U.S. Department

of Transportation

Federal Transit

Administration

March 2002

Best Practices Manual: FTA Drug

and Alcohol Testing Program

Office of Safety and Security
Notice 

This document is disseminated under the sponsorship of 

the Department of Transportation in the interest of 

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Final Report 

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4. TITLE AND SUBTITLE 

Best Practices Manual: FTA Drug and Alcohol Testing Program 

5. FUNDING NUMBERS 

U2027/TM254 

6. AUTHOR(S) 

Robert L. Gaumer 

7. PERFORMING ORGANIZATION NAME(S) AND ADDRESS(ES) 

EG&G Technical Services * 

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U.S. Department of Transportation 

Federal Transit Administration 

Office of Safety and Security 

Washington, DC 20590 

10. SPONSORING/MONITORING 

AGENCY REPORT NUMBER 

FTA-MA-90-5005-02-1 

11. SUPPLEMENTARY NOTES 

*Under contract to: 

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12a. DISTRIBUTION/AVAILABILITY STATEMENT 

This document is available to the public through the National Technical Information Service, 

Springfield, Virginia 22161. 

12b. DISTRIBUTION CODE 

13. ABSTRACT (Maximum 200 words) 

This document is part of a two-volume set prepared under the Federal Transit Administration’s (FTA) General Technical Assistance Program, to 

provide guidance to the recipients of FTA funding that are required to test their safety-sensitive employees for drug use and alcohol misuse. 

This volume discusses “best practices” used by employers to establish and maintain a compliant testing program. The other volume, 

Implementation Guidelines for Drug and Alcohol Regulations in Mass Transit, explains the regulatory requirements, which were revised in 

2001. 

The best practices discussed here were identified during 5 years of FTA-sponsored audits of existing programs. They are responses to the 

requirements that allow for flexibility in how to comply, i.e., areas where employers have to choose between different options and areas where 

they may want to exceed the minimum FTA requirements. This document identifies the areas where choices are required, the issues involved in 

making those choices, and “real world” examples of choices made. The discussions are organized according to the four required elements of an 

FTA anti-drug use and alcohol misuse program: (1) a program policy statement, (2) an education and training program, (3) a testing program, 

and (4) a procedure for referring policy violators to a substance abuse professional. 

14. SUBJECT TERMS 

Drugs and alcohol, drug and alcohol testing, best practices, public transit, safety, accidents, Federal Transit 

Administration, FTA, regulations. 

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328 

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SD Catalog No. C13 10286 Updated 6/17/98 
BEST PRACTICES 

FTA Drug and Alcohol Testing Program 

Preface 

In 1995, the Federal Transit Administration (FTA) established an on-site audit 

program to monitor compliance with the drug and alcohol testing regulations 

enacted by the U.S. Department of Transportation in 49 CFR Part 40, 

Procedures for Transportation Workplace Drug and Alcohol Testing Programs, 

and by FTA in 49 CFR Part 653, Prevention of Prohibited Drug Use in Transit

Operations, and 49 CFR Part 654, Prevention of Alcohol Misuse in Transit

Operations. The many audits conducted under this program have revealed 

efficient and effective methods used by recipients of FTA funding to comply 

with the many areas of flexibility in those regulations. These methods are 

referred to as “best practices.” 

This document discusses the issues that employers should address when 

deciding how to comply with and whether to exceed the DOT/FTA

requirements, and provides best practice examples (identified during the 

audits) of decisions made by the audited entities. The examples are responses 

to the various regulatory requirements. Also included are multiple responses 

to the same requirements to show different approaches used by different types 

of employers. Because the workforces and operating environments of FTA 

funding recipients vary widely in some respects, the material in every example 

will probably not be applicable to every entity, and in some cases none of the 

examples may be applicable word-for-word. 

This Best Practices manual assumes that the reader understands the 

regulatory requirements, which are explained in Implementation Guidelines for

Drug and Alcohol Regulations in Mass Transit. The Implementation Guidelines

document updates the document published under the same title in April 1994 

(FTA-OH-26-001-94-1). The revised Implementation Guidelines summarize and 

interpret the revised 49 CFR Part 40 issued in December 2000 and the revised 

FTA regulations, issued in August 2001 in 49 CFR Part 655, Prevention of

Alcohol Misuse and Drug Use in Transit. 

All of the examples in this manual were audited and judged to be compliant 

with Part 40 before it was recently revised and with Parts 653 and 654. Each 

of the example policy statements (contained in Appendix A, and discussed and 

referenced in Chapter 2) have been updated to address the revised Part 40 and 

Part 655, but no policies have been audited for compliance with the revised 

Part 40 and Part 655. The other best practice examples have been adjusted by 

the author to reflect the revisions in Parts 40 and 655. 

This manual will be posted on the FTA Office of Safety and Security website: http://transitsafety.volpe.dot.gov, and will be updated periodically. The web posting will probably be 

updated more often than the printed document.

 Page iii
BEST PRACTICES 

FTA Drug and Alcohol Testing Program 

Acknowledgements 

The author wishes to thank Mark Snider of the Federal Transit Administration 

(FTA) Office of Safety and Security for his guidance and direction in preparing 

this manual. The author also thanks James Harrison of the Volpe National 

Transportation Systems Center for his direction and coordination of the various 

resources required for this project. Special appreciation is given to Robbie 

Sarles and Jeff Halstead of RLS & Associates for their invaluable assistance in 

providing information and best practice examples, for providing contacts for 

additional examples, and for reviewing the draft text and appendices. Rodney 

Sams of ICF Consulting and Leila Procopio-Makuh of LPM and Associates also 

provided information and best practice examples. John Morrison of Ketron 

reviewed the technical accuracy of the text and policy examples. Appreciation 

is given to the many transit agencies and state departments of transportation 

that contributed examples of their practices. These include: 

• Broward County (Florida) Transit 

• City of Albuquerque, Transit Department 

• Denver Regional Transit District 

• Des Moines Metropolitan Transportation Authority 

• Government of the Virgin Islands 

• Greater Cleveland Regional Transit Authority (GCRTA) 

• Hartford (Connecticut) Regional Transit District 

• Long Beach (California) Transit 

• Los Angeles County Metropolitan Transportation Authority (LACMTA)

• Massachusetts Bay Transportation Authority (MBTA) 

• Rhode Island Public Transit Authority (RIPTA) 

• San Francisco Bay Area Rapid Transit (BART) District 

• Southeastern Pennsylvania Transportation Authority (SEPTA) 

• Southwestern Ohio Regional Transit Authority (SORTA)/Cincinnati Metro 

• SuTran Transit System, Sioux Falls, South Dakota 

• Tri-County Metropolitan Transit District, Oregon/Tri-Met 

• Washington Metropolitan Area Transportation Authority (WMATA) 

• Western Maine Transportation Services 

• Florida Department of Transportation 

• Georgia Department of Transportation 

• Minnesota Department of Transportation 

• Ohio Department of Transportation 

• West Virginia Department of Transportation, Division of Public Transit

The author also thanks Nathan Grace of EG&G Technical Services for assisting 

with the review process and coordinating the production of this manual. 

 Page iv
BEST PRACTICES 

FTA Drug and Alcohol Testing Program 

Table of Contents 

Page

Preface.................................................................................................................... iii 

Acknowledgements ................................................................................................. iv 

List of Figures.......................................................................................................... vii 

1. Introduction ....................................................................................................... 1-1 

1.1 Background................................................................................................ 1-1 

1.2 Scope of Best Practices ............................................................................ 1-2 

1.3 Organization of Best Practices Information................................................ 1-3 

2. Program Policy Statement.................................................................................. 2-1 

2.1 FTA Test Requirement................................................................................ 2-4 

2.2 Optional Provisions ..................................................................................... 2-4 

2.3 Applicability ............................................................................................. 2-5 

2.4 Prohibited Behavior..................................................................................... 2-6 

2.5 Testing Circumstances ............................................................................... 2-7 

 Pre-Employment Testing ............................................................................ 2-7 

 Reasonable Suspicion Testing.................................................................... 2-8 

 Post-Accident Testing ................................................................................. 2-8 

 Random Testing.......................................................................................... 2-9

2.6 Testing Methodology and Integrity.............................................................. 2-9 

2.7 Refusal Behavior and Consequences ........................................................ 2-10 

2.8 Consequences of Drug Use and Alcohol Misuse........................................ 2-10 

 Return-to-Duty and Follow-Up Testing ....................................................... 2-12 

2.9 Designated Contact Person ........................................................................ 2-12 

3. Education and Training ..................................................................................... 3-1 

3.1 Education.................................................................................................... 3-1 

3.2 Training....................................................................................................... 3-2 

 Training for Safety-Sensitive Employees .................................................... 3-4 

 Training for Determining Reasonable Suspicion of Drug and Alcohol Abuse 3-6 

4. Testing Program Implementation and Management........................................... 4-1 

4.1 Internal Administration ................................................................................ 4-2 

 General Administrative Duties..................................................................... 4-2 

 Pre-Employment Testing ............................................................................ 4-3 

 Reasonable Suspicion Testing.................................................................... 4-4 

 Post-Accident Testing ................................................................................. 4-5 

 Random Testing.......................................................................................... 4-6

4.2 External Administration ............................................................................... 4-7 

 Procurement of Service Agents ................................................................... 4-8 

 Oversight of Service Agents and Contractors/Subrecipients ....................... 4-9 

 Page v
BEST PRACTICES 

FTA Drug and Alcohol Testing Program 

4.3 Specimen Collection and Analysis .............................................................. 4-10 

 Collection Procedures ................................................................................. 4-10 

 Collection Facilities ...................................................................................... 4-11 

Monitoring of Collection and Analysis Operations ........................................ 4-14 

Selection of Collection and Analysis Service Agents ................................... 4-16 

4.4 Medical Review ........................................................................................... 4-17 

 Managing the Medical Review Process....................................................... 4-17 

 Selection of Medical Review Officers .......................................................... 4-18 

 Monitoring Performance of Medical Review Officers ................................... 4-19 

4.5 Records Management.................................................................................. 4-19 

 Record Keeping Methods ............................................................................ 4-20 

 Records Security and Access Control ......................................................... 4-20 

5. Referral, Evaluation, and Treatment .................................................................. 5-1 

 5.1 Managing the Referral, Evaluation, and Treatment Process ....................... 5-1 

 5.2 Selection of Substance Abuse Professionals ............................................ 5-3 

 5.3 Monitoring Performance of Substance Abuse Professionals....................... 5-3 

Appendix A. Example Policies................................................................................ A-1 

Appendix B. Example Administrative Forms and Lists ........................................... B-1 

Appendix C. Example Oversight Forms and Lists .................................................. C-1 

Appendix D. Example Specimen Collection Forms and Lists................................. D-1 

Appendix E. Example Medical Review Forms and Lists......................................... E-1 

Appendix F. Example Substance Abuse Referral Forms ...................................... F-1

 Page vi
BEST PRACTICES 

FTA Drug and Alcohol Testing Program 

 Page vii

List of Figures 

 

Figure Page

4-1 Typical Rest Room as Collection Site ........................................................... 4-11 

4-2 Collector in Rest Room with Donor ............................................................... 4-12 

4-3 Side View of Collection Van.......................................................................... 4-13 

4-4 Rear View of Collection Van ......................................................................... 4-13 

4-5 Rear Step of Collection Van.......................................................................... 4-13 

4-6 Interior of Collection Van............................................................................... 4-14 

4-7 Toilet in Enclosure in Collection Van............................................................. 4-14 

4-8 Sink in Collection Van .............................................................................. .... 4-14 

BEST PRACTICES 

FTA Drug and Alcohol Testing Program

1. Introduction 

This Best Practices manual discusses issues in the US Department of 

Transportation’s (US DOT) and Federal Transit Administration’s (FTA) drug and 

alcohol testing regulations where employers have to make decisions on how to 

comply with the requirements, and provides “real world” examples of choices 

made. This manual and Implementation Guidelines for Drug and Alcohol 

Regulations in Mass Transit are being issued as a two-volume set under the 

FTA’s General Technical Assistance Program, to provide guidance to the FTA 

grantees that are required to test their safety-sensitive employees for drug use 

and alcohol misuse. The Best Practices manual assumes that the reader 

understands the regulatory requirements, which are explained in the 

Implementation Guidelines. 

1.1 Background 

In 1991, in response to growing concerns about the risks posed by the use of 

drugs and misuse of alcohol by transportation industry employees while 

performing safety-sensitive functions, Congress passed The Omnibus 

Transportation Employee Testing Act, which mandated all agencies of US DOT

to implement a drug and alcohol testing program. In 1994, US DOT published 

the minimum uniform requirements for the programs of all the modal 

administrations, in 49 CFR Part 40, Procedures for Transportation Workplace 

Drug and Alcohol Testing Programs. 

