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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

Maintenance and environmental compliance go hand in hand
2026-08-21T05:00:00Z

Maintenance and environmental compliance go hand in hand

Environmental compliance is often viewed as the responsibility of the environmental, health, and safety (EHS) department. In reality, many compliance successes and failures occur on the plant floor, in maintenance shops, and around equipment managed by maintenance personnel.

Maintenance employees regularly handle used oil, inspect tanks, repair air pollution control equipment, respond to spills, and maintain secondary containment systems. Their daily decisions can directly affect compliance with federal, state, and local environmental requirements. As facilities face increased scrutiny of air emissions, waste management, and spill prevention programs, coordination between environmental and maintenance personnel has become increasingly important. That is why one of the most valuable members of an environmental compliance team is often someone from maintenance.

Used oil management starts in the shop

Many maintenance departments generate used oil from equipment servicing, vehicle maintenance, and hydraulic system repairs. While used oil can often be managed under streamlined regulations, improper handling can quickly create compliance problems.

Common issues include storing used oil in unlabeled containers, mixing used oil with hazardous waste, or failing to address leaks from storage containers. Even small mistakes can increase disposal costs or change how the waste must be managed. Maintenance personnel can help reduce these risks by ensuring used oil containers remain closed when not in use, are properly labeled, and are routinely inspected for signs of leakage or deterioration.

Spill response depends on employees closest to the release

When a spill occurs, maintenance staff are often among the first employees on scene.

Their actions during the first few minutes can affect both environmental impacts and regulatory obligations. Quickly stopping the source of a release, protecting drains, and containing spilled material can prevent a minor incident from becoming a reportable event.

Facilities should ensure maintenance personnel understand spill response procedures, know where response equipment is located, and recognize when environmental staff or emergency responders must be notified.

Even facilities with formal spill response plans depend on maintenance employees to implement many of the initial response actions.

Air compliance requires reliable equipment

Many facilities rely on air pollution control devices such as baghouses, scrubbers, thermal oxidizers, or dust collection systems to comply with permit requirements.

Environmental managers may be responsible for reporting emissions and maintaining permit records, but maintenance staff are often responsible for keeping control equipment operating properly.

A failed pressure gauge, malfunctioning fan, broken duct connection, or neglected preventive maintenance task can affect emissions performance and potentially result in permit deviations.

Facilities should ensure maintenance programs include environmental control equipment and that maintenance personnel understand which equipment has environmental significance.

Tanks and containment need routine attention

Storage tanks and secondary containment systems are another area where maintenance and environmental responsibilities overlap.

Maintenance personnel may also maintain stormwater controls, drainage structures, and outdoor storage areas that affect permit compliance.

Routine inspections can identify corrosion, damaged coatings, leaking fittings, deteriorated hoses, and cracks before they become larger problems. These conditions may not seem urgent from an operational perspective, but they can increase the risk of releases and regulatory violations.

Facilities should establish inspection procedures, clearly define responsibilities, and document findings. A simple inspection program can often identify problems early, reducing both environmental risk and repair costs.

Communication helps prevent violations

Many environmental compliance issues occur when operational changes are made without considering environmental impacts.

New equipment, replacement tanks, process modifications, and maintenance projects can affect air emissions, waste generation, chemical storage, or spill prevention requirements. Environmental staff may not become aware of these changes until after installation.

Regular communication between maintenance and environmental personnel can help identify potential compliance concerns before work begins. In many cases, a short conversation during project planning can prevent significant compliance challenges later.

Building a partnership between maintenance and environmental teams

Environmental compliance is most effective when it is integrated into daily operations. Maintenance teams often have the best understanding of equipment conditions, storage systems, and operational changes occurring throughout a facility.

Environmental awareness training, maintenance involvement in inspections, and regular communication can strengthen compliance programs and identify problems sooner.

Environmental managers bring regulatory expertise. Maintenance personnel bring operational knowledge. Together, they create a stronger foundation for compliance than either group can achieve alone.

Key to remember: Environmental compliance is not solely an EHS responsibility. Maintenance staff play a critical role in preventing spills, managing used oil, maintaining compliance equipment, and identifying problems before they become violations.

2026-08-14T05:00:00Z

Virginia requires PFAS monitoring for wastewater

Effective date: September 9, 2026

This applies to: Publicly owned treatment works (POTW)

Description of change: The Virginia State Water Control Board adopted amendments to the Virginia Pollutant Discharge Elimination System (VPDES) Permit regulation. The updated regulations:

  • Require POTWs to mandate quarterly discharge monitoring for per- and polyfluoroalkyl substances (PFAS) for certain industrial user categories,
  • Establish a 30-day reporting deadline for monitoring results, and
  • Specify acceptable test methods.

