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DEPARTMENT OF TRANSPORTATION

Office of the Secretary

49 CFR Part 40

Pipeline and Hazardous Materials Safety Administration

49 CFR Part 199

[Docket DOT-OST-2022-0027]

RIN 2105-AF01

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

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

ACTION: Notice of proposed rulemaking (NPRM).

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

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

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

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

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

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

Fax: 202-493-2251.

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

FOR FURTHER INFORMATION CONTACT:

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

SUPPLEMENTARY INFORMATION:

This NPRM is organized as follows:

I. Executive Summary

II. Public Participation and Request for Comments

A. Submitting Comments

B. Viewing Comments and Documents

C. Privacy Act

III. Legal Basis for the Rulemaking

IV. Background

V. Advance Notice of Proposed Rulemaking (ANPRM) Overview

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

VII. Amending Part 40 To Permit Electronic Documents and Signatures

VIII. Electronic ATF

IX. Section-by-Section Analysis

X. Regulatory Analyses and Notices

I. Executive Summary

Purpose and Summary of the Major Provisions

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

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

II. Public Participation and Request for Comments

A. Submitting Comments

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

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

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

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

B. Viewing Comments and Documents

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

C. Privacy Act

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

III. Legal Basis for the Rulemaking

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

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

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

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

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

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

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

IV. Background

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

3 68 FR 43946 (July 25, 2003).

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

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

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

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

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

V. Advance Notice of Proposed Rulemaking (ANPRM) Overview

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

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

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

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

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

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

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

VII. Amending Part 40 To Permit Electronic Documents and Signatures

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

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

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

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

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

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

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

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

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

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

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

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

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

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

VIII. Electronic ATF

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

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

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

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

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

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

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

IX. PHMSA Proposed Changes

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

X. Section-by-Section Analysis

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

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

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

Section 40.4 May electronic documents and signatures be used?

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

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

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

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

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

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

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

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

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

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

Section 40.79 How is the collection process completed?

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

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

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

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

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

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

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

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

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

Section 40.163 How does the MRO report drug test results?

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

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

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

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

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

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

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

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

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

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

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

Section 40.205 How are drug test problems corrected?

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

Section 40.225 What form is used for an alcohol test?

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

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

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

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

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

Section 40.271 How are alcohol testing problems corrected?

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

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

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

X. Regulatory Analyses and Notices

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

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

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

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

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

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

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

Unfunded Mandates

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

Environmental Impact

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

Executive Order 13132: Federalism

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

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

Executive Order 13175: Consultation and Coordination With Indian Tribal Governments

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

Paperwork Reduction Act

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

Privacy Act

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

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

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

Pay-As-You-Go Act of 2023

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

List of Subjects

49 CFR Part 40

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

49 CFR Part 199

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

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

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

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

Authority:

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

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

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

* * * * *

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

* * * * *

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

3. Add §40.4 to read as follows:

§40.4 May electronic documents and signatures be used?

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

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

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

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

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

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

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

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

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

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

* * * * *

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

* * * * *

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

§40.79 How is the collection process completed?

(a) * * *

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

* * * * *

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

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

* * * * *

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

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

* * * * *

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

* * * * *

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

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

* * * * *

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

* * * * *

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

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

* * * * *

(c) * * *

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

* * * * *

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

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

* * * * *

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

* * * * *

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

* * * * *

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

§40.163 How does the MRO report drug test results?

* * * * *

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

* * * * *

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

* * * * *

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

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

* * * * *

(c) * * *

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

* * * * *

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

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

* * * * *

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

* * * * *

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

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

* * * * *

(c) * * *

(2) * * *

(iv) * * *

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

* * * * *

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

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

* * * * *

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

* * * * *

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

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

* * * * *

(b) * * *

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

* * * * *

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

§40.205 How are drug test problems corrected?

* * * * *

(b) * * *

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

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

* * * * *

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

§40.225 What form is used for an alcohol test?

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

* * * * *

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

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

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

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

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

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

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

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

(a) * * *

(5) * * *

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

* * * * *

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

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

* * * * *

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

* * * * *

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

§40.271 How are alcohol testing problems corrected?

* * * * *

(b) * * *

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

* * * * *

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

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

* * * * *

(b) * * *

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

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

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

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

Authority:

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

23. In §199.3:

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

b. Add paragraph (a).

The addition reads as follows:

§199.3 Definitions.

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

* * * * *

24. Add §199.4 to read as follows:

§199.4 Electronic documents, records, and signatures.

