Interpretation Response #PI-93-033
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
June 25, 1993
This is in response to your correspondence of April 20, 1993, to the Transportation Safety Institute, Pipeline Safety Division, requesting an opinion to determine whether the services that Turner Tank Trucks, Inc., (TTT) provides to your company would subject their employees to the drug testing requirements under Part 199 and 40.
Your correspondence indicates that TTT's only involvement as a contractor is providing services to vacuum up liquids and haul it away from the spill site. They do not perform any functions to or on the pipeline.
Based on the information provided, it would appear that TTT's employees do not perform covered functions on a pipeline or LNG facility. Furthermore, the functions performed by TTT's employees (environmental cleanup) are not regulated by 49 CFR Part 195. Therefore, TTT's employees would not be subject to the drug testing regulations.
Thank you for your inquiry. Please let me know if you need additional information about our drug testing requirements.
Richard L. Rippert
Drug Compliance Coordinator
Office of Pipeline Safety