Also in 1994, FTA published requirements for certain recipients of FTA 

financial assistance, in 49 CFR Part 653, Prevention of Prohibited Drug Use in 

Transit Operations, and 49 CFR Part 654, Prevention of Alcohol Misuse in

Transit Operations. The FTA regulations were consistent with the provisions of 

Part 40. They were designed to provide the maximum level of safety to 

passengers using public transit services across the country, the employees of 

such providers, and others who may share the roadway with transit vehicles; to 

protect civil rights; and to minimize liability in all locations. 

Shortly after the FTA regulations were implemented, FTA initiated a program to 

monitor compliance. Monitoring consists of review of annual reports submitted 

by the grantees, as required by the regulations, and on-site audits of the 

grantees’ drug and alcohol testing programs. The number of transit accidents 

per passenger mile involving operators, dispatchers, and others who control the 

movement of vehicles has decreased since the program was initiated. 

In 2000, US DOT revised Part 40, to clarify the organization and language, to 

incorporate guidance and interpretations, and to respond to changes in 

Chapter 1. Introduction Page 1-1
BEST PRACTICES 

FTA Drug and Alcohol Testing Program

technology and the testing industry. The amended Part 40 was published in 

the Federal Register in December 2000. 

Accordingly, the FTA regulations were revised to conform with the amended 

Part 40. The revised FTA drug and alcohol regulations were combined in a 

single rule: 49 CFR Part 655, Prevention of Alcohol Misuse and Drug Use in 

Transit. The revised rule also incorporates comments from the FTA grantees 

and guidance that FTA has issued in the past several years, including technical 

assistance, letters of interpretation, audit findings, newsletters, training 

classes, safety seminars, and public speaking engagements. 

1.2 Scope of Best Practices 

Although some of the FTA testing requirements are rigid and prescriptive with 

straight forward responses, many of the requirements have no single response 

that would be correct for all grantees. There are areas of flexibility requiring 

decisions on how to comply. Part 655 also allows employers to exceed its 

minimum requirements. 

This document discusses the issues that employers should factor into their 

decisions of how to comply with and whether to exceed the FTA requirements. 

It also provides the numerous “best practices” identified during the many onsite audits conducted over the past several years. “Best Practices” are efficient 

and effective methods used by grantees to comply with the requirements. 

The practices in this document include policy statements, forms and 

checklists, and narrative descriptions of approaches actually used by grantees. 

In some cases, multiple examples for addressing the same issue or requirement 

are given to show different solutions for different types of transit systems or 

operating scenarios, or just to offer the grantees choices for achieving the same 

result. Though the audit teams have found the grantees to be very similar in 

general, they have found them to be very different in specifics. Therefore, the 

material in every example will probably not be applicable to every entity, and in 

some cases none of the examples may be applicable word-for-word. 

The companion to this document, Implementation Guidelines for Drug and

Alcohol Regulations in Mass Transit, updates the document published under 

the same title in April 1994 (FTA-OH-26-001-94-1). The revised Implementation

Guidelines summarize and interpret Part 655. The Implementation Guidelines

and the Best Practices are intended to be used together; each document 

provides numerous cross-references to the other document. The 

Implementation Guidelines tell the reader what the requirements are, and the 

Best Practices tell how to comply with them.

Chapter 1. Introduction Page 1-2
BEST PRACTICES 

FTA Drug and Alcohol Testing Program

1.3 Organization of Best Practices Information

This manual is designed for easy reference for specific issues or requirements, 

and it refers readers to the Implementation Guidelines for explanation of the 

requirements. 

The many best practice examples in this manual appear in six appendices, and are 

referenced and discussed in the text. The text is bound separately so it can be removed 

from the binder for ease of use when referring to the examples. The separately bound text 

can also be readily carried or stored in a pocket or briefcase for use as a portable reference. 

Chapters 2 through 5 address the four required elements of a drug and alcohol 

testing program specified in Part 655.12. Chapter 2 addresses the program 

policy statement requirements and cites examples from compliant1 policies; it 

is subdivided according to the many content areas specified in Part 655.15. 

Chapter 3 describes the types of education and training programs that have 

been implemented to satisfy the requirements in Part 655.14, and summarizes 

lengthy full-text examples that will be provided on the FTA Office of Safety and 

Security website: http://transit-safety.volpe.dot.gov. Chapter 4 provides best 

practice discussions and cites many examples for implementing and managing 

a drug and alcohol testing program; it is subdivided by program functions--

internal administration (the employer’s own program), external administration 

(the program of the employer’s contractors, subrecipients, and service agents), 

specimen collection and analysis, medical review, and records management. 

Chapter 5 addresses referral, treatment, and evaluation of employees who 

produce positive drug or alcohol test results, including procuring and 

monitoring substance abuse professionals (SAPs). 

Appendix A contains the full-text example policies discussed in Chapter 2. 

Appendix B contains the example administrative forms and lists discussed in 

Section 4.1. Appendix C contains the example oversight forms and lists 

discussed in Section 4.2. Appendix D contains the example specimen 

collection forms and lists discussed in Section 4.3. Appendix E contains the 

example medical review forms and lists discussed in Section 4.4. Appendix F 

contains the example substance abuse referral forms discussed in Chapter 5. 

 

http://transitsafety.volpe.dot.govThis manual will be posted on the FTA Office of Safety and Security website: 

, and will be updated periodically. The web posting will probably be 

updated more often than the printed document. 

1 Each of the example policies cited in Chapter 2 (and presented in Appendix A) was audited and judged 

to be compliant with Part 40 before it was recently revised and with Parts 653 and 654, and each of them 

has been updated to address the revised Part 40 and Part 655. However, no policies have been audited 

for compliance with the revised Part 40 and Part 655. 

Chapter 1. Introduction Page 1-3

Best Practices 

FTA Drug and Alcohol Testing Program 

2. Program Policy Statement 

As mentioned in the Implementation Guidelines (in Chapter 4), FTA requires 

each employer to establish a policy that defines its Drug and Alcohol Testing 

Program, and requires the entity’s governing body to formally adopt the policy. 

An entity’s governing body is the board of directors or highest ranking officials. 

The person who is primarily responsible for implementing and managing the 

program usually guides development of the initial draft of the policy, and 

presents it to the governing body for review and approval. It is generally useful 

to involve top management officials, union officials (if the employees are 

represented), and local legal counsel in reviews of the draft policy. 

To show proof of governing board adoption, some entities include a header on 

their entire document that contains the policy number, adoption date, and 

appropriate signature. Other common methods include a page documenting 

meeting minutes, or a formal adoption page complete with signatures. Another 

method is to include it as an appendix.

Although policies must be changed, readopted, and redistributed to reflect 

significant regulatory revisions, policy readoption is not necessary for minor 

regulatory changes or minor changes in the policy statement, such as the 

name of the entity’s new Drug and Alcohol Program Manager, Medical Review 

Officer (MRO), Substance Abuse Professional (SAP), collection site, or testing 

laboratory. Such changes are often included in an appendix and described in a 

form distributed to safety-sensitive employees. Moreover, these types of 

changes can often be avoided by adding the words “or successor” after the 

names of specific persons and organizations. 

Some employers use their own staff to develop the policy. Others contract with 

an outside expert or company. Both approaches have been successful. Peer 

systems can share their policies, but they should read the shared language 

carefully to make sure it meets the specific needs of their system. The key to a 

successful policy is that it be clear to the employees and clear to the attorneys 

and auditors. Clearly stated policies that focus on specifics tend to have the 

fewest legal challenges. 

Use of a consultant may be preferable if the entity lacks the appropriate 

internal resources and if consultants are available who are extremely familiar 

with the FTA regulations and fully understand the local situation. The 

experience of prospective consultants should be examined carefully before they 

are hired. The audit teams have found a broad range in the quality of policies 

developed by consultants. Even some of the large consulting companies 

providing transportation safety support do not seem to be fully aware of the 

Chapter 2. Program Policy Statement Page 2-1
Best Practices 

FTA Drug and Alcohol Testing Program 

FTA regulations. Some of them assume that Federal Motor Carrier Safety 

Administration (FMCSA) testing requirements are the same as those for FTA. 

Appendix A contains six example policies for entities that wish to develop their 

policy internally or oversee the work of consultants: 

(1) Southwestern Ohio Regional Transit Authority/Cincinnati Metro 

(2) Long Beach Transit (California) 

(3) Tri-County Metropolitan Transit District/Tri-Met (Portland, Oregon) 

(4) Des Moines Metropolitan Transit Authority (Iowa) 

(5) Ohio Department of Transportation 

(6) Georgia Department of Transportation 

Each of these policies was audited and judged to be compliant with Part 40 before 

it was recently revised and with Parts 653 and 654, and each of them has been 

updated to address the revised Part 40 and Part 655. However, no policies have 

been audited for compliance with the revised Part 40 and Part 655. 

The Cincinnati Metro and Long Beach Transit Policies in Appendix A have not

been formally approved by their governing boards since they were revised. 

These six policies were chosen to provide a broad cross section of different 

types of grantees. Cincinnati Metro and Long Beach Transit are large bus 

systems. Tri-Met is a large bus and light rail system. The Des Moines 

Metropolitan Transit Authority (MTA) is a medium-size bus system. The Ohio 

Department of Transportation (DOT) and Georgia DOT each issue a model 

policy to all their subrecipients (almost all of which are small transit operators 

and most of them rural), and strongly encourage its use. 

The Cincinnati Metro and Long Beach Transit Policies are zero tolerance for 

testing positive. The Ohio DOT Policy permits the subrecipient to specify zero 

tolerance or a second chance. The Des Moines MTA Policy is zero tolerance for 

testing positive on all tests except random, but it specifies a second chance for 

a random positive. The Tri-Met and Georgia DOT Policies permit a second 

chance but do not guarantee it. 

The Long Beach Transit Policy is configured differently than the others. It is 

packaged as a booklet that employers and supervisors can readily carry with 

them. It begins with a 22-point summary of the policy, divided into three 

areas: illegal drug policy, FTA drug policy, and alcohol policy. The summary is 

followed by “guidelines” for administering the policy. 

Chapter 2. Program Policy Statement Page 2-2
Best Practices 

FTA Drug and Alcohol Testing Program 

Point-by-point discussions of the minimum policy-content requirements in Part 

655.15 with specific references to the examples in Appendix A are provided in 

the remainder of this chapter. These discussions are organized in subsections 

that generally correspond with the requirements, though the order has been 

changed to reflect the needs and preferences of the grantees and employers: 

(1) FTA Test Requirement - The requirement that safety-sensitive 

employees must submit to drug and alcohol testing administered in 

accordance with Part 655 

(2) Optional Provisions - Employer-implemented requirements of the drug 

and alcohol program that exceed the minimum requirements in Parts 40 

and 655 

(3) Applicability - The categories of employees subject to the regulations 

(4) Prohibited Behavior – Specific information concerning the conduct that 

is prohibited by Part 655 

(5) Testing Circumstances - The specific circumstances under which 

safety-sensitive employees will be tested for alcohol and prohibited drugs 

(6) Drug and Alcohol Testing Methodology and Integrity - The procedures 

used to test for the presence of drugs and alcohol, to protect the 

employee and the integrity of the testing process, to safeguard the 

validity of the test results, and to ensure that the test results are 

attributed to the correct employee (A statement that the employer will 

follow all the requirements in 49 CFR Part 40 will suffice.) 

(7) Refusal Behavior and Consequences - A description of the behavior that 

constitutes a refusal to take a drug or alcohol test and a statement that 

refusal constitutes a violation of the employer’s policy 

 (8) Consequences of a Drug or Alcohol Positive - The consequences for an 

employee who has a verified positive drug test, has a verified alcohol 

concentration of 0.04 or greater, or refuses to submit to a drug or alcohol 

test (including mandatory requirements of immediate removal from the 

safety-sensitive function and evaluation by a SAP), and the consequences 

(as set forth in Part 655.35) for an employee who has a verified alcohol 

concentration of 0.02 or greater but less than 0.04

 (9) Designated Contact Person - The identity of the person designated by the 

employer to answer employee questions about the drug and alcohol program 

Many policies combine these categories and include additional categories. 

Training and education often appear in policy statements, though not required by 

Part 655.15. The Tri-Met Policy (in Section L), the Ohio DOT Policy (in Section D), 

and the Long Beach Transit Guidelines (in Section V) include a section on 

education and training. The Cincinnati Metro Policy (in Part III Section 9.0) and 

the Georgia DOT Policy (in Section 9.0) include a section on training.