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

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

§199.117 Recordkeeping.

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

* * * * *

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

§199.119 Reporting of anti-drug testing results.

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

* * * * *

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

§199.227 Retention of records.

* * * * *

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

* * * * *

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

§199.229 Reporting of alcohol testing results.

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

* * * * *

Signed on: Thursday, October 3, 2024.

Pete Buttigieg,

Secretary of Transportation.

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

BILLING CODE 4910-9X-P

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Most Recent Highlights In Environmental

2026-01-02T06:00:00Z

New York establishes Mandatory Greenhouse Gas Reporting Program

Effective date: December 10, 2025

This applies to: Certain GHG emission sources

Description of change: Entities subject to 6 NYCRR Part 253 must submit annual reports of greenhouse (GHG) emissions during the previous calendar year by June 1. Reporting facilities must keep records used for the reports, and larger sources have to obtain third-party verification of their reported emissions. The first report will cover 2026 GHG emissions data and will be due on June 1, 2027.

The regulation applies to emission sources that are in a listed category and operate in New York. The rule establishes three reporting threshold categories:

  • Suppliers of fuels, electricity, or fertilizer;
  • Facilities that emit more than 10,000 metric tons of carbon dioxide equivalent of GHGs annually; and
  • Sources with a specific operational activity.

Related state info: Clean air operating permit state comparison

2026-01-02T06:00:00Z

Washington restricts PFAS products

Effective date: December 21, 2025

This applies to: Manufacturers, sellers, and distributors of certain consumer products with intentionally added PFAS

Description of change: The Washington State Department of Ecology amended regulations to restrict the manufacture, sale, and distribution of consumer products with intentionally added per- and polyfluoroalkyl substances (PFAS) in these categories:

  • Apparel and accessories,
  • Automotive washes, and
  • Cleaning products.

The department also added requirements for manufacturers to report intentional use of PFAS for nine other consumer product categories, including:

  • Apparel intended for extreme and extended use,
  • Footwear,
  • Gear for recreation and travel,
  • Automotive waxes,
  • Cookware and kitchen supplies,
  • Firefighting personal protective equipment,
  • Floor waxes and polishes,
  • Hard surface sealers, and
  • Ski waxes.

New restrictions take effect on January 1, 2027, and initial reports are due by January 31, 2027 (and by January 31 annually thereafter).

Related state info: Hazardous waste generators — Washington

2026-01-02T06:00:00Z

New Jersey amends rules for contaminated site remediation, redevelopment

Effective date: November 17, 2025

This applies to: Facilities subject to site remediation and redevelopment regulations

Description of change: The New Jersey Department of Environmental Protection made amendments to:

  • The Industrial Site Recovery Act,
  • The Administrative Requirements for the Remediation of Contaminated Sites,
  • The Technical Requirements for Site Remediation, and
  • The Heating Oil Tank System Remediation Rules.

In addition to adding the Site Remediation Reform Act’s requirements to the regulations, the department adopted amendments to simplify the remedial action permit process and implementation of the licensed site remediation professional program.

2026-01-02T06:00:00Z

New Hampshire adds fines for contaminated site management obligations

Effective date: November 4, 2025

This applies to: Parties responsible for investigating and remediating regulated sites impacted by releases of regulated contaminants

Description of change: The New Hampshire Department of Environmental Services readopted contaminated site management rules with changes. The amended rule:

  • Adds requirements for the responsible party’s obligation for managing contaminated groundwater and soil during construction and dewatering activities,
  • Adds requirements for the responsible party’s obligations for assessing and remediating discharges causing vapor intrusion to indoor air,
  • Adds requirements for the responsible party’s obligation for managing extracted contaminated groundwater for dewatering purposes, and
  • Adds fines to implement when a responsible party doesn’t meet obligations.
2026-01-02T06:00:00Z

Florida adds grease waste hauler requirements

Effective date: December 7, 2025

This applies to: Haulers of grease waste from food establishments

Description of change: The Florida Department of Environmental Protection established removal and disposal regulations for haulers of grease waste from originator food establishments. Haulers must dispose of grease waste at certified facilities and document removals and disposals using a service manifest.

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Most Recent Highlights In Transportation

2026-01-02T06:00:00Z

California codifies industrial ethyl alcohol exemption

Effective date: November 17, 2025

This applies to: Generators, transporters, and recycling facilities

Description of change: The California Department of Toxic Substances Control adopted a permanent rule that exempts spent, unused, and off-specification industrial ethyl alcohol from a majority of the hazardous waste regulations when it’s recycled at a facility permitted by the Alcohol and Tobacco Tax and Trade Bureau.

