b'eralRegisternoticeDOT-OST-2022-0027,Could these communications be handledelectronic records if switching recordkeep-the ANPRM is seeking information that willelectronically? If so, how? ing services, or if the service agent main-enable the DOT to draft rules for an electron- tainingtheirelectronicrecordsgoesout ic process that will parallel the existingink- 13. Should third parties (i.e. IT and securityof business? Relatedly, how can employerssigned and stored paper system.consultants, data management firms, etc.)ensure that records are not deleted, poten-play a role in maintaining electronic sys- tially leaving the DOT program participant 1. What are the practical impacts of authoriz- tems and transmitting data for employers?without the records they are required toing a fully or partially electronic system? If so, to what degree?maintain under part 40?2. What are the economic impacts of authoriz- 14. If records are kept electronically, and theThe entire Federal Register notice and the abil- ing a fully or partially electronic system? business relationship ends, how would em- ity to comment plus all public comments to ployers ensure that they have access to theirdate can be found at regulations.gov.3. How would confidentiality and system se- curity be maintained to prevent against data breach and data loss?4.How many levels of authentication should be utilized to ensure the reliability and security of the signatures of program participants?5. Howisthenon-repudiationofasystemensured? 6. Are there any lessons learned or shared bestpractices available related to paperless non-DOT regulated testing? 7. Are there any limitations in either a paperless or electronic environment that impact pro-gram efficiency?8.Would moving to a paperless system involve the creation of more labels and bar codes and use of additional packaging, etc., not required in a paper-based system. If so, are there any cost and/or efficiency impacts as a result?9.What additional definitions would need to be added to part 40 to accommodate any elec-tronic capabilities or a fully electronic system?10. What measures need to be established to ensurethat,whendocumentsaretrans-mitted to multiple parties, each party is able to properly access and use the elec-tronic system?11.Part 40 requires urine collectors and breath alcoholtechnicians(BAT)topreparea memorandum for the record (MFR) when certain problems are encountered during the conduct of a drug or alcohol test under part 40. How would the MFR be created andtransmittedtoMROs,laboratories, and employers electronically?12.Part 40 requires communication between MROsandtheemployeesphysicianre-gardingshybladdersituations,certain safetyconcerns,andopioidsevaluations. 23 SEPTEMBER 2022'