create a system that better reflects real risks during transportation.
Pushing for change
PHMSA first raised the idea of dividing Class 9 during the 66th and 67th UN Sub-Committee of Experts on the Transport of Dangerous Goods meetings in mid and late 2025. According to PHMSA, the initial response from other countries was positive. That feedback encouraged them to continue developing the concept and bring a more defined proposal to the UN session planned for June 2026.
The main issue is that Class 9 covers too many unrelated hazards under a single label. While that flexibility has worked historically, PHMSA sees an opportunity to add structure without completely overhauling the system or creating unnecessary burdens for shippers.
Four proposed subdivisions
PHMSA outlined four subdivisions that would sit under the existing Class 9 umbrella. Each one groups materials with similar risk characteristics.
Division 9.1: Environmentally hazardous materials These materials already rely on established criteria, including marine pollutant concepts. PHMSA emphasized that this subdivision would build on existing systems and could potentially integrate environmental hazard information into the current Class 9 label, rather than creating something entirely new.
Division 9.2: Energy storage devices This subdivision would be dedicated to items like lithium batteries and other energy storage technologies. The intent is to improve hazard awareness and allow flexibility as technology changes over time.
Division 9.3: Low hazard energetics This category would organize materials with energetic properties that do not rise to the level of other hazard classes. PHMSA described this as a way to better recognize existing Class 9 assignments while allowing room for future criteria development.
Division 9.4: Other miscellaneous dangerous goods This final group would capture all remaining Class 9 materials that do not fit into the other subdivisions. PHMSA indicated no major changes are expected for this category.
What this means going forward
At this stage, the subdivision of Class 9 is still a concept, not a regulation. With that said, the fact that PHMSA has already raised it at multiple UN meetings and plans to continue the discussion in 2026 signals that this idea has momentum.
For shippers, carriers, and compliance professionals, this is worth watching. Breaking Class 9 into subdivisions could eventually affect labeling, training, and how hazards are communicated across all modes of transportation. Even if changes are still years away, understanding where regulators are heading helps organizations avoid being caught off guard.
Key to remember: Class 9 has always been a necessary catch-all. PHMSA’s proposal suggests the future of hazmat classification may focus less on convenience and more on clearly communicating risk.
NewsTraining & DevelopmentIn-Depth ArticleUSAHR ManagementEnglishTalent Management & RecruitingAssociate Benefits & CompensationDiscriminationGender DiscriminationDiscriminationTitle VII (The Civil Rights Act of 1964)Industry NewsRecruiting and hiringRecruiting and hiringInterviewingHR GeneralistFocus AreaFleet OperationsAssociate RelationsTransportationHuman Resources
2026-05-05T05:00:00Z
Stinky hiring process soils waste management company’s efforts to fill garbage truck driver role
When a hiring manager tells a qualified female job applicant to “think carefully” and “talk to her husband” before accepting a job as a garbage truck driver, it stinks of sex discrimination.
The U.S. Equal Employment Opportunity Commission (EEOC) responded by dumping a lawsuit on the employer. In April 2026, the EEOC announced that a nationwide waste management company will pay $200,000 to settle a sex discrimination in hiring lawsuit.
According to the EEOC’s lawsuit, in May 2020, the female job candidate applied to work for the company as a garbage truck driver based out of Springfield, Missouri. During the interview, company managers told the applicant that female drivers hadn’t worked out in the past. They went on to say she should carefully consider whether she wanted the position because the company would have to build a locker room with a shower for female drivers if she were hired.
The EEOC alleged that when the applicant followed up and said she wanted the job, the company rejected her application and hired a less-qualified male for the position.
The company didn’t have any female drivers at the time. The suit also alleged that since at least March 2020, the company routinely failed to hire qualified female applicants for driver positions because of their sex.
“When employers make hiring decisions based on sex, rather than qualifications, both the employer and the applicants suffer,” said Andrea G. Baran, regional attorney for the EEOC’s St. Louis District.
This alleged conduct violated Title VII of the Civil Rights Act of 1964, which prohibits sex discrimination in employment.
Where did this company go wrong?
The company had a history of not hiring female employees — a practice not looked kindly upon by the EEOC. The waste management company also made several key errors during the hiring process, such as:
- It assumed household gender roles by telling the female applicant to “talk to her husband” about her job possibility. That line of thinking is not only archaic; it violates Title VII by making sex-based assumptions.
- The managers implied that creating a shower space for her would be a burden to the company wreaks of discriminatory language. It basically says hiring a female would be a problem.
- Hiring a less-than-qualified male applicant made it implicit that she wasn’t hired because of her sex.
What should other employers do?
While it’s important to learn about a prospective employee, companies could face liability if they ask the wrong questions during an interview. Before conducting interviews, employers should have a script of safe questions. Asking the same questions of all candidates not only helps to compare them equally, it also minimizes the possibility of slipping up and saying something improper.