The exemption isn’t new; it was adopted multiple times via temporary emergency rulemaking. This rulemaking action permanently establishes the exemption in the California Code of Regulations.

Related state info: Hazardous waste generators — California

2026-01-02T06:00:00Z

District of Columbia adds nonwoven disposable product regulations

Effective date: November 14, 2025

This applies to: Manufacturers of nonwoven disposable products sold in D.C.

Description of change: The Washington, D.C. Department of Energy and Environment (DOEE) added regulations (21 DCMR Chapter 24) for nonwoven disposable products labeling to implement the Nonwoven Disposable Products Act of 2016.

The chapter sets the standards for determining whether a nonwoven disposable product may be labeled as flushable, including testing and labeling requirements for flushable and nonflushable products. It applies to all nonwoven products that may potentially be used in a bathroom and flushed (e.g., baby wipes, disinfecting wipes, makeup removal wipes, general purpose cleaning wipes, etc.).

Compliance requirements start in May 2027.

Related state info: Industrial water permitting — District of Columbia

2026-01-02T06:00:00Z

Maryland establishes fuel provider reporting program

Effective date: December 22, 2025

This applies to: Heating fuel providers delivering heating fuel in Maryland

Description of change: The Maryland Department of the Environment established the Maryland Heating Fuel Provider Reporting Program. It requires heating fuel providers to submit an annual report by April 1 that covers the monthly amount of fuel delivered in the state, organized by fuel type, sector, and county.

Heating fuel providers should begin gathering data in January 2026. The initial report for calendar year 2026 will be due by April 1, 2027. The department plans to publish the annual reporting template in Spring 2026.

Related state info: Clean air operating permit state comparison

2026-01-02T06:00:00Z

California updates UST regulations

Effective date: January 1, 2026

This applies to: UST owners and operators

Description of change: The California State Water Resources Control Board updated the underground storage tank (UST) construction, monitoring, and testing requirements. Significant changes include:

  • Replacing the classification of new and existing USTs with a three-category classification system based on the installation date;
  • Requiring testing notifications to be sent to Unified Program Agencies (UPAs);
  • Requiring USTs installed on or after January 1, 2027, to be anchored;
  • Requiring UPA approval before repairing UST systems;
  • Reducing the timeline to submit enhanced leak detection test results to 30 days; and
  • Changing closure requirements.

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

2026-01-02T06:00:00Z

Minnesota establishes PFAS reporting, fees rule

Effective date: December 8, 2025

This applies to: Manufacturers of products with intentionally added PFAS

Description of change: The Minnesota Pollution Control Agency added rules that require manufacturers that sell, offer for sale, or distribute products in the state that contain intentionally added per- and polyfluoroalkyl substances (PFAS) to:

  • Submit annual reports, and
  • Pay a fee.

The initial report is due by July 1, 2026. Thereafter, annual reports will be due by February 1. Reports will be submitted electronically through the PFAS Reporting and Information System for Manufacturers (PRISM).

See More

Most Recent Highlights In Safety & Health

2026-01-02T06:00:00Z

Iowa adds fees for Title V, asbestos air programs

Effective date: January 14, 2026

This applies to: Entities required to obtain a Title V operating permit and owners or operators of sites subject to asbestos notifications

Description of change: The Iowa Environmental Protection Commission added a new annual base fee for Title V operating permit holders, due by July 1.

Additionally, the commission added a fee for revising asbestos notifications. It applies to sites required by the National Emission Standards for Hazardous Air Pollutants to submit asbestos demolition or renovation notifications.

Related state info: Clean air operating permits state comparison

Aboveground storage tanks: SPCC integrity test FAQs
2025-12-30T06:00:00Z

Aboveground storage tanks: SPCC integrity test FAQs

Integrity matters, especially when it’s the one factor standing between your aboveground storage container and the accidental release of thousands of gallons of oil. Consistently checking the structural soundness of aboveground storage tanks (ASTs) is vital to preventing spills and the potential related consequences.

Facilities covered by the Environmental Protection Agency’s (EPA’s) Spill Prevention, Control, and Countermeasure (SPCC) rule must inspect and test ASTs for integrity regularly. By comparing the test results, facilities can monitor changes in the condition of ASTs and determine whether it’s safe to keep using them.