Chapter 2. Program Policy Statement Page 2-3
Best Practices 

FTA Drug and Alcohol Testing Program 

2.1 FTA Test Requirement 

A statement that covered employees must submit to drug and alcohol testing 

administered in accordance with Part 655 often appears near the beginning of 

the policy and in conjunction with the list of DOT prohibited substances, as in 

the Ohio DOT Policy where it appears as a subpoint under prohibited 

substances (in Section E). Cincinnati Metro covers this requirement under 

policy (in Part III Section 2.0) immediately before the prohibited substances 

section. Both the Des Moines MTA and Georgia DOT Policies cover the 

requirement in the purpose (in Section 2.0) shortly before the prohibited 

substances section. The statement appears (in Section J) farther from the 

prohibited substances discussion (Section D) in the Tri-Met Policy. Long Beach 

Transit covers this requirement in several different areas (in Items 12 through 

15 of its policy summary and the introduction to the guidelines). 

2.2 Optional Provisions

Employers rarely include optional provisions as a separate section of the policy 

text. Optional provisions are normally mentioned and identified as additional 

in the sections where they logically belong. This is the method used in all of 

the example policies in Appendix A. Some employers use underlines, italics, or 

bold to distinguish between DOT/FTA (i.e., Parts 40 and 655) and nonDOT/FTA testing requirements. The Cincinnati Metro, Long Beach Transit, 

and Georgia DOT Policies present the DOT/FTA requirements in bold. The Long 

Beach Transit and Georgia DOT Policies also italicize the requirements of the 

Drug-Free Workplace Act of 1988 (49 CFR Part 29). The Ohio DOT Policy uses 

standard typeface for the DOT/FTA requirements and uses underlines for the 

transit agency’s requirements. 

Some employers use a testing notification letter that explicitly informs 

employees of the authority under which they will be tested. In addition to 

being clearly differentiated from DOT/FTA requirements, optional provisions 

should be clearly stated to minimize the likelihood that they will be contested. 

Additional requirements often include prohibition and testing of additional 

substances, employee assistance programs, and rehabilitation options. Most 

policies prohibit all controlled substances. Some refer to substances prohibited 

by the Drug Free Workplace Act of 1988. Some employers provide for testing of 

other substances, e.g., ecstasy, barbiturates, non-barbiturate sedatives 

(methaqualone), benzodiazipines (Valium, Librium, Xanax), non-amphetamine 

stimulants, and LSD. LSD is the most difficult and expensive drug to identify 

forensically. Any additional substances must be listed in the policy if an 

employer intends to test for them. The Tri-Met Policy (in Section J1a) requires 

applicants for safety-sensitive positions to provide a second urine specimen for 

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testing of barbiturates, benzodiozepenes, methadone, and propoxyphene. In 

the Des Moines MTA Policy (in Section 6.0), the MTA “reserves the right” to test, 

under its own authority, for any drugs that an employee is reasonably 

suspected of abusing. 

2.3 Applicability

Each position title that includes safety-sensitive duties should be listed in the 

policy regardless of the percentage of the position’s duties that are safety 

sensitive. The policy should also state that all employees and their duties have 

been reviewed. Including the names of all employees subject to testing is the 

clearest method, though possibly not practical in organizations with more than 

a few employees. 

Because 85 percent of all court cases related to drug and alcohol testing in the 

transit industry involve whether the employee testing positive was subject to 

the testing requirement and why, employers should review all duties and 

potential duties of each job title and employee. Front-line operations and 

safety supervisors usually perform safety-sensitive duties. Other managers/ 

supervisors (e.g., general manager, road supervisor, safety officer, and 

operations manager) are sometimes considered to be safety-sensitive because 

they may operate a vehicle. These employees are most likely to operate a 

vehicle (or perform dispatching duties) at small transit operations that have few 

employees, where it is often necessary for managers/supervisors to have a 

broad range of duties, perform multiple roles, or be available to substitute for 

safety-sensitive employees. Positions that people do not usually think of as 

being safety-sensitive, such as bus washers, must also be reviewed carefully 

because the employee may be required to move revenue service vehicles. 

The most complicated position to identify as safety-sensitive is dispatcher 

because the functions vary from agency to agency. According to the FTA 

definition of safety sensitive, a dispatcher controls movement of vehicles, and 

in most rail operations and large bus operations this is perfectly clear. 

However, in many paratransit operations, a dispatcher is merely the person 

who receives and relays transportation requests or makes schedules. Many of 

these employers (which are often in rural and small areas) have few appropriate 

candidates for this position who are willing to be tested. The difficulty is these 

employees may occasionally be asked to instruct the drivers on routes to 

destinations. 

Employers have stated their applicability policy in a number of ways. Large 

employers with many positions often use an appendix, attachment, or exhibit to 

list all safety-sensitive position titles, as in the Cincinnati Metro, Long Beach 

Transit, and Tri-Met Policies. The Ohio DOT and Georgia DOT Policies, though 

they are intended for small employers, recommend listing the positions in an 

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attachment. These positions are listed at the end of the Des Moines MTA Policy, 

following the section on contact persons, but the list is not labeled as an 

appendix, attachment, or exhibit. Tri-Met also includes the position codes in its 

list. 

Some policies expand applicability beyond the DOT/FTA requirements. 

Cincinnati Metro, Long Beach Transit, Tri-Met, and Des Moines MTA require all 

their employees (and applicants) to be tested under the agency’s authority for 

all categories except random. The requirement that non-safety-sensitive 

employees are also subject to the policy appears near the beginning of the 

policies (in Part III Section 1.0 of the Cincinnati Metro Policy, in Section III of 

the Long Beach Transit Guidelines, in Section B of the Tri-Met Policy, and in 

Section 3.0 of the Des Moines MTA Policy). The exception for random testing in 

the Tri-Met Policy appears in Section J1d. The exception for random testing in 

the Des Moines MTA Policy appears in Section 6.0, which also includes an 

exception for follow-up and return-to-duty testing. 

2.4 Prohibited Behavior 

The policy should specify behavior prohibited by the employer, including use, 

manufacture, distribution, dispensing, and possession of controlled 

substances. Possession and use of alcohol on the premises should also be 

addressed. Most employers use a separate section for prohibited behavior (or 

conduct), as in the Tri-Met, Des Moines MTA, Ohio DOT, and Georgia DOT

Policies (in Sections E, 5, F, and 5, respectively). Cincinnati Metro, however, 

addresses this requirement by reprinting the Drug-Free Workplace Act of 1988 

in its policy (in Part II). Long Beach Transit cites the prohibited behavior 

requirements of the Drug-Free Workplace Act for drugs and for alcohol in Items 

10 and 21, respectively, of its policy summary. 

Another issue to be addressed is use and notification of prescription and overthe-counter drugs. The policy should state that ingestion of controlled 

substances is prohibited regardless of the source. A procedure for employees 

to report use of all prescription and over-the-counter drugs and assignment of 

responsibility for reviewing the reports may be helpful. The Cincinnati Metro 

Policy addresses use of prescription and over-the-counter drugs under 

consequences (in Part IV, Section 11.0). Long Beach Transit requires (in Item 9 

of its policy summary) employees who take any prescribed medication that 

could affect their job performance to notify the agency in advance. The Tri-Met 

Policy requires reporting the use of any legal drugs that may impair 

performance (in Section H), and mentions use of prescription and over-thecounter drugs under prohibited substances and prohibited behavior (in 

Sections D and E). The Des Moines MTA, Georgia DOT, and Ohio DOT Policies 

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address use of legal drugs under prohibited substances (in Section 4.2, Section 

4.2, and Item 2 of Section E, respectively). 

2.5 Testing Circumstances 

This section addresses specific issues related to pre-employment, reasonable 

suspicion, post-accident, and random testing policies. Since return-to-duty and 

follow-up tests are linked to the employer’s consequences policy, they are 

discussed in Section 2.8. 

Some policies address salary compensation for testing. The Des Moines MTA 

Policy has a subsection (6.1) on compensation for testing. Most employers pay 

employees’ time (including overtime if the testing extends beyond their shift) for 

all tests except pre-employment (or pre-promotion or transfer), return-to-duty, 

and follow-up, but often do not state that in their policies. The Des Moines MTA 

also pays employees’ time for follow-up testing. The Cincinnati Metro Policy (in 

Part III Section 5.6) provides for compensation at the applicable rate for 

employees during random tests, but compensation is not mentioned under any 

of the other test categories. The Tri-Met Policy (in Section J1d) requires the 

employee to be paid overtime for the time that a random test collection extends 

beyond the end of the shift. 

Many policies address payment for re-tests (i.e., split sample) that are 

performed at the employee’s request. Most of them require employees who test 

positive on split samples to pay for the split sample, though the specifics vary. 

The Cincinnati Metro Policy (in Part III Section 4.1.3, the Long Beach Transit 

Guidelines (in Section IXD), and the Ohio DOT Policy (in Section I) require the 

transit agency to cover the initial cost, but also require the employee to 

reimburse the agency if the sample is positive. The Des Moines MTA Policy (in 

Section 6.2) states that all expenses for the test will be collected from the 

employee via a one-time payroll deduction unless the result invalidates the 

result of the original test. The Georgia DOT Policy (in Section 6.1, Note 24) 

recommends including the statement “the split sample test will occur 

regardless of up-front payment, but that the transit system reserves the right 

to seek reimbursement from the employee.” 

 

Pre-Employment Testing

There are two areas of flexibility in stating the Part 655 requirements for preemployment testing. First, the employers may, under their own authority, 

require pre-employment alcohol testing provided their policy states the FTA 

requirements that pertain to such testing. Second, employers may specify, 

under their own authority, a shorter time for retesting employees for drugs who 

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have not performed a safety-sensitive function for 90 consecutive days and who 

have been out of the random test pool during that time. 

Reasonable Suspicion Testing 

The employer may want to include examples, in the policy, of the legally 

accepted reasons for ordering reasonable suspicion tests or use wording that 

the employees are more likely to understand. 

Some policies address transportation of employees to the collection site when a 

reasonable suspicion test is ordered, to ensure they do not drive if unfit 

(particularly a company vehicle) and that they report immediately and directly 

to the collection site. The Ohio DOT Policy (in Section L) states “the Transit 

Department shall be responsible for transporting the employee to the testing 

site.” The Tri-Met Policy (in Section J1b) prohibits the employee from driving 

home, though the employee is responsible for transportation home; it states 

that the Transit District will arrange and pay for transportation home if 

necessary. The Des Moines MTA Policy only states a requirement for 

employees to be escorted to the collection site under random testing (in Section 

6.7), but this requirement is implied for all testing under paid testing (in 

Section 6.1): “. . . until such time as they are released by the supervisor 

escorting the employee.” 

Post-Accident Testing

Some employers provide, in their policy, for testing covered employees for all 

accidents to remove all decision making of whether to test, which may occur 

during difficult circumstances. However, they must still decide which 

authority to test under, and must clearly indicate on the accident report which 

authority they are testing under. The policy may also use a more stringent 

definition of an accident, providing it also states the FTA definition. Some 

employers use a fixed-dollar amount of property damage as the definition. TriMet exceeds FTA requirements for post-accident testing. The Tri-Met Policy (in 

Section J1c) requires a test if an employee receives a citation while on the job

for a violation that affects public safety, or violates District rules or procedures 

and poses a threat to the safety of employees or the public or to property (e.g., 

a run-away vehicle or allowing a vehicle to strike a fixed object). 

Employers may want to address transportation of employees to the collection 

site when a post-accident test is ordered for the same reasons as addressing it 

when a reasonable suspicion test is ordered. Transportation is not addressed 

as frequently for post-accident tests because unfitness for duty is not always 

suspected as in reasonable suspicion testing. The Tri-Met Policy (in Section

J1c) also prohibits the employee from driving home following a post-accident

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test, though the employee is responsible for transportation home; it states that 

the Transit District will arrange and pay for transportation home if necessary. 

The Des Moines MTA Policy implies that employees are to be escorted to the 

collection site when any drug or alcohol test is ordered, under paid testing (in 

Section 6.1): “. . . until such time as they are released by the supervisor 

escorting the employee.” 

Random Testing

The method used to select safety-sensitive employees for random tests should 

be stated in the policy. Random-number tables or computer-based randomnumber generators mapped to safety-sensitive employees’ identification 

numbers are often used. 

The FTA testing percentages should also be stated in the policy, and the policy 

should be modified to reflect FTA adjustments to those percentages. 

Employers that choose to test non-DOT/FTA safety-sensitive employees should 

state in their policy the categories of employees who will be included in their 

own (non-DOT/FTA) pool, and the rate at which they will be tested. Employers 

should meet the random test percentages stated in their policies. 

Employers may want to require employees selected for random testing to be 

accompanied by a supervisor to the collection site, to ensure that they report 

immediately and directly. The Des Moines MTA Policy (in Section 6.7) requires 

the employee to be escorted immediately to the collection site. 

