# National Counseling Resource — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-97-001
- **title:** National Counseling Resource — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1997-04-04
- **effective on:** Not available
- **summary:** PI-97-001 response to National Counseling Resource concerning 199.243.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-97-001.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-97-001
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1997/PI97001.pdf
**body:**

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Department of Transportation
Office of Drug and Alcohol Policy and Compliance
49 CFR Part 40 Interpretation Notice
Question: Do the Department’ s rules permit the Substance Abuse Professional (SAP)
to recommend a follow-up testing plan if education rather than treatment is the
assistance recommended to address an individual’ s drug and/or alcohol problems?
Response: The Department’ s rules require the SAP to prescribe a follow-up testing
program if assistance is required to address an employee’ s alcohol misuse and/or use
of controlled substances. This assistance can be in the form of education or treatment.
Self-help groups and community lectures when attendance can be independently
verified, and bonafide drug and alcohol education courses are considered appropriate
education experiences. In-patient hospitalization, day-treatment, and out-patient
counseling programs are considered appropriate treatment experiences. Therefore, if
the SAP recommends education or treatment to occur, follow -up testing will be
required.
The follow-up testing plan (with a minimum of 6 tests during the first 12 months
following the employee’ s return to safety-sensitive duties) should be provided as part of
the information the SAP furnishes the employer following the SAP’ s face-to-face
“ Follow-Up Evaluation” with the employee.
Duncan mcpherson
National counseling resource
6821 woodmore oaks drive
Orangevale, ca 95662
Dear Mr. McPherson:

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Thank you for your recent correspondence to the Department of Transportation’ s Office of
Drug and Alcohol Policy and Compliance. In your letter you inquire as to the follow-up
testing requirements a Substance Abuse Professional is to provide to the employer when drug
and alcohol education is the recommended assistance required for your clients. The attached
interpretation is provided in response.
If you wish further clarification, please contact me at (202) 366-3784. Thank you for your
continuing interest in transportation matters.
Sincerely,
Jim L. Swart
Drug and Alcohol Policy Advisor
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