19 industry standards now officially incorporated into the regs, D&A adds Fentanyl to the testing panel, plus a quick recap from our time in New Orleans and Tempe, and how you can help shape what’s next in :AIR™
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Evolving Landscape PHMSA Regulatory Process in the Oil and Gas Pipeline Industry

Hello, Friend with a Pipeline!,

The Evergreen:AIR™ team has been on the move this August, making back-to-back stops at two pipeline safety conferences.

 

From New Orleans at the Louisiana Gas Association’s Pipeline Safety Conference to Tempe for the Western Regional Gas Conference, we’ve been connecting with operators, regulators, and industry experts on the latest challenges and opportunities in pipeline safety.

 

Packed sessions and great conversations gave us plenty of insights to bring back and they reinforce why Evergreen:AIR™ is designed to make compliance easier, faster, and more reliable for operators like you.

 

This week’s update highlights two key federal developments you’ll want on your radar: PHMSA’s final rule incorporating 19 updated industry standards into the Pipeline Safety Regulations, and DOT’s proposed changes to CFR 49 Part 40, including the addition of fentanyl to transportation drug-testing panels.

 

Breathe in that fresh Evergreen:AIR™ – Your Compliance Compass™

James

Pipeline Safety: Periodic Standards Update II

8/21/2025 – Docket No. PHMSA-2020-0013; Amdt. Nos. 191-37, 192-156, 195-117; RIN 2137-AF48

 

PHMSA has finalized a rule that strengthens the Pipeline Safety Regulations (49 CFR Parts 190–199) by incorporating 19 updated industry technical standards into federal law. These standards, developed by leading domestic and international organizations, now carry the force of regulation and directly shape how pipeline operators design, build, maintain, and operate their systems.

 

Why it matters:

  • Public Safety First: Each standard has been reviewed to ensure protections for the public and the environment are maintained or improved.

  • Clarity & Consistency: Current editions replace outdated versions, reducing confusion and conflicts.

  • Encouraging Innovation: Adoption of the latest practices supports efficiency and new technologies while limiting compliance burdens.

  • Proven Approach: With more than 80 industry standards already incorporated by reference, this update continues PHMSA’s practice of keeping regulations aligned with technical advances.

Bottom line: these 19 standards are technically feasible, cost-effective, and practicable and they raise the bar on the safety foundation of our industry.

 

Effective Date: January 10, 2026. The incorporation by reference of the listed publications is approved by the Director of the Federal Register as of that date.

DOT Proposes Updates to Part 40 Drug & Alcohol Testing Rules

September 2, 2025 – The Department of Transportation (DOT) has issued a Notice of Proposed Rulemaking (NPRM) to update 49 CFR Part 40, the regulations that govern workplace drug and alcohol testing for safety-sensitive transportation employees. The full NPRM appears in the Federal Register / Vol. 90, No. 167.

 

Key Proposals You Should Know:

  • Fentanyl/Norfentanyl: Add fentanyl (urine and oral fluid) and norfentanyl (urine only) to DOT’s testing panels.

  • Morphine Cutoff:  Double the urine confirmatory cutoff (2,000 → 4,000 ng/mL), reducing unnecessary MRO review.

  • Oral Fluid Rules: Remove physical exam requirements in some cases; add a new “fatal flaw” for missing specimen volume.

  • Biomarker Testing: Allow biomarker tests (once approved by HHS) to detect substituted or invalid specimens.

  • Marijuana Nomenclature: Update analyte names to reflect current scientific terminology.

  • Training: Require qualification training and mock collections within 30 days for collectors and alcohol testing technicians.

  • Other Fixes: Clarify shy bladder/dry mouth procedures, correct cross-references, and update SAP reporting.

Why it matters:


Fentanyl is now one of the leading drivers of overdose deaths in the U.S. Aligning DOT’s testing rules with HHS’s Mandatory Guidelines aims to improve workplace safety, reduce regulatory confusion, and strengthen defenses against specimen tampering.

 

Comments Deadline: October 17, 2025 

On the Road: Highlights from LGA & WRGC

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The Evergreen:AIR™ team just wrapped up two standout events on the pipeline safety calendar: the LGA Pipeline Safety Conference in New Orleans and the Western Regional Gas Conference in Tempe, AZ.

 

At LGA, operators and regulators dug into incident reporting, corrosion control, underground gas storage, and CO₂ emergency preparedness. Meanwhile at WRGC, the focus was on practical solutions advanced leak detection, internal audits, and PHMSA’s shifting priorities for 2025–2026.

 

That Compliance Lady (Erin) presented on the value of effective internal audits and heard the same challenge raised again and again: how do operators keep pace with constant regulatory change?

 

If we didn’t get the chance to connect with you at either event, let’s fix that. We’d be glad to show you how Evergreen:AIR™ helps operators cut through the noise and stay ahead of compliance.

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You're never on your own. The Evergreen:AIR™ team is always here to help. Whether you need research support, key regulatory details, or anything else, just reach out, we’ve got you covered.

 

Contact us anytime at Hello@thatcompliancelady.com or call 713-487-7373.

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Erin McKay

Anchorage, Alaska
Erin@ThatComplianceLady.com
907-351-1835

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That Compliance Lady, PO Box 240631, Anchorage, AK 99524, 713-487-7373

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