Picture this: Your crew is about to start work on a drilling rig, heavy machinery is active, hazardous materials are on site, and schedules are tight.
Now, imagine one worker shows up under the influence. This isn't just a personal issue, it’s suddenly a safety threat to the entire site.
That’s why drug and alcohol testing isn’t optional in the oil and gas industry. It’s a safeguard for people and projects. And with PHMSA’s 2025 update, HR leaders have more on their plates than ever.
Why Drug Testing Matters
- Oil and gas jobs are some of the most high risk in the country.
- One incapacitated worker can cause injuries, delays or even entire shutdowns.
- Drug and alcohol screening is mandatory for certain safety-sensitive roles under federal rules.
- Zero tolerance is the industry standard.
In 2023, the Pipeline & Hazardous Materials Safety Administration (PHMSA) reported higher levels of positive test results which has led to the agency tightening their requirements.
“We’ve seen firsthand how one lapse in testing can ripple across an entire project,” says Constance Brackett, Chief of Staff at KRESS. “HR leaders in oil and gas can’t afford to treat testing as a box to tick. It has to be built into daily operations.”
When Drug Testing Happens
Test Type | When | Purpose |
|---|---|---|
Pre employment drug testing | Before starting work | Confirms new hires are clear before entering a site |
Random drug testing | Any time during employment | Reinforces a drug-free workplace |
Post-incident testing | After an accident or event | Helps determine if impairment played a role |
Return-to-duty | After a violation, before resuming | Confirms the worker is ready to come back |
Follow-up testing | After return-to-duty | Ongoing check for compliance |
Reasonable suspicion testing | When behavior raises concerns | Allows supervisors to act before risks grow |
Random testing is one of the most effective ways to prevent substance abuse and drug use in the workplace. It lowers workplace risks and ensures compliance with both company rules and federal requirements.
The PHMSA 2025 Update
In January 2025, the Pipeline and Hazardous Materials Safety Administration doubled the random testing rate for covered employees, moving from 25% to 50%. The trigger was simple: more workers were testing positive in 2023, crossing PHMSA’s 1% threshold.
For employers, this means:
- Updating drug testing programs and policies.
- Keeping precise drug testing records ready for audits.
- Reporting drug testing results through PHMSA’s secure system.
If these steps are missed, the risks are steep: fines, failed audits, or unsafe sites. Many companies learned the hard way after past audits flagged gaps in recordkeeping. That’s avoidable with preparation.
“Audit stress is real in this industry,” adds Brackett. “We work with HR teams every day to make sure records are airtight and crews are always site-ready.”
State Marijuana Testing Laws
State laws add another layer of complexity. For example:
- California, Nevada, and New York limit how THC testing can be used, especially for non-safety-sensitive roles.
- Michigan prohibits pre-employment marijuana testing, except for safety-sensitive jobs.
- Vermont, Minnesota, and Hawaii require a conditional offer before testing applicants.
- Federally regulated roles like DOT-covered positions must still follow federal zero-tolerance rules, regardless of state law.
Employers need to adapt drug-testing policies based on where employees live and work. Compliance isn’t one-size-fits-all. Policies must reflect both federal requirements and state-specific restrictions.
Marijuana Testing Overview by State
State | Restriction |
California | THC testing limited; can’t be used to deny non-safety-sensitive roles |
Nevada | Employers may not refuse to hire based on pre-employment marijuana test results |
New York | Limits marijuana testing except for safety-sensitive positions |
Michigan | Prohibits pre-employment marijuana testing, except safety-sensitive jobs |
Vermont, Minnesota, Hawaii | Conditional offer required before testing |
Building Robust Drug and Alcohol Testing Programs
In the oil and gas industry, programs can’t just exist on paper. They need to work in the field. A compliant, effective program includes:
- Coverage for remote and offshore locations: Ensure occupational health services reach rigs, pipelines, and offshore sites where access is difficult.
- Supervisor training: Equip managers to act quickly on reasonable suspicion, with documented procedures to avoid legal risk.
- Clear policies tailored to state and federal rules: For example, a policy may state that marijuana use off-duty isn’t grounds for discipline unless the worker is in a DOT-covered or safety-sensitive role.
- Thorough documentation: Record every test, decision, and outcome, from pre employment testing through follow-up, to stay audit-ready.
- Alignment with DOT standards: Follow DOT drug testing regulations in 49 CFR Part 40 for all federally regulated employees.
- Alcohol policy compliance: Include clear rules on alcohol testing to ensure compliance with safety standards and reduce workplace risks.
Example Policy Clauses for Employers
- “All covered employees in safety-sensitive positions are subject to random drug and alcohol testing at a rate set by PHMSA.”
- “Marijuana use, even if permitted under state law, is prohibited for employees in federally regulated roles.”
- “Supervisors may require reasonable suspicion testing based on documented behavior or performance concerns.”
- “Test records will be retained for a minimum of five years and made available for federal or client audits.”
- “Employees who undergo testing after a violation must complete return-to-duty and follow-up testing under a structured plan.”
“Policies aren’t just about compliance, they protect people,” says Brackett. “By putting clear rules in place, employers reduce risk, prevent substance abuse and drug abuse issues, and maintain workplace safety.”
Companies that prepare in this way don’t just meet compliance requirements, they build trust with clients and workers while avoiding costly enforcement actions.
Staying Prepared
Drug testing programs aren’t just about catching someone breaking rules. They’re about prevention, safer workplaces, and protecting both people and reputation. A strong program shows regulators, clients, and workers that safety isn’t negotiable.
PHMSA doubled random drug testing requirements to 50%. Is your program ready? KRESS helps employers ensure compliance with reliable drug testing solutions and reporting tools. Learn more about our substance abuse testing services or get in touch if you have any questions.
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