An energy operation is rarely governed by a single rule. This operator had roles covered by PHMSA under 49 CFR Part 199, a commercial fleet covered by FMCSA under Part 382, and plant and office staff outside both who are covered by company policy. Before PSI, those groups were managed in pieces, by different vendors and different spreadsheets, which is how gaps develop, and the contractor personnel doing covered work had been treated as a policy question when Part 199 makes them the operator's covered employees (49 CFR 199.3). PSI consolidated the whole workforce under one administrator: a PHMSA pool that includes contractor personnel, an FMCSA pool with its Clearinghouse work, and a non-DOT policy pool, each selected and documented to its own regulator's standard, with the written PHMSA plans in place, one point of contact, and one set of audit-ready records. Three rule sets, one program.
How the engagement runs
- A PHMSA pool for covered functions, including contractor personnel, at PHMSA's own random rate
- An FMCSA pool for the commercial fleet
- A non-DOT policy pool for plant and office staff outside both regimes
- Each pool selected and documented to its own regulator's standard, with the written PHMSA anti-drug and alcohol misuse plans on file
- Pre-employment testing and Clearinghouse queries for the FMCSA fleet hires
- Supervisor training across the safety-sensitive workforce
- Return-to-duty support when a violation takes a driver off the road
- One administrator, one point of contact, one audit-ready record set
About this example
- Details generalized to protect the client's confidentiality; the operator, its sector, and its locations are not identified