Self-Assessment Checklist

FTA Drug and Alcohol Regulation Updates
Issue 14, page 3

Drug Testing Checklist

   The Department of Transportation Procedures for Transportation Workplace Drug and Alcohol Testing Programs (49 CFR Part 40) define the procedures to be used for drug testing. All FTA grantees, sub-grantees, and safety-sensitive contractors are required to follow these procedures when conducting drug tests under FTA authority. To assist in clarifying the drug testing procedures, the FTA has developed this checklist for use by employers in their individual program assessments. The checklist includes regulatory requirements, but should not be construed as the “last word” in regulatory compliance. The checklist is merely provided for guidance.

Drug Testing Procedures

  • Have you made provisions to conduct drug tests during all days and hours that the transit system employees perform safety-sensitive functions?
  • Does the transit agency test for the following drugs?
  • Marijuana
  • Cocaine
  • Opiates (e.g., heroin, morphine, codeine)
  • Phencyclidine (PCP)
  • Amphetamines (e.g., racemic amphetamine, dextroamphetamine, and methamphetamine)
  • If the transit agency tests for additional drugs, is the testing being performed separately from the FTA test? Performing separate tests means that a separate urine specimen must be collected with a non-DOT custody and control form. The employee must be notified whether he or she is being tested under FTA authority or the transit agency’s authority.

Specimen Collection

  • Does the collection site(s) follow the Department of Transportation’s guidelines published in “Procedures for Transportation Workplace Drug and Alcohol Testing Programs”?
  • Does the collection site check the donor’s ID? Does the collection site have a procedure in place to confirm donor identity when no ID is presented (i.e., supervisor attests to identity)?
  • Does the collection site:
  • Provide a privacy enclosure for urination, a void receptacle, a suitable clean writing surface, and a water source for hand washing, which, if practicable, should be outside the privacy enclosure?;
  • Secure the privacy enclosure when not in use or, if this is not possible, (e.g, when a public restroom is used), visually inspect it prior to specimen collection to ensure that unauthorized persons are not present and that there are no unobserved entrance points?;
  • Have restricted access during specimen collection?;
  • Add bluing agent to the toilet to prevent dilution of the specimen?; and
  • Turn off, tape, or prevent the use of other sources of water (e.g., sink or shower) that are located in the privacy enclosure where urination occurs?
  • Does the collection site have a procedure in place for notifying the employer if the employee does not report for the test in the designated time frame?
  • Does the collection site use the correct USDOT Chain of Custody and Control forms for DOT/FTA tests (and only DOT tests)? Does the collection site have a secure storage location for specimens and specimen collection materials?
  • Are collection sites available to perform collections during all days and hours that transit system employees perform safety-sensitive job duties?

Collection Site Personnel

  • Is the collection site staff trained to prepare the collection site, collect specimens, examine specimens for tampering or adulteration, observe collections, split the specimens, properly label, and preserve the chain of custody of specimens?
Where To Find?.....

49 CFR Part 654, Prevention of Alcohol Misuse in Transit Operation
February 15, 1994
Federal Register Vol. 59
Pages 7532-7571

Amended:
May 10, 1995
Federal Register Vol. 60
Pages 24765-24766
Primary Topic: Suspension of Pre-employment Alcohol Testing

August 2, 1995
Federal Register Vol. 60
Pages 39618-39620
Primary Topic: Exemption of Volunteers and Post-Accident Testing Provision

December 8, 1998
Federal Register Vol. 63
Pages 67612-67613
Primary Topic: Use of Law Enforcement Post-Accident Test Results

December 14, 1998
Federal Register Vol. 63
Pages 68818-68819
Primary Topic: Random Alcohol Testing Rate at 10%

January 5, 1999
Federal Register Vol. 64
Pages 425-427
Primary Topic: Safety-Sensitive Maintenance Functions

Technical Corrections:
March 6, 1995
Federal Register Vol. 60
Pages 12296-12300
Primary Topic: Corrections and Clarifications

The information presented on this page should be used to update Chapters 7 of the Implementation Guidelines.

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