Interviewers can ask general questions to help determine if a candidate can perform the essential functions of a particular job, such as:
- What kind of job experience do you have?
- What aspects of your current job or previous jobs do you consider most crucial?
- Of all the work you’ve done, what have been your biggest successes?
- What would you change about your current job?
- What aspects do you like best about your current job? Least?
- What are you looking for in your next job?
Key to remember: Employers must dump off-limit topics, questions, and “trashy” comments during the interview process, or they could find themselves hauled into court.
Most Popular Highlights In Human Resources
NewsIndustry NewsIndustry NewsHR GeneralistFamily and Medical Leave Act (FMLA)Family and Medical Leave Act (FMLA)USAHR ManagementEnglishFocus AreaHuman Resources
2023-09-06T05:00:00Z
Appellate court sided with employee's (almost) 3-year-delayed FMLA claim
Back in October 2018, Laffon had a medical emergency and needed some time off under the federal Family and Medical Leave Act (FMLA).
Her leave lasted until November 15. Ten days after she returned to work, on November 26, her employer terminated her.
She sued, arguing that the employer retaliated against her because of her FMLA leave.
The catch? She didn't bring the suit until almost three years later.
No link between leave and termination
In court, the employer argued that there was no causal link between Laffon taking FMLA leave and her termination. Although the court documents aren't robust, they do reveal that the employer indicated that Laffon's allegations didn't show that her taking FMLA leave was a factor in the decision to terminate her. The documents showed only that the termination chronologically followed her leave.
The court agreed with the employer. It also agreed that Laffon failed to allege a willful violation of the FMLA, which would allow her to benefit from the FMLA's three-year statute of limitations.
Laffon appealed the case to the Ninth Circuit.
Statute of limitations
Under the FMLA, employees have two years from the date of the last event constituting the alleged violation for which they can bring a claim.
Those two years are extended to three years if the employer's actions were "willful." This means that an employee must show that the employer either knew or showed reckless disregard for whether its conduct violated the FMLA.
Ruling overturned
Fast forward to August 2023, when the Ninth Circuit reversed the lower court's decision. It indicated that, based on Laffon's amended complaint and liberally construing the law, her allegations establish that her leave was causally connected to her termination and that the employer's action (her termination) was willful.
Glymph v. CT Corporation Systems, No. 22-35735, Ninth Circuit Court of Appeals, August 22, 2023.
Key to remember: Terminating an employee soon after returning from FMLA leave is risky, unless there is a clear, well-documented, non-leave-related reason. Case documents did not show such a clear reason, which can also increase the risk of a willful finding. Employees have time to file claims, even years.
NewsHuman Resource ManagementHuman Resource ManagementEmployee RelationsFamily and Medical Leave Act (FMLA)In-Depth ArticleFamily and Medical Leave Act (FMLA)HR ManagementEnglishHuman ResourcesIndustry NewsEmployee RelationsHR GeneralistAssociate RelationsCommunication ToolsFocus AreaUSA
2026-05-12T05:00:00Z
What does your FMLA process look like?
Administering employee leave under the federal Family and Medical Leave Act (FMLA) basically involves a process that starts when an employee puts the employer on notice of the need for leave and (hopefully) ends when the employee returns to work.
Beyond the compliance requirements, employers can help make the FMLA process more or less challenging for employees and for themselves. If, for example, a process involves handing an employee 40 pages of FMLA-related documents without any explanation, it might be overwhelming for the employee and inefficient in the long run for the employer.
8 steps to help smooth out the FMLA process
Employers might look at their FMLA process and see if there’s room for improvement. Ideas can include the following:
- Walk through the process. Talk with the employee so they know what to expect and when. Have conversations and ask if the employee has any questions. It never hurts to ask, “What can we do to help?” or something to that effect along the way.
- Consider the factors of each situation. Employees who need leave are usually in a stressful situation, even if the reason for leave is happily welcoming a new child. They often aren’t familiar with the nuances of the FMLA, so it’s new territory for them. A bit of empathy goes a long way.
- Follow through. Provide employees with answers to any questions or glitches in the process. While employees might have 15 days to gather a certification, for example, meeting that deadline can be challenging in some situations. If it’s missed, talk to the employees so they understand why.
- Provide gentle reminders. While it’s not technically required, if deadlines are coming up, gently remind employees.
- Use technology to your advantage. If your system enables employees to access the process and its parts from their mobile device, all the better; if that’s how an employee would prefer to proceed, great!
- Overcommunicate rather than under-communicate. It’s better to say more than less when it comes to explaining how the FMLA process works and what’s expected. Ask employees which method they prefer to receive information. If, for example, you prefer to make phone calls, but an employee seldom accepts phone calls, both you and the employee can be frustrated.
