DOT agency
PHMSA (Pipeline and Hazardous Materials Safety Administration)
Regulation
49 CFR Part 40 & 49 CFR Part 199
Format
In-person & telehealth, Pennsylvania-wide
Who this is for
- Pipeline operators and controllers
- Field maintenance technicians
- Leak survey and integrity crews
- Valve operators
- Emergency response personnel
- Natural gas distribution and transmission employees
What to expect
Your initial evaluation is a confidential 60–90 minute clinical session. We discuss the Part 199 violation, your background, and your situation, then recommend specific education or treatment.
After completion, you return for the follow-up evaluation. Once cleared, your employer arranges the directly observed return-to-duty test and we issue a follow-up testing plan.
Mode-specific details
Operator-specific plans: Each PHMSA-regulated pipeline operator maintains its own anti-drug and alcohol misuse plan under Part 199. The SAP process is uniform regardless of which operator's plan triggered the testing.
No Clearinghouse: Unlike FMCSA, PHMSA has no national database. Your records stay with your employer and any inspection record.
Multi-mode workers: If you also hold a CDL for hauling product, FMCSA rules apply to that side of your work and the SAP process satisfies both.
Frequently asked
I work on a pipeline crew but I'm not the operator — does PHMSA apply to me?+
49 CFR Part 199 covers employees who perform operation, maintenance, or emergency-response functions on a covered pipeline. If you operate valves, perform leak surveys, respond to emergencies, or maintain pipeline facilities, you're likely covered. Your employer's drug & alcohol plan will list which positions are covered.
Can I work on non-pipeline construction while I complete the SAP process?+
PHMSA only restricts covered pipeline functions. Whether you can perform other work depends entirely on your employer's policy and assignment decisions.
Does the PHMSA process require Clearinghouse reporting?+
No. The FMCSA Drug & Alcohol Clearinghouse only applies to CDL drivers under FMCSA. PHMSA does not have an equivalent national database — your violation and SAP records stay with your employer's records and any applicable DOT inspection records.
I work for a small pipeline operator — do the same rules apply?+
Yes. Part 199 applies regardless of pipeline operator size if the pipeline is covered. The SAP process is identical.