Covered industrial categories include:

  • PFAS manufacturing facilities;
  • Electroplating and metal finishing facilities using PFAS;
  • Semiconductor and circuit board facilities using PFAS;
  • Paper and packaging manufacturing facilities using PFAS;
  • Textile mills and tanneries using PFAS and leather, fabric, and carpet treaters using PFAS;
  • Centralized waste treatment industrial facilities;
  • Industrial launderers; and
  • Any other facility or site that’s a source of PFAS (such as landfills).

The POTWs must report results quarterly to the Virginia Department of Environmental Quality. Additionally, industrial users must report monitoring results within 30 days of receiving the laboratory results.

Related state info: Industrial water permitting — Virginia

2026-08-14T05:00:00Z

Virginia amends water withdrawal reporting requirements

Effective date: September 9, 2026

This applies to: Water users providing water to another person off-site

Description of the change: The Virginia State Water Control Board amended water withdrawal reporting requirements for water users providing water to another person off-site. These users are now required to report monthly (or quarterly if applicable) the total volumes of potable water and reclaimed water that they provided:

  • To a data center with an air permit from the Virginia Department of Environmental Quality; and
  • For domestic, commercial, industrial, and all other non-categorized purposes.

The reporting requirement takes effect on January 1, 2027.

TSCA Exposure Control Plan: 5 FAQs answered
2026-08-14T05:00:00Z

TSCA Exposure Control Plan: 5 FAQs answered

Do you have a toxic work environment — literally? For facilities that handle chemicals, the answer is likely yes. And for specific chemicals, federal environmental regulations require facilities to protect workers by controlling their exposure to these substances.

The Workplace Chemical Protection Program (WCPP) is one way the Environmental Protection Agency (EPA) protects potentially exposed workers from hazardous chemicals in the workplace. And at the core of the WCPP is the Exposure Control Plan (ECP); it’s the roadmap documenting how a facility will keep its employees safe. If your business manufactures (including imports), processes, distributes, uses, or disposes of a chemical substance subject to risk management regulations under Section 6 of the Toxic Substances Control Act (TSCA), an ECP may be required.

Consider these FAQs to help you implement an effective ECP that guards your workers against a “toxic work environment."

What’s an ECP?

An ECP is a strategic document explaining:

  • What exposure controls the facility takes to reduce occupational exposure to a regulated chemical to or below EPA’s exposure limits; and
  • How the facility will implement the other WCPP requirements (such as implementing exposure controls, establishing regulated areas, and providing training).

Any time a facility uses a TSCA Section 6 chemical that’s subject to the WCPP regulations (40 CFR Part 751), an ECP is required. This applies even if exposure monitoring determines that the concentration of a regulated chemical substance is below the existing chemical exposure limit or action level.

How do you develop an ECP?

Owners or operators must establish an ECP using the hierarchy of controls framework, following a sequence of actions to identify the control measures that will best reduce hazardous workplace exposures. The hierarchy of controls is ordered from the most to the least effective methods:

  • Elimination stops the use of the chemical.
  • Substitution replaces the chemical with a safer alternative.
  • Engineering controls prevent people from coming into contact with the chemical (e.g., local exhaust ventilation and protective barriers).
  • Administrative controls establish work practices that reduce the duration, frequency, or intensity of chemical exposure (like limiting access to exposure areas).
  • Personal protective equipment (PPE), such as respirators, reduces or mitigates exposure.

EPA requires owners or operators to consider every level of the hierarchy. PPE should be a last resort and used only when other controls aren’t possible or when other methods don’t sufficiently reduce hazardous exposure to safe levels.

What’s in an ECP?

Generally, an ECP must include the following:

  • The exposure control measures that were considered using the hierarchy of controls;
  • The reason why each control measure was selected or not selected based on feasibility, effectiveness, or other relevant information;
  • The actions required to implement the selected controls (e.g., installation, maintenance, training);
  • The regulated areas (workplace locations where worker exposure may exceed exposure limits), how they’re identified, and the people authorized to enter them;
  • The process for reviewing and updating the ECP to ensure that the exposure controls are effective, updated when needed, and properly implemented; and
  • The procedures for responding to new sources of or increases in exposure to the regulated chemical, including taking corrective actions.

Owners or operators must review and update ECPs when making major changes to the WCPP. However, EPA’s chemical-specific rules limit the length of time between reviews. The review frequency in the chemical-specific rule is the minimum requirement.

For example, the perchloroethylene rule (751.607) requires facilities to review and update the ECP at least every 5 years, while the chrysotile asbestos rule (751.511) requires facilities to review and update the ECP at least annually.

Can an ECP be added to an existing safety program?