Consider these FAQs about inspections and tests to help ensure your facility’s aboveground tanks are structurally sound.

What do industry standards have to do with integrity testing?

The answer in one word is everything. EPA’s SPCC rule requires facilities to regularly inspect and test ASTs in accordance with industry standards (40 CFR 112.8(c)(6)). The standards are technical guidelines that serve as the minimum practices accepted for inspections and tests.

The regulations require facilities to develop and implement an SPCC Plan to prevent, prepare for, and respond to oil spills. In the plan, facilities establish how they’ll conduct integrity inspections and tests for ASTs (referred to as bulk storage containers in the regulations). If your SPCC Plan states that the facility will use a specific industry standard for integrity inspections and tests, it must comply with all relevant parts of that standard.

In EPA’s Spill Prevention, Control and Countermeasure Plan (SPCC) Program Bulk Storage Container Inspection Fact Sheet, the agency references two industry standards frequently used for integrity inspections and tests:

  • American Petroleum Institute (API) Standard 653, Tank Inspection, Repair, Alteration, and Reconstruction; and
  • Steel Tank Institute (STI) SP001, Standard for the Inspection of Aboveground Storage Tanks.

When should facilities conduct integrity tests?

EPA requires facilities to inspect or test ASTs for integrity:

  • On a regular schedule, and
  • Whenever you make material repairs.

Your facility must use industry standards to determine the types and frequency of inspections and tests needed. These considerations have to be based on the AST’s size, configuration, and design.

Who can conduct integrity tests?

Generally, industry standards mandate that certified individuals conduct integrity inspections and tests. The standards should describe the qualifications an individual must have to be considered certified. This may involve certifying individuals in your facility or hiring certified personnel.

What are the types of integrity inspections and testing?

The proper type of integrity inspection or test (which must be nondestructive) depends on the specific container and its configuration. Industry standards identify the type of inspection or test needed and may require using a combination of methods. Examples include:

  • Acoustic emissions testing,
  • Helium leak testing,
  • Hydrostatic testing,
  • Inert gas leak testing,
  • Liquid penetrant examinations,
  • Magnetic flux leakage scanning,
  • Magnetic particle examinations,
  • Radiographic testing,
  • Ultrasonic testing,
  • Ultrasonic thickness measurements,
  • Vacuum box testing,
  • Visual inspections, and
  • Weld inspections.

Industry standards may require your facility to establish baseline conditions for ASTs that haven’t undergone integrity testing or where such information isn’t available (e.g., when a business purchases a facility with ASTs). The baseline evaluation determines the container’s metal thickness, corrosion rates, and likely remaining service. Facilities then compare the results of subsequent integrity inspections and tests with the baseline data.

What are the recordkeeping requirements?

The SPCC rule requires facilities to maintain integrity inspection and test records (namely, comparison records) for at least 3 years. These records must be signed by the supervisor or inspector and kept with the SPCC Plan. Consider maintaining these records for the life of the AST, especially since many industry standards recommend it.

What’s a hybrid inspection program?

Sometimes, an alternative inspection program may be more appropriate than using an industry standard. If your facility and a certified Professional Engineer (PE) determine this to be the case, you can implement an environmentally equivalent inspection program. The SPCC rule also allows some facilities to replace certain parts of an industry standard with environmentally equivalent approaches.

However, these hybrid (site-specific) programs have additional regulatory requirements. A facility with a hybrid inspection program must include in the SPCC Plan:

  • A certification by the PE of the alternative program,
  • An explanation of why the facility isn’t using industry standards,
  • A comprehensive description of the alternative program, and
  • A description of how the alternative provides the same environmental protection as the relevant industry standard.

What about state requirements?

State and local AST regulations must be at least as stringent as EPA’s requirements. However, some may require additional or stricter compliance obligations. Verify AST rules with the state environmental agency.

Key to remember: Industry standards determine how a facility conducts integrity inspections and tests on aboveground storage tanks.

Lamps, batteries, and fines: Fixing the 5 biggest universal waste mistakes
2025-12-19T06:00:00Z

Lamps, batteries, and fines: Fixing the 5 biggest universal waste mistakes

Let’s be honest, managing compliance is tough. But when it comes to Universal Waste (UW), items like fluorescent bulbs, used batteries, aerosol cans, and old thermostats can expose employers to fines without them even realizing it. Why? Because Universal Waste is the ultimate regulatory paradox. These items are still classified as hazardous waste, but the EPA created a streamlined rule set (40 CFR Part 273) to make recycling easier. The problem is that many employers assume "streamlined" means "ignorable." Fixing these problems is incredibly straightforward. By tackling the most common UW mistakes, you don’t just avoid penalties; you build a predictable, efficient, and cost-effective waste program.

