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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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DOT modes & testing: Different inputs, same result

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Most Recent Highlights In Environmental
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EHS Monthly Round Up - August 2026
In this August 2026 monthly roundup video, we'll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
Citing elevated injury and illness rates, OSHA relaunched a National Emphasis Program, or NEP, on Warehousing and Distribution Center Operations. Retail operations are no longer targeted by this NEP, as they were previously. Inspectors will focus on common hazards in warehousing and distribution such as powered industrial vehicle operations, materials handling and storage, and fire protection. The NEP also offers OSHA greater discretion in whether to expand an inspection.
OSHA state-plan enforcement continued to gain momentum in fiscal year 2025. In an upward trend, inspection numbers, violation counts, and penalty amounts all increased. The latest data stem from the Occupational Safety and Health Plan Association’s Grassroots Worker Protection report.
OSHA’s Safe+Sound Week was held August 10 through the 16. The event gave employers an opportunity to highlight their safety and health programs and bring attention to common workplace hazards.
The Mine Safety and Health Administration reopened the comment period for proposed changes to the approval criteria for its mine roof control and ventilation plans. The new deadline for comments is September 30.
Turning to environmental news, EPA extended the compliance dates of certain Workplace Chemical Protection Program requirements for perchloroethylene and carbon tetrachloride. The revised deadlines affect facilities subject to the TSCA PCE and CTC risk management rules finalized in 2024.
And finally, EPA published a proposed 2027 general stormwater permit for construction. It applies to construction activities in areas where EPA is the NPDES permitting authority, including Massachusetts, New Hampshire, New Mexico, and the District of Columbia. If finalized, the rule will replace the existing 2022 permit, which expires in early 2027.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
NewsIndustry NewsIndustry NewsAir EmissionsEnvironmental Protection Agency (EPA)Renewable and Alternative EnergyBiofuelCAA ComplianceEnvironmentalFocus AreaEnglishAir ProgramsAir ProgramsUSA
2026-09-03T05:00:00Z
EPA extends RFS annual compliance report deadline
The Environmental Protection Agency (EPA) issued a final rule extending the Renewable Fuel Standard (RFS) annual compliance reporting deadline for the 2025 compliance year from September 1 to October 1, 2026.
Who’s impacted?
The RFS annual compliance report applies to obligated parties, including:
- Refiners of gasoline or diesel fuel (transportation fuel), and
- Importers of transportation fuel.
Under the RFS program, obligated parties with renewable volume obligations (RVOs) must retire enough Renewable Identification Numbers (RINs) to meet their RVOs for the calendar year.
What’s the change?
EPA extended the 2025 RFS compliance reporting deadline to October 1, 2026, giving obligated parties additional time to comply with their 2025 RVOs and submit their annual compliance reports.
Why the change?
EPA recently released its small refinery exemption (SRE) decisions for the 2025 compliance year, exempting 1.76 billion RINs for 29 small refineries. SREs affect the cost and availability of RINs for all obligated parties. The extension gives obligated parties more time to assess the impact of the SRE decisions and adjust their strategies before completing their 2025 RFS reporting obligations.
Key to remember: EPA has extended the Renewable Fuel Standard annual compliance reporting deadline from September 1 to October 1, 2026.
NewsEnvironmental Management SystemsEMS PlanningCAA ComplianceEnvironmental Management SystemsIn-Depth ArticleCWA ComplianceWaste/HazWasteEnglishIndustry NewsEMS GoalsEMS Audits and EvaluationsEnvironmentalFocus AreaUSA
2026-09-01T05:00:00Z
10 operational changes that should trigger an environmental compliance review
Environmental compliance issues often arise not because regulations change, but because operations change.
A facility may replace equipment, begin using a new chemical, increase production, or modify a process for legitimate business reasons. However, even routine operational changes can affect permits, reporting obligations, waste generation, emissions, wastewater discharges, or stormwater exposure.
Organizations that review environmental impacts before implementing changes are better positioned to identify compliance obligations early and avoid costly surprises.
What's an environmental compliance review?
An environmental compliance review is a structured evaluation of how a proposed change could affect a facility's environmental obligations.
Many organizations incorporate environmental reviews into an environmental management system (EMS) or formal change-management process. These procedures help ensure that environmental obligations are evaluated before operational changes are implemented. The updated ISO 14001 standard places greater emphasis on managing changes that may affect environmental performance, reinforcing the need to assess environmental impacts before decisions are made.
The review doesn't need to be complicated. In many cases, it involves determining whether the change could affect air permits, wastewater discharges, stormwater permits, hazardous waste management, chemical reporting, spill prevention requirements, or other environmental programs.
The goal is to identify environmental impacts before a change is implemented rather than after a regulator, auditor, or inspector discovers a problem.
Production increases
Increasing production is often viewed as a business decision rather than an environmental one. However, greater production may increase air emissions, wastewater generation, chemical usage, and waste generation.
Facilities should evaluate whether higher throughput could affect permit limits, reporting thresholds, or compliance obligations before production levels increase.
New chemicals or raw materials
A new chemical can trigger a wide range of environmental requirements.
Changes in raw materials may affect hazardous waste determinations, emergency planning requirements, air emissions calculations, Toxics Release Inventory reporting, spill prevention planning, or wastewater characteristics.
Before purchasing or introducing a new chemical, facilities should evaluate its environmental implications and ensure required controls are in place.
Equipment replacements and upgrades
Many organizations assume replacing equipment is simply a maintenance activity. In reality, equipment changes can have environmental consequences.
Replacing a boiler, coating operation, storage tank, dust collector, scrubber, or process equipment may affect emissions, waste streams, monitoring requirements, or permit applicability. Even when equipment serves the same function, environmental impacts should be evaluated before installation.
Process modifications
Changing how a product is manufactured can create environmental consequences even when production levels stay the same.
New process steps, altered operating conditions, different fuels, or modified treatment systems can affect emissions, waste generation, water usage, and permit conditions. Process changes should be reviewed to determine whether existing permits and operating procedures remain appropriate.
Facility expansions
Building additions, new production lines, warehouse expansions, and site development projects often involve environmental considerations beyond construction activities.
Organizations should evaluate potential impacts on air permits, stormwater management, wastewater infrastructure, storage capacity, and environmental monitoring programs before expansion projects begin.
Changes in waste management practices
Facilities occasionally change waste vendors, storage practices, recycling programs, treatment methods, or waste handling procedures to improve efficiency or reduce costs.
While these changes may appear administrative, they can affect generator status, accumulation practices, recordkeeping obligations, and waste determinations. Environmental personnel should review proposed changes before implementation.
New products or services
New products often require new materials, equipment, or processes that may affect existing environmental obligations.
Contractor activities
Contractor activities involving chemicals, waste management, tank cleaning, painting, excavation, demolition, or maintenance may create environmental compliance implications that warrant review.
Property and infrastructure changes
Changes to storage areas, containment systems, drainage patterns, tanks, or utilities can affect stormwater exposure and other environmental obligations.
Acquisitions and ownership changes
Acquiring a facility or business can introduce new permits, reporting obligations, and compliance responsibilities that should be evaluated during due diligence.
Train employees to recognize when a review may be needed
Environmental departments cannot review changes they never hear about.
Engineering, maintenance, operations, purchasing, project management, and production personnel are often the first to learn about proposed changes. Providing basic awareness training can help these groups recognize situations that may have environmental implications.
Employees don't need to become environmental experts. Instead, they should know when to notify EHS and ask whether a compliance review is warranted. A simple "check with EHS before proceeding" expectation can prevent significant compliance problems and reduce the likelihood that environmental requirements will be discovered too late.
Key to remember: Many environmental compliance issues begin with an operational change. Establishing a process to identify and review changes before implementation can help organizations avoid permit problems, reporting errors, and unexpected regulatory obligations.
NewsIndustry NewsWater ProgramsWater QualityEnvironmental Protection Agency (EPA)Industrial WastewaterEnvironmentalIn-Depth ArticleCWA ComplianceEnglishFocus AreaUSA
2026-08-26T05:00:00Z
National wastewater pretreatment program: What type of industrial user is your facility?
Before the wastewater can flow from your facility into a municipal treatment plant, there’s something you need to know: What type of industrial user is your facility? The answer to this question determines the federal environmental regulations your facility must meet.
The Environmental Protection Agency (EPA) regulates wastewater discharges from industrial and commercial facilities to publicly owned treatment works (POTWs) through the National Pretreatment Program. These facilities, known as industrial users (IUs), must obtain a permit or other control mechanism to send wastewater to a POTW. However, IUs must comply with all applicable federal, state, and local pretreatment requirements, regardless of whether the facility has been issued a permit or other control mechanism.
The National Pretreatment Program applies to:
- Industrial users (IUs),
- Significant IUs (SIUs), and
- Categorical IUs (CIUs).
EPA’s regulations at 40 CFR Part 403 contain compliance requirements for all IUs as well as additional requirements for SIUs and CIUs. To know which regulations to comply with, you must identify the types of IUs that apply to your facility.
Is my facility an IU?
The first type of user is the easiest determination to make. If your industrial or commercial facility discharges wastewater to a POTW, it’s an IU.
Is my facility an SIU?
If your facility can answer “yes” to any of these four questions, it qualifies as an SIU:
- Is the facility subject to the categorical pretreatment standards under 403.6 and Subchapter N?
- Does the facility discharge an average of at least 25,000 gallons daily of process wastewater to the POTW (not including sanitary, noncontact cooling, and boiler blowdown wastewater)?
- Does the facility contribute a process waste stream that makes up at least 5 percent of the POTW’s average dry weather hydraulic or organic capacity?
- Is your facility designated as an SIU by the control authority (i.e., the POTW, state, or EPA)?
Even if the first three criteria don’t apply, the control authority may designate your facility as an SIU if it determines that there’s a reasonable potential for your facility’s wastewater discharges:
- To adversely affect the POTW’s operation, or
- To violate the pretreatment standards.
Limited exceptions allow the control authority to designate a facility as a non-significant CIU (if the facility meets specific conditions according to 403.3(v)(2)) or to determine that the facility has no reasonable potential to harm POTW operations or violate the standards (403.3(v)(3)).
Is my facility a CIU?
The National Pretreatment Program has rules that apply to specific industrial processes, known as categorical pretreatment standards. If your facility is subject to a categorical requirement in Parts 405–471, it’s considered a CIU. Examples of covered categories include:
- Metal finishing (Part 433);
- Organic chemical, plastic, and synthetic fiber manufacturing (Part 414); and
- Petroleum refining (Part 419).
Submit a category determination request
The control authority director determines whether any of the categorical standards apply to a facility through a process called “categorical determination.” IUs may submit a category determination request when a new categorical standard is established that could apply to their existing facility. Additionally, EPA requires IUs to request a determination when:
- An existing facility adds or changes an operation or process that may make it subject to an existing categorical pretreatment standard, and
- A facility becomes a new source of discharge to a POTW.
The director will issue a final decision as to whether any of the regulations in Parts 405–471 apply to the facility.
Which pretreatment regulations apply?
The control authority will include the applicable regulations in the facility’s permit or implement the requirements through other control mechanisms. These will be at least as stringent as the following federal standards.
Requirements for all IUs
General and specific prohibitions apply to all types of IUs, banning facilities from discharging pollutants and categories of pollutants that can cause pass through or interference at the POTW.
Additionally, all IUs must report specific discharges and changes to existing discharge practices to the control authority.
Requirements for SIUs
SIUs have additional compliance obligations, such as:
- Conducting self-monitoring and submitting periodic compliance reports every 6 months for SIUs not subject to categorical standards, and
- Developing and implementing a slug control plan if required.
Requirements for CIUs
CIUs also have more requirements, including (but not limited to):
- The applicable categorical pretreatment standards (Parts 405–471),
- The categorical standards at 403.6, and
- Additional reporting and notification requirements.
Understanding the types of IUs that characterize your facility can help clarify which federal wastewater rules apply.
Key to remember: The type of industrial user determines the National Pretreatment Program requirements applicable to facilities that discharge wastewater to publicly owned treatment plants.
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2026-08-25T05:00:00Z
New Hampshire adopts PFAS product regulations
Effective date: July 17, 2026
This applies to: Any entity that manufactures or supplies specific consumer products with intentionally added per- and polyfluoroalkyl substances (PFAS)
Description of change: The New Hampshire Department of Environmental Services adopted rules to implement the Per- and Polyfluoroalkyl Substances Products Control Program, which bans certain PFAS-added consumer products from being sold, offered for sale, or distributed for sale or promotional purposes.
The regulations:
- Ban certain products with intentionally added PFAS from being sold or distributed in New Hampshire (unless specifically exempt);
- Establish the certificate of compliance (COC) process, under which manufacturers and suppliers must provide a COC upon request of the department to demonstrate compliance; and
- Establish exemptions.
The ban applies to PFAS-added products manufactured on or after January 1, 2027. Product categories include:
- Carpets and rugs;
- Cosmetics;
- Feminine hygiene products;
- Food packaging and containers;
- Juvenile products;
- Textile furnishings;
- Textile treatments;
- Upholstered furniture; and
- Waxes for use on boats; skis; surfboards; bodyboards; and skimboards.
Examples of exempted products include all products manufactured before January 1, 2027; secondhand products; and products with at least 85 percent recycled content.