Yes! Owners or operators can either:

  • Incorporate the ECP into an existing industrial hygiene or chemical management program (like a chemical hygiene plan) if the ECP contains all the required components, or
  • Develop an individual document for the ECP.

Can one ECP be used for multiple regulated chemicals?

EPA allows owners or operators to develop one standalone ECP that covers multiple chemicals subject to TSCA Section 6 regulations if the plan complies with each chemical’s specific requirements.

Key to remember: The Exposure Control Plan explains how a facility will implement the Workplace Chemical Protection Program and the exposure controls needed to protect workers from hazardous chemical exposures.

The environmental compliance program hiding in your chemical inventory
2026-08-13T05:00:00Z

The environmental compliance program hiding in your chemical inventory

Environmental programs may appear unrelated, but most rely on accurate information about the chemicals a facility uses, stores, or generates. Air permits, hazardous waste determinations, emergency planning, chemical reporting, and spill response programs all depend on knowing what chemicals are on site.

Yet chemical inventory management is often divided among multiple departments. Purchasing tracks what comes in, operations tracks what is used, maintenance stores products for later use, and environmental staff may only become involved when reporting deadlines approach. When inventories are incomplete or outdated, compliance problems can quickly follow.

A single source of truth supports multiple programs

Before a facility can determine its environmental obligations, it must first understand what chemicals are present on site.

The information contained in a chemical inventory supports numerous environmental programs, and different inventory data serve different purposes. Product quantities may affect EPCRA reporting. Chemical constituents help identify TRI chemicals and estimate releases. Usage data support air emissions calculations, while information about spent materials can help determine whether hazardous waste rules apply. Storage quantities, container types, and locations may also affect spill prevention and emergency response planning.

Consider a facility that introduces a new solvent for equipment cleaning. Purchasing may view it as a routine substitution, but the environmental implications may be much broader. The solvent may contain volatile organic compounds (VOCs) that affect air permits, TRI-listed constituents, or chemicals subject to EPCRA. If the spent solvent is discarded, hazardous waste regulations may also come into play. A complete inventory and chemical review process can identify these issues before the product enters service.

When departments maintain separate inventories using different data sources, inconsistencies can develop. One database may show a product as active while another indicates it is no longer used. A chemical stored in a maintenance room may never make its way into environmental records. These gaps can create reporting errors and complicate inspections.

Small changes can have large compliance impacts

Chemical inventories are not static. New products are introduced, suppliers change formulations, production processes evolve, and maintenance departments purchase materials to address operational needs.

Even seemingly minor changes can affect compliance programs. A reformulated product may contain a reportable constituent that it did not contain previously. A new coating operation may increase air emissions. Additional chemical storage may trigger emergency planning requirements or affect secondary containment needs.

Without a chemical review process involving environmental, safety, operations, and purchasing personnel, facilities may not recognize these implications until well after a change has occurred. This approach helps identify regulatory concerns before products are ordered, stored, or put into use.

Inspections often begin with inventory questions

Environmental inspectors often compare records against actual site conditions. Chemical inventories frequently become a focal point because they intersect with multiple regulatory programs.

Inspectors may compare inventory records with container labels, safety data sheets (SDSs), storage areas, waste accumulation locations, or reported chemical quantities. Discrepancies can raise questions about reporting accuracy and program oversight.

A well-maintained inventory shows that a facility has systems to manage compliance and allows personnel to quickly answer questions about chemical storage and use.

Building a stronger inventory program

The challenge is deciding what information to track and how to keep it current. An effective chemical inventory program does not need to be complicated, but it should be consistent.

At a minimum, facilities should track product names, storage locations, quantities on site, usage rates, SDS information, and key chemical constituents. Different data elements support different programs. Storage quantities may affect EPCRA reporting, chemical constituents may drive TRI evaluations, and usage rates often provide critical data for air emissions calculations. Some organizations also identify whether a product contains TRI chemicals, hazardous air pollutants (HAPs), VOCs, PFAS, or other substances subject to reporting or permitting requirements. Centralizing this information can simplify environmental evaluations throughout the year.

Facilities should establish clear ownership of inventory data, periodically verify inventory accuracy in the field, review new chemicals before purchase, and ensure information is shared across departments. Environmental staff should also periodically compare inventory data against reporting submissions, air permits, waste records, and emergency planning documentation. The goal is not simply to maintain a list of chemicals, but to create a reliable foundation for environmental decision making. A well-managed inventory supports air permitting, chemical reporting, emergency planning, spill prevention, and hazardous waste programs. When inventory data is accurate and readily available, environmental professionals spend less time chasing information and more time managing compliance risks.

Key to remember: Chemical inventory management is more than a recordkeeping exercise. A complete and accurate inventory provides the information needed to support air, waste, emergency planning, spill prevention, and chemical reporting programs, helping facilities identify compliance obligations before problems arise.

