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If you fail or refuse a PHMSA drug test, it can threaten your career as a safety-sensitive worker.
You’ll have to complete an SAP evaluation and the return-to-duty (RTD) process before you can get back to your job.
In this guide, you’ll learn about the PHMSA drug test and what to do if you fail.
Key Takeaways
- If you fail or refuse a PHMSA drug test, you’ll be removed from duty and won’t be able to return to work until you complete an SAP evaluation and all treatment and/or education recommended by your DOT-qualified Substance Abuse Professional (DOT-SAP).
- Once you’ve completed the recommendations, you must pass an observed RTD drug test and follow-up testing for up to five years.
- American River Wellness is a DOT-Qualified SAP that can help you get back to work fast. Contact us today: (833) 436-8727
What is PHMSA Drug Testing?
The Pipeline and Hazardous Materials Safety Administration (PHMSA) is an administration within the U.S. Department of Transportation (DOT) that regulates pipelines and the transportation of hazardous materials across the US.
Companies that are regulated by the PHMSA must comply with both its regulations and the DOT drug and alcohol rules.
These rules require regulated employers to perform 5-panel DOT urine drug tests at specified times and at designated rates each year.
PHMSA drug and alcohol testing is designed to:
- Protect public safety
- Prevent serious accidents and injuries
- Keep pipelines and hazardous material operations compliant with federal law
Who Needs to Take a PHMSA Drug Test?
Employees who work for employers regulated by the PHMSA must undergo PHMSA drug testing if they work in safety-sensitive positions.
This applies to companies operating within the pipeline and energy industries and their safety-sensitive workers.
Covered workers may include:
- Pipeline workers
- Oil and gas workers
- LNG facility employees
- Emergency response personnel
- Maintenance and operations employees
PHMSA Drug Testing Requirements
PHMSA-regulated employers must conduct the following types of tests under 49 CFR Part 199 § 199.105:
- Pre-employment testing – When you apply for a safety-sensitive job with a company the PHMSA regulates, you must take and pass a five-panel DOT drug test. If you fail this test, you won’t be hired.
- Random drug testing – Regulated employers must conduct random drug tests of their covered employees. For 2026, the random drug testing rate for PHMSA-regulated employers is 50%. If selected, you must immediately report to the approved testing site to submit a specimen.
- Post-accident testing – If you’re involved in an accident while working, you must submit to post-accident drug testing within 32 hours. If you fail a post-accident drug test, you may have to complete the SAP process and may face potential termination.
- Reasonable suspicion testing – If your employer has a reasonable and articulable suspicion that you are under the influence of drugs or alcohol while on duty, you’ll be required to complete reasonable suspicion drug testing. For example, if you have bloodshot eyes and smell strongly of alcohol, you might have to take an alcohol test. If you are behaving erratically, you might be asked to take a drug test. If you fail a reasonable suspicion drug test, you will have to complete the SAP process before you can return to work, and you may lose your job.
- Return-to-duty testing – When you’ve violated the DOT’s drug and alcohol rules and have completed the SAP evaluation and process, you must submit to return-to-duty testing before your employer or a new employer can place you back in your job. This test is conducted under direct observation. If you submit a positive result, you’ll have to restart the SAP process.
- Follow-up testing – Once you return to work after completing the RTD process, you must submit to follow-up tests. This involves at least six unannounced drug tests during the first year. Depending on your violation and substance use history, you can be required to submit to follow-up testing for up to five years.
DOT drug tests are urine tests that screen for your recent use of the following substances:
- Marijuana (THC)
- Cocaine
- Opiates (hydrocodone, oxycodone, oxymorphone, heroin, etc.)
- Amphetamines (amphetamines, methamphetamines)
- PCP
The PHMSA alcohol testing rules are found in 49 CFR Part 199 Subpart C.
Under these rules, an employer can request you to submit to a pre-employment alcohol test, but this is optional.
Other times you might have to submit to alcohol testing include:
- Following a PHMSA reportable accident
- When a trained supervisor reasonably suspects that you are under the influence of alcohol while on duty
- When you’re returning to duty after completing the SAP process for refusing or failing an alcohol test
- Upon your SAP’s directions, follow-up alcohol testing might be required after you’ve returned to work
What to Do If You Fail a Pipeline Drug Test
1. Stop Performing Safety-Sensitive Work
When you fail a PHMSA drug test, your employer must immediately remove you from safety-sensitive duties.