- Have templates for letters and forms. Using templates makes it easier to recognize and review information or explain something to the employee. This can also help ensure you treat all similarly situated employees equivalently.
- Document the process. Write down the FMLA process and share it with managers, at least at a high level. Managers don’t need to become FMLA experts, but they might not realize all that’s involved in the FMLA process, and things might get a little easier once they understand. Employees can benefit from such a document, as well.
Because FMLA leave is very personal, employees who have a bad leave experience might consider changing employers or sharing their experience with coworkers, making recruiting and retention more challenging.
Key to remember: Taking a few steps beyond compliance in FMLA leave management can help make the process easier for both employers and employees.
NewsIndustry NewsAssociate RelationsHR GeneralistFamily and Medical Leave Act (FMLA)In-Depth ArticleFamily and Medical Leave Act (FMLA)HR ManagementEnglishUSAFocus AreaHuman Resources
2026-05-14T05:00:00Z
How much FMLA leave do employees get when they go from full- to part-time work?
Eligible employees get 12 of their workweeks of job-protected unpaid leave in a 12-month leave year under the federal Family and Medical Leave Act (FMLA). When employees take that leave intermittently or on a reduced schedule, employers like to look at the 12 weeks as 480 hours. This is fine as long as the employee works 40 hours per week.
If employees switch from full-time to part-time work, employers might wonder how that affects the 480 hours of FMLA leave.
The change details are key
How much FMLA leave employees get when their schedule changes will depend on:
- Who made the change,
- Why they made the change, and
- When they made the change.
If, for example, an employee normally worked 40 hours per week, but is now moving to a 24-hour per week schedule, that change would result in the employee having 288 hours of FMLA leave, not 480 hours. The employee still gets 12 FMLA weeks, though.
The FMLA regulations say that, if the employer has made a permanent or long-term change in the employee's schedule (for reasons other than FMLA, and before the notice of need for FMLA leave), the hours worked under the new schedule are to be used for making this calculation.
Therefore, if all of the following are met, the employer could use the new, 24-hour workweek (288 hours of leave) as a basis for how much FMLA leave the employee gets:
- The employer made the change to shorten the employee’s schedule,
- The decision had nothing to do with FMLA leave, and
- The change was made before the employee needed FMLA leave.
If, however, the schedule change was because of FMLA leave, and it was made after the employee began taking FMLA leave, the employer must use the old schedule of 480 hours of FMLA leave.
Employers and employees might agree to make a schedule change, and that would be fine, as long as the employer ends up making the employee’s desired change.
If an employee has been taking FMLA leave and subsequently wants a shorter schedule, the employer may not decrease the employee’s hours of FMLA leave. The employer would need to use the old schedule.
New leave year reset
When a new 12-month leave year begins, and an employee first puts the employer on notice of the need for leave, the employer would treat it as a new leave request. At that time, one could argue that the schedule change was made before the employee asked for leave.
Key to remember: Whether employers may reduce the amount of FMLA leave employees get when they reduce their schedules will depend on who made the change, why, and when.
NewsIndustry NewsAssociate Benefits & CompensationHR GeneralistFamily and Medical Leave Act (FMLA)In-Depth ArticleFamily and Medical Leave Act (FMLA)Associate RelationsEnglishHR ManagementFocus AreaHuman ResourcesUSA
2025-03-27T05:00:00Z
Who can fill out FMLA forms? The answer might surprise you
One of the most common questions involving the federal Family and Medical Leave Act (FMLA) that we see is: “Can ________ fill out the medical certification?”
This question stumps a lot of HR people and can be a little confusing.
It might be easier to start with who CAN’T fill out an FMLA certification. That includes your coworker, best friend, neighbor, or pet.
Jokes aside, often (but not always) a doctor fills out the FMLA certification, and since March 30 is “Doctors’ Day,” this is a great time to discuss this topic.
FMLA certification basics
Employers aren’t required to use certifications, but if they do, the U.S. Department of Labor (DOL) has five different certification forms to use for various FMLA leave situations.
The forms are as follows:
- Certification of Health Care Provider for Employee's Serious Health Condition,
- Certification of Health Care Provider for Family Member's Serious Health Condition,
- Certification of Qualifying Exigency for Military Family Leave,
- Certification for Serious Injury or Illness of a Current Servicemember for Military Family Leave, and
- Certification for Serious Injury or Illness of a Veteran for Military Family Leave.
Let’s focus on the first two, as these are the most common ones HR administrators use.
Who can fill out an FMLA certification?
The FMLA regulations describe the person who has the authority to fill out a certification as a “health care provider.” The good news is, the regulations include a lengthy list of medical professionals who fit this role.
