If you perform covered pipeline functions or drive a commercial vehicle with a CDL, federal DOT drug and alcohol rules may apply to you, and a violation means you can’t return to that work until you complete the return-to-duty process with a qualified Substance Abuse Professional (SAP). Which agency’s rules apply depends on the duties you perform: PHMSA for pipeline operations, maintenance and emergency response, and FMCSA for CDL driving. Proactive Wellness provides DOT SAP evaluations by secure video in New York, New Jersey, Georgia and Massachusetts.
Article summary
- PHMSA rules (49 CFR Part 199) cover operations, maintenance and emergency-response functions on regulated pipelines and LNG facilities, including contractors.
- FMCSA rules cover CDL holders who drive covered commercial vehicles, including many utility trucks.
- Coverage depends on the functions you perform, not your job title.
- A verified positive test, an alcohol result of 0.04 or higher or a refusal starts the SAP process.
Which DOT rules apply to utility and pipeline work
Utility and energy workers can fall under two different DOT agencies, depending on the work:
- PHMSA covers operators of gas pipelines, LNG facilities and hazardous liquid pipelines, plus their contractors, for employees who perform operations, maintenance or emergency-response functions (PHMSA). See our PHMSA SAP page.
- FMCSA covers drivers who need a commercial driver’s license to operate covered vehicles, which can include line trucks, digger derricks and other utility vehicles. See how commercial drivers start the SAP process.
Electric utility work that doesn’t involve CDL driving or covered pipeline functions generally isn’t covered by DOT testing rules, though your employer may have its own policy. Coverage depends on the functions you actually perform, not just your title or employer.
What counts as a violation
- A verified positive drug test
- An alcohol test result of 0.04 or higher
- A refusal to test, which can include not showing up, leaving early or an adulterated or substituted specimen
After a violation, your employer must remove you from covered duties and give you a list of qualified SAPs (49 CFR Part 40).
Need a DOT SAP evaluation?
Talk with a DOT-qualified SAP by secure live video in New York, New Jersey, Georgia and Massachusetts. Appointments are generally available within 24–48 hours once payment and required paperwork are complete, subject to availability.
The PHMSA return-to-duty process, step by step
- Removal from covered functions. You stop all covered pipeline work.
- Initial SAP evaluation. A face-to-face clinical assessment, which we provide by secure video, with recommendations for education, treatment or both. See what happens at a SAP evaluation.
- Education or treatment. You complete every recommendation.
- Follow-up evaluation. You return to the same SAP, who confirms compliance and reports to your employer.
- Return-to-duty test. Your employer directs it. Drug results must be negative and alcohol below 0.02.
- Follow-up testing. At least six unannounced tests in your first 12 months back, and testing can continue for up to five years.
CDL drivers follow the FMCSA process, which also runs through the Drug and Alcohol Clearinghouse. Read CDL downgrade and return-to-duty.
Coverage depends on the duties you perform, not your job title.
A SAP evaluation is not therapy
The SAP process is a federal safety requirement with a specific job: deciding what education or treatment you need before returning to covered work. It’s separate from voluntary therapy. Counseling can help with the stress, family strain or substance use concerns that often come with a violation, and it can be arranged separately. Don’t assume an employee therapy benefit, such as Spring Health, covers a SAP evaluation.
What to do first
- Stop covered work and follow your employer’s instructions. Ask your Designated Employer Representative (DER) for the list of qualified SAPs.
- Confirm which agency’s rules apply. PHMSA for covered pipeline functions, FMCSA for CDL driving. Your DER can tell you.
- Start your SAP intake promptly. The process can’t begin until your initial evaluation is complete.
- Gather what you have. Your test result notice, your employer contact and any letters from the MRO or your employer.
- Get support for yourself and your family. Voluntary counseling, separate from the SAP process, can help during this time.
Who pays for a SAP evaluation
Payment depends on your situation. Some employers or EAPs pay, and many people pay on their own. Proactive Wellness charges a $500 professional fee plus an $18.15 administrative fee ($518.15 total) for all professional SAP services: the initial evaluation, recommendation and report, the follow-up evaluation, the compliance report and the follow-up testing plan. Outside education or treatment, testing and third-party fees aren’t included. If your employer’s EAP is through Revive (formerly BHS), you might be eligible to have SAP services covered. Coverage is never assumed, so we’ll help you check.
Out of work? You can still complete the SAP process. Read completing the SAP process without an employer.
Keep reading
- PHMSA SAP evaluations and return-to-duty for pipeline employees
- Can you do a DOT SAP evaluation online?
- How long does the DOT SAP process take?
- Utility Worker Mental Health: Stress, Emergency Response and Long Shifts
Frequently asked questions
Is my utility job covered by DOT drug and alcohol rules?
It depends on what you do. Covered pipeline operations, maintenance and emergency-response functions fall under PHMSA, and CDL driving falls under FMCSA. Other utility work generally isn’t DOT-covered, though your employer may have its own policy.
I drive a utility truck with a CDL. Which process applies?
The FMCSA process, which includes the Drug and Alcohol Clearinghouse. Read how commercial drivers start the SAP process.
Can I do my SAP evaluation by video?
Yes. Proactive Wellness provides DOT SAP evaluations by secure video for people in New York, New Jersey, Georgia and Massachusetts.
Who directs my return-to-duty test?
Your employer. After your SAP’s follow-up evaluation confirms you complied, your employer directs the return-to-duty test.
Will my EAP or Spring Health pay for my SAP evaluation?
Don’t assume it will. Therapy benefits are separate from SAP services. Some EAPs, including Revive for eligible members, may cover SAP services. We’ll help you check before you start.
Is the SAP evaluation the same as therapy?
No. The SAP evaluation is a federal safety requirement. Voluntary therapy is separate and can help with stress, family strain or substance use concerns.
References
- Pipeline and Hazardous Materials Safety Administration. Drug and Alcohol Testing Program Overview (49 CFR Part 199).
- U.S. Department of Transportation. 49 CFR Part 40: Procedures for Transportation Workplace Drug and Alcohol Testing Programs.
- SAMHSA. (2019). TIP 35: Enhancing Motivation for Change in Substance Use Disorder Treatment.
Need a DOT SAP evaluation?
DOT SAP evaluations are separate from EAP therapy. Start our SAP intake and we’ll explain the process and payment options. Employer or EAP payment is not guaranteed.
Learn more: PHMSA SAP evaluations for pipeline employees.
