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PHMSA return-to-duty

PHMSA SAP evaluations and return-to-duty for pipeline employees.

Virtual DOT SAP evaluations throughout New York State, plus New Jersey, Georgia and Massachusetts. Appointments are generally available within 24–48 hours once payment and required paperwork are complete, subject to availability.

Pipeline worker operating a valve at a pipeline facility

Who PHMSA covers

PHMSA drug and alcohol rules cover pipeline safety work.

PHMSA testing rules (49 CFR Part 199) apply to pipeline and LNG operators, and their contractors, for employees who perform covered functions:

  • Pipeline and LNG facility operations
  • Pipeline maintenance
  • Emergency response

Coverage depends on the specific functions you perform, not just your employer or job title.

Step by step

The PHMSA return-to-duty process.

Utility and pipeline crew in hard hats and safety harnesses

1. Removal from duty

You are removed from covered functions and given a list of qualified SAPs.

2. Initial SAP evaluation

A face-to-face clinical assessment by secure video, with recommendations for education, treatment or both.

3. Education or treatment

You complete every recommendation. Your SAP confirms your participation with the program.

4. Follow-up evaluation

The same SAP confirms you complied and reports to your employer.

Return-to-duty test

Your employer directs a return-to-duty test. Drug results must be negative and alcohol below 0.02.

Follow-up testing

At least six unannounced tests in your first 12 months back on duty, for up to five years, as your SAP directs.

Contractors

Contractor employees are covered too.

If you work for a contractor performing covered functions on a pipeline or LNG facility, PHMSA rules apply to you just as they do to operator employees.

Your employer, or the operator’s program, directs your return-to-duty and follow-up testing.

Complete DOT SAP Professional Services — $500 + $18.15 Administrative Fee

Total payable: $518.15. One package covers the professional SAP services for both stages of the evaluation process—the initial evaluation and the follow-up evaluation—not just one appointment.

The professional services package includes:

  1. Initial DOT SAP clinical evaluation.
  2. Initial evaluation report and required reporting to the appropriate recipient.
  3. Individualized education or treatment recommendations.
  4. Assistance with an appropriate secondary referral when needed.
  5. Follow-up SAP clinical evaluation after the required recommendations are completed.
  6. Follow-up evaluation report and applicable reporting.
  7. FMCSA Clearinghouse initial and follow-up reporting when the driver’s case is subject to Clearinghouse requirements.

External education, treatment, laboratory testing, return-to-duty testing and third-party services are separate. Professional findings are individualized and never guaranteed.

Scheduling and paperwork

  1. Submit your SAP inquiry.
  2. Our office follows up on inquiries by the next business day.
  3. Pay the full professional SAP fee ($518.15 total).
  4. Once payment is confirmed, you receive immediate access to the required assessment forms.
  5. Payment starts scheduling for the next available evaluation appointment.
  6. Your evaluation cannot proceed until you finish and submit the required paperwork.
  7. Appointments are generally available within 24–48 hours once these steps are complete, subject to availability.

Scheduling and the evaluation are separate steps: payment lets us schedule your appointment, but the evaluation itself takes place only after your paperwork is complete. The full DOT return-to-duty process—education or treatment, your follow-up evaluation and the employer-controlled return-to-duty test—takes longer than 24–48 hours.

If your employer’s employee assistance program is through Revive (formerly BHS), you might be eligible to have your SAP services covered. Proactive Wellness is a contracted Revive provider: call Revive at 800-327-2251 and ask for Nikita Banks, LCSW, SAP by name, or ask us to help you check.

Other DOT agencies

Return-to-duty guidance for every DOT agency.

Railroad worker, truck driver, pilot and transit operator standing together

All DOT SAP services

Pricing, scheduling and the full return-to-duty process for every DOT agency.

SAP services →

Commercial truck driver beside a tractor-trailer

FMCSA: commercial drivers

CDL truck and bus drivers, school bus and passenger carriers.

Return-to-duty steps →

Airline pilot on an airport ramp

FAA: aviation

Pilots, mechanics, flight attendants, dispatchers and air traffic controllers.

Return-to-duty steps →

Railroad worker beside a locomotive

FRA: railroads

Engineers, conductors, dispatchers, signal and maintenance-of-way workers.

Return-to-duty steps →

Public transit bus operator beside a city bus

FTA: public transit

Bus, subway and light-rail operators, dispatch, maintenance and armed security.

Return-to-duty steps →

Commercial mariner aboard a vessel in a harbor

USCG: maritime

Credentialed mariners and crew in safety-sensitive vessel positions.

Return-to-duty steps →

Pipeline questions

PHMSA return-to-duty answers.

Am I covered if I work for a contractor?

Yes, if you perform covered operations, maintenance or emergency-response functions. Coverage follows the function, not the employer.

What if I tested positive for marijuana in a state where it is legal?

DOT testing rules are federal. A verified positive DOT marijuana test is a violation even where marijuana is legal under state law.

Does refusing a test require a SAP evaluation?

Yes, when it counts as a refusal under DOT rules. Refusals can include failing to cooperate with required testing steps.

Why is a SAP evaluation required?

Federal rules require a structured return-to-duty process for covered employees who violate drug or alcohol rules, to protect public safety.

Can I choose my own SAP?

Often, yes. Your employer must give you a free list of qualified SAPs it accepts. If you are still employed, check with your employer before choosing one not on that list.

Why is payment required before scheduling?

Payment reserves your evaluation time and covers the preparation your case needs. This is our practice’s policy, not a DOT requirement.

Get back to covered pipeline work the right way.

Your first inquiry is free. Appointments are generally available within 24–48 hours once payment and your required paperwork are complete, subject to availability.

Written by Nikita Banks, LCSW MSW SAP NY/NJ/MA/GA

Nikita Banks is a licensed clinical social worker and a DOT-qualified Substance Abuse Professional (SAP) under 49 CFR Part 40. She owns Proactive Wellness LCSW PC and conducts SAP evaluations by secure, live video for employees covered by any DOT agency. She is licensed in New York, New Jersey, Georgia and Massachusetts. Call 347-566-5629 to start.