Under the FMLA, a health care provider includes:
- A doctor of medicine or osteopathy,
- A podiatrist,
- A dentist,
- A clinical psychologist,
- An optometrist,
- A chiropractor (limited to manual manipulation of the spine as demonstrated by X-ray),
- A nurse practitioner,
- A nurse midwife,
- A clinical social worker,
- A physician assistant,
- A Christian Science practitioner, and
- Any health care provider from whom the employer or the employer's group health plan's benefits manager will accept a medical certification to substantiate a claim for benefits.
To be qualified to fill out FMLA forms, medical professionals must be authorized to practice in the state and perform within the scope of their practice. This means that the provider must be authorized to diagnose and treat physical or mental health conditions.
What about doctors in a foreign country?
If an employee or an employee's family member is visiting another country, or a family member resides in another country, and a serious health condition develops, the employer must accept a medical certification from a health care provider who practices in that country. This includes second and third opinions.
If a medical certification from a foreign health care provider is not in English, the employee may be required to provide a written translation of the certification.
Key to remember: The FMLA regulations spell out which medical professionals can fill out certification forms.
NewsHuman Resource ManagementHuman Resource ManagementUSAHR ManagementEnglishAssociate Benefits & CompensationDiscriminationIndustry NewsDiscriminationIndustry NewsHR PoliciesAudits - HRGovernment contractsHR GeneralistEEO-1 ReportingAssociate RelationsFocus AreaHuman Resources
2026-05-19T05:00:00Z
Future of EEO reporting uncertain
On May 14, the Equal Employment Opportunity Commission (EEOC) submitted a proposal to rescind Equal Employment Opportunity (EEO) workforce data filing and reporting requirements.
The rule, titled “Recission of EEO-1, EEO-2, EEO-3, EEO-4, EEO-5, And Reporting Requirements Under Title VII, the ADA, GINA, and the PWFA,” is a proposal at this time. Employers should be aware that it doesn’t have an immediate impact on existing data collection or reporting processes.
Reporting requirements
The EEO-1 Component Data Collection (Employer Information Report) requires private employers with 100 or more employees and federal contractors with 50 or more employees that meet certain criteria to report employees’ race/ethnicity, sex, and job category. EEO-2 is a consolidated report for certain multi-establishment employers.
Other EEOC data collections are as follows:
Local referral unions with 100 or more members (EEO-3);
State and local governments with 100 or more employees (EEO-4); and
Public elementary and secondary school systems, and school districts with 100 or more employees (EEO-5).
The EEOC’s proposal raises questions about the future of EEO reporting. Since 1966, aggregated data supplied by these reports have provided worker population data as well as trend data used to interpret the effectiveness of anti-discrimination laws and their enforcement.
The proposal to rescind these reporting requirements was submitted to the Office of Information and Regulatory Affairs and must undergo procedural review before a final rule can be published in the Federal Register, with a comment period to follow. Thus, the proposal is far from being finalized. In the meantime, the EEOC hasn’t yet announced the 2026 filing deadline and notes that it will publish updates to the 2025 EEO-1 Component 1 data collection on its website when they become available.
Employer action items
Until decisions are finalized, employers should:
- Continue collecting workforce demographic data,
- Follow the rulemaking process,
- Watch for the 2026 filing deadline, and
- Plan for continued local reporting requirements.
Key to remember: Although a proposal to rescind requirements has been submitted, employers should continue collecting workforce demographic data and plan to report 2025 data by the 2026 reporting deadline when it’s announced.
NewsIndustry NewsEnglishHR GeneralistIn-Depth ArticleEmployee Mental HealthAssociate RelationsWellnessWellnessHR ManagementFocus AreaUSAHuman Resources
2026-05-15T05:00:00Z
Laughter beats LOL: Face-to-face communication brings mental health benefits
Employees may not be excited about commuting to work, but may be heartened to know that there are mental health benefits to gathering with others in the workplace.
Video calls, texting, and other communication technology make it easy to “socialize alone,” or connect with others when you’re by yourself. While this is better than nothing, it doesn’t measure up to meeting face-to-face.
Research published recently in Perspective on Psychological Science looked at more than 1,000 communication studies and found that when people communicate over technology, they:
- Are less engaged, and
- Don’t have the same positive emotional responses.
“Electronic communication is here to stay, so we need to learn how to integrate it into our lives,” Roy Baumeister, professor of psychology at the University of Queensland and the study’s lead author, noted in a news release. “But if it replaces live interactions, you’re going to be missing some important benefits and probably be less fulfilled.”
The researchers couldn’t find health benefits to typing “LOL” into a text, Baumeister pointed out, while they found a lot of research pointing to the benefits of laughing out loud.
Mental health boost
Another study that looked at communication during the COVID-19 pandemic, published in the journal Nature, found that mental health was better on days when more time was spent communicating face-to-face.
This could be because in-person communication provides the opportunity to take in the nuances of body language, voice pitch, and eye gaze.
While videoconferencing also offers the opportunity to see those cues, researchers found it can be taxing because of prolonged eye contact, a focus on appearance, and larger faces due to screen size.
