PHMSA Compliance

Pipeline Operator and Contractor Compliance 49 CFR Part 199

The Pipeline and Hazardous Materials Safety Administration (PHMSA) which is under the Department of Transportation (DOT), requires pipeline operators and contractors to implement drug and alcohol compliance and testing programs. The required testing is applicable to employees providing covered functions which is defined as an operations, maintenance or emergency response function regulated by 49 CFR part 192, 193 and 195. 

Who is a covered employee?

Any individual who could or may be called upon to perform an operation, maintenance, or emergency response function on the pipeline is subject to testing and full implementation of Part 199.  Employees with a commercial driver license (CDL) who also perform PHMSA covered functions are subject to the PHMSA regulations as well.  Functions such as clerical, payroll and administrative duties not performed in conjunction with pipeline activities would be exempt from the regulation.


Both operators and contractors must have a comprehensive anti-drug and alcohol misuse prevention plan that meet the requirements of the Pipeline and Hazardous Materials Safety Administration (PHMSA), an agency of the DOT. PHMSA and state level agencies monitor compliance with this regulation. In addition, operators and their contractors must compile all testing data and report it directly to PHMSA.  Additionally, pipeline operators must have a process in place to monitor the drug and alcohol compliance of their contractors. Employers must complete a drug and alcohol history check of previous employers within 30 days of hiring a new "covered employee".  

Types of Testing

  • Pre-Employment - Drug only
  • Reasonable Suspicion - Drug and/or alcohol
  • Post Accident - Drug and alcohol
  • Random - Drug only 
  • Return to Duty - Drug and/or alcohol
  • Follow-Up - Drug and/or alcohol

What Drugs are Included in the Testing Process?

  • Marijuana
  • Cocaine
  • Amphetamine
  • Opiates 
  • PCP

Random Selections

Federal regulations require the use of a scientifically valid selection method to comply with the random drug testing requirement. DISA uses a nationally recognized software program for the selection process. Selections from the random pool are pulled each quarter with a total of 25% of the pool tested for drug use each year.

Reasonable Suspicion Awareness Training

PHMSA regulations require that at least one supervisor for each operator or contractor (with 50 or fewer covered employees) must be trained in Reasonable Suspicion Awareness. This training is designed to provide supervisors with information on the signs and symptoms of drug and alcohol misuse. One hour on drug misuse and one hour regarding alcohol misuse is required. For operators and contractors with more than 50 covered employees, a minimum of two supervisors must be trained. This training is included at no additional charge with enrollment in the PHMSA compliance program.

Our Service

The Transportation Advisor is a service agent that acts on your behalf to provide your company with a comprehensive compliance program. The level of service that we provide is enhanced by the relationships we have developed with other service providers across the country. Our extensive database of collection sites means that testing is local and convenient. Our centralized Medical Review Officer provides a speedy turn around time for result reporting. Results are sent via encrypted email or through web reporting.

Upon enrollment, you will receive a PHMSA anti-drug and alcohol misuse and prevention plan, reasonable suspicion awareness training for supervisors, all of the necessary paperwork for the required pre-employment drug tests and forms so we can complete the required drug and alcohol history check of previous employers.  

The Transportation Advisor draws quarterly selections from the random pool, coordinates all testing with the local medical facilities, prepares semi-annual reports and reports to all applicable pipeline operators.

Most companies have a PHMSA compliance program up and running within a week!