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2026-08-25T05:00:00Z
New Hampshire requires electronic applications for AOT permits
Effective date: August 6, 2026
This applies to: Projects that will disturb more than 100,000 square feet of terrain (or 50,000 square feet if it’s within the protected shoreline) and projects that will disturb any area with a 25 percent or steeper land slope that’s within 50 feet of surface water
Description of change: The New Hampshire Department of Environmental Services amended the regulations for Alteration of Terrain (AOT) permitting, requiring applicants to submit all permit applications and permits by notification online through its new e-permitting system, NHEnviro.
The department also made other changes, such as:
- Expanding the general permit rule to cover specific steep slope projects, and
- Exempting excavation and mining projects from the 5-acre open area disturbance limit.
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2026-08-21T05:00:00Z
Maintenance and environmental compliance go hand in hand
Environmental compliance is often viewed as the responsibility of the environmental, health, and safety (EHS) department. In reality, many compliance successes and failures occur on the plant floor, in maintenance shops, and around equipment managed by maintenance personnel.
Maintenance employees regularly handle used oil, inspect tanks, repair air pollution control equipment, respond to spills, and maintain secondary containment systems. Their daily decisions can directly affect compliance with federal, state, and local environmental requirements. As facilities face increased scrutiny of air emissions, waste management, and spill prevention programs, coordination between environmental and maintenance personnel has become increasingly important. That's why one of the most valuable members of an environmental compliance team is often someone from maintenance.
Used oil management starts in the shop
Many maintenance departments generate used oil from equipment servicing, vehicle maintenance, and hydraulic system repairs. While used oil can often be managed under streamlined regulations, improper handling can quickly create compliance problems.
Common issues include storing used oil in unlabeled containers, mixing used oil with hazardous waste, and failing to address leaks from storage containers. Even small mistakes can increase disposal costs or change how the waste must be managed.
Maintenance personnel can help reduce these risks by ensuring used oil containers remain closed when not in use, are properly labeled, and are routinely inspected for signs of leakage or deterioration.
Spill response depends on employees closest to the release
When a spill occurs, maintenance staff members are often among the first employees on scene.
Their actions during the first few minutes can affect both environmental impacts and regulatory obligations. Quickly stopping the source of a release, protecting drains, and containing spilled material can prevent a minor incident from becoming a reportable event.
Facilities should ensure maintenance personnel understand spill response procedures, know where response equipment is located, and recognize when environmental staff or emergency responders must be notified.
Even facilities with formal spill response plans depend on maintenance employees to implement many of the initial response actions.
Air compliance requires reliable equipment
Many facilities rely on air pollution control devices such as baghouses, scrubbers, thermal oxidizers, and dust collection systems to comply with permit requirements.
Environmental managers may be responsible for reporting emissions and maintaining permit records, but maintenance staff members are often responsible for keeping control equipment operating properly.
A failed pressure gauge, malfunctioning fan, broken duct connection, or neglected preventive maintenance task can affect emissions performance and potentially result in permit deviations.
Facilities should ensure maintenance programs include environmental control equipment and that maintenance personnel understand which equipment has environmental significance.
Tanks and containment need routine attention
Storage tanks and secondary containment systems are another area where maintenance and environmental responsibilities overlap.
Maintenance personnel may also maintain stormwater controls, drainage structures, and outdoor storage areas that affect permit compliance.
Routine inspections can identify corrosion, damaged coatings, leaking fittings, deteriorated hoses, and cracks before they become larger problems. These conditions may not seem urgent from an operational perspective, but they can increase the risk of releases and regulatory violations.
Facilities should establish inspection procedures, clearly define responsibilities, and document findings. A simple inspection program can often identify problems early, reducing both environmental risk and repair costs.
Communication helps prevent violations
Many environmental compliance issues occur when operational changes are made without considering environmental impacts.
New equipment, replacement tanks, process modifications, and maintenance projects can affect air emissions, waste generation, chemical storage, and spill prevention requirements. Environmental staff may not become aware of these changes until after installation.
Regular communication between maintenance and environmental personnel can help identify potential compliance concerns before work begins. In many cases, a short conversation during project planning can prevent significant compliance challenges later.
Building a partnership between maintenance and environmental teams
Environmental compliance is most effective when it's integrated into daily operations. Maintenance teams often have the best understanding of equipment conditions, storage systems, and operational changes occurring throughout a facility.
Environmental awareness training, maintenance involvement in inspections, and regular communication can strengthen compliance programs and identify problems sooner.
Environmental managers bring regulatory expertise. Maintenance personnel bring operational knowledge. Together, they create a stronger foundation for compliance than either group can achieve alone.
Key to remember: Environmental compliance isn't solely an EHS responsibility. Maintenance staff members play a critical role in preventing spills, managing used oil, maintaining compliance equipment, and identifying problems before they become violations.
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2026-08-14T05:00:00Z
Virginia requires PFAS monitoring for wastewater
Effective date: September 9, 2026
This applies to: Publicly owned treatment works (POTW)
Description of change: The Virginia State Water Control Board adopted amendments to the Virginia Pollutant Discharge Elimination System (VPDES) Permit regulation. The updated regulations:
- Require POTWs to mandate quarterly discharge monitoring for per- and polyfluoroalkyl substances (PFAS) for certain industrial user categories,
- Establish a 30-day reporting deadline for monitoring results, and
- Specify acceptable test methods.
Covered industrial categories include:
- PFAS manufacturing facilities;
- Electroplating and metal finishing facilities using PFAS;
- Semiconductor and circuit board facilities using PFAS;
- Paper and packaging manufacturing facilities using PFAS;
- Textile mills and tanneries using PFAS and leather, fabric, and carpet treaters using PFAS;
- Centralized waste treatment industrial facilities;
- Industrial launderers; and
- Any other facility or site that’s a source of PFAS (such as landfills).
The POTWs must report results quarterly to the Virginia Department of Environmental Quality. Additionally, industrial users must report monitoring results within 30 days of receiving the laboratory results.
Related state info: Industrial water permitting — Virginia
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2026-08-14T05:00:00Z
Virginia amends water withdrawal reporting requirements
Effective date: September 9, 2026
This applies to: Water users providing water to another person off-site
Description of the change: The Virginia State Water Control Board amended water withdrawal reporting requirements for water users providing water to another person off-site. These users are now required to report monthly (or quarterly if applicable) the total volumes of potable water and reclaimed water that they provided:
- To a data center with an air permit from the Virginia Department of Environmental Quality; and
- For domestic, commercial, industrial, and all other non-categorized purposes.
The reporting requirement takes effect on January 1, 2027.
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2026-08-14T05:00:00Z
TSCA Exposure Control Plan: 5 FAQs answered
Do you have a toxic work environment — literally? For facilities that handle chemicals, the answer is likely yes. And for specific chemicals, federal environmental regulations require facilities to protect workers by controlling their exposure to these substances.
The Workplace Chemical Protection Program (WCPP) is one way the Environmental Protection Agency (EPA) protects potentially exposed workers from hazardous chemicals in the workplace. And at the core of the WCPP is the Exposure Control Plan (ECP); it’s the roadmap documenting how a facility will keep its employees safe. If your business manufactures (including imports), processes, distributes, uses, or disposes of a chemical substance subject to risk management regulations under Section 6 of the Toxic Substances Control Act (TSCA), an ECP may be required.
Consider these FAQs to help you implement an effective ECP that guards your workers against a “toxic work environment."
What’s an ECP?
An ECP is a strategic document explaining:
- What exposure controls the facility takes to reduce occupational exposure to a regulated chemical to or below EPA’s exposure limits; and
- How the facility will implement the other WCPP requirements (such as implementing exposure controls, establishing regulated areas, and providing training).
Any time a facility uses a TSCA Section 6 chemical that’s subject to the WCPP regulations (40 CFR Part 751), an ECP is required. This applies even if exposure monitoring determines that the concentration of a regulated chemical substance is below the existing chemical exposure limit or action level.
How do you develop an ECP?
Owners or operators must establish an ECP using the hierarchy of controls framework, following a sequence of actions to identify the control measures that will best reduce hazardous workplace exposures. The hierarchy of controls is ordered from the most to the least effective methods:
- Elimination stops the use of the chemical.
- Substitution replaces the chemical with a safer alternative.
- Engineering controls prevent people from coming into contact with the chemical (e.g., local exhaust ventilation and protective barriers).
- Administrative controls establish work practices that reduce the duration, frequency, or intensity of chemical exposure (like limiting access to exposure areas).
- Personal protective equipment (PPE), such as respirators, reduces or mitigates exposure.
EPA requires owners or operators to consider every level of the hierarchy. PPE should be a last resort and used only when other controls aren’t possible or when other methods don’t sufficiently reduce hazardous exposure to safe levels.
What’s in an ECP?
Generally, an ECP must include the following:
- The exposure control measures that were considered using the hierarchy of controls;
- The reason why each control measure was selected or not selected based on feasibility, effectiveness, or other relevant information;
- The actions required to implement the selected controls (e.g., installation, maintenance, training);
- The regulated areas (workplace locations where worker exposure may exceed exposure limits), how they’re identified, and the people authorized to enter them;
- The process for reviewing and updating the ECP to ensure that the exposure controls are effective, updated when needed, and properly implemented; and
- The procedures for responding to new sources of or increases in exposure to the regulated chemical, including taking corrective actions.
Owners or operators must review and update ECPs when making major changes to the WCPP. However, EPA’s chemical-specific rules limit the length of time between reviews. The review frequency in the chemical-specific rule is the minimum requirement.
For example, the perchloroethylene rule (751.607) requires facilities to review and update the ECP at least every 5 years, while the chrysotile asbestos rule (751.511) requires facilities to review and update the ECP at least annually.
Can an ECP be added to an existing safety program?
Yes! Owners or operators can either:
- Incorporate the ECP into an existing industrial hygiene or chemical management program (like a chemical hygiene plan) if the ECP contains all the required components, or
- Develop an individual document for the ECP.
Can one ECP be used for multiple regulated chemicals?
EPA allows owners or operators to develop one standalone ECP that covers multiple chemicals subject to TSCA Section 6 regulations if the plan complies with each chemical’s specific requirements.
Key to remember: The Exposure Control Plan explains how a facility will implement the Workplace Chemical Protection Program and the exposure controls needed to protect workers from hazardous chemical exposures.
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2026-08-13T05:00:00Z
The environmental compliance program hiding in your chemical inventory
Environmental programs may appear unrelated, but most rely on accurate information about the chemicals a facility uses, stores, or generates. Air permits, hazardous waste determinations, emergency planning, chemical reporting, and spill response programs all depend on knowing what chemicals are on site.
Yet chemical inventory management is often divided among multiple departments. Purchasing tracks what comes in, operations tracks what is used, maintenance stores products for later use, and environmental staff may only become involved when reporting deadlines approach. When inventories are incomplete or outdated, compliance problems can quickly follow.
A single source of truth supports multiple programs
Before a facility can determine its environmental obligations, it must first understand what chemicals are present on site.
The information contained in a chemical inventory supports numerous environmental programs, and different inventory data serve different purposes. Product quantities may affect EPCRA reporting. Chemical constituents help identify TRI chemicals and estimate releases. Usage data support air emissions calculations, while information about spent materials can help determine whether hazardous waste rules apply. Storage quantities, container types, and locations may also affect spill prevention and emergency response planning.
Consider a facility that introduces a new solvent for equipment cleaning. Purchasing may view it as a routine substitution, but the environmental implications may be much broader. The solvent may contain volatile organic compounds (VOCs) that affect air permits, TRI-listed constituents, or chemicals subject to EPCRA. If the spent solvent is discarded, hazardous waste regulations may also come into play. A complete inventory and chemical review process can identify these issues before the product enters service.
When departments maintain separate inventories using different data sources, inconsistencies can develop. One database may show a product as active while another indicates it is no longer used. A chemical stored in a maintenance room may never make its way into environmental records. These gaps can create reporting errors and complicate inspections.
Small changes can have large compliance impacts
Chemical inventories are not static. New products are introduced, suppliers change formulations, production processes evolve, and maintenance departments purchase materials to address operational needs.
Even seemingly minor changes can affect compliance programs. A reformulated product may contain a reportable constituent that it did not contain previously. A new coating operation may increase air emissions. Additional chemical storage may trigger emergency planning requirements or affect secondary containment needs.
Without a chemical review process involving environmental, safety, operations, and purchasing personnel, facilities may not recognize these implications until well after a change has occurred. This approach helps identify regulatory concerns before products are ordered, stored, or put into use.
Inspections often begin with inventory questions
Environmental inspectors often compare records against actual site conditions. Chemical inventories frequently become a focal point because they intersect with multiple regulatory programs.
Inspectors may compare inventory records with container labels, safety data sheets (SDSs), storage areas, waste accumulation locations, or reported chemical quantities. Discrepancies can raise questions about reporting accuracy and program oversight.
A well-maintained inventory shows that a facility has systems to manage compliance and allows personnel to quickly answer questions about chemical storage and use.
Building a stronger inventory program
The challenge is deciding what information to track and how to keep it current. An effective chemical inventory program does not need to be complicated, but it should be consistent.
