Drug and Alcohol Policy and Procedure Documentation
Drug and Alcohol Policy and Procedure Documentation
FTA-DOT Requires many transit services and/or operators of CDL vehicles to maintain a compliant Drug and Alcohol Program. Agencies are required to maintain documentation of drug and alcohol activities that are audited on a regular basis. It is important to maintain the program in an organized and efficient manner to ensure compliance.
Qualifications
The Transit Services Group team is trained and experienced in drug and alcohol requirements. The TSG team has facilitated audits successfully and has been recognized for high achievements.
Drug and Alcohol Notebook
TSG records all documentation for Drug and Alcohol in a Notebook. This allows for all documents to be organized in a simple manner and quick access to any document needed. Moreover, the information can be shared with Your Company’s managers and auditors with permissions based on need to know.
Review of the Sections, Pages and Details
Audit Management
Employee Acknowledgements
Employees are required to sign a Drug and Alcohol Policy acknowledgement statement to document that they understand that employment and continued employment requires compliance with the agency drug and alcohol policy.
Pre-Employment Drug Testing Requirements
Test Notification
Employee Test Notification
This form is given to the employee to notify them of the Pre-Employment Test. This form is universally used to notify of all test types.
Employee Information- Provides the employee information, date and testing time. The testing time for Pre-Employment test is open. The testing time for all other tests is scheduled. This time is used to determine that the employee arrived in a reasonable amount of time for Random, Post-Accident, and Reasonable Suspicion tests.
The collection site information is provided so the employee knows where to go.
Test Site Confirmation
The testing site completes the form which provide the time of arrival, test collection time and date.
The form is signed by the collector at the facility.
This information is used to verify that the employee completed the test and that the employee arrived in a reasonable time from when they were notified.
Pre-employment tests have an open time and reasonable time arrival is not relevant.
Chain of Custody
Test Site Confirmation
The Employer copy of the Chain of Custody Form is recorded.
Results Report
The results of the drug test is recorded and reviewed. Please note the check marks applied to the result lines and the final review: OK on 6/16/2020 by LM. This is done to provide evidence that the results and documents have been reviewed.
The review needs to ascertain errors in the reports and process. Errors are reviewed to determine if the level created a fatal flaw and the test needs to be ignored.
Tests that have errors but none considered a fatal flaw will be corrected and documented with an affidavit of correction.
Affidavit of Corrections
TSG creates an affidavit of correction to distribute to required stakeholders to include the testing service. The affidavit will identify the errors and notify the stakeholders that the error has been corrected per policy.
Reasonable Suspicion Testing Requirements
Post-Accident Testing
Random Testing Requirements (First Quarter is Provided for Example)
TSG or Your Company will provide the safety sensitive employee roster to the third party consortium provider prior to the next quarter. The consortium will provide a roster of employees that are selected for random testing with alternates when appropriate.
Drug and Alcohol Policy for the Period
Drug and alcohol policies are always changes in response to new rules and regulations or failures in policy. It is important that the Drug and Alcohol Policy that governs the period is recorded.
Safety Sensitive Employee Training
Safety Sensitive Employees are required to complete 2 hours of training, 1 hour of how drugs affect the body and 1 hour of how alcohol affects the body. All training certificates are documented for all safety sensitive employees.
Upon completion of our ‘Drug and Alcohol’ online course, the driver will receive a certificate of completion. The STS Instructor Number is listed in each Drug and Alcohol course certificate.
Supervisor Training
All supervisors that are approved to conduct Reasonable Suspicion Assessments for Drug and Alcohol Testing must have 2 hours of training. This sections documents this training and other supervisor or management training completed.
Drug and Alcohol Program Manager Training
Matthew Liveringhouse is a certified Program Manager for drug and alcohol testing programs at TSG.
The Drug and Alcohol Review Spreadsheet
TSG uses a powerful tool as a control to review total program testing compliance with the Drug and Alcohol Review Spreadsheet. This spreadsheet provides confidence that all testing has been documented, random testing is appropriately random, post-accident tests are accounted for and so much more.
Drug and Alcohol Spreadsheet Details
The Random Test data is entered for type, dates, time, employee category, result, and day of week. Reports are derived to verify randomness is adequate.
Tests are Scheduled Proportionately Month to Month
FTA-DOT requires that Random Tests are completed proportionately through the year. Tests should be reasonably scheduled; Similar numbers of tests need to be scheduled each month. The months are on the Y axis and the number of tests increase through the year. The progression of tests scheduled per month should be a 45% line as demonstrated by the red line in the graph.
Tests are Scheduled Reasonably During all Operational Times
Random tests must be scheduled just before service starts, just after service ends, and proportionate through the operational day.
The splatter chart provides visual representation of test time and verify that the requirements have reasonably been met.
Tests are Scheduled Reasonably During all Days of Operations
Random tests must be scheduled proportionately over the service week. There should be a reasonable number of tests scheduled for each day of service.
Reviewing all charts in whole provides confidence that tests were scheduled proportionality over each month, each day of service, and each day of the week. The result is that tests are truly scheduled randomly and employees are not able to anticipate when testing will occur.
Pre-Employment Testing
The Pre-Employment Testing data is entered into the spreadsheet. Additionally, data for obtaining prior employer testing violation information is reviewed.
Post-Accident Testing Confirmation
Post-accident tests are reviewed to determine accuracy.
The Post-accident data is entered. The spreadsheet will track all the events where the accident met the testing criteria. Accidents where the criteria was not met and a test not conducted are excluded from the aggregate test count.
Lab Results
The testing lab provides reports of all tests conducted. These reports provide a third party source report to match with the internal drug and alcohol results.
The lab reports provide:
1. The quantity of tests completed by test type
2. Number of negatives
3. Number of negative dilutes tests
4. Number rejected
5. Number with fatal flaws
6. Number of positive tests
7. Number adulterized
8. Number of invalid tests
9. Number substituted
Test Summary
The summary provides a reconciliation of the agency data compared to the lab reported data.
Last Sections of the Drug and Alcohol Notebook
The Drug and Alcohol Notebook is a comprehensive resource to organize all required drug and alcohol documentation. The last sections are much like the others but are simpler.
Technician Certificates
The agency is required to obtain certificates of training for all Breath Alcohol Technicians and Drug Test Collectors. This section contains these certifications of training.
MRO Credentials
The agency is required to obtain all Medical Review Office credentials and maintain current certification on file.
SAP Credentials
The agency is required to refer employees with positive results to 3 Substance Abuse Professional. This provides resources to employees that test positive, violate testing requirements or upon request. The agency is required to obtain the Substance Abuse Professional credentials and keep current of file.
ROI Forms
Employers are required to contact applicant’s previous employers that maintain FTA-DOT Drug and Alcohol Programs. The agency is required to file the Release of Information from the applicant. This section also provides documentation of the reasonable attempts made by the agency to obtain the information.
Annual NDT Forms- MIS Reports
The FTA-DOT requires agencies complete MIS Data Collection Forms to submit drug and alcohol data. Transit Services Group will complete all forms and submit appropriately.