An impact on learning
Another drawback to socializing alone is that information isn’t processed as thoroughly as it is in face-to-face situations, Baumeister’s study found. This may make an impact on decision-making and learning in online groups.
In addition, although shy people may prefer typing their comments into a chat, some people may be more likely to say something harmful when communicating online.
Motivation, participation help
The study found two qualities that improve the impact of online communication:
- Motivation to be engaged and
- Full participation with each other.
For example, researchers found high levels of engagement in workers who were highly committed, as well as people in online psychotherapy sessions and people who were romantically involved.
While technology offers more opportunities for interaction, and can be an effective way to communicate when people are highly motivated to meet, it often lacks the benefits of being physically present with the people you’re talking to.
“Humans were shaped by evolution to be highly social,” Bushman added. “But many of the benefits of social interactions are lost or reduced when you interact with people who are not present with you.”
Key to remember: Face-to-face interactions at work support engagement and boost mental health.
Most Popular Highlights In Safety & Health
NewsIn-Depth ArticleEnglishHeat StressIndustry NewsHeat and Cold ExposureSafety & HealthConstruction SafetyGeneral Industry SafetyAgriculture SafetyMaritime SafetyExtreme Temperature PreparationHeat and Cold ExposureMine SafetyFocus AreaUSA
2026-05-13T05:00:00Z
How does wet-bulb globe temperature work?
As you prepare for heat injury and illness prevention regulations, are you leaning toward Heat Index simply because you don’t understand WetBulb Globe Temperature (WBGT)? Don’t sweat it! We will cool your anxiety as you read on.
What is WBGT?
Developed by the US military in the 1950s to prevent heat-related deaths in training camps, WBGT is a measure of the heat stress in direct sunlight. It takes into account more than just temperature, including considerations for humidity, wind speed, cloud cover, and even sun angle.
The Heat Index, on the other hand, considers only temperature and humidity for shady areas. So, if employees are working in direct sunlight, the WBGT may be the better way to monitor.
How does WBGT work?
WBGT calculates three key measurements into one equation:
- Air temperature – measured with a standard outdoor thermometer to show the actual temperature of the air. This gives a baseline for how hot the environment is without the effects of humidity, wind, or radiant heat (sunlight).
- Natural wet bulb temperature – measured using a thermometer wrapped in a wet cloth to simulate the cooling effect of evaporating sweat. Readings can be strongly influenced by wind and humidity, and because the thermometer is exposed to sunlight, it also reflects solar heat.
- Black globe temperature – measured with a thermometer inside a black globe to represent how hot human skin and clothing “feels” in direct sunlight. Readings are of radiant heat that air temperature alone wouldn’t capture.
In layman’s terms, as the water evaporates from the wet, wrapped bulb, the bulb is cooled which pushes the wet-bulb temperature down. Added air moisture (humidity) means less water evaporates and cooling is not as effective. This means the WBGT is high.
Mathematically, here’s how the measurements are used to calculate WBGT:
WBGT = (10% × Air Temp) + (70% × Wet Bulb Temp) + (20% × Black Globe Temp)
For a simplified example, if the air temperature is measured at 80°F, the relative humidity is 80%, and the globe temperature is 80°F, the WBGT would be calculated as follows:
WBGT= (0.1 × 80) + (0.7 × 80) + (0.2 × 80)
= 8 + 56 + 16
= 80°F
This result is a WBGT of 80°F which is a relatively high level of heat stress.
To put this into perspective, studies show that a WBGT of around 87.5°F is nearing the maximum temperature that a healthy worker can handle. Though the number seems palatable, this level of heat with humidity can be stifling and deadly.
OSHA’s proposed Heat Rule update
OSHA held an informal public hearing over multiple days in June and July 2025, concluding on July 2nd. A final ruling has not yet been published to the Federal Register. OSHA’s Rulemaking Process can take between 24 and 60 months to review feedback, analyze the record, and develop a final rule.
In the meantime, employers should comply with their State plan state requirements or OSHA’s National Emphasis Program (NEP) on Outdoor and Indoor Heat-Related Hazards. The federal NEP was recently revised and became effective April 10, 2026, with updates including the removal of outdated background information, reorganization of appendices information and citation guidance, and the addition of inspection triggers.
Key to remember: The weighted approach of WBGT factors in temperature, direct sunlight, humidity, wind, and cloud cover, all of which have an impact on the body’s ability to cool itself.
