# Natural Gas of Milton — Pipeline Safety Interpretation

**Citation:** PI-90-025  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 1990-07-13

PI-90-025 response to Natural Gas of Milton concerning 199.3.

## Document text

<<<PAGE 1>>>

July 13, 1990
Ms. Mary Beth LaCoste
Marketing Manager
Natural Gas of Milton
P.O. Box 909
Milton, FL 32572
Dear Ms. LaCoste:
Thank you for your letter of June 12, 1990, regarding the DOT regulations for drug testing of pipeline
company employees (49 CFR Part 199). You asked whether an employee who receives information
about gas leaks and then transfers it to other personnel without making any decision regarding an
emergency would be subject to testing.
A person is subject to drug testing under Part 199 when that person performs on a gas pipeline to
which the Federal safety standards in 49 CFR Part 192 apply an operation, maintenance, or emergency-
response function that it regulated by Part 192. (See the Part 199 definition of "employee.") This
jurisdictional test may be transformed into two questions, both of which must be answered
affirmatively for Part 199 to require drug testing of a person working on a gas pipeline:
(1) Does the function the person performs involve operation of a pipeline, maintenance of
a pipeline, or response to a pipeline emergency?
(2) Is the function the subject of a Part 192 regulation?
The primary regulation in Part 192 that concerns an operator's response to a pipeline emergency is
§ 192.615, "Emergency plans." Under paragraph (a) of § 192.615, an operator must have procedures
for receiving notices of events that require immediate response by the operator. Among such events is
a gas leak. Therefore, any employee who is responsible for receiving notices about a gas leak is
performing a function involved in an operator's response to a pipeline emergency and is subject to drug
testing. To be subject to drug testing, it is not necessary for the employee who takes such notices also
to make decisions regarding an emergency, because receiving notices of events that require immediate
response is an independent function for which procedures are required by § 192.615(a). At the same
time, an employee who merely answers the phone and refers calls about a gas leak to another employee
who takes the notice would not be subject to drug testing, because the other person is the one who
would take or receive notice of the event, not the person initially answering the phone.
dal/199.3
90-07-13.2
1

<<<PAGE 2>>>

Please let me know if we can be of any further help to you in understanding the Part 199 drug testing
requirements.
Sincerely,
George W. Tenley, Jr.
Director
Office of Pipeline Safety
dal/199.3
90-07-13.2
2

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1990/PI90025.pdf>
- Source ID: `phmsa`
- SHA-256: `a6482d3a7f8238d8de04f55c6c50f577ee67f8072cffda47ef99b63f2e3865c3`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-22T00:53:30.599Z
- Document slug: `phmsa-interpretation-pi-90-025`

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