Top 5 universal waste violations and how to avoid them

  1. The container crime: Leaving it open - Leaving a Universal Waste container open is a common and costly mistake. When boxes or drums holding items like lamps and batteries are left unsealed or without a proper lid, the risk of contamination skyrockets. If a fluorescent tube breaks, mercury vapor escapes; if a battery leaks, corrosive material spills. An open container is considered a failure to prevent a release, which is a core hazardous waste violation. The fix is simple: close the container immediately. Train designated handlers to ensure containers remain sealed except when adding or removing waste, and use containers specifically designed for UW, such as fiber drums for lamps with secure, sealable lids. If it’s open, it’s a violation waiting to happen.
  2. The ticking clock: Missing the accumulation date - Missing the accumulation date is a violation that can cost you. Every Universal Waste container must clearly show the date when the first item was placed inside, and both Small and Large Quantity Handlers have only one year (365 days) to store UW before it must be shipped off-site. Without a visible start date, inspectors will assume you have exceeded that limit. The solution is simple: mark it and track it. Use a permanent marker to write the “Start Date” directly on the container, and do not wait until day 364 to act. A digital spreadsheet or calendar reminder can help you stay ahead, and scheduling vendor pickups between the 9- and 11-month mark creates a critical 30-day buffer against delays or conflicts.
  3. The DIY treatment disaster - Attempting to treat Universal Waste on-site is a recipe for violations. Crushing bulbs, mixing incompatible waste streams, or dismantling items to save space may seem efficient, but it is strictly prohibited under UW rules. These regulations are designed to simplify storage and not treatment. Breaking a fluorescent bulb outside of a permitted device not only risks mercury exposure but also constitutes hazardous waste mismanagement. The fix is simple is to train personnel that their role is to store and package waste correctly, not to alter or treat it. Keep fragile items in secure areas where they will not be crushed by forklifts or stacked boxes. Managing UW means preventing breakage, not creating it.
  4. The identity crisis: Improper labeling - Improper labeling is a common Universal Waste mistake that can lead to serious compliance issues. Containers marked vaguely such as “Recycling” or simply “Hazardous Waste” fail to meet regulatory requirements and create confusion for inspectors and emergency responders who need instant clarity. The term “Hazardous Waste” applies only to RCRA hazardous waste, not UW, and mixing these labels signals that your team has not properly identified the waste stream. Be specific and clear. Every UW container must include the words “Universal Waste” followed by the exact type of material, such as:
    • “Universal Waste – Spent Lamps”
    • “Universal Waste – Used Batteries”
    • “Universal Waste – Mercury-Containing Equipment”
  5. The knowledge gap: Training deficiencies - Training deficiencies are one of the most overlooked Universal Waste compliance gaps. Employees responsible for handling or managing UW must receive documented, recurring training on identification, accumulation limits, and handling protocols. Even the best-written program will fail if the staff placing items into containers do not understand the rules — especially dating and labeling requirements. Without proper training, an audit failure is almost guaranteed. The fix is straightforward — provide documented, annual training. Make sure every relevant staff member understands your facility’s specific UW streams key compliance practices. Maintain clear records of who was trained, when, and on what topics This paper trail is your strongest defense during an inspection.

Keys to remember: Universal waste compliance hinges on keeping containers closed, labeled, dated, and ensuring employees managing these materials are trained and documenting their actions. When your program is consistent, simple, and intentional, you eliminate preventable violations and turn UW management into a predictable, low-risk process.

Ripple effect: How data centers influence compliance strategies
2025-12-17T06:00:00Z

Ripple effect: How data centers influence compliance strategies

The rapid growth of data centers creates new challenges for other regulated facilities. Expansion driven by artificial intelligence (AI) and cloud computing increases their impact on environmental compliance. Key areas include air permitting, attainment status, and regional power supply.

Data centers and air permitting

Data centers depend on backup power to stay online during outages. Most use natural gas or diesel generators. These units release pollutants such as nitrogen oxides and particulate matter. When many generators operate together, their potential emissions can push regions close to or beyond National Ambient Air Quality Standards (NAAQS). This shift can threaten local attainment status and make it harder for nearby facilities to get new permits.