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Most Recent Highlights In Transportation

EHS Monthly Round Up - July 2026

EHS Monthly Round Up - July 2026

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

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

OSHA published its 2026 regulatory agenda on July 3. Of note, the agency projects an April 2027 date for the Emergency Response final rule, and the Heat Illness proposal is slated to be finalized in October 2027. In November 2026, OSHA also expects to publish a final rule addressing the use of subpoenas during investigations.

OSHA reopened the comment period for 14 chemical-specific proposals. This allows the public 30 days to comment on recommendations made by OSHA’s Advisory Committee on Construction Safety and Health.

OSHA updated its Voluntary Protection Programs, which recognize workplaces with strong safety and health programs and low injury rates. The changes align with the seven core elements in the agency’s Recommended Practices for Safety and Health Programs.

The Mine Safety and Health Administration withdrew 4 regulations that it says address outdated effective dates and requirements for various industry equipment and procedures. These relate to conveyor belts, blacksmith shops, diesel emission limits, and permissible flame safety lamps.

Turning to environmental news, EPA released detailed instructions and deadlines for pesticide registrants to begin compliance with the bilingual labeling requirements in the My PeST application. The first compliance deadline was July 31.

EPA aligned regulations under EPCRA Sections 311 and 312 with OSHA’s Hazard Communication amendments for hazardous chemical reporting requirements. Facilities must use OSHA’s hazard classes with their categories for safety data sheet submissions and hazardous chemical inventory reports required under EPCRA Sections 311 and 312.

And finally, EPA published its 2026 regulatory agenda on July 3. Many of the proposed and final rules support the agency’s continued deregulatory efforts and may impact regulatory compliance with air, land, and water rules.

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

EHS Monthly Round Up - February 2026

EHS Monthly Round Up - February 2026

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

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

Fatal work injuries fell 4 percent in 2024, largely due to a decline in workplace drug- and alcohol-related overdoses. According to the Bureau of Labor Statistics, overdose fatalities fell from 512 in 2023 to 410 in 2024. Across all types of workplace incidents, there were 5,070 fatal work injuries in 2024, compared to 5,283 in 2023. Transportation incidents continue to be the most frequent type of fatal event, accounting for over 38 percent of all occupational fatalities in 2024.

OSHA is fast-tracking a proposal to remove the 2036 obligation to upgrade fall protection systems on fixed ladders that extend over 24 feet. This follows an industry petition from major chemical and petroleum industry groups, which argue the provision is unjustified, costly, and not supported by the rulemaking record. OSHA frames the upcoming proposed action as deregulatory, allowing employers to update fixed ladders at the end of their service lives. We’ll provide updates as more information becomes available.

As OSHA leans into “deregulatory” actions, lawmakers are moving to pressure the agency to issue “regulatory” rulemaking to protect American workers. The latest legislative wave of bills aims to fill regulatory gaps, tackle emerging hazards, expand OSHA authority, and raise penalties. Topics addressed by these bills include musculoskeletal disorders, heat stress, infectious diseases, wildfire smoke, and workplace violence.

In a recently issued letter of interpretation, OSHA states that a burn injury caused by a personal lithium-ion battery fire is work related if it occurs in the workplace during assigned working hours. The letter details an incident where an employee was burned when their rechargeable lithium-ion batteries for e-cigarettes sparked a fire after coming into contact with a key used for work.

A new report from the Department of Labor Office of Inspector General concludes that OSHA struggles to meet its mission, particularly in high-risk industries like healthcare, construction, and manufacturing. Several pages point to OSHA’s difficulties in effectively enforcing annual injury and illness reporting requirements, reaching the nation’s high-risk worksites for inspection, and addressing workplace violence by regulatory or other action.

Turning to environmental news, EPA extended the deadlines for Facility Evaluation Reports and related requirements for coal combustion residuals facilities. In most instances, the deadlines have been moved one or two years out.

And finally, EPA announced a final rule eliminating the 2009 Endangerment Finding and related greenhouse gas emission requirements for on-highway vehicles and vehicle engines. When the final rule takes effect, manufacturers and importers of new motor vehicles and motor vehicle engines will no longer have to measure, report, certify, or comply with federal greenhouse gas emission standards.

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

EHS Monthly Round Up - May 2026

EHS Monthly Round Up - May 2026

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

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

The first compliance date for the revised HazCom standard took effect May 19. Employers who work with chemical substances that are aerosols, desensitized explosives, or flammable gases should start to see updated safety data sheets and labels. On a related note, OSHA revised its HazCom directive for inspectors. It instructs OSHA officers on how to conduct inspections and issue citations under the standard. However, it also provides chemical manufacturers, importers, distributors, and employers with insight into what officers will be assessing.