NewsIndustry NewsSafety & HealthConstruction SafetyGeneral Industry SafetyAgriculture SafetyMaritime SafetyIn-Depth ArticleHazard CommunicationHazCom Written ProgramEnglishFocus AreaUSA
2026-05-06T05:00:00Z
Got chemicals? You may need a written HazCom program
What triggers the need for a written Hazard Communication (HazCom) program? The answer to this popular Expert Help question depends on certain requirements, definitions, and exceptions within the standard at 29 CFR 1910.1200. Simply put, if all four of the following statements apply, you must develop, implement, and maintain a written HazCom program at each workplace:
- Your organization is an employer. OSHA defines “employer” at 1910.1200(c) as “a person engaged in a business where chemicals are either used, distributed, or are produced for use or distribution, including a contractor or subcontractor.”
- The HazCom standard applies. If you’re an employer, the standard applies if you have any hazardous chemical that’s known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency. “Hazardous chemical” means any chemical which is classified as a physical or health hazard, simple asphyxiant, combustible dust, or hazard not otherwise classified (HNOC).
- At least one area/operation of the workplace where hazardous chemicals are present is covered by 1910.1200 and not simply exempted under paragraph (b)(3) or (b)(4). According to these paragraphs, OSHA does not require a written HazCom program to be developed for:
- Laboratories [Note: See our Lab applicability FAQ for details on when a laboratory is covered by 1910.1450 or 1910.1200.], or
- Work operations where employees only handle chemicals in sealed containers that are not opened under normal conditions of use, such as those found in marine cargo handling, warehousing, or retail sales.
It should be noted, however, that these operations do have other obligations under the HazCom standard, outlined at 1910.1200(b)(3) and (b)(4).
- At least one hazardous chemical in the workplace is covered by the standard and is not exempted under 1910.1200(b)(6). (Paragraph (b)(6) exempts certain substances from coverage by the HazCom standard.)
What information must the written program include?
Paragraph (e) of 1910.1200 outlines written program requirements. Although the program doesn’t need to be lengthy or complicated, it must include enough detail to explain how your organization is complying with the HazCom standard. There are specific elements OSHA will look for to ensure compliance:
- A list of the hazardous chemicals known to be present in the workplace that matches the identifier on the container label and the safety data sheet (SDS).
- The designation of person(s) responsible for ensuring labeling of in-house containers and the person(s) responsible for ensuring labeling of shipped containers (if any).
- A description of any in-house labeling system(s) and any labeling alternatives used in the facility (if applicable).
- A description of HazCom training provided to employees.
- Procedures to review and update label information when necessary.
- Methods used to inform employees of the hazards of non-routine tasks, such as cleaning reactor vessels, and the hazards of unlabeled pipes in their work areas.
- An explanation of how the employer will comply on multi-employer worksites. Employers on multi-employer worksites who do not use hazardous chemicals, but whose employees are exposed to the chemicals used by other employers on the worksite, are required to have a program and train their employees on the hazards of the chemicals in the work areas.
Key to remember: If you’re covered by the HazCom standard, you may need a written program. It must include specific elements listed in 1910.1200(e).
NewsIndustry NewsSafety & HealthGeneral Industry SafetyMachine GuardingIn-Depth ArticleEnglishMachine GuardingFocus AreaUSA
2026-05-18T05:00:00Z
Addressing machine hazards: Common questions answered
When workers operate or work around machinery, employers are often faced with practical safety questions that aren’t directly addressed in OSHA’s regulations. Common issues such as loose clothing, long hair, guard openings, and control devices like foot pedals are not always covered by the regulatory text. The following questions and answers clarify what OSHA requires when protecting workers from common machine-related hazards.
Can we prohibit loose clothing, long hair, or jewelry for workers operating machinery?
OSHA doesn’t specifically address this in its machine guarding regulation (29 CFR 1910.212). However, agency guidance clearly recognizes these items as hazards around moving machinery:
- Safeguarding Equipment and Protecting Workers from Amputations (OSHA 3170) advises employers to instruct workers not to wear gloves, jewelry, or loose-fitting clothing when operating grinding machines and to secure long hair.
- OSHA’s woodworking eTool similarly states, “Do not allow workers to wear loose clothing or long hair. Loose clothing or long hair can be easily caught up in rotating parts.”
Employers are expected to address recognized hazards in their workplace. As a result, many employers adopt policies restricting loose clothing, long hair, or jewelry when working near machinery. OSHA may issue citations under the General Duty Clause (Section 5(a)(1) of the OSH Act) or the machine guarding standard if workers are exposed to entanglement hazards.
Is there a maximum opening size before a machine guard is required?
OSHA’s machine guarding standard doesn’t specify a maximum opening size before a guard is required. Instead, it requires that the guard be “in conformity with any appropriate standards” and designed and constructed to prevent operators from having any part of their body in the danger zone during the operating cycle.
OSHA refers to the following “appropriate standards”:
- ANSI B11.0, Safety of Machinery
- ANSI B11.19, Performance Requirements for Risk Reduction Measures: Safeguarding and other Means of Reducing Risk
- NFPA 79, Electrical Standards for Industrial Machinery
Additionally, there are several machine-specific ANSI B11 series standards, all of which can be viewed here. These standards provide detailed guidance on guard openings, reach distances, and risk reduction methods.