2.6 Testing Methodology and Integrity

The policy need only state that the tests be conducted in accordance with the 

provisions in 49 CFR Part 40, Procedures for Federal Workplace Drug and 

Alcohol Testing Program. The Tri-Met Policy, in Section J2, states the specimen 

collection and analysis will be conducted in accordance with U.S. Department 

of Health and Human Services Mandatory Guidelines for Federal Workplace 

Drug Testing Programs, Final Guidelines, and with Part 40. Many employers, 

however, repeat portions of the Part 40 Methodology requirements in their 

policies. This is often done at the request of labor unions. Extensive detail on 

testing methodology is included, in varying amounts, in the Cincinnati Metro 

Policy (in Part III Section 4), in the Long Beach Transit Guidelines (in Sections 

IX, X, XI, and XII), in the Des Moines MTA Policy (in Section 6.0), in the Ohio 

DOT Policy (in Sections I and J), and in the Georgia DOT Policy (in Section 6.0). 

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2.7 Refusal Behavior and Consequences 

Numerous examples of the behavior that constitutes a refusal to take a drug or 

alcohol test are listed in Part 40, and in the Implementation Guidelines. This 

information is often incorporated as a separate section (as in the Cincinnati 

Metro Policy, in Part III Section 7.0) or subsection (as in the Long Beach Transit 

Guidelines, in Section VIIA3). Long Beach Transit defines refusal under 

enforcement/ consequences. Another option is to include this information as 

part of a section on compliance, as in the Tri-Met Policy (in Section I), the Des 

Moines MTA Policy (in Section 5.4), and the Georgia DOT Policy (in Section 5.4). 

The Ohio DOT Policy lists numerous examples under its definition of “test 

refusal” in Section C. 

2.8 Consequences of Drug Use and Alcohol Misuse 

In addition to stating the minimum consequences required by FTA for

violations of the regulations (which are summarized in the Implementation

Guidelines), the policy should also clearly state the disciplinary action that will 

be taken by the employer related to the various violations. The disciplinary 

actions stated in policies and the way that they are stated vary widely. 

Some employers (such as Cincinnati Metro and Long Beach Transit) have a 

zero-tolerance policy for testing positive, or refusing to be tested, for drugs and 

at 0.04 or higher for alcohol. That is, the employee is terminated for the first 

offense. Des Moines MTA has a zero-tolerance policy for all positive tests except 

random, but specifies a second chance for a random positive, though employees 

testing positive are prohibited from bidding on or driving designated contracted 

school routes. Many employers state the consequences as discipline up to and 

including termination, allowing discretion on whether to terminate for a first 

offense, as in the Tri-Met and Georgia DOT Policies. Tri-Met specifies that the 

decision will depend on the severity of the violation and the employee’s record. 

The Ohio DOT Policy allows the individual subrecipients to establish their own 

discipline code. The policy includes all the language and sections needed for a 

second-chance policy, but has prompts for insertion of “zero tolerance” in the 

appropriate locations (in Sections A, H, and O). 

Experience has shown that consequence/discipline policies that are very 

specific and allow little discretion tend to receive the fewest legal challenges, 

particularly in agencies with a strong union presence. 

Most employers terminate employees for a first offense of prohibited behavior or 

for refusing to be tested. Most policies include provisions requiring employees 

to inform the employer of convictions for drug- and alcohol-related offenses. 

Most policies also provide lesser consequences for an alcohol test between 0.02 

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and 0.039, which is not a positive as defined by Part 40. Cincinnati Metro’s 

zero-tolerance policy (in Part IV Section 3.0) allows a second chance for those 

who test between 0.02 and 0.039 for alcohol, but it requires a disciplinary 

suspension of at least 30 days without pay (or sick leave) and signing of a lastchance agreement. The Long Beach Transit Guidelines (in Section VIIA1) state 

that those who test between 0.02 and 0.039 on more than one occasion may be 

subject to discipline up to and including discharge, but mentions no discipline 

for the first offense. Both policies offer a second chance for voluntary selfconfessors, but require them to complete a rehabilitation program. Most 

polices exempt self-confessors from disciplinary action and offer treatment 

opportunities providing they do not test positive. The Des Moines MTA Policy 

has a separate section (5.8) on voluntary treatment. It requires referral to the 

SAP at the MTA’s expense, but does not require the employee to follow the 

SAP’s recommended treatment plan, though it encourages the employee to do 

so. 

Provisions for grievance and appeal, beyond the FTA protection of MRO review 

of test results and split-sample testing should also be addressed in the policy. 

The Tri-Met Policy addresses this issue under discipline (in Section M). 

Some policies have separate sections on consequences or discipline, i.e., Long 

Beach Transit (in Section VIIA of its guidelines), Tri-Met (in Section M), Des 

Moines MTA (in Section 7.1), and Ohio DOT (in Section Q). In addition to the 

section on consequences in the Long Beach Transit Guidelines, many of the 

items (4, 6, 8, 10, 16, 17, 19, 20, and 21) in the Long Beach Transit Policy 

summary include consequences. The Tri-Met Policy also discusses 

consequences under prohibited behavior (in Section E) and under return to 

work (in Section N). The Des Moines MTA Policy also discusses consequences 

in various subsections under prohibited conduct (in Section 5), under returnto-duty testing (in Section 6.8), and under re-entry conditions (in Section 8.0). 

The Ohio DOT Policy includes a note for zero-tolerance employers to remove the 

provisions that specify discipline other than termination. The Cincinnati Metro 

Policy has a separate part (IV) on consequences with separate sections on 11 

categories of violations. The Georgia DOT Policy covers consequences under 

treatment requirements (in Section 5.5) and under test procedures (in Section 

6.0). 

The placement of the requirement that all employees who test positive be 

referred to a SAP varies from policy to policy. This requirement appears in a 

separate section on SAP referral in the Cincinnati Metro, Long Beach Transit, 

and Tri-Met Polices. The SAP referral section is under rehabilitation (in Part V 

Section 2.0) in the Cincinnati Metro Policy, in Section XII of the Long Beach 

Transit Guidelines, and under general provisions for drug and alcohol testing 

(in Section J3) in the Tri-Met Policy. The requirement is included under 

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compliance with testing requirements in the Des Moines MTA Policy (in Section 

6.0), under result of drug/alcohol test in the Ohio DOT Policy (in Section Q), 

and under testing procedures in the Georgia DOT Policy (in Section 6.0). 

Return-to-Duty and Follow-Up Testing

All policies that allow a second chance must discuss return-to-duty and followup testing. Because “zero-tolerance” policies often have exceptions for selfconfessors or for alcohol tests under 0.04 (e.g., the Cincinnati Metro and Long 

Beach Transit Policies), all employers should address return-to-duty and 

follow-up testing in their policy. Both the Cincinnati Metro Policy and the Long 

Beach Transit Guidelines include sections on return-to-duty and follow-up 

testing (in Part III Sections 5.3 and 5.4 and in Section VIIIE, respectively) and 

on rehabilitation (in Part V Section 3.0 and in Section XIII, respectively). Even 

an employer that requires termination for all first violations and gives no grace 

for self-confessors should include these provisions in case it is required to 

reinstate an employee, by a higher authority such as the Fair Labor Relations 

Board. 

Most employers require the employee, or the employee’s insurance carrier, to 

pay for rehabilitation and the required return-to-duty and follow-up tests. 

These requirements should be included in the policy and identified as 

independent of FTA authority. All of the policies in Appendix A require the 

employee to be responsible for treatment and rehabilitation cost. 

2.9 Designated Contact Person

Although this requirement is listed first in the policy-content requirements, 

Part 655 does not specify where in the policy to include the identity of the 

contact person. Most employers include it at the end of the policy, as in the 

Tri-Met, Des Moines MTA, Ohio DOT, and Georgia DOT examples. (Tri-Met 

includes its contact persons under program administration, in Section P.) 

However, some employers include the name on the first page. Long Beach 

Transit includes the contact person on the first page of its guidelines, in 

Section II. Still others place it in an appendix along with the names and 

contact information for other important professionals and vendors (e.g., MROs, 

SAPs, collection sites, and laboratories), as in the Cincinnati Metro Policy (in 

Appendix B). Long Beach Transit includes an extended list of contacts in an 

attachment, in addition to the contact name on the first page of the guidelines. 

An appendix or attachment provides employees with a “quick reference guide” 

to this information, and it enables distribution of a revised appendix or 

attachment with updated contact information, thereby avoiding the need to readopt and redistribute the policy. 

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The person designated to answer employee questions about the drug and 

alcohol program is often the person responsible for program administration. 

For smaller organizations, this may be a human resources manager, an 

operations manager, or a general manager. The contact person’s position title, 

address, telephone number, and fax number should also be included, as well 

as the words “and their successor.”

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3. Education and Training 

This chapter discusses methods for meeting the FTA education and training 

requirements contained in Part 655.14, as discussed in the Implementation

Guidelines (in Chapter 5). The issues related to meeting those requirements 

are also discussed. 

3.1 Education

Informational materials on prohibited drug use include posters, pamphlets and 

brochures, fact sheets, and newsletter articles. These materials are often 

distributed to new employees with orientation materials, and are 

communicated via postings and displays in common areas of the workplace, 

anti-drug abuse campaigns, and seminars. A common source of these 

materials is employee assistance programs (EAPs). 

Many transit agencies have contracts with EAP providers to assist employees 

with various types of personal problems. These contracts often require the EAP 

to supply and distribute educational materials on substance abuse. EAPs 

often issue brochures and posters to employers and mail informational 

materials directly to employees’ homes. EAPs also provide employees with 

evaluation and referral, short-term individual counseling, individual case 

management, crisis intervention (24-hour crisis line), and employee 

educational programs. 

 

The Center for Substance Abuse Prevention provides EAP models, as well as 

telephone information and literature on policy, drug testing, and related topics, 

at no cost to employers. It also provides referrals to other information sources 

and lists of consultants by geographic area. This information can be received or 

ordered through the Center’s Drug-Free Workplace Help line, (800) 843-497, 

between 9:00 a.m. and 8:00 p.m. EST Monday through Friday. 

Other national organizations that are frequently used as sources of educational 

information and materials include: 

• Americans for a Drug-Free America--This organization distributes various 

pamphlets on the effects of illegal drug use. These materials are 

published by American Crisis Publishing, Inc., 3800 Hudson Bend Road, 

Austin, TX 78734, (512) 266-2485. 

• National Safety Alliance (NSA), P.O. Box 159060, Nashville, TN 37215, 

(615) 832-0046--Many transit agencies distribute the NSA handbook 

titled Substance Abuse Training for the Workplace. 

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• National Clearinghouse for Alcohol and Drug Information (NCADI), P.O. 

Box 2345, Rockville, MD 20852, (800) 729-6686, (301) 468-2600--The 

Clearinghouse provides fact sheets, films, posters, pamphlets, and 

brochures at no or low cost. Multilingual materials and a free quarterly 

catalog are also available. 

• Partnership for a Drug Free America, 405 Lexington Avenue, New 

York, NY 10174-0002, (212) 922-1560—This organization provides 

posters, audiotapes, and videotapes with high-impact messages. 

There is no charge for these materials, but donations are requested. 

Health insurance carriers, mental health agencies, and state substance abuse 

clearinghouses also provide informational and educational materials on substance abuse for distribution to employers. Each State has at least one federally 

funded clearinghouse that provides nationally and locally produced materials. 

3.2 Training 

Various approaches and combinations of approaches are used to meet both of 

the training requirements in Part 655.14(b). Some employers use one approach 

or combination to train their safety-sensitive employees and another one to 

train their supervisors and other company officials who are responsible for 

determining reasonable suspicion of drug and alcohol use. 

Most of these approaches involve some type of classroom training with an 

instructor or facilitator leading the session. The most comprehensive approach 

includes a lecture, presentation of a video, or use of some other interactive 

technology, a question-and-answer session, discussion of the company policy 

and issues relevant to the employer’s operation, and role playing. A 

professional on the effects and indications of substance abuse would give the 

lecture, show the video, and answer questions about substance abuse. A 

person knowledgeable about the employer’s operations (e.g., a human 

resources official, drug and alcohol program manager (DAPM), or a third-party 

administrator (TPA)--would answer questions about the employer’s operations 

and lead discussions related to the work environment. In some cases, one 

person can perform both functions, such as a DAPM who is also a health 

professional or a TPA who is a substance abuse consultant. 

Many large and medium-size employers and consortia contract with consulting 

firms experienced in delivering workplace training or other substance abuse 

professionals to prepare a curriculum and present it. Some of these large 

organizations have a professional on their internal staff or a TPA who prepares 

or presents the curriculum. Sometimes the internal professional or TPA 

presents a curriculum prepared by a consulting firm or contracted 

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professionals. In some cases, internal professionals work with consultants or 

contractors to prepare and present the training. 

