# Presentation: 310695

## Please Take a Handout Located in the Back of the Room

**Please Take a Handout Located in the Back of the Room**

## How to Save Money

- Michael Redington
- US DOT/Volpe Center

## Know thy Regulations

## Know thy Regulations

- Additional Costs Incurred Due To a Lack of Understanding of:
- What ‘must’ be done
- What ‘may’ be done
- What ‘should’ be done

## Over-Testing

- Random – ‘Minimum’ Required Rates
- 25% for Drug (01/2007)
- 10% for Alcohol
- Appropriate Number of Random Selection Periods for the Number of Covered Employees
- Less Need for Heavy Upfront Testing
- Proper Reasonable Suspicion Testing as Deterrence

## Over-Testing

- Pre-employment
- Many test early in the application process
- Test done prior to background check
- Result is lots of pre-employment testing
- Suggestion – require test after hiring, during training period or later in the application process.  Still need verified negative prior to performing safety-sensitive duty.

## Over-Testing

- Post-Accident
- Auditors Consistently See Unnecessary/Improper Testing
- Contrary to FTA regulations
- Testing doesn't meet threshold
- FMCSA criteria ($ amounts)

## 90 Day Test

- You May - Maintain in Random Pool
- No pre-employment test allowed/required
- Increase in random tests, but less than number of pre-employment tests

**IF**
**Remain in Random Pool**

**No**
** ****Pre-Employment Tests**

**Will Result in **
**More Random Tests**

**Overall Result =**
**Fewer Number of Tests**

## Pre-Employment Alcohol

- Not Required by FTA
- 30,000 Pre-Employment Alcohol Tests in last 3 years
- 25 Results _>_ 0.04
- 18 Refusals
- 1/700 Positive/Refusal
- 0.14% Violation Rate

## Random Selection Method

- Scientifically Valid Method - 655.45(e)
- Random Number Table
- Random Number Generator
- MS-Excel or similar product is an acceptable method
- Not required to have more sophisticated system

- FTA does not endorse nor promote any individual product.

## You Can ‘Piggyback’

- I’m a Random Alcohol Test

- I’m a Random Drug Test

## Piggyback

- Prior to Random Selection – Determine Which of the Selections will be Drug, Which will be Drug and Alcohol
- More Costly Alternative is to do One Selection for Random Drug and a Completely Separate Selection for Random Alcohol

## Waiting at Collection Site

- How much time do your employees spend waiting at the collection site?

## Waiting at Collection Site

- collector

## Waiting at Collection Site

- Are your employees spending too much time here?

- NOTIFICATION

**Time to Collection Site**

**Time at Collection Site**

## Waiting at Collection Site

- Wait Time is Measurable
- Sign-in at Collection Site to Time of Test  as recorded on ATF/CCF
- How much time from
- 			Here         to        Here?

- Wait time can be negotiated in the contract!

## Maintain Records

## Maintain Records

- Keep records as required in 655.71
- FTA Drug & Alcohol Audit
- FTA Triennial Review
- Other situations which may require a review of D&A records (Arbitrations, Court Proceedings, etc.)

## What Must the Employer Pay?

- Which Drug and Alcohol Tests?
- Processing Split Specimens
- Employee’s Testing Records
- Reproduction Costs

## What is the Employer/Vendor NOT Required to Pay?

- D&A tests other than processing split specimen
- SAP services
- Any analysis, study, explanation of a legitimate medical excuse following an unverified positive
- A referral physician acceptable to MRO

## Use ‘FREE’ services

- FTA provides ‘free’ training
- National Conference
- One-day seminars
- TSI 2 1/2 day seminars (very nominal fee)
- FTA provides ‘free’ assistance
- FTA Drug and Alcohol MIS Project Office
- (617) 494-6336, e-mail: FTADAMIS.dot.gov
- ODAPC

- http://www.dot.gov/ost/dapc/

## Use Free services

- FTA Drug and Alcohol Web Site
- transit-safety.volpe.dot.gov
- Discussion Forums
- FTA Publications Clearinghouse
- Publications
- Reasonable Suspicion Videos & Leader’s Guide
- Technical Assistance Tools

## Use P.E.T.E.R.

- Pre-Employment Testing Exemption Request – Pre-Employment Test May _NOT_ Be Required
- Change in Directly-Operated Safety-Sensitive Contractor
- Records Stay in Place and Accessible?
- Negative Pre-Employment Results Available?
- Any Interruption in Safety-Sensitive Duties?
- Any Interruption in Random Testing?

## P.E.T.E.R.

- Send Request to:
**Jerry Powers, FTA Drug & Alcohol Program Manager at Gerald.Powers@dot.gov**

## Saliva Testing

- Allowed for Alcohol Screening Test
- About $3 per Individual Saliva Test Kit
- Currently 1/250 FTA Screening Tests Require (>= 0.02) a Confirmation Test

## Second Chance Policy?

- Is it right for you?
- What should the employer pay:
- SAP Services?
- Return-to-Duty Test?
- Follow-Up Test(s)?
- What do you do if it becomes a 3rd, 4th or 5th chance?

## Should I Join a Consortium?

- Consortia may allow several employers to combine their need and buy in larger quantities – share costs.
- Combine Employer, Contractors, DOT-Regulated (Non-FTA) Employers and FTA-Regulated Employers
- Share Vendor Services (Collection Sites, MROs, SAPs, etc.)

## Vendor Shop

- TPA, Collection Site, Urine Collector, BAT, Saliva Test Technician, SAP, MRO, Lab
- The ‘Customer is Always Right’
- Do Vendor Policies/Procedures Coincide with Employers Best Interest
- Do You Get the Following?
- Proper and timely completion of paperwork
- Professional and respectful approach when contacting employees
- Clear communication from to DER