What EPA is doing

On December 11, 2025, the Environmental Protection Agency's (EPA’s) Office of Air and Radiation launched the “Clean Air Act Resources for Data Centers” webpage. It provides regulatory guidance, permitting tools, and technical letters. The goal is to make air permitting for data centers faster and more transparent while protecting air quality.

Why this matters for other regulated facilities

  • Attainment status at risk

Large data centers add cumulative emissions from multiple generators. Even permitted emissions from nearby plants can combine and push an area into nonattainment. That change triggers stricter air permitting rules for everyone.

  • Power demand competition

Data centers use large amounts of electricity. They often need on-site generators or new grid connections. This can strain local power supplies. In some cases, grid operators give data centers priority during peak demand, leaving other facilities with less reliable power.

  • Stricter air quality modeling requirements

Some states now require detailed modeling for backup generators. For example, Illinois reviewed 34 generators for one data center before granting a permit. If modeling shows high emissions, regulators may limit operating hours or require extra controls.

Broader regulatory shifts

EPA recently updated its interpretation of New Source Review (NSR) rules. In September 2025, the agency said construction can start before full air permits are issued, as long as emission-related work waits for approval. This speeds up projects but makes it harder for neighboring facilities to predict cumulative emissions early.

What non-data center facilities should do

  • Stay informed

Watch for new data center projects in your area. Their emissions could affect your permits.

  • Engage early

Join public comment periods for data center permits. Push for full modeling of combined impacts.

  • Plan for power

Work with grid operators. Understand how demand-response programs and EPA’s “50-hour rule” for emergency generators affect your reliability.

  • Choose sites wisely

Consider locating new projects in areas with robust infrastructure and cleaner attainment status. Data centers might compete for the same grid upgrades or site approvals.

Key to remember: Data centers are more than tech hubs. They influence air permitting and power allocation. Their growth can affect your ability to expand, or even operate, under current compliance rules.

Acid Rain Program compliance: SO2 vs. NOx
2025-12-11T06:00:00Z

Acid Rain Program compliance: SO2 vs. NOx

Did you know that the federal government regulates the power sector’s impact on rain? The Acid Rain Program limits the amount of sulfur dioxide (SO2) and nitrogen oxides (NOx) — the main causes of acid rain — that fossil fuel-fired electric generating units (EGUs) may emit. However, the SO2 and NOx reduction programs operate differently, and the ways that facilities can meet the SO2 and NOx limits are distinct.

It's essential to know the compliance options because facilities that don’t meet the SO2 and NOx standards must pay penalties for their excess emissions. And in November 2025, the Environmental Protection Agency (EPA) set higher penalties for the next two compliance years.

So, what are the differences?

Who’s affected?

The first thing to confirm is whether your facility is subject to the Acid Rain Program (40 CFR 72.6). The program regulates fossil fuel-fired power plants. It applies to:

  • EGUs that serve generators with an output capacity of more than 25 megawatts, and
  • All new EGUs.

Note that the NOx program applies to a specific subset of coal-fired boilers.

SO2 reduction program

EPA operates the SO2 reduction program through an allowance trading system (Part 73). The agency sets a cap on the total SO2 emissions for the year and then allocates SO2 allowances to regulated units. One allowance represents 1 ton of SO2 emissions.

For each compliance year, a facility must show that it has enough allowances to cover its emissions of SO2. It’s similar to EPA’s hydrofluorocarbon allowance program.

There are multiple compliance options. Facilities may:

  • Sell extra allowances if they have more allowances than needed,
  • Save extra allowances if they have more allowances than needed (and use them in the future), or
  • Buy extra allowances if they can’t keep emissions below their allocated level.

Facilities can purchase allowances from or sell allowances to individuals, companies, groups, or brokers. Additionally, facilities may bid on allowances at EPA’s annual Acid Rain Program SO2 Allowance Auction.

NOx reduction program

EPA sets annual emission limits for the NOx reduction program (Part 76), which applies to these types of boilers:

  • Dry bottom wall-fired boilers,
  • Tangentially fired boilers,
  • Cell burner boilers,
  • Cyclone boilers,
  • Vertically fired boilers, and
  • Wet bottom boilers.

Like the SO2 program, the NOx program offers multiple compliance options. Facilities can:

  • Meet the standard annual emission limitations,
  • Average the emissions rates of two or more boilers, or
  • Apply for an alternative emission limit (AEL) if they can’t meet the standard emission limit.

