Date:  6-2-2005

Department of Transportation Docket Facility

400 7th St SW PL-401

Washington D.C. 20590

RE: Docket RSPA-04-19856

    Pipeline Safety: Drug and Alcohol Testing MIS

	S & G Associates, Inc. is a C/TPA dealing with a client base that are
subject to several different modes of DOT regulations.  The clients
consist of one person   entities up to and including companies with
several hundred employees.

	We assist all of our DOT regulated clients with preparing annual MIS
reports.  The one size fits all MIS Report Form has reduced the time we
spend each year preparing these reports.  

	All DOT Drug and Alcohol regulations are written on an industry wide
basis and should continue to be enforced on that basis.  Do not attempt
to split the contractors from the operators.  An employee performing
maintenance on a pipeline is performing that duty in the same manner,
whether they are a contractor or a direct employee of the operator.

	Part 1 of the MIS report contains enough information to differentiate
employers submitting reports.  Obtaining a unique identifier from OPS
could be a needless burden on OPS and the contractor.  However, this
burden could be some what alleviated if a contractor or an agent (C/TPA)
for the contractor could register the contractor via the internet.  Many
of the smaller contractors do not have their own internet access.  Make
the registration only valid for one calendar year.  Thus, as contractors
go out of business, as they do quite frequently, the system is not
overloaded with invalid identifiers.  If a contractor chooses to
maintain their status as a qualified contractor they could log on and
renew their authorization number before it expired.

    We also recognize that pipeline maintenance tends to be seasonal.  A
contractor that had 50 or more covered employees in a random pool at one
time, any time during the previous year should be required to submit a
MIS report for that year.

	The FAA has a simple form that could be used as a basis to develop a
form specific to the PHMSA industry.  Specifically, the company has to
state whether they have 50 or less safety-sensitive employees.  As the
FAA does, one could do a random sampling of those contractors with less
than 50 covered employees.

	Other responders have suggested that a contractor be required to submit
a copy of their annual MIS report to the operator. This is fine, but
does not address the case of a newly organized contractor.  If the
operators would accept a simple letter to the effect that the contractor
was not required to submit an annual MIS the previous year, we would
have no problem with their suggestion.

	My experience over the past 15 years is that there is no significant
difference between contractors and operators in the rate of positive
drug test.  Substance abuse has no social, economic, or employment
boundaries.

Respectfully submitted,

Linda M. Graves, VP

S & G Associates, Inc.

