PHMSA drug and alcohol testing applies to covered employees—individuals who perform operations, maintenance, or emergency-response functions regulated under 49 CFR Parts 192, 193, or 195 on a pipeline or liquefied natural gas (LNG) facility.
Covered employees include personnel performing the following functions:
- Gas pipeline operations and maintenance personnel (49 CFR Part 192).
- Hazardous liquid pipeline operations and maintenance personnel (49 CFR Part 195).
- LNG facility operations personnel (49 CFR Part 193).
- Underground natural gas storage facility personnel.
- Emergency-response personnel responding to incidents involving covered pipeline or LNG systems.
Coverage depends on the specific duties being performed—not simply working near a regulated pipeline or facility. For example, an employee moving an extension cord to eliminate a trip hazard, without performing an operations, maintenance, or emergency-response function, is not considered a covered employee for that task.
Contractors are also subject to PHMSA drug and alcohol testing requirements. Employees of contractors performing covered functions on behalf of a pipeline operator must comply with Part 199. While operators may delegate testing, education, and training responsibilities to contractors, the operator remains responsible for ensuring overall compliance and must make contractor records available to PHMSA and applicable state agencies upon request.
PHMSA drug and alcohol testing requirements apply across a wide range of pipeline and storage operations, including:
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Natural Gas Pipelines (49 CFR Part 192). Covers operators of natural gas transmission, distribution, and qualifying gathering pipelines.
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Hazardous Liquid Pipelines (49 CFR Part 195). Covers operators transporting crude oil, petroleum products, and other regulated hazardous liquids.
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LNG Facilities (49 CFR Part 193). Covers facilities involved in liquefying, storing, vaporizing, or transferring liquefied natural gas.
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Underground Natural Gas Storage Facilities. Covered under the same Part 199 testing framework applicable to regulated pipeline operations.
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Pipeline Construction & Maintenance Contractors. Contractor employees performing covered functions on regulated pipeline or LNG facilities are subject to the same testing requirements as operator employees.
Contractor status does not create an exemption from PHMSA drug and alcohol testing requirements.
PHMSA drug and alcohol testing requirements under 49 CFR Part 199 differ from several other DOT agencies because drug and alcohol testing are not required under the same circumstances.
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Pre-employment. Required before a new hire or transferred employee begins performing covered functions.
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Random. Unannounced testing conducted throughout the year using the applicable annual random testing rate.
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Reasonable Cause. Based on specific, contemporaneous observations indicating probable drug use.
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Post-Accident. Required following a qualifying pipeline or LNG accident.
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Return-to-Duty. Required before an employee resumes covered functions after a drug and alcohol testing violation.
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Follow-Up. A series of unannounced tests directed by a Substance Abuse Professional (SAP).
- Post-Accident
- Reasonable Suspicion
- Return-to-Duty
- Follow-Up
Unlike drug testing, PHMSA does not require alcohol testing for pre-employment or random testing. This distinction is one of the most frequently misunderstood aspects of Part 199 compliance.
The minimum annual random drug testing rate is currently 50% of all covered employees. PHMSA confirmed on December 9, 2025, that the 50% rate remains in effect for the entire 2026 calendar year.
Under 49 CFR 199.105, PHMSA may reduce the annual random testing rate to 25% if the industry-wide positive drug test rate remains below 1% for two consecutive calendar years. If the positive rate reaches 1% or higher, the random testing rate must return to 50%.
This adjustment has occurred in recent years. The random testing rate was reduced to 25% during 2023 and 2024, then increased back to 50% for 2025 based on industry DAMIS data, and PHMSA has confirmed the same 50% rate for 2026.
Operators should verify the current published testing rate each year rather than assuming the previous year's rate still applies. Employers participating in a consortium should also confirm their random testing pool has been calibrated to the current PHMSA requirements.
Many small and mid-sized operators—including regional utilities, compressor stations, and pipeline maintenance contractors—participate in a Consortium/Third-Party Administrator (C/TPA). These programs combine covered employees from multiple operators into a compliant random testing pool while managing selections, scheduling, documentation, and MIS reporting.