Additional requirements apply to facilities that use options other than complying with the limits:

  • Facilities that want to average emissions rates must submit an averaging plan that’s approved by the permitting authorities (76.11).
  • Facilities that apply for an AEL are required to use the NOx emission control technology used as the basis for the emission limit and must demonstrate that the unit can’t comply using the technology (76.10).

It pays (or, at least, costs less) to comply!

Excess emissions penalties can add up quickly. That’s why it’s vital to ensure your facility understands how to comply with the SO2 and NOx reduction programs properly.

The adjustment rates that EPA set for compliance years 2025 and 2026 (2.5265 and 2.6001, respectively) are used to calculate the total penalties a facility must pay if it exceeds SO2 or NOx limits during these compliance years.

Here are the formulas:

  • Penalty for excess SO2 emissions = $2,000/ton x annual adjustment factor x tons of excess SO2 emissions
  • Penalty for excess NOx emissions = $2,000/ton x annual adjustment factor x tons of excess NOx emissions

Let’s run through a couple of examples of what noncompliance could cost.

FactorsPenalty Per TonTotal Penalties
  • Tons of excess SO2 emissions: 10
  • Compliance year: 2025
  • Annual adjustment factor: 2.5265
$2,000 x 2.5265 = $5,053$5,053 x 10 = $50,530
  • Tons of excess NOx emissions: 5
  • Compliance year: 2026
  • Annual adjustment factor: 2.6001
$2,000 x 2.6001 = $5,200.20$5,200.20 x 5 = $26,001

As shown in the example above, excess emissions can cost facilities a lot in penalties. Just 1 ton of excess emissions will result in more than $5,000! Knowing your compliance options for the Acid Rain Program’s SO2 and NOx reduction programs can help your facility avoid steep fines.

Key to remember: The Acid Rain Program limits SO2 and NOx emissions from fossil fuel-fired power plants, but the compliance options for each type of emission differ. Understanding the distinct options can help facilities avoid penalties for excess emissions.

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Most Recent Highlights In Human Resources

EPA’s 2026 regulatory shift: How environmental managers can stay ahead
2025-12-05T06:00:00Z

EPA’s 2026 regulatory shift: How environmental managers can stay ahead

The clock is ticking for environmental teams. By 2026, several new EPA regulations will reshape compliance obligations for U.S. companies. Organizations that act now will avoid costly penalties and operational disruptions.

What’s changing and why it matters

Although EPA has been deregulating or loosening some requirements, there are still some standards being tightened across multiple fronts in the coming year:

  • Renewable fuel standards (RFS): The EPA proposed higher volume requirements for 2026, including 24.02 billion renewable identification numbers (RINs), up nearly 8% from 2025. This increase pushes stricter expectations on fuel producers and organizations purchasing renewable fuels.
  • Stormwater multi-sector general permit (MSGP): A new MSGP set to take effect by February 2026 will require quarterly PFAS indicator monitoring, expanded benchmark sampling, and resiliency measures in stormwater control designs.
  • PFAS Reporting under the Toxic Substances Control Act (TSCA): TSCA Section 8(a)(7) mandates PFAS manufacturing and import data collection beginning in April 2026, through October 2026, with extended deadlines for certain small manufacturers.

Failure to prepare could lead to fines, reputational damage, supply chain disruptions, and permit delays. Companies that weave compliance planning into their 2026 strategy will be positioned not just to meet legal deadlines but to sustain operations smoothly.

Key areas of impact

  • Renewable fuel standards (RFS) and air emissions The proposed increase in 2026 Renewable Identification Numbers (RIN) volumes, from 24.02 billion to 24.46 billion for 2027, signals tightening air and fuels policy that affects fuel use and emissions accounting.
  • Stormwater management The upcoming 2026 MSGP requires expanded quarterly PFAS monitoring, new benchmark triggers, corrective action plans, and integration of climate resilience in design standards.
  • PFAS disclosure (TSCA Section 8(a)(7)) Manufacturers and importers of PFAS must submit electronic reporting of usage, volumes, disposal, and exposure data between April and October 2026, with extensions available for smaller operations.

Steps to take now

  • Audit compliance programs: Cross-check operations against RIN inventory, stormwater permits, and TSCA reporting duties.
  • Upgrade monitoring and recordkeeping: Implement robust electronic systems to track PFAS, stormwater quality, fuel volumes, and emissions.
  • Staff training: Educate teams on PFAS obligations, new stormwater protocols, and RFS structures.
  • Engage regulators early: Comment on proposed rules, consult during permit drafting, and flag issues during the notice-and-comment period.

