Interpretation Response #PI-93-048 ([The Williams Companies, Inc.] [Jeff Martin])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: The Williams Companies, Inc.
Individual Name: Jeff Martin
Location State: OK Country: US
View the Interpretation Document
Response text:
August 9, 1993
Mr. Jeff Martin
Legal Department
The Williams Companies, Inc.
Suite 3600
One Williams Center
Tulsa, OK 74172
Dear Mr. Martin:
This is in response to your correspondence of June 29, 1993, to the Transportation Safety Institute, Pipeline Safety Division, requesting an opinion to determine whether the procedures your company has in place for monitoring contractors' compliance with applicable DOT drug testing regulations are adequate.
Your correspondence indicates that your company presently requires contractors to comply with the drug testing regulations in the following manner:
- Require contractors to agree by contract that they will comply with the regulations; and
- o Require contractors to have an anti-drug plan that complies with the regulations.
Based on the information provided, it would appear that you are not adequately monitoring your contractors to ensure that they are in compliance with the drug testing regulations as set forth in 49 CFR Section 199.21.
The Office of Pipeline Safety has issued a compilation of opinion letters which are contained in a publication entitled "Pipeline Safety Regulations, Part 199 and Part 40" (redbook). The publication's availability was published in the Federal Register on July 24, 1990, (55 FR 30003). An agency position on operators monitoring of contractors was published on November 14, 1991, and provided guidance in this area of the regulations and listed several options that an operator might consider implementing to satisfy the requirements of Section 199.21. A copy of the "redbook" is herewith enclosed for your review.
Thank you for your inquiry. Please let me know if you need additional information about our drug testing requirements.
Sincerely,
Richard L. Rippert
Drug Compliance Coordinator
Office of Pipeline Safety
Compliance
Enclosure