Pipeline Regulations and CDL Holders: Understanding the Differences

Managing compliance in the pipeline industry can get complicated, especially when employees with Commercial Driver’s Licenses (CDLs) are involved. The overlap between Federal Motor Carrier Safety Administration (FMCSA) and pipeline regulations often creates confusion, particularly when it comes to drug and alcohol testing. Here’s an easy-to-follow guide to help clarify these differences.

Pipeline Employees with CDLs: Testing Under the Right Regulations

Pipeline workers often hold CDLs, but the type of DOT regulations they fall under depends on their specific duties. Here’s what you need to know:

1. Pipeline Testing vs. FMCSA Testing

Employees working in pipeline positions are tested under pipeline regulations, even if they have a CDL.

However, if they are driving a commercial motor vehicle (CMV) as part of their job, the testing may fall under FMCSA regulations.

It’s critical to confirm with the Designated Employee Representative (DER) whether a test was conducted under pipeline rules or FMCSA rules.

2. Alcohol Testing Differences

Random alcohol testing is not required under pipeline regulations. If there’s a random alcohol positive, it’s almost certainly under FMCSA regulations since pipeline rules don’t mandate random alcohol testing.

CDL Holders and DOT Violations: When It Counts

One important distinction is that simply having a CDL doesn’t automatically mean pipeline workers are subject to FMCSA testing or DOT violations.

Driving a CMV Matters: Even if an employee holds a CDL, they must be driving a commercial motor vehicle as part of their job for an issue to be considered a DOT rule violation under FMCSA.

For example, a CDL holder working in a refinery who never drives a CMV is subject to pipeline regulations, not FMCSA rules.

Key Takeaways for Employers and DERs

1. Verify Testing Type: Always confirm whether a test is being conducted under pipeline or FMCSA regulations, especially when reviewing positive results. The distinction affects how violations are handled.
2. Understand Alcohol Testing Differences: If you’re seeing a random alcohol test, you can rule out pipeline regulations since they don’t require random alcohol testing.
3. Distinguish Duties vs. CDL: A CDL alone doesn’t make a pipeline worker subject to FMCSA rules. It’s their role and responsibilities (e.g., driving a CMV) that determine this.

Final Thoughts

Compliance in the pipeline industry requires a clear understanding of how DOT testing regulations apply to workers with CDLs. By verifying testing circumstances and aligning them with the correct regulations, employers can avoid confusion and ensure proper handling of positive test results. Clear communication with DERs and employees is key to maintaining a compliant and safe workplace.