OSHA revoked a standard that prohibited open fires and fires in drums or similar containers in marine terminals. The agency stated that since this is no longer typical practice, removing the standard would lessen the compliance burden without compromising worker safety.

OSHA received the backing of an advisory committee as it advances a comprehensive Tree Care Operations proposal. During the Advisory Committee on Construction Safety and Health meeting, the group unanimously voted in favor of moving ahead. This clears the path for OSHA to publish its long-awaited proposal.

Turning to environmental news, EPA extended the submission date for the TSCA Section 8(d) Health and Safety Data Reporting Rule one-time report from May 22, 2026, to May 21, 2027.

EPA published the first round of expiring confidential business information claims for information submitted under TSCA. The list covers claims that expire from June 22 to July 31, 2026. Businesses must submit extension requests to keep the information protected.

EPA postponed the effective compliance date for trichloroethylene users with TSCA Section 6(g) exemptions until pending judicial review is concluded. The agency has yet to establish a new compliance date.

And finally, EPA revised HFC use restrictions for certain subsectors. This applies to entities that are subject to the 2023 Technology Transition Rule requirements. The agency also proposed a rule that would exempt transportation refrigeration units from leak repair requirements regardless of charge size.

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

EHS Monthly Round Up - March 2026

EHS Monthly Round Up - March 2026

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

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

OSHA released an updated Job Safety and Health poster. Employers can use either the revised version or the older one, but the poster must be displayed in a conspicuous place where workers can easily see it.

OSHA recently removed a link from its Data topic webpage that displayed a list of “high-penalty cases” at or over $40,000 since 2015. The agency says it discontinued and removed it in December. The data is frozen and archived elsewhere.

OSHA published two new resources as part of its newly launched Safety Champions Program. The fact sheet provides an overview of how the program works, eligibility criteria, and key benefits. The step-by-step guide helps businesses navigate the core elements of OSHA’s Recommended Practices for Safety and Health Programs.

Several forces are nudging OSHA to address a number of workplace hazards and high-hazard industries. This comes from other agencies, safety organizations, watchdogs, legislative proposals, and persistent injury/fatality data. Among the hazards are combustible dust; first aid; personal protective equipment; and workplace violence. How all this translates into new regulations, guidance, programmed inspections, or other initiatives remains to be seen.

Turning to environmental news, EPA issued a proposed rule to require waste handlers to use electronic manifests to track all RCRA hazardous waste shipments. Stakeholders have until May 4 to comment on the proposal.

On March 10, EPA finalized stronger emission limits for new and existing large municipal waste combustors and made other changes to related standards.

And finally, EPA temporarily extended coverage under the 2021 Multi-Sector General Permit for industrial stormwater discharges until the agency issues a new general permit. The permit expired February 28 and remains in effect for facilities previously covered. EPA won’t take enforcement action against new facilities for unpermitted stormwater discharges if the facilities meet specific conditions.

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

EHS Monthly Round Up - April 2026

EHS Monthly Round Up - April 2026

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

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

OSHA revised its National Emphasis Program on heat-related hazards. Going forward, the agency will prioritize inspections in 55 high-risk industries in indoor and outdoor work settings. The program remains in effect for 5 years from its April 10 effective date.

An OSHA proposed rule seeks to eliminate the November 18, 2036, deadline in the Walking-Working Surfaces standard that would require all fixed ladders extending more than 24 feet above a lower level to be equipped with personal fall arrest systems or ladder safety systems. OSHA also seeks feedback on nine specific questions related to the proposal, with comments due on June 5.

On April 17, OSHA revoked its House Falls in Marine Terminals standard at 1917.41. The agency said that because most cargo has been containerized and is moved by cranes, the standard is no longer necessary to protect employees.

Turning to environmental news, an EPA final rule further delays the submission period for the one-time PFAS report required of manufacturers. It pushes the start of the submission period to either 60 days after the effective date of a future final rule updating the PFAS Reporting Rule or January 31, 2027, whichever comes first.

An EPA final rule makes technical changes to the emission standards established in March 2024 for crude oil and natural gas facilities. The changes take effect June 8.

EPA published the draft 6th Contaminant Candidate List for the next group of contaminants to be considered for regulation under the Safe Drinking Water Act. The proposed list designates microplastics and pharmaceuticals as priority contaminant groups for the first time.

And finally, EPA plans to make significant changes to coal combustion residuals requirements. A proposed rule published April 13 would revise the regulations governing the disposal of coal combustion residuals in landfills and surface impoundments, as well as the beneficial use of coal combustion residuals.