You won’t be able to return to work until you’ve completed the SAP evaluation and RTD process.
Your employer must retain records of your failure and report it to any potential regulated employers until and unless you complete the SAP process.
2. Contact a DOT SAP Provider
Your employer will give you a list of DOT-qualified Substance Abuse Professionals (DOT-SAPs).
You can also search for one online.
DOT-qualified SAPs have undergone extensive training and know the regulatory requirements of both the PHMSA and the DOT.
You must choose a DOT-qualified SAP. A substance abuse counselor who isn’t DOT-qualified won’t count.
Your SAP will complete an evaluation with you and design a treatment plan.
DOT-qualified SAPs like American River Wellness often offer virtual SAP evaluations for increased convenience.
3. Complete the SAP Evaluation
Once you’ve selected your SAP and scheduled your evaluation, you should prepare. Gather information about your violation and review your company’s drug and alcohol policy.
During your session, your SAP will review your substance use history and discuss your violation.
Based on their findings, they will create a tailored plan with recommendations for treatment and/or education.
4. Finish Any Required Education or Treatment
You must complete all of your SAP’s recommendations before you’ll be allowed to return to work. Common recommendations include:
- Drug and/or alcohol counseling
- Drug and/or alcohol education classes
- Support groups
- Inpatient treatment (when necessary)
The requirements vary by person and depend on your needs. Your SAP will monitor your progress throughout the program.
5. Pass the Return-to-Duty Test
Once you’ve completed all of the recommendations, you’ll meet with your SAP again.
You must pass a directly observed DOT drug test before you can return to work per PHMSA regulations.
If your SAP is satisfied that you are safe to return to duty, they will write a report and submit it to your employer.
6. Complete Follow-Up Testing
Your employer has the final decision about whether to return you to work.
If you’re allowed to return, you’ll need to complete follow-up drug tests.
This includes a minimum of six follow-up tests during your first 12 months, and you may be required to submit to follow-up testing for up to five years, depending on your SAP’s recommendations.
If you go to a different regulated employer instead of returning to your former job, you’ll still have to complete follow-up testing as recommended by your SAP.
You must comply with follow-up testing to remain eligible for safety-sensitive work.
Key Laws & Regulations
49 CFR Part 199
49 CFR Part 199 contains the PHMSA’s regulations for drug and alcohol testing.
This includes rules that govern who must take drug and alcohol tests, when they must do so, and what the employer’s and employee’s responsibilities are.
The PHMSA drug and alcohol regulations largely mirror the DOT drug and alcohol regulations found in 49 CFR Part 40.
49 CFR Part 40
The DOT drug and alcohol rules are found in 49 CFR Part 40.
These rules apply to safety-sensitive workers working for companies regulated by any of the DOT administrations, including the PHMSA.
They include when you must be tested, the types of tests you may be required to take, the random testing rates for the various administrations, how employers must treat failed or refused drug or alcohol tests, the requirement to complete the SAP evaluation and RTD process, and more.
Trust American River Wellness to Help You Get Back to Work Fast
If you failed or refused a PHMSA drug test, you must complete the SAP evaluation and return-to-duty process before you can get back to work.
The sooner you complete the evaluation, the sooner you’ll be able to return.
At American River Wellness, we are a DOT-qualified SAP that provides the PHMSA SAP program with same-day or next-day virtual appointments, so you can start the process without delay.
DISCLAIMER: This information is intended solely for educational and informational purposes. It should not be interpreted as legal counsel or guidance.
FAQ
Oil fields use DOT urine drug tests at designated times for safety-sensitive employees.
Since they are regulated by the DOT, they must comply with the rules in 49 CFR Part 199 and 49 CFR Part 40.
These regulations mandate five-panel DOT urine tests. Alternative methods (hair, saliva) are currently not approved, although an employer might use an alternate method for non-covered employees in some cases. Non-covered employees are workers who might work in a non-safety-sensitive job, such as a secretary.
The duration of the SAP process depends on your needs, violation severity, and history of drug and/or alcohol abuse.
Most workers can complete the SAP process within one week, but others might take longer.
Yes, you can request a split-sample confirmatory test.
Under 49 CFR Part 40, § 40.171, you must contact the MRO immediately to request that they test the split specimen. Your request may be verbal or in writing.
However, this will involve testing the second specimen that you submitted rather than submitting a new one.
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