A missed post-accident test, an employee placed in the wrong random pool, or a contractor left out of the program can create a serious PHMSA compliance issue. PHMSA testing requirements are specific to pipeline and LNG operations, and they require more than ordering a test when an incident occurs. Operators need a documented, consistently administered drug and alcohol testing program that meets 49 CFR Part 199 and the DOT procedures in 49 CFR Part 40.

For pipeline operators, the practical challenge is keeping field operations, contractor oversight, testing access, supervisor decisions, and records aligned. The program must work when a technician is dispatched after hours, when a new contractor begins covered work, and when an incident demands immediate action.

What PHMSA Testing Requirements Cover

PHMSA regulates drug and alcohol testing for employees who perform covered functions for natural gas pipeline, hazardous liquid pipeline, and liquefied natural gas facilities. The requirements apply to operators, including operators that use contractors to perform covered work.

A covered employee is not limited to a full-time company employee. A contractor, temporary worker, or other individual performing a covered function on an operator’s behalf may need to be included in the testing program. This is one of the most common areas of exposure: the operator remains responsible for ensuring covered work is performed under a compliant testing program, even when the person is employed by another company.

Covered functions generally involve operations, maintenance, or emergency-response activities on a pipeline or LNG facility. The right determination depends on the duties actually performed, not a job title. A payroll employee who never performs covered work may not belong in the Part 199 pool, while a contractor who performs maintenance or emergency-response duties may belong in it.

Part 199 works alongside DOT Part 40. Part 199 establishes who must be tested and when. Part 40 governs how collections, laboratory testing, medical review, alcohol testing, return-to-duty processes, and related procedures must be completed. An employer cannot substitute a general workplace testing process for the DOT process when a PHMSA-covered test is required.

When PHMSA Drug and Alcohol Tests Are Required

A compliant program must address several testing situations. The six core categories are pre-employment, random, post-accident, reasonable cause or reasonable suspicion, return-to-duty, and follow-up testing.

Pre-employment drug testing

Before a covered employee performs a covered function for the first time, the operator must receive a verified negative DOT drug test result. This requirement applies whether the worker is hired directly or supplied through a contractor arrangement.

Pre-employment alcohol testing is not required by PHMSA in the same way as pre-employment drug testing. An operator may choose to conduct alcohol testing under its own policy, but any DOT alcohol test must follow Part 40 procedures. Employers should keep company-policy testing clearly separated from federally required testing so that records and consequences are handled correctly.

Random testing

Random testing must be scientifically valid, unpredictable, and conducted throughout the calendar year. Selection cannot be based on supervisor preference, performance history, location, or an employee’s prior testing record. Each covered employee must have an equal chance of selection every time selections are made.

PHMSA establishes annual minimum random testing rates for drugs and alcohol. Those rates can change, so operators should verify the current annual PHMSA notice before setting their testing schedule. The random pool must include all covered employees subject to the operator’s program, including applicable contractor personnel. A pool that excludes a remote crew, an after-hours employee, or contractor staff is not complete.

Random selections must also be acted on promptly. Delaying a test until an employee returns from a long assignment or allowing repeated scheduling exceptions can undermine the random nature of the program. A nationwide collection-site network and after-hours coordination can make a meaningful difference when a selected employee is working far from the office.

Post-accident testing

Post-accident testing is required after certain pipeline accidents or incidents when an employee’s performance either contributed to the event or cannot be completely discounted as a contributing factor. The decision is not simply based on whether a vehicle crash occurred or whether an employee appears impaired.

Operators need a response process that identifies the event, determines which covered employees may need testing, documents decisions, and initiates testing as soon as practicable. DOT rules impose strict timing expectations. For alcohol testing, employers must document attempts if a test is not completed within the applicable time period and stop attempts after eight hours. Drug testing has a 32-hour outside limit, with documentation required when testing cannot be completed.