At a minimum, facilities should track product names, storage locations, quantities on site, usage rates, SDS information, and key chemical constituents. Different data elements support different programs. Storage quantities may affect EPCRA reporting, chemical constituents may drive TRI evaluations, and usage rates often provide critical data for air emissions calculations. Some organizations also identify whether a product contains TRI chemicals, hazardous air pollutants (HAPs), VOCs, PFAS, or other substances subject to reporting or permitting requirements. Centralizing this information can simplify environmental evaluations throughout the year.
Facilities should establish clear ownership of inventory data, periodically verify inventory accuracy in the field, review new chemicals before purchase, and ensure information is shared across departments. Environmental staff should also periodically compare inventory data against reporting submissions, air permits, waste records, and emergency planning documentation. The goal is not simply to maintain a list of chemicals, but to create a reliable foundation for environmental decision making. A well-managed inventory supports air permitting, chemical reporting, emergency planning, spill prevention, and hazardous waste programs. When inventory data is accurate and readily available, environmental professionals spend less time chasing information and more time managing compliance risks.
Key to remember: Chemical inventory management is more than a recordkeeping exercise. A complete and accurate inventory provides the information needed to support air, waste, emergency planning, spill prevention, and chemical reporting programs, helping facilities identify compliance obligations before problems arise.
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EHS Monthly Round Up - July 2026
In this July 2026 monthly roundup video, we'll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
OSHA published its 2026 regulatory agenda on July 3. Of note, the agency projects an April 2027 date for the Emergency Response final rule, and the Heat Illness proposal is slated to be finalized in October 2027. In November 2026, OSHA also expects to publish a final rule addressing the use of subpoenas during investigations.
OSHA reopened the comment period for 14 chemical-specific proposals. This allows the public 30 days to comment on recommendations made by OSHA’s Advisory Committee on Construction Safety and Health.
OSHA updated its Voluntary Protection Programs, which recognize workplaces with strong safety and health programs and low injury rates. The changes align with the seven core elements in the agency’s Recommended Practices for Safety and Health Programs.
The Mine Safety and Health Administration withdrew 4 regulations that it says address outdated effective dates and requirements for various industry equipment and procedures. These relate to conveyor belts, blacksmith shops, diesel emission limits, and permissible flame safety lamps.
Turning to environmental news, EPA released detailed instructions and deadlines for pesticide registrants to begin compliance with the bilingual labeling requirements in the My PeST application. The first compliance deadline was July 31.
EPA aligned regulations under EPCRA Sections 311 and 312 with OSHA’s Hazard Communication amendments for hazardous chemical reporting requirements. Facilities must use OSHA’s hazard classes with their categories for safety data sheet submissions and hazardous chemical inventory reports required under EPCRA Sections 311 and 312.
And finally, EPA published its 2026 regulatory agenda on July 3. Many of the proposed and final rules support the agency’s continued deregulatory efforts and may impact regulatory compliance with air, land, and water rules.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
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EHS Monthly Round Up - February 2026
In this Februrary 2026 roundup video, we'll discuss the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
Fatal work injuries fell 4 percent in 2024, largely due to a decline in workplace drug- and alcohol-related overdoses. According to the Bureau of Labor Statistics, overdose fatalities fell from 512 in 2023 to 410 in 2024. Across all types of workplace incidents, there were 5,070 fatal work injuries in 2024, compared to 5,283 in 2023. Transportation incidents continue to be the most frequent type of fatal event, accounting for over 38 percent of all occupational fatalities in 2024.
OSHA is fast-tracking a proposal to remove the 2036 obligation to upgrade fall protection systems on fixed ladders that extend over 24 feet. This follows an industry petition from major chemical and petroleum industry groups, which argue the provision is unjustified, costly, and not supported by the rulemaking record. OSHA frames the upcoming proposed action as deregulatory, allowing employers to update fixed ladders at the end of their service lives. We’ll provide updates as more information becomes available.
As OSHA leans into “deregulatory” actions, lawmakers are moving to pressure the agency to issue “regulatory” rulemaking to protect American workers. The latest legislative wave of bills aims to fill regulatory gaps, tackle emerging hazards, expand OSHA authority, and raise penalties. Topics addressed by these bills include musculoskeletal disorders, heat stress, infectious diseases, wildfire smoke, and workplace violence.
In a recently issued letter of interpretation, OSHA states that a burn injury caused by a personal lithium-ion battery fire is work related if it occurs in the workplace during assigned working hours. The letter details an incident where an employee was burned when their rechargeable lithium-ion batteries for e-cigarettes sparked a fire after coming into contact with a key used for work.
A new report from the Department of Labor Office of Inspector General concludes that OSHA struggles to meet its mission, particularly in high-risk industries like healthcare, construction, and manufacturing. Several pages point to OSHA’s difficulties in effectively enforcing annual injury and illness reporting requirements, reaching the nation’s high-risk worksites for inspection, and addressing workplace violence by regulatory or other action.
Turning to environmental news, EPA extended the deadlines for Facility Evaluation Reports and related requirements for coal combustion residuals facilities. In most instances, the deadlines have been moved one or two years out.
And finally, EPA announced a final rule eliminating the 2009 Endangerment Finding and related greenhouse gas emission requirements for on-highway vehicles and vehicle engines. When the final rule takes effect, manufacturers and importers of new motor vehicles and motor vehicle engines will no longer have to measure, report, certify, or comply with federal greenhouse gas emission standards.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
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EHS Monthly Round Up - May 2026
In this May 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.
The first compliance date for the revised HazCom standard took effect May 19. Employers who work with chemical substances that are aerosols, desensitized explosives, or flammable gases should start to see updated safety data sheets and labels. On a related note, OSHA revised its HazCom directive for inspectors. It instructs OSHA officers on how to conduct inspections and issue citations under the standard. However, it also provides chemical manufacturers, importers, distributors, and employers with insight into what officers will be assessing.
OSHA revoked a standard that prohibited open fires and fires in drums or similar containers in marine terminals. The agency stated that since this is no longer typical practice, removing the standard would lessen the compliance burden without compromising worker safety.
OSHA received the backing of an advisory committee as it advances a comprehensive Tree Care Operations proposal. During the Advisory Committee on Construction Safety and Health meeting, the group unanimously voted in favor of moving ahead. This clears the path for OSHA to publish its long-awaited proposal.
Turning to environmental news, EPA extended the submission date for the TSCA Section 8(d) Health and Safety Data Reporting Rule one-time report from May 22, 2026, to May 21, 2027.
EPA published the first round of expiring confidential business information claims for information submitted under TSCA. The list covers claims that expire from June 22 to July 31, 2026. Businesses must submit extension requests to keep the information protected.
EPA postponed the effective compliance date for trichloroethylene users with TSCA Section 6(g) exemptions until pending judicial review is concluded. The agency has yet to establish a new compliance date.
And finally, EPA revised HFC use restrictions for certain subsectors. This applies to entities that are subject to the 2023 Technology Transition Rule requirements. The agency also proposed a rule that would exempt transportation refrigeration units from leak repair requirements regardless of charge size.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
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EHS Monthly Round Up - March 2026
In this March 2026 roundup video, we'll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
OSHA released an updated Job Safety and Health poster. Employers can use either the revised version or the older one, but the poster must be displayed in a conspicuous place where workers can easily see it.
OSHA recently removed a link from its Data topic webpage that displayed a list of “high-penalty cases” at or over $40,000 since 2015. The agency says it discontinued and removed it in December. The data is frozen and archived elsewhere.
OSHA published two new resources as part of its newly launched Safety Champions Program. The fact sheet provides an overview of how the program works, eligibility criteria, and key benefits. The step-by-step guide helps businesses navigate the core elements of OSHA’s Recommended Practices for Safety and Health Programs.
Several forces are nudging OSHA to address a number of workplace hazards and high-hazard industries. This comes from other agencies, safety organizations, watchdogs, legislative proposals, and persistent injury/fatality data. Among the hazards are combustible dust; first aid; personal protective equipment; and workplace violence. How all this translates into new regulations, guidance, programmed inspections, or other initiatives remains to be seen.
Turning to environmental news, EPA issued a proposed rule to require waste handlers to use electronic manifests to track all RCRA hazardous waste shipments. Stakeholders have until May 4 to comment on the proposal.
On March 10, EPA finalized stronger emission limits for new and existing large municipal waste combustors and made other changes to related standards.
And finally, EPA temporarily extended coverage under the 2021 Multi-Sector General Permit for industrial stormwater discharges until the agency issues a new general permit. The permit expired February 28 and remains in effect for facilities previously covered. EPA won’t take enforcement action against new facilities for unpermitted stormwater discharges if the facilities meet specific conditions.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
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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 - June 2026
In this June 2026 roundup video, we'll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
OSHA won’t increase its penalty amounts in 2026. The agency is required to annually adjust its penalties for inflation, based specifically on the October Consumer Price Index data released by the Bureau of Labor Statistics. Due to a lapse in funding, BLS did not release the October 2025 data. Because no alternative calculation is allowed, OSHA penalties will remain at the 2025 amounts.
OSHA updated its inspection guidance for the Hazard Communication standard. While the document is geared towards OSHA inspectors, it provides insights for chemical manufacturers, importers, distributors, and employers as to what the agency will look for during an inspection.
OSHA will hold a series of informal, virtual hearings on multiple proposed rules beginning August 19th. The majority relate to respiratory protection requirements for different chemical substances. All of the proposed rules were originally published in the Federal Register on July 1, 2025.
Nevada OSHA published a list of frequently asked questions related to its recently adopted heat illness rule. The state’s rule took effect April 29.
Turning to environmental news, EPA restored emergency-related affirmative defense provisions for Title V operating permits. This allows stationary sources to assert a regulatory affirmative defense for certain air emission violations caused by events beyond their control.
EPA released two proposed rules that would have major impacts on drinking water regulations for PFAS. The agency will accept comments on the proposals until July 20.
And finally, EPA now allows facilities to submit PCB annual reports electronically. Facilities can start with the upcoming report that’s due July 15.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
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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!
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2026-08-05T05:00:00Z
Environmental compliance during capital projects: What gets missed most often
Capital projects often focus on budgets, schedules, engineering specifications, and operational goals. Project teams, however, frequently treat environmental compliance as a secondary consideration until late in the project lifecycle. That approach can create costly delays, permit violations, unexpected expenses, and even enforcement actions.
The most commonly missed environmental compliance issue during capital projects is the failure to evaluate how seemingly routine changes affect regulatory obligations. Changes to equipment, raw materials, production capacity, fuel usage, waste generation, emissions, water discharges, or storage practices can trigger new environmental requirements. What appears to be a straightforward operational improvement may alter permit applicability, increase emissions, generate new waste streams, or require additional monitoring and recordkeeping. Organizations that wait until construction is underway to ask environmental compliance questions often discover that regulatory reviews should've occurred months earlier.
Operational changes can trigger new requirements
Many capital projects are initiated to improve efficiency, increase production, or expand capabilities. As a result, project teams often focus on engineering and operational objectives without fully evaluating how proposed changes will affect environmental compliance.
Even relatively modest modifications can create compliance obligations that weren't considered during project planning. A project that increases throughput, changes operating patterns, or introduces new materials may trigger additional permitting, monitoring, or reporting requirements. Facilities that conduct environmental reviews during the early planning stages are generally better positioned to identify and address these issues before they affect project schedules.
Air and water impacts are often underestimated
Air permitting is one area where projects frequently encounter surprises. Process changes and production increases can affect emission calculations and permit thresholds. Facilities sometimes assume that replacing equipment with newer technology automatically improves compliance. In reality, changes in throughput, operating hours, fuels, or process materials can increase potential emissions or trigger new regulatory requirements even when newer equipment is more efficient.
Water-related requirements are also frequently overlooked. Site expansions may alter drainage patterns, increase impervious surfaces, or create new industrial stormwater exposure areas. Construction activities can trigger erosion and sediment control obligations, while process changes may affect wastewater characteristics, discharge volumes, or pretreatment requirements. These issues are often easier and less expensive to address during project design than after construction begins.
Chemical and waste management challenges
Hazardous waste and chemical management considerations are also frequently overlooked during capital projects. Introducing new raw materials, products, or process chemicals may create waste streams that require different handling, storage, transportation, or disposal practices.
Additional storage capacity may require updates to spill prevention measures, emergency response procedures, or chemical inventories. In some cases, project teams don't identify these impacts until after equipment is installed and operational.
Facilities may also discover that existing waste determinations no longer apply to modified operations. Failure to evaluate new or changed waste streams can result in improper waste management practices and increased regulatory risk.
Compliance doesn't end with the permit
Permitting is only one component of environmental compliance. Capital projects often require updates to a variety of compliance-related documents and programs that support day-to-day operations.
Facilities may need to revise Stormwater Pollution Prevention Plans (SWPPPs); Spill Prevention, Control, and Countermeasure (SPCC) Plans; inspection procedures; training materials; and recordkeeping systems. These updates are sometimes overlooked when project teams focus primarily on obtaining permits or completing construction milestones.
Failing to update supporting documentation can create compliance gaps even when all necessary permits have been obtained.
Communication and change management matter
Another common challenge is communication. Environmental compliance responsibilities often extend beyond environmental staff to engineering, operations, maintenance, purchasing personnel, and contractors. When environmental requirements aren't communicated effectively, critical information may never reach those responsible for implementing controls, maintaining records, or conducting inspections.
