PHMSA SAP Program

PHMSA looks at your job duties, not just your job title.

Under 49 CFR § 199.3, PHMSA considers certain operations, maintenance, and emergency-response duties on regulated pipelines and LNG facilities to be covered functions.

That can include work involving:

• Pipeline operations
• Pipeline maintenance
• Equipment inspection or repair
• Emergency response
• LNG facility operations
• LNG facility maintenance
• Other regulated pipeline work

If you do this type of work, PHMSA testing rules may apply to you even if your job title does not mention safety-sensitive or regulated work.

You can fall under PHMSA testing rules even if you work for a contractor instead of directly for the pipeline operator.

If your contractor sends you to perform covered pipeline work, the same federal drug and alcohol rules may apply.

Under 49 CFR § 199.115 and 49 CFR § 199.245, contractors can run drug and alcohol testing programs for their covered employees.

The pipeline operator will still be responsible for ensuring that everyone follows the federal testing requirements, and the contractor must retain records for inspections and audits.

You can have a drug violation if you:

• Test positive on a required DOT drug test
• Refuse a required drug test
• Provide an adulterated or substituted specimen that counts as a refusal
• Leave the testing site early
• Fail to comply with the site’s instructions

Under 49 CFR § 199.103, your operator cannot let you continue covered work after a failed or refused drug test until you meet the required return-to-duty conditions. PHMSA also has specific alcohol rules.

You cannot:

• Work in a covered function with an alcohol concentration of 0.04 or higher under 49 CFR § 199.215
• Drink alcohol while doing covered work under 49 CFR § 199.217
• Drink within four hours before starting covered work under 49 CFR § 199.219
• Drink during the restricted period (eight hours) after certain pipeline accidents under 49 CFR § 199.221
• Refuse a required alcohol test under 49 CFR § 199.223

If you fail or refuse a required DOT test, your employer must take you out of covered PHMSA work.

For drug violations, 49 CFR § 199.105 requires you to complete the applicable return-to-duty steps before you can go back to covered work.

For alcohol violations, 49 CFR § 199.233 requires your operator to remove you from covered duties.

Under 49 CFR § 40.285, you must complete the DOT SAP process before you can perform DOT safety-sensitive work again.

Completing the SAP process makes you eligible to move forward, but it does not force your employer to put you back in your previous job. Your employer still makes that decision under 49 CFR § 40.305.

If your alcohol result is 0.02 to 0.039, you cannot keep working right away, even though the result is below the 0.04 violation level.

Under 49 CFR § 199.237, your employer must keep you out of covered work until:

• Another test shows an alcohol concentration below 0.02, or
• Your next scheduled work period begins and at least eight hours have passed

So while this result does not carry the same return-to-duty requirements as a 0.04 or higher result, it can still temporarily keep you off covered work.

If you work in a covered position, you may need to take a DOT drug test in several situations.

Under 49 CFR § 199.105, these include:

• Pre-employment
• Post-accident
• Random testing
• Reasonable cause
• Return-to-duty
• Follow-up testing

Before you start covered pipeline work, you generally need to pass a pre-employment DOT drug test unless a federal exception applies.

PHMSA does not use the same testing categories for alcohol that it uses for drugs.

Under 49 CFR § 199.225, you may need an alcohol test after:

• A qualifying accident
• Reasonable suspicion of alcohol use
• A return-to-duty process
• A follow-up testing requirement
• Certain alcohol results between 0.02 and 0.039

PHMSA does not require random alcohol testing under Part 199.

If you’re involved in a qualifying pipeline accident, your employer may need to test you when your actions contributed to the accident or cannot be completely ruled out.

For drugs, 49 CFR § 199.105(b) requires the test as soon as possible and no later than 32 hours after the accident.

Alcohol testing has a shorter window.

Under 49 CFR § 199.225, your employer should arrange the alcohol test as soon as practical.

If you are not tested within two hours, your employer has to document why. If eight hours pass without a test, the employer must stop trying to test you and document why the test did not happen.

If you work in a PHMSA-covered job, your employer may select you for a random drug test at any time during the year.

For 2026, PHMSA set the minimum annual random drug testing rate at:

• 50% of covered employees.

Under 49 CFR § 199.105(c), PHMSA can change this minimum rate based on industry drug-testing results.

The 50% rate applies to the testing pool. It does not mean that you personally will be tested a certain number of times.

Every covered employee in the pool must have an equal chance of selection, and employers must spread random testing reasonably throughout the year.

If you test positive and believe the result is wrong, you can ask to have your split specimen tested.

Under 49 CFR § 40.171, you generally have 72 hours after your Medical Review Officer (MRO) tells you about the verified result to request the second test.

You can ask verbally or in writing.

The second part of your original specimen will then go to another HHS-certified laboratory for testing.

This does not automatically cancel the first result, but it gives you a way to have the second part of your sample tested independently.

Even if marijuana is legal in your state, federal DOT drug-testing rules still apply when you work in a PHMSA-covered job.

A medical marijuana card or legal recreational use does not change a positive DOT marijuana test.

Under 49 CFR § 40.137, your Medical Review Officer must follow federal standards when reviewing the result.

DOT also explains in its marijuana guidance that state-authorized medical marijuana use does not count as a legitimate medical explanation for a federally confirmed marijuana-positive test.