Smaller entities not affiliated with a consortium often have a staff member lead 

the training using commercial training programs or training manuals and 

materials acquired from their state department of transportation (DOT), a 

nearby transit agency, or FTA. Self-paced training programs in booklet and 

videotape formats are available from standard suppliers of training materials 

for the transit industry or from companies and individuals that advertise on 

the Internet. Some state DOTs purchase these materials and distribute them 

to their transit employers, particularly for small entities with limited budgets. 

Other state DOTs hire consultants to prepare standard training manuals (or 

prepare them using internal staff) for their transit agencies. 

Discussion and role-playing techniques can be used with any of these 

approaches at minimal additional expense, and are very effective because they 

allow the agency’s staff to address other issues. 

Professionals who may prepare training curricula or provide training include: 

• EAP providers 

• Nurses and physicians 

• Mental health professionals 

• Drug and alcohol treatment specialists 

• Pharmacists 

• Toxicologists 

• Law enforcement drug awareness specialists 

Organizations that may be sources for identifying or locating training 

professionals include: 

• National organizations and their local affiliates, such as the Employee 

Assistance Professionals Association and their state chapters and the 

National Council on Alcoholism and Drug Dependence 

• State substance abuse clearinghouses 

• State-wide nonprofit organizations, such as Connecticut’s “Drugs Don’t 

Work!” or Texas’ “War on Drugs” 

Though FTA requires that all training records be kept for only 2 years, many 

employers retain all training records indefinitely. This is particularly important 

if consulting companies or contracted professionals are used. 

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Training for Safety-Sensitive Employees 

The required drug abuse training is often incorporated in the employee 

orientation process. Many employers find it difficult to cover all the required 

information in 60 minutes, particularly if questions, discussions, and role 

playing are included. Some trainers also test the participants before they begin 

to assess their knowledge and enable them to tailor the training to the 

employees’ needs. They may also test them again upon completion to asses 

their comprehension. Thus, many transit agencies have found 2 hours to be a 

more appropriate drug training period. It is also helpful to encourage 

employees to talk to their physicians and supervisors about over-the-counter 

and prescription medications to determine alternatives to their use while on 

duty. Some employers also cover alcohol misuse and aspects of drug abuse 

not required by Part 655.14, such as effects of additional illegal drugs and 

over-the-counter and prescription medications. 

Videos are a useful tool for employee training, providing they support and do 

not contradict the specifics of the FTA regulations. One example of an effective 

video is Effects of Drugs and Alcohol on the Human Body by Comdata, though 

FTA does not endorse the product. 

The Florida Department of Transportation has a Public Transportation 

Substance Abuse Program that it distributes to the FTA grantees in Florida. 

The Employee’s Manual and Instructor’s Manual will be available on the FTA 

Office of Safety and Security website: http://transit-safety.volpe.dot.gov. The 

program contains modules on: 

• Drugs and public safety 

• Alcohol 

• Each of the FTA prohibited drugs 

• Over-the-counter drugs 

• Combining drugs 

• Florida DOT policy

• Availability of help 

• A test and certification

The Des Moines Metropolitan Transit Authority (MTA) has a Substance Abuse 

Training Manual, which will also be available on the FTA Office of Safety and 

Security website: http://transit-safety.volpe.dot.gov. This manual addresses: 

• The Regulatory Requirements 

• Jobs considered Safety Sensitive 

• Required Types of Testing 

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• Signs, Symptoms, and Effects of the Five Prohibited Drugs 

• Alcohol Testing 

• Sample Collection Procedures 

• Role of Outside Professionals and Hotline Telephone Number 

• Confidentiality 

• Disciplinary Action 

The Des Moines MTA Training Manual also includes the outline for the training 

for safety-sensitive employees: 

Des Moines MTA Substance Abuse Training Outline 

• Impact of Drug Abuse on Society and Industry 

− National, Regional, and Local Statistics on Prohibited Drug Use 

− Safety, Personal Health, and Work Environment 

• Response of the Federal Government and the Transit Industry 

− Drug-Free Workplace Act 

− Prevention of Alcohol Misuse and Prohibited Drug Use in Transit Operations (49 CFR Part 655) 

− Procedures for Transportation Workplace Drug and Alcohol Testing Programs (49 CFR Part 40) 

− MTA Policy on Prohibited Drugs and Alcohol 

• Safety, Personal Health, and Work Environment Effects of Each of the Five Prohibited Drugs 

• Manifestations and Behavioral Cues That May Indicate Use of Each of the Five Prohibited Drugs 

• Procedures and Protections of the FTA Drug and Alcohol Testing Program 

• Questions and Answers

When hiring professional trainers, employers should be sure that the trainers 

thoroughly understand the FTA regulations. The same caution should be 

exercised when acquiring self-paced training materials. Many trainers and 

training material producers prepare and deliver products used to comply with 

the Federal Motor Carrier Safety Administration (FMCSA) requirements, and 

believe that they also apply to FTA. The FMCSA and FTA regulations have 

significant differences. Applying the FMCSA requirements to a transit program 

could affect employer liability and employee civil rights. 

Important criteria to consider in selecting a trainer are: 

• Workplace experience with transit or similar industries 

• Concern with safety, cost reduction, productivity, liability, and public 

image, as well as employee welfare 

• Understanding of Parts 40 and 655 and how to respond to employee 

attitudes and concerns regarding drug and alcohol testing 

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• Training style, platform skills, techniques, tools, and methods appropriate 

to adult learning, including appropriate and high-quality audio/visual 

material, handouts, role playing, and case studies 

• Willingness to learn about the customer’s operations, policy, programs, 

values, and culture 

• Flexibility, professionalism, and tact in handling diverse opinions and 

needs of resistant employees, assertive managers, supervisors, 

executives, and union representatives 

Some professional trainers use commercial off-the-shelf curricula. Such 

curricula have to be tailored to reflect the employer’s procedures, discipline 

policy, and EAP. The employer may want to have its own human resources, 

medical, or labor relations professional work with the contracted training 

professionals in developing and presenting the training sessions. 

Training for Determining Reasonable Suspicion of Drug and Alcohol Abuse 

Most employers exceed the scope of the requirements in Part 655(2)(b). 

Additional topics typically addressed in supervisory training include: 

• Role and responsibility of supervisors and other company officials who 

are responsible for determining reasonable suspicion 

• Initiating, substantiating, and documenting a test referral 

• Intervention and confrontation with employees 

Other elements that can further improve the training effectiveness include 

introducing the context of the regulation, reviewing the testing program 

requirements, and reviewing agency disciplinary procedures. Role playing has 

proved to be especially effective in reasonable suspicion training. 

Given their tendency to expand the scope, most employers have found that 

reasonable suspicion cannot be effectively covered in the required minimum of 

60 minutes. A comprehensive program often requires 3 hours of training for 

drugs and an additional 3 hours for alcohol. Medium-size and large transit 

agencies often dedicate at least a day or two to reasonable suspicion training. 

The Massachusetts Bay Transportation Authority (MBTA), for example, has 

developed a week-long program for determining reasonable suspicion of drug 

and alcohol use. The MBTA program consists of live presentations and 

extensive role playing, and is presented by contracted professional trainers, the 

MBTA Medical Unit, and the EAP provider. Considerable research and effort 

has been spent on developing the program, based on the environment at the 

MBTA. In the past, the agency experimented with commercial off-the-shelf 

presentations and videotaping of MBTA materials, and found both approaches 

to be far less effective than live presentations. 

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Because identification of suspicious behavior is an important part of a substance abuse prevention program and it is difficult and uncomfortable for many 

supervisors, many employers require refresher training at specified intervals. 

A video and a leader’s guide on reasonable suspicion have been produced for 

and are available from FTA at no charge. The video consists of four segments: 

(1) General Requirements on Reasonable Suspicion Referrals

(2) Alcohol Abuse in the Workplace

(3) Prohibited Drug Use in the Workplace

(4) Make the Call: the Reasonable Suspicion Interview 

The Leader’s Guide —Reasonable Suspicion Referral for Drug and Alcohol 

Testing: A Training Program for Transit Supervisors, Leader’s Guide— will be 

available on the FTA Office of Safety and Security website: http://transitsafety.volpe.dot.gov. It contains a trainer packet and a trainee packet on five

exercises: 

(1) General Requirements for Making Reasonable Suspicion Referrals

(2) Alcohol Abuse in the Workplace

(3) Prohibited Drug Use in the Workplace

(4) Make the Call: the Reasonable Suspicion Interview

(5) Wrap-up Discussion

The Hartford (Connecticut) Regional Transit District has documented its 

supervisor training in a manual (prepared by NSA) titled Substance Abuse in

the Workplace: Supervisor Training. This manual, which is used by all but one 

of the approximately 60 transit operators in the state, addresses the following 

issues: identification of a problem, the supervisor’s role in an effective 

substance abuse program, situations confronting supervisors, reasonable 

suspicion testing information and step processes, and three parts of an 

effective confrontation interview. It also contains appendices on drug retention 

time in the body and suggested demeanor for supervisors, tips on 

confrontational interviews, documentation forms, and DOT information. 

The Des Moines MTA Substance Abuse Training Manual (mentioned in the 

discussion of training for safety-sensitive employees) also includes the outline 

for the MTA’s additional training for supervisors and other officials responsible 

for determining reasonable suspicion: 

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Chapter 3.Training Page 3-8 

Des Moines MTA Reasonable Suspicion Training Outline

• Impact of Drug Abuse on Society and Industry 

− National, Regional, and Local Statistics on Prohibited Drug Use 

− Safety, Personal Health, and Work Environment 

• Response of the Federal Government and the Transit Industry 

− Drug-Free Workplace Act 

− Prevention of Alcohol Misuse and Prohibited Drug Use in Transit Operations (49 CFR Part 655) 

− Procedures for Transportation Workplace Drug and Alcohol Testing Programs (49 CFR Part 40) 

− MTA Policy on Prohibited Drugs and Alcohol 

• Safety, Personal Health, and Work Environment Effects of Alcohol Use and Prohibited Drug Use 

• Procedures and Protections of the MTA Drug and Alcohol Testing Program 

• Responsibility of Supervisors, Especially as Related to Drug and Alcohol Programs 

− To Supervise 

− To Deal with Problems in Workplace (e.g., Unacceptable, Deteriorating, and Unsafe Performance) 

• Indicators of Probable Alcohol Misuse or Prohibited Drug Misuse (common to all substance abuse 

and individually to alcohol and to each of the 5 DOT prohibited drugs) 

− Physical 

− Behavioral 

− Speech 

− Performance 

− Body Odors 

• Supervisory Responsibilities Related to Reasonable Suspicion 

− Removal from Safety-Sensitive Position

− Observation and Documentation 

− Confidentiality of the Employee 

− Review Findings 

− Make Reasonable Suspicion Decision 

− Escort to Collection Site 

− Escort Home 

− Special Considerations in Dealing with Alcohol- or Drug-Influenced Employees 

• Conflict Resolution 

• Resources Available to the Supervisor 

− Drug and Alcohol Program Manager (DAPM) and Designated Employer Representative (DER) 

− Medical Review Officer 

− Substance Abuse Professional 

− Employee Assistance Program 

− Security and Law Enforcement 

− Other 

• Questions and Answers
Best Practices 

FTA Drug and Alcohol Testing Program 

4. Testing Program Implementation and Management 

The employer is ultimately responsible for maintaining an FTA mandated Drug 

and Alcohol Testing Program that complies with 49 CFR Parts 40 and 655. 

Likewise, the grantee is responsible for ensuring that all of its operations and 

maintenance contractors and subrecipients maintain a compliant program. 

The required program consists of three test functions: urine collection and 

analysis, breath collection and analysis, and medical review. 

Each employer must have an employee or employees responsible for ensuring 

operation of a compliant program. Large employers often have a separate 

position for administering the program, often referred to as Drug and Alcohol 

Program Manager (DAPM) and occasionally as Substance Abuse Program 

Manager (SAPM). The responsibilities of this position are sometimes performed 

by more than one employee. Small employers do not usually have a separate 

position of DAPM or SAPM; the program management functions are assigned to 

an employee or employees to perform in addition to their other duties. 

Program managers come from various backgrounds, and there is no particular 

discipline that seems to provide a more appropriate experience than any other. 

The most common backgrounds include general manager, operations 

management, safety, risk management, human resources, and administrative 

assistant. The primary requirement is that they are very knowledgeable of the 

regulations; all employees who perform program management functions should 

attend FTA seminars conducted by the Transportation Safety Institute (TSI). 

