When pipeline contractors hear the phrase “NCMS monitoring,” the reaction is often uncertainty: What does NCMS look for? Why is my company being monitored? What happens if we don’t pass?
It isn’t as daunting as it sounds, but it is valuable for contractors to understand. Compliance becomes more straightforward when contractors know what goes into the process of monitoring, why it exists, and how to demonstrate their programs are effective.
Pipeline operators can’t simply assume that contractors are maintaining compliant drug and alcohol testing programs – they must oversee it. The federal agencies behind pipeline regulation won’t accept guesswork. It is both a responsibility and a best practice for operators, and NCMS helps provide verification of strong programs through monitoring.
To understand why NCMS monitoring exists, it helps to first understand what it actually means.
What Is NCMS Monitoring?
A crucial layer to job site safety, NCMS monitoring is the process of reviewing and verifying a contractor’s drug and alcohol testing program to determine whether it meets applicable regulatory requirements and/or operator-specific requirements.
When it comes to oversight, there are a few key players:
- Pipeline Operators
- Ensure that contractors performing covered pipeline work comply with applicable regulations.
- Conduct compliance reviews internally, or rely on a qualified third-party organization to analyze performance.
- Request audits for specific contractors through NCMS directly.
- Contractors
- Maintain their own drug and alcohol testing programs.
- Provide documentation and records demonstrating compliance.
- Know what their operator requirements are and confidently understand how their program is administered.
- NCMS
- Acts as an independent compliance oversight partner for operator clients.
- Reviews contractor programs, verifies implementation, and reports compliance status.
- Conducts audits to help operators upkeep safe job sites.
Monitoring is not the same as conducting tests, which can be a point of confusion. NCMS does not perform specimen collections or laboratory testing – NCMS evaluates whether a contractor’s existing program is properly established, documented, and followed. Our monitoring provides the evidence operators need to confidently confirm contractor compliance.
Why Do Pipeline Operators Use NCMS Monitoring Services?
- The regulatory challenge: Pursuant to 49 CFR Part 199, pipeline operators covered by PHMSA regulations must maintain drug and alcohol programs that follow specific rules of compliance. These responsibilities extend to ensuring that contractors meet the same mark. NCMS monitoring helps operators have confidence that contractors are meeting required safety expectations.
- The practical challenge: Pipeline operators may be responsible for overseeing hundreds of contractors and subcontractors. Making sure each company follows the required compliance standards can be a significant challenge. Tracking records, verifying information, and maintaining consistent oversight across so many organizations can quickly become overwhelming. NCMS helps simplify this process by providing standardized evaluations, independent verification, and streamlined reporting.
What Does NCMS Review?
- Written drug & alcohol program documentation. Does the contractor have a written program? NCMS provides a compliant drug and alcohol testing plan and evaluates how that plan is being maintained. This includes verifying the service agents the contractor uses, reviewing job titles and covered positions, confirming employee and supervisor information, and ensuring required training requirements are met.
- Testing program records. Is the contractor actually following the written program? NCMS reviews evidence that the program is being implemented correctly and tests are being administered as they should. This is done by reviewing:
- Blank chain of custody forms
- Blank history check forms
- Specific drug testing and/or history check documents as part of a Validation
- Random testing program administration. Are the very specific requirements of random testing being followed? NCMS verifies proper administration and documentation of random testing by checking protocol, testing rates, completion of tests, and quarterly requirements through statistical data.
- Service provider documentation. Does the contractor keep up with requirements for testing administrators? NCMS may take a contractor’s relationship with testing professionals into consideration. If a service agent is listed in a contractor’s Model Plan, NCMS will want to confirm that they are being utilized through use of continuance compliance framework (CCF) and drug test validations. Service agents up for review include the contractor’s stated:
- Laboratory
- MRO (medical review officer)
- SAP (substance abuse professional)
- Collection sites
How Should Contractors View Monitoring?
The idea of being “monitored” can feel a bit like a trip to the principal’s office. Most people do not enjoy having their work reviewed while trying to get through the day.
At NCMS, we see monitoring differently. The goal is not simply to verify federal and/or operator compliance requirements. It is to help support a safe workplace where employees performing safety-sensitive work can return home safely each day.
Monitoring evaluates both the structure of your program and the records that support it. A strong drug and alcohol testing program helps protect employees, support safe operations, and reduce regulatory risk.
While monitoring is conducted on behalf of operators, it benefits contractors by identifying and addressing compliance gaps before they become larger issues. The most successful reviews happen when contractors maintain accurate records, understand their program requirements, and communicate openly throughout the process.
Ultimately, monitoring is more than a compliance exercise. It is an opportunity to better understand your program and to demonstrate your commitment to compliance while reflecting a shared commitment to safety, accountability, and the people who perform this important work every day.