Many of these issues can be traced to the absence of a formal management of change (MOC) process. Capital projects frequently evolve as designs are refined, equipment is substituted, or project scopes change. Without a structured review process, environmental impacts identified early in the project may no longer reflect the final design.
An effective MOC process helps ensure that environmental considerations are reevaluated throughout the life of a project rather than only during the initial planning phase.
Building compliance into the project lifecycle
Most capital project compliance problems are preventable. Organizations that involve environmental personnel early, integrate compliance reviews into project planning, maintain clear communication channels, and establish a structured change-management process are less likely to encounter regulatory surprises.
Environmental compliance should be incorporated throughout planning, design, construction, and startup activities. Doing so can help organizations identify potential issues sooner, avoid costly delays, and reduce the likelihood of noncompliance after a project becomes operational.
Key to remember: The most common compliance pitfalls in capital projects stem from failing to evaluate how operational changes affect existing environmental requirements.
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2026-08-04T05:00:00Z
EPA proposes 2027 general stormwater permit for construction
The Environmental Protection Agency (EPA) published the proposed 2027 National Pollutant Discharge Elimination System (NPDES) Construction General Permit (CGP) for public comment on August 3, 2026. The CGP covers stormwater discharges from construction activities.
Who’s impacted?
The CGP applies to construction activities in areas where EPA is the NPDES permitting authority (including Massachusetts, New Hampshire, New Mexico, and the District of Columbia). Construction site operators must obtain a stormwater discharge permit for any construction activity that:
- Disturbs 1 acre or more of land, or
- Disturbs less than 1 acre of land but is part of a larger common plan of development or sale that will disturb 1 acre or more of land.
What are the proposed changes to the CGP?
EPA’s proposed 2027 CGP contains multiple modifications to the 2022 CGP. Significant changes include:
- Replacing the broad requirement for permittees to “meet applicable water quality standards” for receiving waters (i.e., the waters that permittees discharge into) with more specific limits that indicate water quality problems in the discharge and applying these indicator conditions to all permittees;
- Requiring CGP applicants to submit with the Notice of Intent (NOI) an electronic copy of the Stormwater Pollution Prevention Plan (SWPPP), a website address where the SWPPP can be viewed, or a copy of the SWPPP site map and the signed certification;
- Requiring construction sites that install a sediment basin to implement stabilization measures before directing stormwater to the basin; and
- Streamlining specific requirements, such as:
- Clarifying that perimeter sediment controls are only required for areas that may receive stormwater from disturbed areas;
- Clarifying the stabilization deadlines for sites in arid, semi-arid, and drought-stricken areas;
- Allowing sites that experience unforeseeable winter weather conditions to temporarily suspend the requirement to stabilize exposed portions of the site for 14 days or more of inactivity while the extreme weather conditions persist;
- Eliminating the requirement to submit pre-stabilization photos with a Notice of Termination;
- Reducing the frequency of turbidity monitoring from daily to weekly for sites discharging dewatering water continuously for longer periods of time;
- Relieving some operators of turbidity benchmark monitoring reporting requirements at sites where multiple operators coordinate monitoring efforts (if the operators submit an initial quarterly report to inform EPA that they’re relying on another permitted operator on-site to monitor and report); and
- Eliminating the reporting requirement when no dewatering discharges occur during a monitoring quarter.
Who needs to apply for 2027 CGP coverage?
Operators of both new sites (construction activities begin on or after the final 2027 CGP’s effective date) and existing sites must apply for coverage under the 2027 CGP.
If an existing site obtained permit coverage under the 2022 CGP before the permit’s expiration date (February 17, 2027), the site will automatically remain covered for a limited period of time, allowing operators to submit a new Notice of Intent for coverage under the 2027 CGP.
What’s next?
Public comments are due by September 2, 2026 (Docket ID No. EPA-HQ-OW-2025-0760).
EPA will host a webinar on August 18, 2026, to review the proposed 2027 CGP and answer questions. You may register for the webinar on EPA’s “Proposed 2027 Construction General Permit (CGP) and Related Documents” webpage. If the proposed 2027 CGP is finalized, it will replace the existing 2022 CGP, which expires on February 17, 2027.
Key to remember: EPA seeks public comment on the proposed 2027 Construction General Permit for stormwater discharges.
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EHS Monthly Round Up - August 2026
In this August 2026 monthly roundup video, we'll review the most impactful environmental health and safety news.
Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.
Citing elevated injury and illness rates, OSHA relaunched a National Emphasis Program, or NEP, on Warehousing and Distribution Center Operations. Retail operations are no longer targeted by this NEP, as they were previously. Inspectors will focus on common hazards in warehousing and distribution such as powered industrial vehicle operations, materials handling and storage, and fire protection. The NEP also offers OSHA greater discretion in whether to expand an inspection.
OSHA state-plan enforcement continued to gain momentum in fiscal year 2025. In an upward trend, inspection numbers, violation counts, and penalty amounts all increased. The latest data stem from the Occupational Safety and Health Plan Association’s Grassroots Worker Protection report.
OSHA’s Safe+Sound Week was held August 10 through the 16. The event gave employers an opportunity to highlight their safety and health programs and bring attention to common workplace hazards.
The Mine Safety and Health Administration reopened the comment period for proposed changes to the approval criteria for its mine roof control and ventilation plans. The new deadline for comments is September 30.
Turning to environmental news, EPA extended the compliance dates of certain Workplace Chemical Protection Program requirements for perchloroethylene and carbon tetrachloride. The revised deadlines affect facilities subject to the TSCA PCE and CTC risk management rules finalized in 2024.
And finally, EPA published a proposed 2027 general stormwater permit for construction. It applies to construction activities in areas where EPA is the NPDES permitting authority, including Massachusetts, New Hampshire, New Mexico, and the District of Columbia. If finalized, the rule will replace the existing 2022 permit, which expires in early 2027.
Thanks for tuning in to the monthly news roundup. We’ll see you next month!
NewsEnvironmental Management SystemsEMS PlanningCAA ComplianceEnvironmental Management SystemsIn-Depth ArticleCWA ComplianceWaste/HazWasteEnglishIndustry NewsEMS GoalsEMS Audits and EvaluationsEnvironmentalFocus AreaUSA
2026-09-01T05:00:00Z
10 operational changes that should trigger an environmental compliance review
Environmental compliance issues often arise not because regulations change, but because operations change.
A facility may replace equipment, begin using a new chemical, increase production, or modify a process for legitimate business reasons. However, even routine operational changes can affect permits, reporting obligations, waste generation, emissions, wastewater discharges, or stormwater exposure.
Organizations that review environmental impacts before implementing changes are better positioned to identify compliance obligations early and avoid costly surprises.
What's an environmental compliance review?
An environmental compliance review is a structured evaluation of how a proposed change could affect a facility's environmental obligations.
Many organizations incorporate environmental reviews into an environmental management system (EMS) or formal change-management process. These procedures help ensure that environmental obligations are evaluated before operational changes are implemented. The updated ISO 14001 standard places greater emphasis on managing changes that may affect environmental performance, reinforcing the need to assess environmental impacts before decisions are made.
The review doesn't need to be complicated. In many cases, it involves determining whether the change could affect air permits, wastewater discharges, stormwater permits, hazardous waste management, chemical reporting, spill prevention requirements, or other environmental programs.
The goal is to identify environmental impacts before a change is implemented rather than after a regulator, auditor, or inspector discovers a problem.
Production increases
Increasing production is often viewed as a business decision rather than an environmental one. However, greater production may increase air emissions, wastewater generation, chemical usage, and waste generation.
Facilities should evaluate whether higher throughput could affect permit limits, reporting thresholds, or compliance obligations before production levels increase.
New chemicals or raw materials
A new chemical can trigger a wide range of environmental requirements.
Changes in raw materials may affect hazardous waste determinations, emergency planning requirements, air emissions calculations, Toxics Release Inventory reporting, spill prevention planning, or wastewater characteristics.
Before purchasing or introducing a new chemical, facilities should evaluate its environmental implications and ensure required controls are in place.
Equipment replacements and upgrades
Many organizations assume replacing equipment is simply a maintenance activity. In reality, equipment changes can have environmental consequences.
Replacing a boiler, coating operation, storage tank, dust collector, scrubber, or process equipment may affect emissions, waste streams, monitoring requirements, or permit applicability. Even when equipment serves the same function, environmental impacts should be evaluated before installation.
Process modifications
Changing how a product is manufactured can create environmental consequences even when production levels stay the same.
New process steps, altered operating conditions, different fuels, or modified treatment systems can affect emissions, waste generation, water usage, and permit conditions. Process changes should be reviewed to determine whether existing permits and operating procedures remain appropriate.
Facility expansions
Building additions, new production lines, warehouse expansions, and site development projects often involve environmental considerations beyond construction activities.
Organizations should evaluate potential impacts on air permits, stormwater management, wastewater infrastructure, storage capacity, and environmental monitoring programs before expansion projects begin.
Changes in waste management practices
Facilities occasionally change waste vendors, storage practices, recycling programs, treatment methods, or waste handling procedures to improve efficiency or reduce costs.
While these changes may appear administrative, they can affect generator status, accumulation practices, recordkeeping obligations, and waste determinations. Environmental personnel should review proposed changes before implementation.
New products or services
New products often require new materials, equipment, or processes that may affect existing environmental obligations.
Contractor activities
Contractor activities involving chemicals, waste management, tank cleaning, painting, excavation, demolition, or maintenance may create environmental compliance implications that warrant review.
Property and infrastructure changes
Changes to storage areas, containment systems, drainage patterns, tanks, or utilities can affect stormwater exposure and other environmental obligations.
Acquisitions and ownership changes
Acquiring a facility or business can introduce new permits, reporting obligations, and compliance responsibilities that should be evaluated during due diligence.
Train employees to recognize when a review may be needed
Environmental departments cannot review changes they never hear about.
Engineering, maintenance, operations, purchasing, project management, and production personnel are often the first to learn about proposed changes. Providing basic awareness training can help these groups recognize situations that may have environmental implications.
Employees don't need to become environmental experts. Instead, they should know when to notify EHS and ask whether a compliance review is warranted. A simple "check with EHS before proceeding" expectation can prevent significant compliance problems and reduce the likelihood that environmental requirements will be discovered too late.
Key to remember: Many environmental compliance issues begin with an operational change. Establishing a process to identify and review changes before implementation can help organizations avoid permit problems, reporting errors, and unexpected regulatory obligations.
NewsIndustry NewsIndustry NewsAir EmissionsEnvironmental Protection Agency (EPA)Renewable and Alternative EnergyBiofuelCAA ComplianceEnvironmentalFocus AreaEnglishAir ProgramsAir ProgramsUSA
2026-09-03T05:00:00Z
EPA extends RFS annual compliance report deadline
The Environmental Protection Agency (EPA) issued a final rule extending the Renewable Fuel Standard (RFS) annual compliance reporting deadline for the 2025 compliance year from September 1 to October 1, 2026.
Who’s impacted?
The RFS annual compliance report applies to obligated parties, including:
- Refiners of gasoline or diesel fuel (transportation fuel), and
- Importers of transportation fuel.
Under the RFS program, obligated parties with renewable volume obligations (RVOs) must retire enough Renewable Identification Numbers (RINs) to meet their RVOs for the calendar year.
What’s the change?
EPA extended the 2025 RFS compliance reporting deadline to October 1, 2026, giving obligated parties additional time to comply with their 2025 RVOs and submit their annual compliance reports.
Why the change?
EPA recently released its small refinery exemption (SRE) decisions for the 2025 compliance year, exempting 1.76 billion RINs for 29 small refineries. SREs affect the cost and availability of RINs for all obligated parties. The extension gives obligated parties more time to assess the impact of the SRE decisions and adjust their strategies before completing their 2025 RFS reporting obligations.
Key to remember: EPA has extended the Renewable Fuel Standard annual compliance reporting deadline from September 1 to October 1, 2026.
NewsIndustry NewsSuperfundCERCLA, SARA, EPCRA CERCLA, SARA, EPCRAEnvironmental EdgeEnvironmentalIn-Depth ArticleEnglishSARA ComplianceFocus AreaUSA
2022-05-16T05:00:00Z
Waste associations pursue relief from CERCLA liability for PFAS
On May 10, 2022, the National Waste & Recycling Association (NWRA) along with the Solid Waste Association of North America (SWANA) sent a letter to the leadership of the Senate Environment and Public Works, House Transportation and Infrastructure Committee, and House Energy and Commerce Committee. The letter asked Congress to give the municipal solid waste (MSW) industry a slight exemption from specific provisions of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) when it comes to per- and poly-fluoroalkyl substances (PFAS).
The establishments are concerned with who will be held liable with the Environmental Protection Agency’s proposed rule of designating certain PFAS as hazardous substances under CERCLA. The final rule is expected in the summer of 2023. This designation would require facilities nationwide to report on certain PFAS releases that meet or exceed reportable quantities set for those substances.
NWRA and SWANA argue that landfills neither manufacture nor use PFAS. But rather they get discarded materials with PFAS and thus they believe they should not be held financially liable under CERCLA for PFAS contamination. They go on to discuss how removing PFAS from landfill leachate necessitates technical treatment methods which are quite costly. NWRA and SWANA estimate the implementation of this would incur national costs of roughly $966 million to $6.279 billion each year for the solid waste industry.