Some employers use their employees to perform all the program management 

functions while others hire third party administrators (TPA) to administer part 

or all of their program. The three test functions are frequently contracted out, 

though some large employers use internal staff to perform one or two or all 

three of these functions. Employers must have an effective overarching 

method for ensuring that the required tests are performed in accordance with 

the policy and records are kept. 

This chapter addresses the issues associated with implementing and 

maintaining a compliant program and references best practice examples 

(contained in Appendices B, C, D, and E) for addressing them. These 

discussions appear in five sections: 

(1) Internal administration (managing DAPM functions performed by the 

employer’s staff, examples in Appendix B) 

(2) External administration (procuring service agents and monitoring 

service agents and contractors/subrecipients, examples in Appendix C) 

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(3) Specimen collection and analysis (both urine and breath, examples in 

Appendix D) 

(4) Medical review (examples in Appendix E)

(5) Records management 

4.1 Internal Administration 

This section addresses general administrative issues and concerns and the 

issues related to and methods used for ensuring compliance with the four 

types of testing required for all employers: pre-employment, reasonable 

suspicion, post-accident, and random. (Issues related to return-to-duty and 

follow-up tests are discussed in Chapter 5.) Though this section may be most 

useful to program managers who either perform the functions themselves or 

delegate them to internal staff, the discussions here and the examples in 

Appendix B may also be useful to managers who contract out their 

administrative functions. They can be used as benchmarks or standards in 

evaluating performance of TPAs and can be offered as advice or tools to TPAs 

and contractors/subrecipients. 

Many employers use forms and checklists to create consistent routines for 

performing administrative functions and to document completion of those 

functions. Appendix B contains examples that have been used successfully. 

General Administrative Duties 

A frequent audit finding is no evidence that employees received the policy 

statement. Some grantees require that safety-sensitive employees sign forms 

acknowledging that they have received the drug and alcohol policy statement, 

and retain the documents as a means of proof of notification. Examples of 

policy receipt certification forms used by the Massachusetts Bay 

Transportation Authority (MBTA), the Washington Metropolitan Area 

Transportation Authority (WMATA), and the Tri-County Metropolitan Transit 

Authority (Tri-Met), Portland, OR, appear in Figures B-1, B-2, and B-3, 

respectively. 

Lists of employees and supervisors, or other company officials, who attend and 

complete required training are often maintained to provide documentation that 

the training requirement was met. Lists used by Cincinnati Metro for this 

purpose appear in Figures B-4 and B-5, respectively. Some employers also 

issue certificates to each employee who completes the training, and retain file 

copies of the certificates issued. Figure B-6 is a an example of a form, used by 

the Government of the Virgin Islands, for certifying that supervisors or other 

company officials have received the required reasonable suspicion training. 

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The City of Albuquerque uses printed lists to document and disseminate the 

roles and responsibilities of the Program Manager, department program 

coordinators, departmental divisional contacts, and front-line supervisors, 

shown in Figures B-7, B-8, B-9, and B-10, respectively. 

The City of Albuquerque also uses an Excel spread sheet with tracking facility 

as a master log to assist with managing each of the four types of FTA tests 

required for all employers. These are discussed and referenced individually 

later in this section under their respective testing types. The MBTA uses a 

single log, shown in Figure B-11, to track all testing. 

The City of Albuquerque uses a form (shown in Figure B-12) to document the 

results of each test through each step of the process, from collection to the 

disciplinary action. This form includes provision for signatures by the 

laboratory scientists who identify the result and the medical review officer 

(MRO) who reviews it. 

Broward County (Florida) Transit provides a log (shown in Figure B-13) for 

each supervisor to fill out whenever a test is ordered. This form provides for a 

very detailed sequence of events. It allows the employer to monitor the amount 

of time the employee spends en route to the site, the amount of time spent 

waiting to be tested after arriving at the site, and the amount of time the 

employee spends on the return trip to work. 

 

Forms are commonly used to notify employees of ordered tests and to 

document the order. Notification forms used by the Ohio Department of 

Transportation (DOT) and MV Transportation (an operations contractor for 

several transit agencies) appear in Figures B-14 and B-15, respectively. The 

MV Transportation form includes the time that the employee is sent for testing 

and the time the employee arrives at the collection site, and it provides for 

transportation to the site by a supervisor. 

Forms are also used to document and notify management of positive test 

results. Figures B-16 and B-17 are forms used by the Los Angeles County 

Metropolitan Transportation Authority (LACMTA) to document positive drug 

test results and positive alcohol test results, respectively. The MBTA uses one 

form (shown in Figure B-18) to notify an employee of a positive drug or alcohol 

result. The MBTA also uses a form (shown in Figure B-19) to notify the 

immediate supervisor of an employee’s positive result. 

Pre-Employment Testing

The West Virginia DOT Division of Public Transit documents its preemployment testing process in a flow chart, shown in Figure B-20. 

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FTA Drug and Alcohol Testing Program 

The City of Albuquerque uses a summary sheet (shown in Figure B-21) to 

document the test of each applicant for a safety-sensitive position, including 

both FTA and City definitions of safety sensitive. Albuquerque’s Excel spreadsheet master log for tracking pre-employment testing appears in Figure B-22. 

The MBTA uses a form (shown in Figure B-23) to notify an applicant for a 

safety-sensitive position of a positive drug or alcohol result. 

Reasonable Suspicion Testing

The West Virginia DOT Division of Public Transit documents its reasonable 

suspicion testing process in a flow chart, shown in Figure B-24. Western 

Maine Transportation Services, a small rural seasonal fixed-route bus system, 

documents its reasonable suspicion testing process in a slightly different flow 

chart and uses a form along with it to document symptoms and referrals, as 

shown in Figure B-25. 

Three variations on documentation forms used by large systems appear in 

Figures B-26, B-27, and B-28—LACMTA, MBTA, and Albuquerque, 

respectively. Ohio DOT also distributes the form shown Figure B-28 to its 

subrecipients, which include many small systems. The LACMTA form is the 

most compact of the three and calls for the least amount of written 

explanation. 

Both the San Francisco Bay Area Rapid Transit (BART) District and the Denver 

Regional Transit District (RTD) use a single form to document circumstances 

for ordering both reasonable suspicion and post-accident tests. BART’s 

“Observation/Incident Report” appears in Figure B-29, and Denver RTD’s 

“Accident/Incident/Reasonable Cause Report” appears in Figure B-30. Both 

forms distinguish between tests ordered per FTA authority and those ordered 

under the transit district’s rules. The BART form lists the criteria for testing 

under each set of rules separately, and lists BART’s procedures for reasonable 

suspicion testing on the back of the form, along with a space for comments, 

incident description, and action taken. The Denver form requires the 

supervisor to check which rules apply to the test ordered, but does not describe 

the rules. The Denver form is the only one of the six aforementioned 

reasonable suspicion documentation forms that does not require the supervisor 

to check off observed behavioral and appearance symptoms from an extensive 

list. It requires written comments under several different categories. The 

groupings of symptoms used in the six different examples vary widely. 

Albuquerque also requires its supervisors to fill out and sign a summary report 

(shown in Figure B-31) for each reasonable suspicion test ordered, in addition 

to filling out the “Fitness for Duty” form shown in Figure B-28. Albuquerque’s 

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FTA Drug and Alcohol Testing Program 

Excel spreadsheet master log for tracking reasonable suspicion testing is 

shown in Figure B-32. 

Occasionally, a reasonable suspicion test ordered by a supervisor is not 

administered. It is useful to document these occasions on a standard form. 

Albuquerque’s summary report (shown in Figure B-31) has a block for 

explaining such an occurrence. Sioux Falls Transit System (SuTran), South 

Dakota, uses a separate form (shown in Figure B-33) when an ordered 

reasonable suspicion drug test is not performed. 

Many times, employees have tested negative in FTA reasonable suspicion tests 

even though the criteria for ordering the tests was met. Employers should 

understand that many of the symptoms that are basis for these tests are also 

symptoms of other problems (e.g., marital stress, sleep disorders, job 

dissatisfaction) that may impair performance of safety-sensitive functions. 

Though it is not required by FTA, some employers require (or strongly 

recommend) counseling for employees who test negative in properly ordered 

reasonable suspicion tests, to identify such problems. 

Post-Accident Testing

Many employers have devised forms to assist supervisors in determining 

whether to test operators following an accident (and under what authority), in 

documenting procedures to be followed after the decision is made, in recording 

all the required information, and in providing explanations of why tests were 

not conducted at specific times. 

The Greater Cleveland Regional Transit Authority (GCRTA) issues a two-sided 

card (shown in Figure B-34) to its supervisors. The front side contains a 

decision tree for determining whether to order a post-accident test under FTA 

authority. The back lists the criteria for ordering a test under GCRTA 

authority. However, the GCRTA card is merely a decision-making guide; it 

requires no documentation. 

The West Virginia DOT Division of Public Transit documents its post-testing 

process in a flow chart shown in Figure B-35. It also issues a decision-making 

form (shown in Figure B-36) for supervisors to fill out to document occurrences 

and decisions made following each accident. It requires the supervisor to note 

which authority (FTA or company) the decision to test was made under, and to 

explain why an alcohol test was not performed within 8 hours of the accident 

and a drug test was not performed within 32 hours of the accident. 

The San Francisco BART “Observation/Incident Report” (shown in Figure B-29) 

requires supervisors to check off post-accident criteria that are met following 

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FTA Drug and Alcohol Testing Program 

an accident. There are two lists of three items each—one list with FTA criteria 

and the other with BART criteria. A test should be ordered if any of the items 

are checked; it should be an FTA test if any FTA item is checked. This BART

report also requires the supervisor to check off symptoms, from the extensive 

list, observed in the operator following the accident. The presence of these 

symptoms could be basis for ordering a reasonable suspicion test if none of the 

post-accident criteria are met. BART also issues procedural instructions 

(shown in Figure B-37) to be followed when an accident occurs. These include 

making the decision and what to do after either decision is made. 

The Denver RTD “Accident/Incident/Reasonable Cause Report” (shown in 

Figure B-30) requires written explanations under the three FTA non-fatalaccident test scenarios, completion of the reasonable cause section if the 

second or third scenario exists, and indication of whether FTA or RTD rules 

apply. The FTA post-accident test criteria are listed on the back of the form. 

LACMTA uses a form (shown in Figure B-38) that summarizes the FTA postaccident testing regulations, and requires the supervisor to document answers 

to questions leading to a decision of whether to test under FTA authority, 

requires documentation of reasons why tests are delayed or not performed if 

FTA criteria are met, and provides a checklist of procedures. 

 

Figures B-39 and B-40 also show forms that require complete documentation 

of accident information, including whether ordered tests were performed at 

specific times with explanations if they were not performed. Figure B-39 is 

used by the Southeastern Pennsylvania Transportation Authority (SEPTA). It 

provides a checklist of both FTA and SEPTA criteria. Figure B-40 is a 

summary report that the City of Albuquerque requires its supervisors to 

complete and submit within 24 hours of an accident. SuTran uses a separate 

form (shown in Figure B-41) when an FTA criterion for a post-accident test is 

met but no test is performed within 32 hours. 

Figure B-42 is Albuquerque’s Excel spreadsheet master log for tracking postaccident testing. 

Random Testing

Figures B-43 and B-44 are flow charts showing procedures for random testing. 

The two charts use different approaches. The approach in Figure B-43, which 

is used by the West Virginia DOT Division of Public Transit, is oriented to the 

employee’s response to the testing order. There are two separate event 

sequences following the notification of testing: one for the employees who 

report to the collection site as ordered and another for those who do not report. 

There are also two separate sequences for employees who report to the 

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collection site: one for those who provide a specimen and another for those 

who do not. The approach in Figure B-44, which is used by San Francisco 

BART, is oriented to the supervisor who is notified of an employee’s selection. 

It lists the steps to be followed by the supervisor. 

Many employers notify their employees of selection for a random test in writing, 

and keep copies of the notices in their records. Figures B-45 and B-46, used 

by BART and the MBTA, respectively, are examples of notices of selection for a 

random test. Both of these forms call for documentation of all pertinent 

notification information, contain instructions to the selected employee chosen 

for a random test and consequences for non-compliance, and require the 

employee to sign the form to acknowledge receipt. 

The City of Albuquerque has a comprehensive set of forms that it uses to 

disseminate instructions and provide for documentation of its random selection 

process. The instructions for the selections process are listed in Figure B-47. 

The roles and responsibilities of the selector are listed in Figure B-48. The form 

used by the Transit Department to list the names of all the employees selected 

during a particular draw appears in Figure B-49; this list includes the date and 

time of the scheduled test, the test notification, and the actual test. A separate 

form, shown in Figure B-50, is used to list all employees within each department 

tested during each test period and to record their collection dates and times. 