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

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Most Recent Highlights In Safety & Health

EHS Monthly Round Up - June 2026

EHS Monthly Round Up - June 2026

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

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

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

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

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

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

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

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

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

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

EHS Monthly Round Up - January 2026

EHS Monthly Round Up - January 2026

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

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

Chemical manufacturers, importers, distributors, and employers will have an extra four months to comply with the provisions of OSHA’s revised Hazard Communication standard. When the rule was revised in 2024, it contained staggered compliance dates for those who classify or use chemical substances and mixtures. The first compliance date is now May 19 rather than January 19 of 2026.

On January 8, OSHA issued further technical corrections to its Hazard Communication final rule. An initial set of corrections was published in October 2024, and OSHA continued to review the standard for errors. The agency said these corrections should reduce confusion during the chemical classification process and prevent errors on labels and safety data sheets.

In 2024, private industry employers reported 2.5 million nonfatal workplace injuries and illnesses, according to the Bureau of Labor Statistics. This is down 3.1 percent from 2023 and largely due to a decrease in respiratory illnesses. The greatest number of cases involving days away from work, job restriction, or transfer were caused by overexertion, repetitive motion, and bodily conditions, followed by contact incidents.

Registration is open for OSHA’s Safety Champions Program, which is designed to help employers develop and implement effective safety and health programs. Participants can work at their own pace through Introductory, Intermediate, and Advanced levels.

Turning to environmental news, on January 9, EPA withdrew its direct final rule on SDS/Tier II reporting tied to OSHA HazCom, before it had a chance to take effect. The direct final rule was published back on November 17, 2025, and was intended to relax the Tier II and safety data sheet reporting requirements and align with OSHA’s HazCom standard. EPA said it plans to write a new rule addressing all public comments.

And finally, EPA published a final rule that changes certain requirements for wastewater discharges from coal-fired steam electric power plants. It applies to the deadlines established by the preceding rule finalized in 2024.

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

Environmental compliance during capital projects: What gets missed most often
2026-08-05T05:00:00Z

Environmental compliance during capital projects: What gets missed most often

Capital projects often focus on budgets, schedules, engineering specifications, and operational goals. Project teams, however, frequently treat environmental compliance as a secondary consideration until late in the project lifecycle. That approach can create costly delays, permit violations, unexpected expenses, and even enforcement actions.

The most commonly missed environmental compliance issue during capital projects is the failure to evaluate how seemingly routine changes affect regulatory obligations. Changes to equipment, raw materials, production capacity, fuel usage, waste generation, emissions, water discharges, or storage practices can trigger new environmental requirements. What appears to be a straightforward operational improvement may alter permit applicability, increase emissions, generate new waste streams, or require additional monitoring and recordkeeping. Organizations that wait until construction is underway to ask environmental compliance questions often discover that regulatory reviews should've occurred months earlier.

Operational changes can trigger new requirements

Many capital projects are initiated to improve efficiency, increase production, or expand capabilities. As a result, project teams often focus on engineering and operational objectives without fully evaluating how proposed changes will affect environmental compliance.

Even relatively modest modifications can create compliance obligations that weren't considered during project planning. A project that increases throughput, changes operating patterns, or introduces new materials may trigger additional permitting, monitoring, or reporting requirements. Facilities that conduct environmental reviews during the early planning stages are generally better positioned to identify and address these issues before they affect project schedules.

Air and water impacts are often underestimated

Air permitting is one area where projects frequently encounter surprises. Process changes and production increases can affect emission calculations and permit thresholds. Facilities sometimes assume that replacing equipment with newer technology automatically improves compliance. In reality, changes in throughput, operating hours, fuels, or process materials can increase potential emissions or trigger new regulatory requirements even when newer equipment is more efficient.

Water-related requirements are also frequently overlooked. Site expansions may alter drainage patterns, increase impervious surfaces, or create new industrial stormwater exposure areas. Construction activities can trigger erosion and sediment control obligations, while process changes may affect wastewater characteristics, discharge volumes, or pretreatment requirements. These issues are often easier and less expensive to address during project design than after construction begins.

Chemical and waste management challenges

Hazardous waste and chemical management considerations are also frequently overlooked during capital projects. Introducing new raw materials, products, or process chemicals may create waste streams that require different handling, storage, transportation, or disposal practices.

Additional storage capacity may require updates to spill prevention measures, emergency response procedures, or chemical inventories. In some cases, project teams don't identify these impacts until after equipment is installed and operational.

Facilities may also discover that existing waste determinations no longer apply to modified operations. Failure to evaluate new or changed waste streams can result in improper waste management practices and increased regulatory risk.

Compliance doesn't end with the permit

Permitting is only one component of environmental compliance. Capital projects often require updates to a variety of compliance-related documents and programs that support day-to-day operations.