The problem lies in the fact that CERCLA as it currently stands, imposes liability on parties responsible for, altogether or in part, the existence of hazardous substances at a location. The liability is considered joint and several under CERCLA. Any single potentially responsible party (PRP) may be held liable for the cleanup of the site overall. Liable parties include current owners and operators of a facility, past owners and operators at the time the wastes were disposed, generators that arranged for the disposal or transport of the substances, and transporters. If a PRP sent some amount of the hazardous waste found at the site, that party is liable. So even if MSW landfills did not manufacture the PFAS, they could still be liable with the proposed designation of defining PFAS as hazardous substances. NWRA and SWANA are ultimately suggesting a shift in liability.
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.
NewsEnforcement and Audits - OSHAPesticidesWorker Protection from PesticidesIn-Depth ArticleHazard CommunicationHR ManagementEnglishUSAIndustry NewsOSHA InspectionsSafety & HealthContingent WorkforceConstruction SafetyGeneral Industry SafetyAgriculture SafetyMaritime SafetyEnvironmentalHazard CommunicationTemporary EmployeesFocus AreaPesticidesHuman Resources
2026-05-26T05:00:00Z
OSHA packs new HazCom directive with enforcement clues
The first compliance date for the amended Hazard Communication (HazCom) standard has arrived, and OSHA finally issued its updated directive. The CPL instructs OSHA officers on how to conduct inspections and issue citations under the standard. However, it also provides chemical manufacturers, importers, distributors, and employers with insight into what officers will be assessing.
In effect, this CPL translates regulatory text into inspector expectations. It shows what adherence to the standard looks like in practice. That makes it a critical resource given recent and upcoming dates at 29 CFR 1910.1200(j).
CPL rewritten for the 2024 standard
On May 19, 2026, OSHA posted a revised CPL 02-02-079, “Inspection Procedures for the Hazard Communication Standard (HCS 2024),” replacing the July 9, 2015, version. The 132-page document reflects the reconfigured HazCom standard published May 20, 2024, effective on July 19, 2024, along with corrections issued through early 2026.
The agency designed this enforcement playbook to maintain uniform inspections during the transition period and after full implementation. Because of the extensive regulatory changes to definitions, hazard classification, labeling, safety data sheets, and trade secrets, the CPL is not a light refresh.
For those familiar with the rulemaking, the new CPL edits will not be surprising. Still, the directive should provide more clarity than the regulatory text.
Front matter and appendices
Updates to Sections I to IX are typical of a CPL, including:
- Cancellation of the 2015 CPL;
- A modified title and references to the 2024 final rule and corrections;
- Alignment with revisions 7 and 8 of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS); and
- A new summary of changes, historical background, and compliance dates.
OSHA also modernized appendices for dates, hazard lists, pictogram hazards, SDS review guidance, chemical resources, and related directives.
Reworked inspection guidelines
Section X outlines inspector instructions for paragraphs (b) through (j) of the standard. The latest modifications impact most sections:
- Scope, applicability, and exemptions — The directive offers new examples and expanded explanations, such as:
- A formaldehyde hazard example for hair smoothing products;
- An overview of pesticide labeling requirements and exemptions;
- Discussion of the EPA Agricultural Worker Protection standard preemption; and
- Greater detail about biological hazards from plants.
- Definitions — The document introduces terms and explains bulk shipment, immediate outer package, physical hazard, released for shipment, and more. It also revisits the terms combustible dust and manufacturer. Lithium-ion batteries are now referenced in the distributor context.
- Hazard classification — The directive instructs OSHA officers to consider the classification of:
- Hazards associated with a chemical’s intrinsic properties, including changes in physical form and reactions from known or reasonably anticipated uses; and
- Impurities, additives, and individual constituents.
- Written plan — The directive clarifies:
- Employers must revise programs by the compliance dates when new information is received from suppliers;
- The use of computers and third-party administrators of safety data sheets (SDSs); and
- The written program must describe how employees will be trained in a language and at a literacy level they understand.
- Labeling — The directive broadens the sections on Department of Transportation labeling, bulk shipments, and small container labeling. It incorporates final rule flexibility too:
- Phased-in compliance dates for labeling;
- Hazards not otherwise classified (HNOCs) and hazards identified and classified under 1910.1200(d)(1)(ii) don’t need to be addressed on the container;
- The exclamation mark pictogram is permitted (but not required) for HNOCs, under certain conditions;
- Minor textual variations for precautionary statements are allowed; and
- OSHA offers alternatives for chemical containers released for shipment.
- Safety data sheets (SDSs) — Amended text focuses on U.S. jurisdiction and technical provisions, such as:
- Phased-in compliance dates for SDSs;
- Importer SDS responsibilities;
- Using a U.S. address and phone number;
- The hazard class and category reflecting intrinsic properties;
- Required Chemical Abstracts Service (CAS) number or other unique identifiers; and
- No need to obtain updated SDSs to replace already received SDSs.
- Employee information/training — The directive references a temporary workers bulletin. It also emphasizes:
- Phased-in compliance dates for necessary training adjustments; and
- Delivering training in a language employees understand.
- Trade secrets — The instruction aligns with the 2024 rule:
- Allows the exact percentage, exact concentration range, or CAS number to be withheld if certain criteria are met; and
- Addresses the use of confidentiality agreements.
- Dates — The directive overhauls compliance timelines and discusses documentation of due diligence and good faith efforts.
In addition, the directive softens citation language with phrases like “should normally cite” instead of “shall cite.” This shift suggests inspectors may have greater discretion based on case-specific circumstances.
Key to remember
While 1910.1200 remains the baseline for employers and chemical manufacturers, importers, and distributors, the revised CPL 02-02-079 provides an enforcement lens. With implementation underway, regulated entities can use the CPL to steer their efforts and conform with how OSHA will inspect them in the field.
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2026-08-27T05:00:00Z
Roundabouts: Engineering genius or just going in circles?
Ah, the traffic roundabout — nature’s way of testing whether drivers truly understand the concept of yielding, or if they just enjoy circling endlessly like confused ducks in a kiddie pool. Some say roundabouts are the perfect solution to traffic congestion, reducing accidents and keeping things flowing like a well-oiled machine. Others argue they’re glorified spinning traps designed to confuse, frustrate, and occasionally launch unsuspecting minivans into orbit.
So, are roundabouts the heroes of modern traffic design or just circular chaos with landscaping in the middle? Buckle up as we take a few laps around this debate.
Running in circles or reducing incidents?
Believe it or not, roundabouts aren’t just there to make you question your sense of direction, make your GPS recalculate for the fifth time, or give your Uncle Bob another conspiracy theory to support. These circular marvels are actually traffic safety ninjas.
Studies by the Federal Highway Administration (FHWA) have shown that roundabouts typically result in:
| A 37% reduction in overall collisions. | A 75% reduction in injury collisions. |
| A 40% reduction in pedestrian collisions. | A 90% reduction in fatality collisions. |
| A 62-74% reduction in traffic delays. | As a planetary bonus, a 30% reduction in vehicle emissions. |
How to maneuver the roundabout
Don’t let these circular conundrums make drivers question everything you thought they knew about right-of-way, geometry, and your own patience. Here what to know so you can manage roundabouts without the road rage:
- Counterclockwise travel — Traffic travels counterclockwise around the center island. (In other words, spin around to the right.) Drivers should choose the lane where they want to go after the roundabout since there’s not much time to shift gears (or lanes).
- Entry yields control — Vehicles entering the roundabout yield to traffic already circulating. (In other words, whoever is in the circle first has the right-of-way.) Drivers must yield to traffic in all lanes of the roundabout, not just in the lane closest to them, and allow room for larger vehicles like semis or those pulling trailers.
- Don’t stop if you don’t have to — The entrance to the roundabout is a “yield” rather than a “stop.” (In other words, plan ahead so you can enter seamlessly into the circle so the confident roundabout renegade behind you doesn’t join you in your back seat!)
- Low speed — The curvature of the roundabout requires slower vehicle speeds (15-25 mph) throughout the roundabout. (In other words, slow down!)
- No power necessary — Unlike traffic signals, roundabouts are not susceptible to power failures to keep a tab on traffic chaos.
Think of navigating a roundabout like you are joining a polite game of bumper cars — everyone’s circling, and nobody’s crashing. You enter and exit only when you’ve proven you know how to yield without panicking (or making eye contact). Until then, you can always ask Siri how to avoid them altogether, but you may want to leave the house earlier!
Where the idea originated
For the critical thinkers who like to know where this concept of avoiding vertigo on the way to the office originated, here’s a historical detour to see that the idea isn’t new. Roundabouts have been a concept since an 18th century inventor called Pierre L’Enfant designed what became known as “traffic circles” in Washington DC.
The traffic trickery became part of the transportation system in 1905, when the Columbus Circle opened in New York City—one of the first traffic circles designed for cars. We have William Phelps Eno to thank (or criticize, depending upon your opinion of roundabouts) for that. The first European roundabout was built in 1907 in Letchworth Garden City, England — not for traffic, but as a pedestrian island. So yes, the early roundabouts weren’t even meant for cars, which might explain why some drivers still treat them like mysterious crop circles.
Improvements were made in the UK in the 1960’s to help prevent circular intersections from locking up, by not allowing vehicles to enter the intersection until there were enough gaps in circulating traffic. In addition, smaller circular intersections were proposed to not just fit the geography but that made vehicles turn more tightly, resulting in slower entry and circulating speeds.
The modern roundabout has greatly improved in terms of operations and safety, when compared with older roadway rotaries. The benefits of which include:
- Promoting lower speeds and traffic calming which reduces incidents;
- Reducing conflict points and traffic back-ups which improves traffic flow and reduces driver anxiety and frustration;
- Improving vehicle operational performance (e.g., gas conservation, reducing engine overheating, etc.); and
- Meeting a wide range of traffic conditions with versatility in size, shape, and design.
These obnoxious orbs are popping up everywhere across the U.S. and Canada, but now you are prepared to circle in style!
Key to remember: Roundabouts aren’t just a fancy way to make you feel like a NASCAR driver. Once you crack the circular code, you may just embrace these engineering superheroes for their ability to not only reduce traffic jams and fender benders but save lives!
NewsUnified Carrier Registration Agreement (UCR)Federal Motor Carrier Safety Administration (FMCSA), DOTChange NoticesChange NoticeFocus AreaFleet OperationsEnglishTransportationRegistration and Permits - Motor CarrierUSA
2026-09-01T05:00:00Z
FMCSA Final Rule: Fees for the Unified Carrier Registration Plan and Agreement
FMCSA amends the regulations governing the annual Unified Carrier Registration (UCR) Plan and Agreement registration fees that participating States collect from motor carriers, motor private carriers of property, brokers, freight forwarders, and leasing companies. On September 18, 2025, the UCR Board recommended a fee increase for the 2027 registration year and subsequent registration years, averaging 20 percent over the fee structure adopted for 2025 and retained for 2026, with increases ranging from $9 to $9,329 per entity depending on the applicable fee bracket. Although the fees for registration year 2027 are increased, they remain lower than the fees in effect during registration years 2019 through 2022. FMCSA adopts the recommended fee increase.
DATES: Effective October 1, 2026. Petitions for reconsideration of this final rule must be submitted to the FMCSA Administrator no later than October 1, 2026.
Published in the Federal Register September 1, 2026, page 56063.
View final rule.
| §367.30 Fees under the Unified Carrier Registration Plan and Agreement for Registration Year 2023 | ||
| Entire section | Removed, §367.40 redesignated as §367.30 | View Text |
| §367.40 Fees under the Unified Carrier Registration Plan and Agreement for Registration Years Beginning in 2025 and Ending in 2026 | ||
| Entire section | §367.50 redesignated as §367.40, revised | View Text |
| §367.50 Fees under the Unified Carrier Registration Plan and Agreement for Registration Year 2027 and Subsequent Years | ||
| Entire section | Added | View Text |
Previous Text
§367.30 Fees under the Unified Carrier Registration Plan and Agreement for Registration Year 2023.
| Bracket | Number of commercial motor vehicles owned or operated by exempt or non-exempt motor carrier, motor private carrier, or freight forwarder | Fee per entity for exempt or non- exempt motor carrier, motor private carrier, or freight forwarder | Fee per entity for broker or leasing company |
|---|---|---|---|
| B1 | 0-2 | $41 | $41 |
| B2 | 3-5 | 121 | |
| B3 | 6-20 | 242 | |
| B4 | 21-100 | 844 | |
| B5 | 101-1,000 | 4,024 | |
| B6 | 1,001 and above | 39,289 |
§367.40 Fees under the Unified Carrier Registration Plan and Agreement for Registration Years Beginning in 2025 and Ending in 2026.
| Bracket | Number of commercial motor vehicles owned or operated by exempt or non-exempt motor carrier, motor private carrier, or freight forwarder | Fee per entity for exempt or non-exempt motor carrier, motor private carrier, or freight forwarder | Fee per entity for broker or leasing company |
|---|---|---|---|
| B1 | 0-2 | $46 | $46 |
| B2 | 3-5 | 138 | |
| B3 | 6-20 | 276 | |
| B4 | 21-100 | 963 | |
| B5 | 101-1,000 | 4,592 | |
| B6 | 1,001 and above | 44,836 |
NewsIndustry NewsIndustry NewsFleet SafetyFederal Motor Carrier Safety RegulationsEntry-Level driver trainingEntry-level driver trainingCMV drivingFocus AreaFleet OperationsEnglishTransportationBusiness planning - Motor CarrierUSA
2026-09-02T05:00:00Z
Steps to bring trucking industry fraud to a halt
Federal officials recently announced their interagency effort to identify and eliminate fraud in the trucking industry, reduce roadway fatalities, and protect the nation’s highway safety.