The form used to document each individual test order, the result, and the action 

taken when the result is positive appears in Figure B-51. Figure B-52 is 

Albuquerque’s Excel spreadsheet master log for tracking random testing. 

Excel spreadsheets with a tracking facility have proved especially useful in 

tracking random testing. 

Forms can also be used to help employers keep the random pool fully populated 

with all currently working employees. The Rhode Island Public Transit 

Authority (RIPTA) requires that an employee status form, shown in Figure B-53, 

be filled out whenever a safety-sensitive employee begins or terminates work. 

This form is used to add or delete the employee’s name from the random pool. 

4.2 External Administration 

As previously mentioned, many employers contract out some or all of their 

administrative responsibilities to TPAs. Small transit agencies and operations 

and maintenance contractors often enter into a TPA consortium (C/TPA) with 

other small employers, for economic and logistical reasons. Larger agencies and 

contractors often hire their own TPAs. Administrative functions performed by 

TPAs vary widely from employer to employer and consortium to consortium. 

TPAs are sometimes used to procure and monitor other service agents—urine 

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collectors and laboratories, screen test technicians (STTs) and breath analysis 

technicians (BATs), medical review officers (MROs), and substance abuse 

professionals (SAPs). Some TPAs even employ some or all of these specialists on 

their staff. Many employers, however, contract with these service agents directly. 

Program managers should exercise caution when selecting service agents. 

Some of the large nationwide companies, particularly TPAs, have the worst 

compliance records. Program managers also need to closely and proactively 

monitor all of their contracted service agents, as well as the programs 

conducted by any subrecipients or operations and maintenance contractors 

subject to Parts 40 and 655. 

Procurement of Service Agents 

Many employers seek service agents that are part of a trade association. 

Membership is no guarantee of a quality provider, but it is an advantage. The 

members are informed, some associations have a certification process, and 

substandard performance and uncooperative behavior by member providers 

can be reported to the organization. Examples of these organizations include: 

• Drug & Alcohol Testing Industry Association: 800-355-1257, www.datia.org

• American Association of Medical Review Officers: 919-489-5407

• American Society of Addictive Medicine: 301-656-3920

• American College of Occupational and Environmental Medicine: 847-228-

6850

• Substance Abuse Program Administration Association: 800-672-7229 

The following general steps have proved helpful in selecting various types of 

service agents for FTA drug and alcohol testing programs. These steps apply to 

all providers: 

• Contact other employers in the area to identify vendors that have 

performed their duties well. (Either local or nationwide companies can be 

suitable.) 

• Prepare a written request for proposals (RFP) that clearly states the 

procedures that must be effectively performed by each type of provider 

needed, including complete documentation of their professional 

credentials, a short statement on the FTA procedures for their specialty 

and how they contrast with other applications they have been involved 

with, and a summary of the training that their personnel have received 

and how their performance is monitored. 

• Formulate standards for evaluating the proposals, assemble a panel to 

review the proposals against the standards, select those that score the 

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highest on the evaluation, and invite them for a brief presentation of their 

proposal and a question and answer session. 

• Formulate a checklist of questions for the interview that will demonstrate 

their understanding of the relevant FTA requirements and will reveal the 

training received by their personnel for all functions to be performed. 

• Take detailed notes during the interviews so the data can be used in the 

final evaluation process by the evaluation panel. 

• Select the agency that scores the highest. 

• Enter an agreement that, ideally, includes a provision allowing the transit 

agency to terminate the contract at will and for convenience. 

Specific advice for selecting specimen collection and analysis companies, MROs, 

and SAPs appear in Section 4.3, Section 4.4, and Chapter 5, respectively. 

Oversight of Service Agents and Contractors/Subrecipients

To help ensure that contracted service agents comply with the regulations, 

many employers develop a relationship with their providers. They talk with 

them, ask questions, impose performance standards, require documentation, 

visit their facilities at least once per year to perform informal reviews or formal 

audits, and impose corrective action for non-compliance. Employers can also 

report substandard performance and uncooperative behavior by service agents 

to FTA. If problems persist, FTA can initiate a Public Interest Exclusion (PIE), 

under Part 40, against the service vendor. 

Because grantees (and other employers) are responsible for the compliance of 

their operations and maintenance contractors and all subrecipients, they often 

develop similar relationships with those entities as developed with service 

agents. Many grantees also require quarterly management reports summarizing 

test reports and annual management information systems (MIS) reports. 

The Implementation Guidelines contain regulatory checklists for evaluating 

compliance of service agents and contractors/subrecipients. Appendix C 

contains examples of forms and lists used by state DOTs and transit agencies 

for monitoring compliance of subrecipients, operations and maintenance 

contractors, and contracted service agents. 

Minnesota DOT issues comprehensive checklists to its subrecipients for 

monitoring their TPAs and C/TPAs, shown in Figures C-1 and C-2, 

respectively. Specific issues and concerns related to monitoring specimen 

collection and analysis companies, MROs, and SAPs appear in Section 4.3, 

Section 4.4, and Chapter 5, respectively. 

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LACMTA issues written guidelines, shown in Figure C-3, to all of its operations 

and maintenance contractors. These guidelines are used as a basis for judging 

compliance when LACMTA staff visit the contractor’s facilities. GCRTA uses a 

single-page form, shown in Figure C-4, for documenting compliance when its 

staff visit the contractor’s facilities. Ohio DOT uses a very detailed multi-page 

checklist, shown in Figure C-5, for evaluating the programs of contractors. 

4.3 Specimen Collection and Analysis 

 

Many of the concerns and issues associated with urine collection and breath 

collection are similar, and both tests are often ordered at the same time and 

performed at the same facility. Therefore, this section addresses both of these 

functions. It is organized by the following topics: collection procedures, 

collection facilities, monitoring of collection and analysis operations, and 

selection of collection and analysis service agents. Within each topic, issues 

that are unique to each collection process are discussed separately. The 

analysis procedures are different and are also discussed separately. Examples 

of forms and lists used to assist with specimen collection appear in Appendix D. 

Collection Procedures 

As mentioned in Chapter 2, some transit agencies require, in their policies, 

that employees ordered to take reasonable suspicion or post-accident tests be 

transported or escorted to the collection site to ensure that they travel directly 

to the site. Transporting or escorting people for all tests is good practice, if 

feasible, and can be required when the test is ordered even if the requirement 

is not documented in the policy. 

As in all aspects of the testing process, forms can be a useful tool in 

communicating collection practices and documenting occurrences, such as 

arrival times and performance of the various steps in the process. 

San Francisco BART issues collection instructions (shown in Figure D-1) to 

each employee who is tested, and requires urine collectors to complete and sign 

a checklist (shown in Figure D-2) for each collection performed. 

Forms are also useful in documenting a donor’s inability, or unwillingness, to 

produce a urine or breath specimen. Ohio DOT issues “shy bladder” and “shy 

lung” forms (shown in Figures D-3 and D-4, respectively) to its subrecipients to 

document these occurrences. Some delays in producing specimens by donors 

who ultimately produce a negative specimen have been interpreted as a ploy to 

collect additional pay or avoid work. A useful device for monitoring the amount 

of water consumed by “shy bladder” donors is to issue 10-ounce bottles of 

water one at a time to a maximum of four bottles, record the number of empty 

bottles, and observe the consumption. 

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Another frequent issue in urine collection is hand washing. Many donors do 

not want to handle their own pen before they wash their hands and do not 

want to use the collector’s pen that was used by others before they washed 

their hands. One solution is to issue throw-away pens. 

Collection Facilities 

Some large transit authorities, such as New York City Transit (NYCT), New 

Jersey Transit (NJT), SEPTA, MBTA, and LACMTA have their own collection 

facilities and have trained urine collectors, STTs, and BATs on their staff. Most 

other employers contract out for these services, either directly or through a TPA 

or C/TPA. Specimens can be collected at a fixed location, at the employees’ 

facilities, or at or near the employees’ facilities using a collection vehicle. 

Either internal or contracted urine collectors, STTs, and BATs can be used at 

any of these locations. 

The ideal environment for ensuring compliance with FTA urine collection

requirements contains the following features: 

• Clean rest rooms that are large enough to conduct an observed collection 

with sufficient personal space for the donor 

• Sinks with electrical switches that allow the hot and cold running water 

to be turned off from outside of the rest room 

• Absence of drop ceilings in the rest room 

• A pressurized cold water system in the toilet tank that prevents access 

without dismantling the system 

• Lockable storage containers suitable for securing valuables such as 

purses and wallets 

However, these features cannot always be found in vendor 

fixed locations. They are found even less often at on-site 

Figure 4-1. Typical Rest 

Room as Collection Site

employee facilities. On-site urine collection is often done 

in a typical rest room, shown in Figure 4-1, of a transit 

office building. These rest rooms are typically not secure. 

They may have places to hide clean urine specimens (e.g., 

above ceiling tiles) or may contain adulterants (hot and 

cold running water, soaps, cleaning chemicals). 

One way to safeguard the process in an unsecured rest 

room is to have the collection technician stand inside the 

rest room but outside the private toilet stall (as shown in Figure 4-2) while the 

specimen is being produced. There are also several ways to secure the 

facilities.

Chapter 4.Testing Program Implementation and Management Page 4-11 
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One way to temporarily secure a water source at a sink is 

to install winged water faucet controls, drill holes in the 

Figure 4-2. Collector in 

Rest Room with Donor

holes in the wings, and put a metal bar between the wings. 

Another method is to place evidence tape over the faucet 

handles to prevent the donor from turning on the water or 

at least to enable the collector to detect tampering with the 

faucets. Evidence tape tears when someone tries to 

remove it. Masking tape, however, does not serve this 

purpose because it can be easily removed and reapplied. 

Evidence tape can also be placed across the tiles and 

frames of drop ceilings and on toilet tops to enable the collector to detect 

removal of fixtures. Waste baskets and toilet paper, paper towel, and Kleenex 

dispensers are common places for storing clean specimens and adulterants, 

and should be removed during the collection process. 

Toilets and urinals with sensors, which cause automatic flushing when a 

person moves away from the fixture, should not be used because flushing 

washes out the bluing agent. Some collectors place masking tape over sensors 

with some success, though others have not found this approach useful. 

Some collectors place tape over the flush handles to detect flushing of the 

colored water to get access to clear water. However, since the color of the water 

in the bowl would be clear, indicating the toilet had been flushed, the tape 

would only serve to detect replacement of bluing agent. 

There are fewer concerns with breath collection facilities. Breath samples can 

be taken and analyzed in any room that is visually private and reasonably 

soundproofed, provided the equipment meets FTA specifications and is properly 

calibrated, the technician operating the equipment is properly trained, and 

precautions are taken to prevent contamination of breath samples. 

Alcohol, alcohol swabs, and other contaminants should not be stored anywhere 

near breath collection and analysis equipment. One issue with the equipment 

is its height. It should be adjustable to make it easy for everyone to blow into. 

HEIGHT OF BREATH COLLECTION EQUIPMENT 

Metro-Dade Transit Agency (MDTA), a unionized system in Miami, Florida, experienced a 

grievance regarding placement of breath collection and analysis equipment on tables. Donors 

had difficulty blowing into the equipment when they were sitting down. In response, MDTA 

attached the collection and analysis equipment on a flat tray and mounted the tray on a jack. 

This assemblage was then placed on top of a chest of drawers. All of the necessary materials 

are kept in the drawers. The height of the collection and analysis device can be adjusted up or 

down to be at the same height as the mouth of the donor. The adjustable-height system is 

always level at any available height. The donors are now better able to provide a complete 

sample during the specified available time.

Chapter 4.Testing Program Implementation and Management Page 4-12 
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FTA Drug and Alcohol Testing Program 

The bigger concern with breath testing is the cost and availability of the 

equipment. Evidential breath testing (EBT) devices are expensive and BATs

have to be trained to use them. Many small operators are unable to afford EBT

devices. EBT service agents are often difficult to find in rural areas. Many 

rural employers often arrange to use EBTs that are owned by other entities, 

e.g., trucking companies, school bus companies, railroads, small airstrips, U.S. 

Coast Guard. Most attempts to use EBTs owned by police departments have 

not proved successful. 

Mobile collection facilities have become popular for both drug and alcohol 

testing. Many employers contract with mobile collection vendors, and some 

transit systems with large safety-sensitive work forces acquire vans, equip 

them with the necessary equipment, and hire full-time employees to staff them. 

For some operations, use of mobile facilities can reduce testing life-cycle costs. 

Merely driving the collection vehicles past employee facilities can have a 

deterrent effect. If properly configured and equipped, vehicles can provide a 

secure and comfortable environment for both urine and breath collection. 

Figures 4-3 through 4-8 show the mobile urine collection facility used by 

SuTran’s vendor2 in Sioux Falls, South Dakota. 