Facilities may need to revise Stormwater Pollution Prevention Plans (SWPPPs); Spill Prevention, Control, and Countermeasure (SPCC) Plans; inspection procedures; training materials; and recordkeeping systems. These updates are sometimes overlooked when project teams focus primarily on obtaining permits or completing construction milestones.

Failing to update supporting documentation can create compliance gaps even when all necessary permits have been obtained.

Communication and change management matter

Another common challenge is communication. Environmental compliance responsibilities often extend beyond environmental staff to engineering, operations, maintenance, purchasing personnel, and contractors. When environmental requirements aren't communicated effectively, critical information may never reach those responsible for implementing controls, maintaining records, or conducting inspections.

Many of these issues can be traced to the absence of a formal management of change (MOC) process. Capital projects frequently evolve as designs are refined, equipment is substituted, or project scopes change. Without a structured review process, environmental impacts identified early in the project may no longer reflect the final design.

An effective MOC process helps ensure that environmental considerations are reevaluated throughout the life of a project rather than only during the initial planning phase.

Building compliance into the project lifecycle

Most capital project compliance problems are preventable. Organizations that involve environmental personnel early, integrate compliance reviews into project planning, maintain clear communication channels, and establish a structured change-management process are less likely to encounter regulatory surprises.

Environmental compliance should be incorporated throughout planning, design, construction, and startup activities. Doing so can help organizations identify potential issues sooner, avoid costly delays, and reduce the likelihood of noncompliance after a project becomes operational.

Key to remember: The most common compliance pitfalls in capital projects stem from failing to evaluate how operational changes affect existing environmental requirements.

EPA proposes 2027 general stormwater permit for construction
2026-08-04T05:00:00Z

EPA proposes 2027 general stormwater permit for construction

The Environmental Protection Agency (EPA) published the proposed 2027 National Pollutant Discharge Elimination System (NPDES) Construction General Permit (CGP) for public comment on August 3, 2026. The CGP covers stormwater discharges from construction activities.

Who’s impacted?

The CGP applies to construction activities in areas where EPA is the NPDES permitting authority (including Massachusetts, New Hampshire, New Mexico, and the District of Columbia). Construction site operators must obtain a stormwater discharge permit for any construction activity that:

  • Disturbs 1 acre or more of land, or
  • Disturbs less than 1 acre of land but is part of a larger common plan of development or sale that will disturb 1 acre or more of land.

What are the proposed changes to the CGP?

EPA’s proposed 2027 CGP contains multiple modifications to the 2022 CGP. Significant changes include:

  • Replacing the broad requirement for permittees to “meet applicable water quality standards” for receiving waters (i.e., the waters that permittees discharge into) with more specific limits that indicate water quality problems in the discharge and applying these indicator conditions to all permittees;
  • Requiring CGP applicants to submit with the Notice of Intent (NOI) an electronic copy of the Stormwater Pollution Prevention Plan (SWPPP), a website address where the SWPPP can be viewed, or a copy of the SWPPP site map and the signed certification;
  • Requiring construction sites that install a sediment basin to implement stabilization measures before directing stormwater to the basin; and
  • Streamlining specific requirements, such as:
    • Clarifying that perimeter sediment controls are only required for areas that may receive stormwater from disturbed areas;
    • Clarifying the stabilization deadlines for sites in arid, semi-arid, and drought-stricken areas;
    • Allowing sites that experience unforeseeable winter weather conditions to temporarily suspend the requirement to stabilize exposed portions of the site for 14 days or more of inactivity while the extreme weather conditions persist;
    • Eliminating the requirement to submit pre-stabilization photos with a Notice of Termination;
    • Reducing the frequency of turbidity monitoring from daily to weekly for sites discharging dewatering water continuously for longer periods of time;
    • Relieving some operators of turbidity benchmark monitoring reporting requirements at sites where multiple operators coordinate monitoring efforts (if the operators submit an initial quarterly report to inform EPA that they’re relying on another permitted operator on-site to monitor and report); and
    • Eliminating the reporting requirement when no dewatering discharges occur during a monitoring quarter.

Who needs to apply for 2027 CGP coverage?

Operators of both new sites (construction activities begin on or after the final 2027 CGP’s effective date) and existing sites must apply for coverage under the 2027 CGP.

If an existing site obtained permit coverage under the 2022 CGP before the permit’s expiration date (February 17, 2027), the site will automatically remain covered for a limited period of time, allowing operators to submit a new Notice of Intent for coverage under the 2027 CGP.

What’s next?

Public comments are due by September 2, 2026 (Docket ID No. EPA-HQ-OW-2025-0760).