Must foot pedals used to operate machinery be guarded or have a cover?
If unintentionally pressing on a foot pedal exposes workers to a hazard, OSHA expects employers to implement protective measures, such as guarding or covering the pedal. Although there are no foot pedal requirements in OSHA’s machine guarding standard, its Mechanical Power Presses standard (29 CFR 1910.217) offers some, such as:
- The pedal must be protected against accidental operation (e.g., from falling objects or unintended contact).
- The pedal must have a nonslip contact surface.
- Return springs must be designed to prevent failure.
- Counterweights must have enclosed travel paths.
Key to remember: Even in situations where OSHA does not provide detailed regulatory requirements, recognized hazards like entanglement or unintended machine activation must still be controlled.
NewsDrug and Alcohol TestingDrug and alcohol policy - Motor CarrierDrug and Alcohol TestingDrug and Alcohol Testing - DOTDrug testing - Motor CarrierDrug and alcohol training - Motor CarrierIn-Depth ArticleUSAHR ManagementEnglishIndustry NewsFleet SafetySafety & HealthGeneral Industry SafetyFocus AreaPre-employment drug testing - Motor CarrierSafety-sensitive function - Motor CarrierTransportationHuman Resources
2023-09-28T05:00:00Z
Canada’s drug testing rules will leave you in a haze
Ever since Canada legalized recreational cannabis back in 2018, it has left many motor carriers wondering if they can drug test their drivers. Impairment from cannabis use is a safety risk, and for most employers, performing drug tests to manage the risk is not an option. Where do motor carriers and drivers fit in, and what are their options?
Submitting employees to drug tests
Can motor carriers drug test their drivers? The short answer is no. Canada does not have a federal regulation that requires drug testing for drivers. However, this does not mean that Canadian motor carriers cannot implement and enforce a drug and alcohol policy for their drivers. In fact, many carriers have developed successful policies that minimize the risk of getting in trouble with the law and ensure the safety of their drivers and the public.
For the most part, drug testing not only violates the Human Rights Code, but it is also a gross infringement on an individual’s reasonable right to protection of privacy. Motor carriers operating in Canada need to make sure they consider the human rights and privacy rights of their drivers when implementing any type of drug testing program and policy.
Motor carriers have the right to expect their drivers to arrive at work fit for duty and remain that way throughout the duration of their shift. Communicating this expectation to them is important and, at a minimum, should be communicated by implementing a ”fit-for-work” policy that makes your expectations around impairment of any kind clear.
When drug testing may be permissible
There are some circumstances in which drug testing is allowed, though they are rare and very specific.
1. Safety-sensitive positions: Universal random drug testing would be acceptable in workplaces that can be shown to be extremely dangerous and where a worker’s impairment would likely result in catastrophe. Based on this definition commercial truck drivers would be considered to be in a safety-sensitive position.
2. Reasonable suspicion of impairment: If an employee appears to be obviously impaired, drug testing may be permissible, especially if they’re involved in a collision and there is reasonable suspicion that they are under the influence of drugs.
3. As part of a rehabilitation/return-to-work program: A driver with substance abuse disorder may be subject to unannounced drug testing to be carried out as part of a rehabilitation program and return-to-work program.
Unlike in the United States, pre-employment drug testing is generally not permitted in Canada, except in limited circumstances. Each Canadian province has its own legislation regarding testing for drugs. In Alberta, the courts have been less protective of individual privacy rights and have allowed drug testing in the oil and gas sector. Most companies in Ontario and British Columbia opt not to test for drugs, adhering to human rights legislation and privacy concerns.
Policies must be clear
Motor carriers must inform their drivers about the drug and alcohol policy and unlike U.S. testing programs, are required to obtain their consent before conducting any test. By working together, motor carriers and drivers can create a safe and healthy work environment for everyone involved.
Carriers should update their policies addressing drug and alcohol use at least once per year. Carriers must pay close attention to:
- Permissible testing for the jurisdictions they operate in, including if they cross the border into the United States;
- Frequent reminders for drivers on their obligations under the policies; and
- Training for managers and supervisors on detecting impairment through physical symptoms.
Key to remember: Drug testing in Canada is legal but not regulated, so carriers must exercise caution when implementing a drug testing policy. There’s a fine line between allowable testing and human rights/employee privacy violations.
NewsSafety Data SheetsIndustry NewsIndustry NewsEnglishHazard ClassificationsSafety & HealthGeneral Industry SafetyOccupational Safety and Health Administration (OSHA), DOLHazard CommunicationHazard CommunicationHazcom LabelingFocus AreaUSA
2026-05-12T05:00:00Z
First HazCom compliance date almost here!