Looking ahead

The EPA’s 2026 updates reflect a trend toward increased transparency and environmental accountability. Companies that treat compliance as strategic will not only avoid enforcement but also gain resilience and stakeholder trust.

Key to remember: Start planning now. Early action on EPA rule changes will save time, money, and headaches when enforcement begins.

EPA confirms oil, gas emissions compliance extensions
2025-12-05T06:00:00Z

EPA confirms oil, gas emissions compliance extensions

The Environmental Protection Agency (EPA) issued a rule on December 3, 2025, that finalizes compliance deadline extensions for certain emissions standards applicable to crude oil and natural gas facilities. The final rule also further delays compliance timelines for two requirements.

EPA’s delays affect:

  • The New Source Performance Standards for crude oil and natural gas facilities (40 CFR 60 Subpart OOOOb), and
  • The emissions guidelines (EGs) for crude oil and natural gas facilities (60 Subpart OOOOc).

EPA’s December 2025 final rule is a direct response to the interim final rule (IFR) it issued in July 2025.

The July 2025 IFR extended the compliance deadline for net heating value (NHV) monitoring of flares and enclosed combustion devices (ECDs) to November 28, 2025. The IFR moved the rest of the compliance deadlines to January 22, 2027, for:

  • ECD performance tests;
  • Cover and closed vent system requirements for no identifiable emissions (NIEs), including:
    • Design and operation standards,
    • Test methods and procedures, and
    • Inspections.
  • Equipment leak repair requirements;
  • Phase two of zero-emission standards for process controllers;
  • Storage vessel requirements, including:
    • Using potential emissions limits that qualify as legally and practicably enforceable,
    • Triggering throughput-based modifications, and
    • Using a 30-day period of production to calculate potential emissions.
  • Flare and ECD pilot flame rules, including:
    • Ensuring the devices operate with a continuous pilot flame, and
    • Installing and operating a system to send an alarm to the nearest control room when a pilot flame is unlit.
  • Implementation of the Super Emitter Program, and
  • Submission of state plans for implementing the updated EGs.

What’s the same?

EPA’s December 2025 final rule maintains the same compliance deadlines for all requirements delayed to January 22, 2027.

What’s different?

The agency’s December 2025 final rule sets a new compliance date of June 1, 2026, for the NHV monitoring requirements. This includes an alternative performance test (sampling demonstration) option for flares and ECDs.

Additionally, the rule moves the compliance date for annual reporting, establishing that no annual report is due before November 30, 2026. It gives owners and operators until November 30, 2026, to submit any reports that were originally due before this date. Note that the final rule specifies that annual reports due after November 30, 2026, must be submitted within 90 days of the end of each annual compliance period.

Key to remember: EPA’s final rule confirms deadline extensions for certain emissions standards that apply to crude oil and natural gas facilities. It also further delays a couple of the requirements.

2025-12-02T06:00:00Z

Minnesota requires air toxics emissions reporting in 7 counties

Effective date: October 6, 2025

This applies to: Facilities with air permits in the counties of Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, and Washington

Description of change: The Minnesota Pollution Control Agency adopted new rules mandating that facilities with air permits (except for Option B registration permits) in the Minnesota counties of Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, and Washington submit annual air toxics emissions reports. The covered toxics include certain hazardous air pollutants (HAPs), per- and polyfluoroalkyl substances (PFAS), and other pollutants of concern. Annual emissions reports on HAPs, PFAS, and other covered pollutants are due by April 1.

View related state info: Clean air operating permits — Minnesota

2025-12-02T06:00:00Z

Maine designates currently unavoidable uses of PFAS

Effective date: October 7, 2025

This applies to: All nonexempt new and unused products sold, offered for sale, or distributed for sale in Maine that contain intentionally added PFAS

Description of change: The Maine Department of Environmental Protection established designations for currently unavoidable uses of intentionally added per- and polyfluoroalkyl substances (PFAS) in products subject to sales prohibitions that start on January 1, 2026.

2025-12-02T06:00:00Z

Vermont updates drinking water rules

Effective date: January 1, 2026

This applies to: Public water systems

Description of change: The Vermont Department of Environmental Conservation made multiple changes to the Water Supply Rule. Some of the major amendments include:

  • Changes to the per- and polyfluoroalkyl substances (PFAS) regulations,
  • Additions to the contaminants covered by the rule, and
  • A new method to calculate the impact of PFAS mixtures.
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