EPA will host a webinar on August 18, 2026, to review the proposed 2027 CGP and answer questions. You may register for the webinar on EPA’s “Proposed 2027 Construction General Permit (CGP) and Related Documents” webpage. If the proposed 2027 CGP is finalized, it will replace the existing 2022 CGP, which expires on February 17, 2027.

Key to remember: EPA seeks public comment on the proposed 2027 Construction General Permit for stormwater discharges.

Expert Insights: Environmental compliance doesn't stop at the state level
2026-07-31T05:00:00Z

Expert Insights: Environmental compliance doesn't stop at the state level

Most industrial facilities have a good understanding of federal and state environmental requirements. However, many compliance issues arise because companies overlook county and municipal requirements.

Local governments often have their own environmental ordinances, permitting programs, and enforcement authorities that apply in addition to state and federal regulations. In some cases, local requirements are more restrictive than state rules and can lead to penalties even when a facility believes it’s operating in compliance.

Local governments play an important environmental role

Environmental compliance isn’t handled solely by the Environmental Protection Agency (EPA) and state environmental agencies. Counties, municipalities, sewer authorities, and local stormwater programs often regulate activities that directly affect water quality, public infrastructure, and community health.

For example, local governments commonly regulate:

  • Stormwater discharges,
  • Erosion and sediment control,
  • Industrial wastewater discharges to sewer systems,
  • Hazardous material storage,
  • Spill prevention requirements,
  • Fire code and emergency planning requirements, and
  • Local environmental permits and inspections.

Many municipalities adopt ordinances that supplement state regulations and give local officials authority to inspect facilities, issue notices of violation, and assess penalties.

Industrial wastewater: Local sewer authorities have enforcement power

Industrial wastewater is one of the most common areas where facilities encounter local environmental requirements. Companies that discharge wastewater to a publicly owned treatment works (POTW) are often regulated by a municipal sewer authority rather than directly through a National Pollutant Discharge Elimination System (NPDES) permit.

Local sewer authorities may issue discharge permits, establish local limits, require monitoring and reporting, conduct inspections, and enforce violations through penalties or corrective actions. Facilities can face enforcement for unauthorized discharges, exceedances, or reporting failures even when no state inspection has occurred.

Stormwater compliance often includes local requirements

Stormwater compliance frequently extends beyond state permit requirements. Many counties and municipalities operate under Municipal Separate Storm Sewer System (MS4) permits and have adopted ordinances that regulate activities affecting stormwater quality.

Local rules commonly address outdoor material storage, drainage system maintenance, erosion controls, illicit discharges, stormwater infrastructure inspections, and construction activities. A facility may comply with its industrial stormwater permit but still violate local requirements if it fails to maintain drainage systems, creates unauthorized storm sewer connections, or performs regulated site work without local approval.

Hazardous waste compliance may involve local agencies

While hazardous waste requirements are primarily federal and state responsibilities, local agencies often regulate related operational activities. These requirements may include hazardous material storage permits, fire code compliance, spill prevention measures, emergency response planning, zoning approvals, and inspections by fire marshals or emergency management officials.

Local inspectors often identify storage, containment, labeling, or emergency planning deficiencies before state environmental agencies conduct inspections. Addressing these requirements helps reduce enforcement risk and improve overall compliance performance.

A multilevel compliance strategy is essential

A strong environmental compliance program considers federal, state, county, and municipal requirements. Before expanding operations, constructing facilities, modifying wastewater systems, or changing stormwater infrastructure, companies should evaluate applicable local ordinances and permit obligations.

Regular communication with sewer authorities, stormwater programs, fire departments, and planning agencies can help:

  • Identify local requirements early,
  • Avoid costly project delays, and
  • Reduce the risk of enforcement actions.

Ignoring local obligations can create compliance gaps even when a facility meets federal and state environmental requirements.

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Most Recent Highlights In Human Resources

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

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

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

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

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

Which construction projects could be affected?

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

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

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

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

What are emission offsets?

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

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

How does the guidance impact permitting?

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

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

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

What’s the possible impact on facilities?

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

Here's an example:

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

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

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

Keep these points in mind!

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

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

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

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

EPA extends PCE and CTC compliance deadlines

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

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

Who’s impacted?

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

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

What are the new PCE and CTC compliance dates?

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

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

Below is a summary of the new compliance deadlines.

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

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

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

2026-07-24T05:00:00Z

New Mexico classifies AFFF as hazardous waste

Effective date: August 1, 2026

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

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

Changes include:

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

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

Related state info: Hazardous waste generators — New Mexico

2026-07-24T05:00:00Z

Colorado revises annual emissions reporting requirements

Effective date: July 15, 2026

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

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

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

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

Related state info: Clean air operating permits state comparison

2026-07-24T05:00:00Z

Nevada revises hazardous waste recycling rules

Effective date: July 1, 2026

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

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

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