OSHA’s revised Hazard Communication (HazCom) standard, which took effect in July 2024, includes staggered compliance dates stretching into 2028. The first of these is just around the corner. By May 19, 2026, chemical manufacturers, importers, and distributors evaluating substances must be in compliance with all modified provisions of the standard. (“Substance” is defined in 1910.1200(c).) This means manufacturers and importers must reclassify aerosols, desensitized explosives, and flammable gases under the new criteria in Appendix B to 1910.1200 and make corresponding changes to safety data sheets (SDSs) and labels.
Additionally, these manufacturers, importers, and distributors must comply with changes to the following elements, as applicable:
- Labels for packages released for shipment, bulk shipments, and small containers;
- SDS subsections; and
- Trade secrets.
Downstream users of substances that are aerosols, desensitized explosives, or flammable gases will start to see updated SDSs and labels on shipped containers of hazardous chemicals (if they haven’t already). For more information, see our related FAQ.
NewsMine SafetyForklifts and Powered TrucksTraining & DevelopmentOccupational Safety and Health Administration (OSHA), DOLPIT Training RequirementsIn-Depth ArticleUSAEnglishIndustry NewsSafety & HealthForklifts and Powered TrucksConstruction SafetyGeneral Industry SafetyAgriculture SafetyMaritime SafetySafe Operation of PITsFocus AreaHuman Resources
2023-07-06T05:00:00Z
Commonly asked questions about forklift licensure and certification
Are your forklift operators certified? Do they need a state driver’s license? Are they physically able to operate forklifts? All are commonly asked questions — so, let’s make sure you're compliant.
The intent of the standard
OSHA’s powered industrial truck (PIT) standard (29 CFR 1910.178) is intended to ensure the safe use of fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines. The standard outlines requirements for operational permits and certification.
And, though not specified in the standard itself, PIT operators must be at least 18 years old per federal child labor regulations.
License and certification Q&A
The OSHA PIT standard clearly defines requirements for training and certification. However, some licensing and certification information isn’t as clear. Here are some clarifications:
Q: Who can train, evaluate, and certify PIT operators?
A: OSHA requires in 1910.178(l)(2)(iii) that, “All operator training and evaluation shall be conducted by persons who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence.” The OSHA standard doesn’t further define this requirement or set any specific or additional certifications.
Q: Does OSHA require PIT operators to have a valid driver's license?
A: Federal OSHA has no requirement that a forklift operator has a valid motor vehicle driver's license. Some states are more stringent, so check your local and state requirements to confirm.
Q: Does OSHA have regulations that impact an employee’s ability to operate PITs if they’ve received a DUI or suspended license?
A: Because OSHA doesn't require a valid motor vehicle driver's license, the status of that license doesn’t impact PIT operator permitting. Individual states or the employer may have policies that dictate otherwise.
Q: Are PIT drivers required to have their license on them when they are working?
A: Federal OSHA doesn’t require PIT operators to have a license or permit. However, some states such as Michigan do require this. Typically, in states that require a permit or license, the license must be “readily available.” Companies have the option to require the permit or license be carried with the operator.
Q: Are operators required to be trained on each manufacture of PIT model?
A: A June 15, 1999, OSHA letter of interpretation (LOI) clarifies that operators are to be trained and evaluated in the safe operation for the type of truck they’ll be assigned. Operators wouldn’t need additional training for same truck types but would need additional training when truck- or workplace-related training topics are different.
Q: Do PIT operators need to be recertified if they move from one state to another with the same company?
A: In an LOI dated October 1, 1999, OSHA states, "As long as the employer has a reasonable basis to believe that the third-party trainer is qualified and has a program that meets the requirements of the standard, it can rely on that trainer to conduct the training and evaluation of employees and can certify that these employees have been trained. However, the employer may need to provide additional training on site-specific or truck-specific matters." This shouldn’t require retraining for the same type of forklift as already certified; however, workplace conditions or other factors of the new work location may require training for forklift operation in the other state(s).
| Interested in information on how material handler training can help forklift operators? See our Compliance Network article "To improve forklift safety, train material handlers." |
Operator Impairments
In addition to being properly trained and evaluated, OSHA expects employers to ensure physical capabilities. OSHA references the American National Standards Institute (ANSI) Standard B56.1-1969. Section 6 clarifies that, “Operators of powered industrial trucks shall be physically qualified. An examination should be made on an annual basis and include such things as field of vision, hearing, depth perception, and reaction timing."
Employers should consider OSHA PIT regulations and the General Duty Clause, ANSI standards, and the Americans with Disabilities Act (ADA) requirements when evaluating physical qualifications. In short, if a worker demonstrates the visual, auditory, and mental ability to safely operate PITs, he or she is permitted to operate them.
Keys to Remember
OSHA requires employers ensure the safe use of forklifts and other powered industrial vehicles. Employers must ensure operators have the knowledge, skills, and physical ability to safely operate PITs.
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