Through the actions of the Department of Transportation (DOT), the Department of Homeland Security (DHS), and the Department of Justice (DOJ), these agencies have pooled their resources together to enact widespread change.
DOT’s actions
Along with removing over 28,000 unqualified drivers from roadways, canceling 30,000 illegally issued licenses, and removing over 8,000 unqualified training schools from the Entry-Level Driver Training (ELDT) Training Provider Registry (TPR) over the past year and half, the DOT’s most recent steps toward enforcing greater safety and less fraud include:
- “The Emergency Removal of Training Providers,” which involves removing over 110 ELDT providers from the TPR due to not meeting the English Language Proficiency requirements;
- “Performing Targeted Investigations and Proposing Removals,” which involved non-compliance in terms of training driving space, instructors, documentation, and classroom location; and
- “Conducting a Nationwide Audit of Third-Party Skills Testers,” which involves holding states accountable for failing to compliantly authorize third-party testers.
DHS’s actions
The DHS has begun a criminal investigation across the commercial driver’s license (CDL) and commercial trucking spaces to identify fraud, financial crimes, exploitation, and potential human/drug trafficking activities, including:
- A synchronized investigation at over 200 CDL-related schools, carriers, employers, and businesses;
- Publicizing over 1,000 CDL-related leads from companies suspected of transportation-related offenses;
- Investigations concerning fraudulent and unauthorized activities related to CDL fraud, unauthorized employment, and fraudulent medical certification.
DOJ’s actions
The DOJ announced its upcoming creation of the Joint Task Force Crossroads of America, which will:
- Protect U.S. borders and roadways to reduce fatalities, injuries, and criminal activity;
- Team up U.S Attorney’s Offices in IL, IN, MI, and OH with state police and federal partners.
NewsIndustry NewsFleet SafetyRisk Management TransportationRisk Management - Motor CarrierDriver qualificationsDrivers qualification (DQ file)Focus AreaIn-Depth ArticleEnglishTransportationUSA
2023-03-17T05:00:00Z
When a fleet is acquired, are new DQ files and queries needed?
Carrier acquisitions have increased based on 2022 trucking industry data. During and after an acquisition, questions arise regarding driver qualification (DQ) files and Clearinghouse queries for the acquired fleet’s drivers.
Federal Motor Carrier Safety Administration (FMCSA) allows an acquiring carrier to accept the DQ files from the acquired company and forego a pre-employment query. Below are FMCSA’s requirements in more depth and industry best practices to mitigate DQ file and query risks at the time of an acquisition.
FMCSA guidance
1. DQ files - An acquiring carrier does not have to create a new DQ file for drivers when:
- The acquired company deactivates their United States Department of Transportation (USDOT) number and Federal Employer Identification Number (FEIN), and
- There is no break in employment for the drivers.
“No break in employment” means that the acquired company’s drivers did not have to reapply for their job.
Best Practice: To avoid confusion during an FMCSA audit, put a note in each file showing that the driver files were part of an acquisition, along with the date the drivers started working for the acquiring company.
2. Clearinghouse queries - There is no need to run a pre-employment Drug and Alcohol Clearinghouse query for the acquired company’s commercial driver’s license (CDL) drivers if there is no break in employment. However, an annual query must be run within one year of the last query while at the acquired company. The dates of the prior annual query may be a different date for each driver, which is not easy to track.
Best Practice: Run the annual query on the new drivers before they operate a commercial motor vehicle (CMV) requiring a commercial driver’s license (CDL) for the acquiring company. This query is to verify that no driver is in a “Prohibited” status due to a positive test and missing a negative return-to-duty test. The query also resets the next annual query date to a known day a year in advance for each driver.
What are the risks of not creating new DQ files?
The acquiring company owns all errors and omissions in a DQ file. If, for any reason, a driver is not fully qualified and all documents are not current, the acquiring carrier is responsible.
Suppose serious violations on a new driver’s motor vehicle record (MVR) do not meet the company’s hiring criteria. If an MVR wasn’t run as is normally required for new-hire DQ files, a plaintiff’s attorney may accuse the acquiring company of negligent hiring in post-crash litigation.
Best practices:
- Audit each file for compliance gaps as part of the acquisition process.
- Document violations along with remedial actions, if any.
- Review the MVR and any other performance history available for each driver.
If documents are missing or incorrect, the acquiring carrier would still be subject to a violation if audited by FMCSA. Acknowledging errors and documenting “meaningful action” could mitigate penalties.
Keys to remember: Audit the DQ files of an acquired company’s drivers and document compliance issues and remedial actions. Also, run an annual query to detect drivers prohibited from driving a CMV.
NewsIndustry NewsEnglishFleet SafetyFocus AreaIn-Depth ArticleEnforcement - DOTRoadside InspectionsTransportationUSA
2022-07-08T05:00:00Z
What does the alphabet soup following 392.2 on a roadside inspection report mean?
One question that comes up when reviewing roadside inspection reports is, “What is the meaning of the letters that follow a violation of 392.2 on a roadside inspection report?”
‘State and local laws’
A violation of 392.2 is a violation of a local or state law, regulation, or ordinance. These must be obeyed due to 392.2, which reads, “Every commercial motor vehicle must be operated in accordance with the laws, ordinances, and regulations of the jurisdiction in which it is being operated.”
The confusion is that there are no paragraphs in 392.2, so there technically should be no letters following that section. However, to inform the driver, carrier, and the Federal Motor Carrier Safety Administration (FMCSA) what particular state or local law or regulation was involved, FMCSA has developed a system of suffix codes. The letters following “392.2” – the “suffix” — show which state or local law or regulation was involved.
When one of these codes is used, the officer should include a description of the specific violation in the “violation details” area on the actual inspection report. FYI: Summary roadside inspection reports (such as the ones visible in CSA’s SMS) do not show these details.
| For more information, see our ezExplanation on Roadside Inspections. |
Not all 392.2 violations are used in CSA
Not all of these state and local law or regulation violations are used by the FMCSA for scoring purposes. The Compliance, Safety, Accountability (CSA) Safety Measurement System (SMS) does not use the 392.2 violations that cannot be tied to crash causation. Here are a couple of examples: 392.2UCR Failure to pay UCR fee and 392.2W Size and weight are not used.
Most common 392.2 violations
Below are the top 10 392.2 violations written during 2021. All of these violations are safety-related, and therefore used in the CSA SMS for scoring. The BASIC within the SMS the violation is scored in is shown following the violation description.
- 392.2SLLS2 Speeding 6-10 miles per hour over the speed limit (Unsafe Driving)
- 392.2C Failure to obey traffic control device (Unsafe Driving)
- 392.2LV Lane Restriction violation (Unsafe Driving)
- 392.2SLLS3 Speeding 11-14 miles per hour over the speed limit (Unsafe Driving)
- 392.2WC Wheel (Mud) flaps missing or defective (Vehicle Maintenance)
- 392.2SLLS4 Speeding 15 or more miles per hour over the speed limit (Unsafe Driving)
- 392.2ML Failure to maintain lane (Unsafe Driving)
- 392.2SLLSWZ Speeding work/construction zone (Unsafe Driving)
- 392.2PK Unlawfully parking and/or leaving vehicle in the roadway (Unsafe Driving)
- 392.2FC Following too close (Unsafe Driving)
Key to remember
In general, FMCSA does not write traffic codes. They rely on local and state agencies to do that. When state or local traffic codes are violated, it appears on a roadside inspection report as a violation of 392.2, with a suffix indicating which traffic code was involved.
NewsIndustry NewsFleet SafetyLoading and unloading - Motor CarrierCargo loading and securementFocus AreaIn-Depth ArticleCargo securementEnglishTransportationWheel chocks - Motor CarrierUSA
2026-08-20T05:00:00Z
When a routine pickup turns fatal
A truck driver’s routine pickup became a deadly reminder of how quickly loading operations can go wrong, especially when equipment doesn’t perform as expected and safe loading procedures break down.
According to a Washington State investigation, a 63-year-old truck driver with decades of experience was killed after being crushed by a yard tractor he was loading onto a beavertail gooseneck semi-trailer.
The yard tractor required a jump-start, but once it was running, the engine began revving uncontrollably and the brakes didn’t work. Nevertheless, the driver drove the tractor onto the deck until it came to rest against the front of the trailer. The driver began securing the tractor and was positioned between the axles when it suddenly rolled backward and crushed him. He died two days later from his injuries.
A chain of risks
This incident was not caused by a single mistake. Investigators identified several contributing factors:
- The driver was unaware of the tractor’s unsafe brakes before arriving to pick it up. The vehicle also had an unsafe gear shifter. The bill of sale only indicated that the equipment would not start and needed a new battery.
- The driver left the tractor in neutral with the engine running, its parking brakes released, and its wheels unchocked before he went underneath it.
- The driver’s employer had no standard operating procedures for loading yard tractors or similar equipment.
A common scenario
Many open-bed carriers move wheeled equipment like yard tractors, forklifts, sweepers, farm equipment, or other heavy machinery that’s not designed for highway use. Too often, these loads are treated as routine, especially by experienced drivers who have “done it before.”
The danger is that loading operations can introduce serious hazards, especially when the driver is unfamiliar with the equipment or is unaware of defects. Once a driver is on a trailer deck with a heavy piece of equipment, there is very little room for error.
Develop a loading-specific procedure
A generic cargo securement policy is not enough. Motor carriers should have written procedures for loading powered equipment, including:
- Required training before operating unfamiliar equipment,
- Pre-pickup equipment assessments to uncover safety defects,
- Communication with sellers regarding known defects,
- Safe loading methods,
- Required securement devices, and
- Emergency response steps when equipment malfunctions.
Drivers should be trained — and reminded about — the danger of putting themselves in harm’s way, even for a moment. Each loading operation can create unique challenges, but drivers should never place themselves under equipment unless it has been positively secured against movement using approved methods.
Used and abused
Highly used (and abused) equipment often comes with unknown risks. Before dispatching a driver, carriers should gather as much information as possible regarding the load’s condition as it relates to driver safety, including brake functionality and steering or transmission issues.
If the equipment cannot be safely operated onto the trailer, alternative loading methods should be considered.
Even when the brakes are functioning, drivers should be equipped with wheel chocks or other methods to prevent movement while the equipment is secured.
When a loading or securement operation doesn’t go as planned, the safest decision may be to stop. Requiring drivers to contact a supervisor when they encounter unexpected safety issues during loading can prevent on-the-spot decisions that expose them to hazards.
Key to remember: Equipment loading operations present unique challenges, and experience does not eliminate risk, as highlighted by a driver’s recent, tragic fatality. Ensure drivers are trained and equipped to manage the hazards.
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.
NewsIndustry NewsPerformance ManagementDisciplineEmployee RelationsIn-Depth ArticleUSAHR ManagementEnglishFocus AreaHuman Resources
2026-09-03T05:00:00Z
Playlist: Handling employee misconduct
Employee misconduct can range from repeated policy violations and inappropriate workplace behavior to more serious offenses that may warrant immediate action. For supervisors, knowing how to respond consistently, fairly, and legally can be challenging. This playlist brings together Compliance Network resources that help managers distinguish between performance problems and misconduct, apply progressive discipline appropriately, document issues effectively, and determine when corrective action, a Performance Improvement Plan (PIP), or termination may be warranted. Whether you're addressing a first-time offense or navigating a more serious situation, these resources provide practical guidance.
- Start with a review of employee relations basics.
- Determine whether the problem can be resolved by using a Performance Improvement Plan (PIP), or if it’s a conduct issue and possibly serious enough to move directly to termination.
- Understand the purpose of employee discipline before moving forward.
- Follow the steps of progressive discipline.
- If necessary, write up an incident report.
This playlist brings together key Compliance Network resources to simplify the employee discipline. For deeper guidance, consider exploring related topics such as Termination, HR Policies, Performance management, and Discrimination within Compliance Network.
A Compliance Network playlist is a curated collection of practical resources designed to help you quickly address a specific event, task, or compliance challenge. Each playlist brings relevant guidance together in one place so you can spend less time searching and more time taking action. Stay tuned — more practical, ready-to-use collections are coming soon.
NewsHR ManagementEnglishTalent Management & RecruitingAssociate Benefits & CompensationWage and HourChange NoticesChange NoticeWage and HourCaliforniaHR GeneralistMinimum WageNon-Exempt employees Associate RelationsFocus AreaHuman Resources
2026-08-11T05:00:00Z
California will increase minimum wage, salary in 2027
Effective date: January 1, 2027
This applies to: Employers with employees in California
Description of change: Under California Labor Code section 1182.12(c), the state's minimum wage will increase from $16.90 to $17.40 per hour, effective January 1, 2027. The annual salary threshold for exempt employees will increase from $70,304 to $72,384 in 2027.