PHMSA drug testing uses the DOT-required 5-panel urine drug test. All specimens are analyzed at a SAMHSA-certified laboratory and reviewed by a Medical Review Officer (MRO). The test screens for:
- Marijuana (THC)
- Cocaine
- Opiates
- Phencyclidine (PCP)
- Amphetamines (including methamphetamine)
PHMSA compliance requires urine specimens only. While hair and oral fluid testing may be used for certain non-DOT purposes, neither specimen type satisfies PHMSA drug testing requirements under DOT regulations.
Alcohol testing is conducted using evidential breath testing (EBT) and applies only immediately before, during, or immediately after an employee performs a covered function.
Alcohol test result thresholds include:
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0.02 to 0.039 BAC. The employee must be removed from covered functions until their next regularly scheduled shift.
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0.04 BAC or greater. Considered a violation and treated the same as a verified positive drug test.
A verified positive drug test or refusal to test requires immediate action under PHMSA regulations.
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Immediate Removal. The employee must be immediately removed from performing covered functions.
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SAP Evaluation. A qualified Substance Abuse Professional (SAP) evaluates the employee and recommends any required education or treatment.
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Return-to-Duty Testing. Before resuming covered functions, the employee must successfully complete a directly observed return-to-duty test in accordance with 49 CFR Part 40.
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Follow-Up Testing. The employee must complete a series of unannounced follow-up tests directed by the SAP.
Test results and related records remain confidential and may generally be released only to the employer and the SAP unless the employee provides written authorization or the information becomes relevant to a grievance, hearing, or legal proceeding initiated by the employee.
Unlike some other DOT agencies, PHMSA does not require operators to report individual positive drug tests or refusals directly to the agency. Operators must instead maintain complete testing records and submit annual aggregate data through the MIS/DAMIS reporting process when required.
Employers that fail to comply with PHMSA drug and alcohol testing requirements may be subject to civil and criminal penalties under the Hazardous Materials Transportation Act, including substantial fines and, for willful violations, potential imprisonment.
Every pipeline operator must maintain a written Anti-Drug Plan and Alcohol Misuse Plan (often combined into a single Drug & Alcohol Plan) explaining how the operator complies with 49 CFR Part 199.
A compliant plan should document your organization's specific policies, procedures, and responsibilities—not simply repeat the regulatory language. Generic plans that fail to describe operator-specific processes are a common audit finding.
In addition to a written plan, operators must maintain:
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Supervisor Training. At least one hour of training on recognizing indicators of probable drug use and a separate one-hour course on recognizing probable alcohol misuse.
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Employee Education Materials. Information explaining the testing program, employee responsibilities, and contacts for questions or assistance.
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Annual MIS/DAMIS Reporting. Due by March 15 for operators and contractors with 50 or more covered employees, or whenever requested by PHMSA. Although a Consortium/Third-Party Administrator (C/TPA) may prepare the report, the operator's anti-drug program manager remains responsible for certifying its accuracy.
US Health Testing works alongside pipeline operators to develop and maintain fully compliant PHMSA drug and alcohol testing programs, including written plans, supervisor training, consortium administration, and ongoing compliance support.
Last Reviewed: July 2026
On December 9, 2025, PHMSA published a Federal Register notice (Docket No. PHMSA-2025-1107) confirming that the minimum annual random drug testing rate remains 50% of all covered employees for calendar year 2026.
The decision was based on 2024 DAMIS data showing an industry-wide positive drug test rate at or above 1%, requiring the random testing rate to remain at 50%. Operators participating in consortium programs should verify that their random testing pool reflects the current annual rate.
We'll continue updating this section each December when PHMSA publishes its annual random testing rate determination.
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Nationwide network of SAMHSA-certified collection sites with strong coverage along major pipeline corridors, industrial facilities, and energy hubs.
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Partnerships with Labcorp and Quest Diagnostics for accurate, court-defensible laboratory testing.
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Every laboratory result is reviewed and verified by a certified Medical Review Officer (MRO) in accordance with 49 CFR Part 40.
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Consortium enrollment and random pool management for operators of every size—from individual compressor stations to multi-state pipeline networks.
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Expert assistance with Anti-Drug Plan development, supervisor training, MIS/DAMIS reporting, and ongoing PHMSA compliance—not just specimen collection.
US Health Testing provides complete PHMSA drug and alcohol testing program management to help pipeline operators stay compliant, reduce administrative burden, and maintain a safe, drug-free workforce.
