Stay current with Evergreen:AIR™: key dates, PHMSA data meeting details, new enforcement cases, and updated case documents.
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Evolving Landscape PHMSA Regulatory Process in the Oil and Gas Pipeline Industry

Hello, Friend with a Pipeline!,

Fall is rolling in, but compliance never cools down. Evergreen:AIR™ keeps you ahead by cutting through the noise and delivering what matters most, straight to your inbox.

 

From looming deadlines to fresh enforcement actions, we’ve surfaced the essentials so you can move fast and stay audit-ready.

 

Inside this issue:

  • What’s coming: Key dates and comment deadlines, plus PHMSA’s upcoming public meeting on pipeline data and safety improvements.
    What’s new: 1 Interpretation, 8 Advisory Bulletins, 2 Rulemakings; 12 new enforcement cases and 19 case files updated with newly available documents.
    Featured analysis: DOT Part 40 NPRM redline; section-by-section, side-by-side guide to the changes (fentanyl/norfentanyl, biomarker validity, MRO verification, oral-fluid cutoffs, and reporting changes).

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

James

Upcoming Important Dates

Upcoming 9-10-2025

Upcoming Important Dates Table

Evergreen:AIR™ Updates

To keep you up to date with regulatory compliance changes, we’ve updated the Evergreen:AIR™ database.

 

:AIR™ Database Updates 

  • 1 New Interpretation
  • 8 New Advisory Bulletins
  • 2 New Rulemakings
  • 12 New enforcement cases.
  • 19 Enforcement Cases have been updated.

Below is an example of the listing of these enforcement cases provided to subscribers monthly. Subscribers have access to complete details for each of these cases directly inside :AIR™.

September AIR Update

DOT Part 40 NPRM Docket: DOT-OST-2025-0049

Evergreen:AIR™ has taken the guesswork out of PHMSA’s latest Notice of Proposed Rulemaking (NPRM). We built a full section-by-section redline of Part 40 against the proposed text, so you can see exactly what changed, why it matters, and where to update your policies.

 

Key Takeaways:

  • New drugs on the panel: Fentanyl and norfentanyl explicitly added to DOT testing panels and semi-annual lab reports.

  • Oral fluid cutoffs updated: HHS-aligned thresholds, including Δ9-THC confirmatory at 2 ng/mL and an explicit fentanyl row.

  • Biomarkers recognized: Labs can now use biomarkers for validity and substitution testing.

  • MRO verification modernized: Clarified handling of opiates, poppy-seed claims, and clinical evidence—especially for oral fluid.

  • Collector training & errors: Tighter 30-day timelines for proficiency and error-correction.

  • Procedural clarity: Expanded rules for refusals, insufficient specimens, hydration guidance, and documentation.

  • Lab reporting: Semi-annual reports now capture fentanyl/norfentanyl categories for both urine and oral fluid.

Why it matters:
These updates align DOT programs with the latest HHS science, target fentanyl as a high-risk opioid, strengthen labs with biomarker testing to detect tampering, and sharpen expectations for collectors and MROs.

 

Here’s a snapshot from the redline, just a small sample of the detailed comparisons you’ll find in :AIR™, designed to help you move from awareness to implementation with ease.

Part 40 NPRM RL

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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