View related state info: Minimum wage - California
NewsIn-Depth ArticleUSAHR ManagementEnglishTalent Management & RecruitingAssociate Benefits & CompensationDiscriminationGender DiscriminationDiscriminationTitle VII (The Civil Rights Act of 1964)Industry NewsRecruiting and hiringProtected classesRecruiting and hiringApplications/ApplicantsHR GeneralistAssociate RelationsFocus AreaHuman Resources
2026-08-27T05:00:00Z
Want to hire only men? Here are $2.6 million reasons not to
Southern summers are hot, and a federal agency turned up the July heat even more on an Alabama recycling plant that engaged in sex-based discriminatory hiring practices. Now the company that owns the plant must pay $2.6 million and provide other relief to settle a lawsuit, according to a recent press release by the U.S. Equal Employment Opportunity Commission (EEOC).
What happened?
The EEOC’s suit charged that the company intentionally violated federal law by engaging in a long-standing pattern of refusing to hire female laborers at one of its plants. This potentially impacted thousands of women, according to the EEOC.
Hiring compliance problems allegedly began in 2006 when the company purchased the plant. Through late 2022, the company intentionally hired only men for laborer positions and converted showers and locker rooms to male-only facilities.
When the company began outsourcing its labor staffing to third-party agencies, it directed them to refer only male applicants even when qualified female candidates were available.
The lawsuit also alleged that the company’s discriminatory practices continued even after the EEOC investigated a whistleblower complaint made by a long-tenured employee who was terminated for telling the truth about its hiring practice. The EEOC previously settled the whistleblower’s retaliation case for $90,000.
More than just a fine
Under the 3-year consent decree resolving the lawsuit, the company will not only pay $2.6 million in monetary damages to compensate women who were denied employment, it must also:
- Hire a Title VII coordinator
- Provide mandatory anti-discrimination training to its managers and employees
- Notify all staffing agencies it works with not to comply with any discriminatory requests, and
- Post a notice to employees about the settlement and how to report any future discrimination.
Staffing agencies dinged, too
The EEOC also fined the two staffing agencies that went along with the company’s illegal hiring scheme. Although the fines were substantially lower for the agencies, chances are they’re on the EEOC’s radar now, as well.
‘Why can’t we just hire men?’
This might’ve been the question company leaders asked prior to the EEOC lawsuit. And, in RARE cases an employer can consider sex when hiring. Sex can be considered where it’s a bona fide requirement. For example, an employer looking to hire models for women’s clothing wouldn’t need to consider male applicants.
But for anyone wondering why the recycling plant couldn’t only hire men, here’s the reason:
Title VII of the Civil Rights Act of 1964 is a federal law enforced by the EEOC. The law prohibits employment discrimination based on protected characteristics, like:
- Race
- Color
- Religion
- Sex
- National origin
Title VII says it’s illegal to discriminate based on protected categories (like sex) in any aspect of employment, like:
- Hiring and firing;
- Compensation, assignment, or classification of employees;
- Transfer, promotion, layoff, or recall;
- Job advertisements;
- Recruitment;
- Testing;
- Use of company facilities;
- Training and apprenticeship programs;
- Fringe benefits;
- Pay, retirement plans, and disability leave; or
- Other terms and conditions of employment.
While that’s a long list of rules, it’s a lot easier to digest than a $2.6 million fine.
Key to remember: Costly lessons in a hiring discrimination case can be a “don’t do what we did” moment for other employers wondering why they can’t hire only men.
NewsIndustry NewsHR GeneralistFamily and Medical Leave Act (FMLA)In-Depth ArticleFamily and Medical Leave Act (FMLA)Associate RelationsEnglishUSAHR ManagementFocus AreaHuman Resources
2022-12-14T06:00:00Z
Must employers tell employees if they run out of FMLA?
There’s a lot to keep track of when administering employees’ time off, especially when it falls under the Family and Medical Leave Act (FMLA).
Employers might wonder if they need to tell employees when their FMLA leave is running out. And the simple answer is “not really.”
Neither the statute nor the regulations specifically require you to notify or remind employees that their FMLA leave exhausted or is close to it. If you know how much time FMLA leave an employee is taking, you are, however, required to include that information on the designation notice. But, otherwise, there isn’t any other form or required document to tell an employee, “Hey, you’re running low on FMLA leave.”
Does this mean you may not give employees such a reminder?
Again, the simple answer is “no.” Employers may even have good arguments for doing so.
Why a gentle reminder can be helpful
When employees are on FMLA leave, the reason behind the need for leave will probably be of great importance to the employee. It could be because a baby was born or because a family member has a serious health condition. In any case, the employees most likely have a lot on their mind. They might not be constantly thinking about when they will return to work or when they will run out of FMLA leave.
Providing a gentle reminder can show employees that you’re thinking of them, and that you expect them to return on a particular date. Employees generally appreciate knowing what is expected of them. Giving them such a reminder can also help allay any questions about whether they knew they were expected back on such a date.
This could also be a good opportunity to remind employees that if they cannot return to work because of continued issues with their own serious health condition, they should let the employer know. In cases like this, an employer then can engage in an interactive process (dialogue) with the employee regarding possible reasonable accommodations under the Americans with Disabilities Act. One accommodation, for example, might be more leave time.
Providing employees with reminders about how much leave time they have left can also address the consequences for any absences after FMLA protections expire. This is especially important in terms of maintaining employee benefits.
Designation notice changes
If the information in the designation notice changes, such as if the employee exhausts FMLA leave then requests more leave, you must provide a written notice of the change. Like with the original designation notice, a change notice must be given to the employee within five business days of receipt of the employee’s first notice of need for additional leave.
Therefore, if, after an employee exhausts all 12 weeks of FMLA leave, the employee asks for more leave, you are to notify the employee of the changes to the designation notice. You may use another designation notice if you wish, but you are not required to do so. You could simply indicate to the employee that there is no more FMLA leave available, so the additional leave will not be designated as FMLA leave.
Key to remember: Keeping the lines of communication open between you and employees who are on FMLA leave can benefit both employers and employees, even if all types of communication aren’t necessarily required.
NewsIndustry NewsRecordkeepingRecordkeepingHR GeneralistFamily and Medical Leave Act (FMLA)In-Depth ArticleFamily and Medical Leave Act (FMLA)HR ManagementEnglishUSAFocus AreaHuman Resources
2026-05-20T05:00:00Z
Do the FMLA notices and certifications expire in June?
The answer to that question for employers is, “No.” The answer to that question for the U.S. Government’s Office of Management and Budget (OMB), however, is, “Yes.”
Employers might notice that the following federal Family and Medical Leave Act (FMLA) documents from the U.S. Department of Labor (DOL) have an expiration date listed as “6/30/26” in the upper right-hand corner:
- WH-381: Eligibility/Rights and Responsibilities Notice
- WH-382: Designation notice
- WH-380-E: Certification of an employee’s serious health condition
- WH-380-F: Certification of a family member’s serious health condition
- WH-384: Certification of a qualifying exigency
- WH-385: Certification for military caregiver of a current military member
- WH-385-V: Certification for military caregiver of a veteran
This, however, doesn’t mean that employers aren’t allowed to use these forms after that date. They may. Employers and employees are allowed to use the current forms beyond that date because the content remains applicable under FMLA law.
The June 30, 2026, date on the FMLA notices and certification forms, doesn’t represent a deadline for FMLA leave itself. It’s the OMB’s expiration date for the forms’ collection and recordkeeping requirements, not the end of the forms’ legal validity.
What the date means
These government documents are subject to certain checks and balances, such as the following:
- OMB control number 1235‑0003 governs the collection of information from employers and employees for DOL compliance purposes.
- The June 30, 2026, date is when the latest version of the forms will be replaced by a new OMB‑approved version.
The OMB has to review the FMLA notices and certification forms every 3 years. The last time it did so, it didn’t make any material changes.
The OMB is part of the U.S. Executive Office and helps the president meet policy and budget, manage details, oversee regulatory objectives, and helps fulfill the agency’s statutory responsibilities.
Model forms optional
Employers aren’t required to use the DOL’s model forms. Many do, however, because it’s easier than creating their own forms. Using the DOL’s forms also helps ensure the notices provide enough information and the certifications don’t ask employees for information beyond what the FMLA allows.
Key to remember: The June 30, 2026, expiration date of FMLA documents is just a form‑collection deadline, not a legal cutoff for FMLA leave or certification. Employers may still use the current forms until a new version is issued.
Most Popular Highlights In Safety & Health
NewsIndustry NewsSafety & HealthConstruction SafetyGeneral Industry SafetyMachine GuardingAbrasive Wheel MachinesIn-Depth ArticleEnglishMachine GuardingFocus AreaUSA
2026-09-03T05:00:00Z
Abrasive wheel machines: small gaps, serious consequences
A bench grinder can look harmless sitting in the corner of a shop until a damaged wheel, missing guard, or small adjustment gap turns a quick grinding job into a serious injury. OSHA accident records include cases involving fractured wheels, facial injuries, amputations, and fatalities tied to abrasive wheel equipment. More recently, OSHA cited a machine shop after employees using a bench grinder were exposed to struck-by hazards because the distance between the wheel and adjustable tongue guard exceeded the allowable one-fourth inch limit.
When hazards often begin
One challenge with abrasive wheel machines is that hazards can develop while the machine still appears to operate normally. The grinder turns on, the wheel spins, and employees continue working or adapt to deficiencies because no injury has occurred, creating a false sense of security.
Abrasive wheel machines are common, familiar, and often used for short tasks such as sharpening tools, smoothing rough edges, removing burrs, or preparing materials for production. Conditions that seem minor on the surface can expose employees to serious struck-by, contact, and fragmentation hazards. Common abrasive wheel machine hazards include:
- Contact with the rotating wheel,
- Flying sparks and debris,
- Wheel breakage or fragmentation,
- Material being pulled between the wheel and support surfaces,
- Improper wheel installation, and
- Inadequate eye and face protection.
What OSHA frequently evaluates
OSHA looks at whether the machine’s safeguards are in place, properly adjusted, and maintained to protect employees during use. As wheels wear down, the relationship between the wheel, work rest, and tongue guard changes with it. These changes happen a little at a time, they can be easy to miss during day-to-day work. If those adjustments aren’t made, a machine that may have been compliant when it was first set up can gradually become unsafe.
Inspections and employee awareness need to work together
Consistent inspections and effective training should work together. Inspections give employers a structured way to verify that abrasive wheel machines remain safe to use, especially after wheel replacement, maintenance activities, or extended periods of use. Training helps employees recognize the warning signs that may show up between those inspections, including unusual vibration, unfamiliar sounds, changes in performance, or equipment conditions that do not look right. Together, inspections and training should help employees evaluate:
- Wheel condition, including cracks, damage, or improper installation,
- Guard condition and proper placement,
- Excessive vibration, unusual sounds, or changes in performance,
- Signs of wear, loose components, or unauthorized modifications, and
- Conditions that require the machine to be removed from service.
Multiple layers of protection provide the best defense
No single safeguard eliminates every abrasive wheel hazard. The strongest programs use multiple layers of protection because wheel condition, machine adjustment, employee behavior, and PPE all affect whether the equipment is safe to use. Those layers should include:
Maintain effective machine guarding: Damaged, altered, or missing guards should be repaired or replaced promptly.
Establish preventative maintenance practices: Regular maintenance helps keep guards, adjustment points, and machine components in safe working conditions.
Encourage employee involvement: Employees should be encouraged to speak up and stop using equipment when something does not look, sound, or feel right.
Use appropriate personal protective equipment: PPE provides an additional layer of protection and works best when combined with engineering and administrative controls, not used as a substitute for them.
Key to remember: Consistent inspections, proactive maintenance, and employee awareness help prevent abrasive wheel equipment from becoming a serious injury hazard.
NewsIndustry NewsSafety & HealthElectrical SafetyElectrical Safety Construction StandardsConstruction SafetyGeneral Industry SafetyElectrical SafetyIn-Depth ArticleEnglishFocus AreaUSA
2023-02-16T06:00:00Z
Worker who died by electrocution found to be avoidable
OSHA cited an employer in January 2023 after allegedly failing to de-energize equipment while an worker performed service and maintenance activities on a rooftop air conditioning.
“This worker’s death was avoidable. Employers must follow well-known electrical safety procedures set forth in federal regulations and industry-recognized practices,” said an OSHA Area Director.
Electricity has long been recognized as a serious workplace hazard, exposing employees to such dangers as electrical shock, electrocution, burns, fires, and explosions.
The technician succumbed to his injuries after being shocked. Workers must understand the following:
- Causes of electrical accidents,
- Understanding what electrical shock is, and
- Applying safe work practices.
Understanding these topics is essential in avoiding an electrical accident.
What causes electrical accidents?
Electrical accidents are caused by one or more of the following:
- Unsafe equipment and/or installation.
- Unsafe workplaces caused by environmental factors.
- Unsafe work practices.
An accident such as high-voltage shocks can cause serious injury or even death.
How can it hurt me?
The effects of an electrical shock on the body can range from a tingle to immediate cardiac arrest.
Electrical currents travel in closed circuits through conducting material. Workers can receive a shock when a part of their body comes into contact with the following:
- Both wires of an electrical circuit.
- One wire of an energized circuit and the ground.
- Part of a machine that is ’hot’ because it is contacting an energized wire and the ground.
Severe shock can cause more damage than can be seen by the naked eye.