The post-accident decision should be based on the regulatory criteria and available facts, not on assumptions about fault. Supervisors should be trained to protect the scene, obtain necessary medical care, contact the designated program representative, and avoid making unsupported determinations in the moment.

Reasonable cause and reasonable suspicion testing

PHMSA uses reasonable cause for drug testing and reasonable suspicion for alcohol testing. These tests must be based on specific, contemporaneous observations concerning appearance, behavior, speech, or body odors. A vague concern, workplace rumor, or an employee’s reputation is not enough.

For alcohol testing, the trained supervisor must make the observations during, just before, or just after the period of covered duty. Documentation should explain what was observed, when it was observed, and who made the determination. Supervisors do not diagnose impairment. Their role is to recognize documented indicators, follow the policy, and arrange testing without delay.

Return-to-duty and follow-up testing

An employee who violates DOT drug or alcohol rules cannot simply be put back on covered duty after a suspension or a negative later test. The employee must complete the required process with a qualified Substance Abuse Professional, comply with the recommended education or treatment, receive a follow-up evaluation, and complete a return-to-duty test with a negative result.

The Substance Abuse Professional also establishes a follow-up testing plan. Follow-up testing is direct observation testing for drugs and must occur as directed during the required period. Employers should manage this plan carefully and keep it separate from random testing. A follow-up test does not replace a random test, and a random selection does not satisfy a scheduled follow-up requirement.

Alcohol and Drug Test Results: What Requires Action

A verified positive drug result, an alcohol result of 0.04 or greater, a refusal to test, or other DOT rule violation requires immediate removal from covered functions. Refusals can include conduct such as failing to appear, leaving before the collection is complete, failing to provide a sufficient specimen without an adequate medical explanation, or adulterating or substituting a specimen.

Alcohol results from 0.02 to 0.039 do not trigger the same violation process as a result of 0.04 or higher, but the employee must be removed from covered duty for the required period. Operators should have clear procedures so supervisors know the difference and do not make return-to-duty decisions independently.

Drug results are reviewed by a Medical Review Officer. Employers should not treat a laboratory report as a final positive before the Medical Review Officer has completed the verification process. This protects the integrity of the program and gives employees the process required under DOT rules.

Recordkeeping Is Part of the Testing Program

Testing compliance is not proven by having a policy on file. It is demonstrated through records that show the program was properly administered. Operators must maintain required records for the applicable retention periods, protect confidential testing information, and be able to produce documentation during an audit or investigation.

Records commonly include random selection documentation, test results, chain-of-custody forms, training records, post-accident decision records, refusals, Substance Abuse Professional reports, follow-up testing plans, and contractor program documentation. The retention period depends on the record type and outcome. For example, records of violations are retained longer than records of negative or canceled tests.

Employers should also maintain a current covered-employee roster and a reliable process for updating it when workers change duties, begin covered work, leave the company, or move between operator programs. A random pool is only defensible when the underlying roster is accurate.

Building a Program That Works in the Field

The most effective PHMSA programs are planned before an incident occurs. They identify the covered population, define contractor responsibilities, establish after-hours contacts, provide supervisor training, and make testing access available where crews actually work. They also include a clear escalation path for post-accident events and reasonable-cause decisions.

For employers managing multiple DOT agencies, separate testing pools and reporting structures can prevent PHMSA records from being mixed with FMCSA, FAA, FTA, FRA, or USCG requirements. A qualified C/TPA can support administration, testing coordination, reporting, and collection access, but the operator should still understand its responsibilities and review program activity regularly.

WOOTS helps regulated employers coordinate DOT-compliant testing programs, dedicated agency pools, supervisor support, and access to collection sites across North America. The goal is practical: make sure a required test can be scheduled, completed, documented, and reported without creating unnecessary disruption for operations.

A PHMSA testing program should be ready before the call comes in. Review your covered-worker roster, contractor agreements, random-pool process, post-accident contacts, and supervisor training now, while there is time to correct a gap.