PHMSA Drug and Alcohol Testing Requirements for Contractors
Drug and alcohol requirements are often misunderstood in pipeline work. This guide helps contractors identify where Part 199 is triggered and how to coordinate with operator programs.
Important disclaimer
Requirements vary by operator, jurisdiction, work scope, and covered function. Confirm requirements with the applicable operator, regulator, and qualified advisors. This guide is informational and is not legal advice.
Quick answer
Part 199 applies to covered employees performing covered functions on regulated pipeline or LNG facilities. It is not a blanket requirement for every employee in every contractor role.
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Practical Part 199 checklist
Determine role applicability
- Identify which roles perform covered functions tied to Parts 192, 193, or 195.
- Separate covered-function roles from support roles that may not be covered under Part 199.
- Confirm applicability with the operator before assigning testing obligations.
Align with operator program
- Confirm the operator's written anti-drug and alcohol misuse plan expectations.
- Verify contractor responsibilities under written contract terms.
- Ensure access to required records and audit support if the operator requests it.
Build implementation controls
- Document pre-employment, random, post-accident, and return-to-duty process responsibilities where applicable.
- Coordinate Part 199 duties with DOT Part 40 procedure requirements.
- Train supervisors on escalation paths for reasonable cause or reasonable suspicion cases.
What varies by operator
- How operators define covered roles for specific scopes and contracts.
- Contract language for contractor plan administration and records access.
- Integration points between Part 199 obligations and operator incident procedures.
- Testing program administration details when multiple contractors share a site.
Common mistakes
- Assuming every employee automatically falls under Part 199 without role review.
- Treating operator guidance as optional when contract terms assign responsibilities.
- Failing to coordinate Part 199 and Part 40 procedures in one documented process.
- Not documenting who is covered and why for each project scope.
Next steps
- Create a role-by-role covered function matrix for each target operator scope.
- Review contract language to confirm who manages testing program elements.
- Update supervisor training for post-accident and suspicion-based triggers.
Sources
- PHMSA — Drug and Alcohol Testing Program Overview (opens in a new tab)
Defines covered employees, covered functions, and operator responsibilities.
- eCFR — 49 CFR Part 199 (opens in a new tab)
Primary federal text for pipeline drug and alcohol testing requirements.
- eCFR — 49 CFR Part 40 (opens in a new tab)
DOT procedures for transportation workplace drug and alcohol testing.
Optional support
Need help applying this information to your company? Cambri Compliance offers an optional paid Contractor Readiness Review. GCC resources remain free, and requesting assistance is entirely optional.
Contact Cambri Compliance (opens in a new tab)What you can do today
Keep your readiness notes simple, align scope with operator expectations, and use GCC as a free public directory while you complete operator-specific qualification and procurement gates.