Safety 101
Workers must:
- Always make sure equipment is de-energized.
- Maintain electrical equipment.
- Regularly inspect tools, cords, grounds, and accessories. Have damaged equipment taken out of service immediately.
- Always use safety features like three-pronged plugs, double-insulated tools, and safety switches.
- Make sure that all machine guards are in place.
- Keep electrical cables and cords clean and free from kinks. Never carry equipment by the cord.
- Avoid touching water, damp surfaces, ungrounded metal, or any bare wires if you are not protected. Wear approved rubber gloves when working with live wires or ungrounded surfaces. Rubber-soled shoes or boots should be worn when working on damp or wet surfaces.
- Avoid wearing jewelry or metal objects when working with electricity.
- Keep the required safe distance from energized parts.
If workers are working where there are electrical hazards, employers must provide them with the appropriate PPE. Ensure that the equipment remains de-energized during service and maintenance activities by using lockout/tagout procedures.
Key to remember
Ensure that workers are familiar with the safety procedures for the job they are assigned to do. They should always use good judgment and common sense when working around electricity.
NewsIndustry NewsConfined SpacesSafety & HealthConfined SpacesConstruction SafetyGeneral Industry SafetyPermit-Required Confined SpacesConfined Space HazardsConfined Space Entry PermitIn-Depth ArticleEnglishFocus AreaUSA
2023-05-18T05:00:00Z
Breaking the plane of a confined space doesn’t require a complete entry
Did you know that OSHA’s standard on permit-required confined spaces (PRCS) says entry occurs as soon as any part of the entrant’s body breaks the plane of the opening into the permit space?
Many workers and employers mistakenly think that placing part of the body or hands into a confined space isn’t entry. Knowing the difference between when entry occurs and not will help employers determine if a permit is required.
Letters of Interpretation
As clarified in an OSHA Letter of Interpretation (LOI) dated October 18, 1995, “When any part of the body of an entrant breaks the plane of the opening of a PRCS large enough to allow full entry, entry is considered to have occurred and a permit is required, regardless of whether there is an intent to fully enter the space.”
This definition of “entry” might seem to be too strict. Still, OSHA’s letter clarifies that there are situations where a partial entry would be hazardous: “Examples of situations where entry by only part of the body into a PRCS can expose an entrant to the possibility of injury or illness are as follows:
- An entrant can possibly suffer a burn while reaching into a PRCS, which is so classified because it contains a thermal hazard.
- An entrant can possibly fall into a below-grade PRCS while standing on a vertical ladder in the opening of the space, which is so classified because it contains an oxygen-deficient atmosphere.
- An entrant can possibly become unconscious as result of his head accidentally entering a PRCS while they are reaching into a PRCS, which is so classified because it contains an oxygen deficient atmosphere.”
As another example, if the space contains a flammable or oxygen-enriched atmosphere, and if the activities during a partial entry could produce a spark or other ignition source, then a fire in the space could flash out of the opening and cause serious injuries to the employee.
OSHA’s guidance continues
This doesn’t necessarily mean you’d be fined if a permit wasn’t followed when someone reached a tank. OSHA’s guidance continues: “However, if entry by only part of the body does not expose the entrant to the possibility of injury or illness, then the violation may be considered a ‘de minimis’ violation.”
A de minimis violation is one in which a standard is violated, but the violation has no direct or immediate relationship to employee safety or health. These violations are documented but no citations are issued.
OSHA says examples of situations where entry by only part of the body into a PRCS would not expose an entrant to the possibility of injury or illness are as follows:
- An entrant reaches through the opening of a horizontal PRCS, which is so classified only because it contains exposed live electrical parts ten feet from the opening.
- An entrant puts his head through the opening of an overhead PRCS, which is so classified only because it contains unguarded rotating parts ten feet from the opening.
Also, consider a situation such as a worker reaching through a small grate to take a sample from a permitted space. The LOI further states, “If a part of the body were placed in an opening through which the worker could not pass into the permit-required confined space, no PRCS entry will have occurred.”
Keep in mind, however, that the employee would still need protection from any hazards involved in the task, but a permit would not be needed.
Key to remember
When any part of the body of an entrant breaks the plane of the opening of a PRCS large enough to allow full entry, entry is considered to have occurred, and a permit is required.
NewsIndustry NewsAt-Will EmploymentSafety & HealthGeneral Industry SafetyTerminationHR GeneralistIn-Depth ArticleUSAHR ManagementEnglishTerminationFocus AreaHuman Resources
2024-08-28T05:00:00Z
When to skip a PIP and move to terminate an employee
The U.S. Bureau of Labor statistics reported in July 2024 that there are 8.2 million job openings in the U.S., but only 7.2 million unemployed workers.
With that in mind, employers might choose to hang onto employees even if they’re under performing. But what about when complaints are rolling in from different angles? Take, for example, a lackluster supervisor who’s annoying employees and disappointing customers.
An employer could be hesitant to let the supervisor go, especially if there’s no documentation backing up claims of misconduct. The employer must weigh their options to decide if putting the supervisor on a performance improvement plan (PIP) or moving right to termination is the ideal choice.
For starters, in most states employers may terminate an employee at-will, meaning they can fire employees for pretty much any reason as long as it doesn’t discriminate against someone in a protected class based on sex, age, race, religion, etc. Employers also cannot terminate in retaliation for an employee making a claim of harassment, discrimination, or safety concerns.
Aside from these limits, employers can terminate employees for good cause, bad cause, or no cause at all.
PIP or terminate
Deciding whether to put an employee on a PIP or terminate must be decided on a case-by-case basis.
A PIP is usually for job performance issues (hence, performance improvement plan). This could mean anything from not making enough sales to being inept at the job’s essential functions. If job performance doesn’t improve under the PIP, termination may be the end result depending on company policies and practices.
Even if an employee has job performance issues, the employer can terminate without going through the PIP process first, unless the usual process is to implement a PIP with employees who have had similar problems. In that case, not doing a PIP could be seen as discrimination against an employee, especially if the person falls into a protected class.
Workplace misconduct, however, is another situation altogether. This could be anything from a one-off poor joke to pervasive harassment. Snapping at customers or coworkers (or worse), for example, is a conduct issue. An employer could issue a warning or move right to termination if the behavior is clearly illegal or a serious threat to workplace safety.
| Read more: ezExplanation on discharging employees |
Termination tips
If an employer decides to terminate, they should treat the employee as respectfully as possible during the termination process. Also, an employer should carefully and clearly communicate the job-related reasons for the termination to avoid any hint of discrimination. Lastly, an employer should document the reasons and reiterate the steps taken leading up to the termination and keep those records handy in case the employee files a wrongful termination lawsuit.
Key to remember: Employers sometimes struggle when making termination decisions. Having a process in place and documenting steps along the way can help if a case lands in court.
NewsIndustry NewsSafety & HealthGeneral Industry SafetyFocus AreaIn-Depth ArticleEnglishMachine GuardingMachine GuardingUSA
2024-03-19T05:00:00Z
Drilling into the four types of machine guards
Machine operators and employees working close to machines face an array of workplace hazards caused by moving machine parts. Possible injuries range from minor abrasions to amputations and crush injuries. The regulations at 29 CFR 1910.212 contain the general guarding standards that apply to all machines. OSHA requires employers to use one or more methods to safeguard any machine part, function, or process that may cause injury (1910.212(a)(1)). A primary safeguarding method is machine guarding, which places physical barriers between employees and the danger areas of machines that could cause injury.
Not all machines are the same, and neither are their guards. Let's drill into the four different types of machine guards to better understand how each one protects workers from hazards.
Fixed guards
A fixed guard is just that — permanently fixed to the machine. It prevents workers from accessing dangerous moving parts of a machine. It’s a physical barrier that doesn’t rely on moving parts to function. Removing the barrier requires tools, so these guards are typically used on parts of machinery that aren’t accessed frequently, like a protective cover that fully encloses a machine’s flywheel.
OSHA requires that the barrier be made from materials that can withstand any impact it may receive and endure prolonged use, such as sheet metal, screens, and bars. Fixed guards are best suited for machines involved in high production with repetitive operations.
Interlocked guards
Opening or removing an interlocked guard on a machine shuts off or disengages the power and stops the machine’s moving parts. The machine can’t start again until the guard is back in place. Interlocked guards require electrical, mechanical, hydraulic, or pneumatic power (or a combination of these) to function. This is where the “interlocked” part comes in; these guards are interconnected with the machines they protect. For example, the bowl of an industrial food mixer with an interlocking guard can operate only when the guard is in position over the bowl, which prevents workers from coming into contact with the moving mixing device. When the guard is lifted, the power automatically shuts off, and the mixing device stops.
OSHA recommends making all removable guards interlocked to prevent occupational hazards. The guards must stop machines before workers can reach danger areas. Further, machines shouldn’t automatically restart when interlocked guards are put back in place. Interlocked guards are most effective on machines where operators need to regularly access the guarded parts for things like clearing jams or adding materials.
Adjustable guards
An adjustable guard is a movable barrier permanently fixed to the machine that can be adjusted for various production operations. A machine operator manually positions this type of guard and locks it into place. Due to the guard’s increased risk of injury, employers must establish proper administrative controls and train workers how to use adjustable guards.
Metalworking and woodworking machinery typically have adjustable guards, such as the guard on a horizontal milling machine that allows workers to change the size of the cutter. Adjustable guards are ideal for machines that process different sizes of materials and conduct various processes.
Self-adjusting guards
A self-adjusting guard places a barrier between the danger area and the operator that automatically adjusts to accommodate stock. When stock is moved into a danger area, it pushes the self-adjusting guard away, providing an opening into the machine that’s only large enough to allow the stock through. Once the stock is removed, the self-adjusting guard automatically returns to the rest position (either by gravity or a spring-loaded mechanism).
By automating the adjustment process, these guards eliminate some of the risks associated with adjusting guards. Self-adjusting guards are commonly used on woodworking machines like table saws.
Which guards should your facility use?
The ultimate purpose of all machine guarding is to eliminate or, if that’s not possible, control the hazards of operating or accidentally coming into contact with a machine. However, there’s not a one-size-fits-all solution to machine guarding. Employers must consider many variables specific to their industry, facility, operator involvement, and the machines they use and comply with any applicable regulations.
Machine-specific guarding requirements under 1910 Subpart O apply to:
- Woodworking machinery,
- Abrasive wheel machinery,
- Mills and calendars in the rubber and plastics industries,
- Mechanical power presses, and
- Forging machines.
In addition to the general industry standards at 1910.212, OSHA has industry-specific standards for:
- Maritime (1917 Subpart G and 1918 Subpart I)
- Construction (1926 Subpart I), and
- Agriculture (1928 Subpart D).
Key to Remember: Machine guards protect workers from the hazards of moving machine parts. Employers must determine which of the four types of guards (or a combination of them) works best for each machine.
NewsEmergency Planning - OSHAIndustry NewsSafety & HealthElectrical SafetyGeneral Industry SafetyEmergency ExitsFire Protection and PreventionIn-Depth ArticleFire ExtinguishersEnglishClearance DistancesFocus AreaUSA
2022-07-08T05:00:00Z
Locked/blocked exits prompt $580K in OSHA penalties
A national retailer, with what OSHA calls a long history of violations, was slapped with four willful citations after local fire officials sent a referral to the agency regarding a Wisconsin store. Once inside the store last December and January, OSHA inspectors found a:
- Locked exit — Emergency exit doors to the back receiving room were padlocked with a bike lock and a board placed through the handles. Employees were not able to open an exit route door from the inside at all times without keys, tools, or special knowledge. This violated 29 CFR 1910.36(d)(1). The violation was considered willful and serious because the retailer had previously been cited for the same violation three times elsewhere in the U.S. Now the store received the maximum penalty of $145,027.
- Blocked exit — Merchandise and carts blocked the exit in the receiving room, according to OSHA. The exit route was not kept free and unobstructed, and violated 1910.37(a)(3). This violation too was considered willful and serious because the retailer had been cited previously for the same violation 12 times in the U.S. This time the penalty was the maximum $145,027.
- Blocked extinguisher — A portable fire extinguisher in the back receiving room was obstructed with carts/containers. The extinguishers were not readily accessible per 1910.157(c)(1). OSHA found that the retailer previously violated this regulation twice in the U.S., so the violation was considered willful and serious and picked up another maximum $145,027 penalty.
- Blocked electrical panel — Adequate space around electrical panels was not provided says OSHA. Inspectors found that the employer obstructed the access and working space about electrical panels with carts/containers, in violation of 1910.303(g)(1). The citation explains that the retailer violated that regulation eight previous times in the U.S., and the violation was willful and serious, but OSHA did not propose a penalty amount.
While store managers explained that the doors needed repair to close properly, OSHA determined the doors were in disrepair for three months. The store has settled the case for $435,081 in penalties.
However, in January, a similar inspection was conducted at another one of the retailer’s stores in Ohio. That location was cited for barrel locks on the inside of a double-door emergency exit in the back room in violation of 1910.36(d)(1) . The Ohio store was cited for one willful violation and settled the case with $145,027 in penalties.
It is noteworthy that officials for the company had signed settlement agreements with OSHA in 2017, promising to resolve similar violations at its stores nationwide. However, OSHA officials say, based on the latest violations, the retailer continues to gamble with workers’ lives and must stop before tragedy strikes.
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