The exterior of Figure 4-3. Side View of Collection Van Figure 4- 4. Rear View of Collection Van

the collection 

vehicle, shown 

in Figures 4-3 

and 4-4, looks 

like any other 

raised-roof van. 

It has a pair of 

side doors to 

Figure 4-5. Rear Step of Collection Van 

provide access to the urine collection area. As 

shown in Figure 4-5, a substantial step has 

been added to the rear bumper, to provide 

primary ingress/egress through the rear doors. 

The step should be designed so that it can be 

used safely in wet, icy, and snowy weather. 

This van includes the required writing surface 

and benches adjacent to the rear doors, as 

shown in Figure 4-6. The space below the seats 

is used to store unopened urine collection kits, 

breath analysis equipment, and other 

materials. 

 

2 Sure Test, Inc., P.O. Box 1840, Sioux Falls, SD 57101. FTA does not recommend or endorse

Sure Test or any other company. The photos are included solely for reference purposes. 

Chapter 4.Testing Program Implementation and Management Page 4-13 
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Figure 4-6. Interior of Collection Van The two-drawer filing cabinet is used to store 

chain-of-custody forms, employer contact 

information, directions, and other printed 

information necessary to provide collection 

service. Interior walls are available for posting the 

collection procedures for the donor. Carpeting or 

other slip-resistant surface can be provided on 

the floor to maximize footing safety. 

The space is reasonably comfortable for the 

collector and the donor to sit and complete all of 

the necessary forms. The gentleman in Figure 4-6 

is approximately 6-feet tall and stocky. 

Behind the collector is the 

enclosure that houses a standard 

Figure 4-7. Toilet in Enclosure 

in Collection Van 

Figure 4-8. Sink in 

Collection Van 

recreational vehicle toilet, shown 

in Figure 4-7. The enclosure is 

large enough to allow a donor to 

produce a specimen without any 

discomfort, either standing or 

sitting. Between the enclosure 

and the operator’s seat is the 

reservoir for water to fill the bowl 

and to eventually flush its 

contents. 

A sink for hand washing, shown in 

Figure 4-8, is located behind the 

filing cabinet. The sink area 

includes a towel rack for drying hands and a wastebasket for used towels and 

other materials. 

Monitoring of Collection and Analysis Operations 

To ensure compliant collection operations, employers should encourage 

feedback from and listen to employees who return from collection sites, and the 

program managers should regularly review the performance of all urine 

collection technicians, STTs, and BATs, whether they are internal staff, 

contracted service agents, or contractor or subrecipient staff. Program 

managers should talk to collection staff and ask them about their collection 

procedures and the type and amount of supervision of their performance. 

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FTA Drug and Alcohol Testing Program 

Program managers should ensure that new collection technicians receive the 

initial training required in Part 40, and that all technicians receive the required 

refresher training. Development of standard forms and certificates can help in 

tracking and documenting the courses completed by the various technicians 

and the dates of completion. Program managers should also sample and 

evaluate data in the collection operation’s central files. Reasons should be 

provided for all collections resulting in cancelled tests, either documented in 

the records or given during the review. 

Common findings during audits of collection and analysis operations include 

EBT devices that are not calibrated, BATs who are not properly trained, and 

urine analysis laboratories with no recorded results for documented collections. 

Questions to ask during a review of a urine collection operation include: 

• What precautions are taken to prevent clean samples from being placed 

in the collection room prior to a donor’s arrival? 

• How are observed collections handled when the donor and the collector 

are different genders (particularly when a collection vehicle is used to 

meet a donor at a remote location)? 

• How often do “shy bladders” occur and how are they documented? 

Questions to ask during a review of a breath collection and analysis operation 

include: 

• What precautions are taken to prevent contamination of breath samples? 

• How often do “shy lungs” occur and how are they documented? 

• Has the EBT device been approved by the National Highway Traffic Safety 

Administration (NHTSA). 

• How often does the manufacturer recommend calibrating the EBT device? 

(Ask to see the manufacturer’s Quality Assurance Plan, QAP, for the 

device.) 

• How often is the EBT device actually calibrated? (Ask to see the 

calibration log and compare it to the QAP.) 

Mock collections should also be conducted at least once per year. Non-routine 

elements (e.g., a bottle of soap in a pocket for a urine collection or refusal to 

sign the form) should be included. In addition to noting any violations or 

errors or fatal flaws in the process, the evaluator should note whether the 

collections staff are aware of any errors or fatal flaws. A form used by Ohio 

DOT for documenting results of mock collections appears in Figure D-5. 

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FTA Drug and Alcohol Testing Program 

It is also useful to schedule a few random tests (both drug and alcohol) during 

the 4 hours immediately after service ends, to ensure there is a facility for postaccident testing during that period. 

Selection of Collection and Analysis Service Agents 

The most common method of specimen collection is using a service agent’s 

fixed location facility offering multiple services, such as occupational health 

practices or clinics, doctors’ offices, hospitals, or testing laboratories. There 

are also specimen collection services that operate independently of any other 

medically related functions. These providers vary widely in terms of their 

business focus. There are also companies with specimen collection as their 

only business that fully understand FTA requirements for urine and/or breath 

collection. These companies are sometimes staffed with multiple trained 

technicians and/or medical doctors and can sometimes provide the level of 

service required. However, such companies are the exception. More often, the 

independent providers are secondary services provided by non-medical 

businesses. One audited specimen collection service was a small operation 

that was part of a computer software development company. 

Entering an agreement with an FTA-compliant company with multiple offices in 

a spatially large service area that is open 24 hours a day and 7 days a week is 

often cost-effective for large and medium-size companies or consortia. However, 

such opportunities do not always exist. Alternatives include: 

• Use of multiple fixed-location urine collection facilities for different times 

of the day, and for weekend days and holidays 

• A collection service that comes to employees’ facilities to collect a sample, 

using a standard rest room for urine collection and a private room for 

breath collection 

• A collection service that uses a mobile collection facility 

Use of a collection service with a mobile facility, for both drug and alcohol 

collection, is particularly common in rural areas among Section 5311 

providers, where other services are not available at the times needed. Many 

other employers have found that the flexibility provided by collection vehicles 

significantly reduces system disruption costs. The vehicles can be deployed on 

any day, at any time, and to any location. Though the cost per collection is 

usually higher with a mobile collector than with a fixed-location collector, the 

life-cycle costs are often lower when service delays, supervisor time, additional 

vehicles, “deadhead” time, and transportation expenses are considered. 

In addition to the practices discussed in Section 4.2 for selecting any service 

agent, evaluators should inquire about the training and supervision the urine 

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FTA Drug and Alcohol Testing Program 

collection technicians, STTs, and BATs receive and their procedures. The 

evaluators should also ask the questions suggested in the “Monitoring of 

Collection and Analysis Operations” discussion earlier in Section 4.3. 

Perspective urine collectors should be asked to perform a detailed mock 

collection at their site for the evaluation panel. Perspective breath collectors 

should be asked to bring their screening devices and EBT devices to the 

interview and allow an evaluator to test them. 

If emergency rooms propose to provide urine and/or breath collection, the 

collection staff should be asked how they will handle drug tests if all medical 

staff are involved with emergency treatment when a specimen donor arrives, 

and what they will do if a patient arrives with a severe emergency condition 

while a specimen collection is being performed. 

A regularly updated list (once per month) of urine analysis laboratories that 

have been certified by the U.S. Department of Health and Human Services 

(DHHS) can be obtained from the Division of Workplace Programs, 5600 

Fishers Lane, Rockwall II Building, Suite 815, Rockville, MD 20857, telephone: 

(301) 443-6014, or at http://www.health.org/workpl.htm. This list is also 

published in the Federal Register under the heading “Substance Abuse and 

Mental Health Services Administration (SAMHSA).” 

Criteria for choosing between compliant laboratories are customer service, 

billing procedures, cost, reliability, and accuracy. Validity testing may 

influence cost. See FTA Drug and Alcohol Testing newsletters, particularly 

Bulletin 16. 

4.4 Medical Review 

This section discusses proven practices used by employers to manage the 

medical review process, to select MROs, and to monitor their performance. 

 

Managing the Medical Review Process

Standard forms have proved useful in managing and documenting the various 

medical review functions. Examples of forms and lists used to assist with 

managing the medical review process appear in Appendix E. 

The City of Albuquerque uses printed lists (shown in Figure E-1) to document 

and disseminate the roles and responsibilities of MROs. Albuquerque issues 

checklists to its MROs to guide them through the entire medical review process 

and to guide them in their interviews with tested employees (shown in Figures 

E-2 and E-3, respectively). 

Chapter 4.Testing Program Implementation and Management Page 4-17 
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Use of standard forms provides records of various medical review occurrences, 

e.g., employee requests to test the split sample following a confirmed positive 

test result and an MRO’s inability to contact a tested employee following a 

confirmed positive result. A split sample form issued by Ohio DOT to its 

subrecipients appears in Figure E-4. A failure to make contact form, prepared 

by University Services (Philadelphia, PA) for the Monroe County (Pennsylvania) 

Transportation Authority, appears in Figure E-5. 

A flow chart of the verification process performed by an MRO (developed by the 

FTA drug and alcohol testing program audit team3, based on the team’s 

knowledge of the regulations and experience in evaluating grantees’ medical 

review programs) appears in Figure E-6. 

 

Selection of Medical Review Officers 

Some large transit authorities, such as NYCT, NJT, SEPTA, MBTA, and 

LACMTA, hire MROs as employees. Most other employers contract out for 

MRO services, sometimes with companies that include support staff as well as 

several MROs, either directly or through a TPA or C/TPA. Prudent practices for 

selecting MROs are the same regardless of the administrative mechanism used 

to procure them. 

There is no national registry of MROs. However, the American Association of 

Medical Review Officers (919-489-5407), the American Society of Addictive 

Medicine (301-656-3920), and the American College of Occupational and 

Environmental Medicine (847-228-6850) have many members who have the MRO 

qualifications required by FTA.

In addition to the practices discussed in Section 4.2 for selecting any service 

agent, employers should include the Part 40 qualification requirements in the 

procurement or solicitation device used to obtain medical review services or hire 

MROs as internal staff. Employers should also carefully examine the credentials 

of prospective MROs, and should meet with them and discuss their experience 

and knowledge about substance abuse disorders and their understanding of 

Parts 40 and 655 and how to interpret them. These discussions should include 

major medical review issues, such as how they handle prescription medications 

and over-the-counter (OTC) medications and what experience they have with 

donors claiming that herbal teas caused their positive test for marijuana. 

 

 

3 The FTA drug and alcohol testing program audits are performed by ICF Consulting and the 

Ketron Division of the Bionetics Corporation.

Chapter 4.Testing Program Implementation and Management Page 4-18 
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FTA Drug and Alcohol Testing Program 

Monitoring Performance of Medical Review Officers

To ensure compliant collection operations, program managers should regularly 

review the performance of MROs, whether they are internal staff, contracted 

service agents, or contractor or subrecipient staff. All correspondence with 

MROs should be reviewed as it is received, to identify unusual situations that 

may indicate questionable performance. Data in the MRO office files should be 

sampled and evaluated regularly. Examples of unusual situations include long 

delays between test dates and reports of positive results that are later reversed, 

lack of timely response to communications, and errors on the type of test 

reported (i.e., pre-employment, reasonable suspicion, post-accident, random, 

return-to-duty, and follow-up). 

One method used to monitor MRO performance is to maintain a matrix of tests 

by category and dates. Any pre-employment test dates occurring well after the 

hire date or well after any random tests suggest a categorization error. Multiple 

postings of the same test results suggest poor record maintenance and may 

suggest overall poor organizational management. 

MRO reversals of positive tests reported by the laboratory should be 

questioned. There are a variety of legitimate reasons for reversing a positive, 

but legitimate cause for doing so occurs very infrequently. Reversal of more 

than a few positives per year for most companies is unusual, though some 

industries and locations have unusual circumstances. Nevertheless, such 

occurrences should be examined thoroughly. 

Additionally, program managers should ensure that all MROs complete the 

continuing education units required by Part 40 within the required time frame. 

They should also establish a mechanism for receiving notification of all new 

hires of MROs, and review their qualifications to ensure compliance with Part 

40. Development of standard forms and certificates will help in tracking and 

documenting the continuing education completed by MROs and in maintaining 

awareness of newly hired MROs and documenting their qualifications. 

 

4.5 Records Management 

As discussed in the Implementation Guidelines, drug and alcohol testing 

programs generate a large number of records that must be stored and 

maintained per Parts 40 and 655. These records are clearly designed to 

document that the required activities have been accomplished correctly. It is 

often useful to exceed FTA’s retention requirements. It is particularly useful to 

maintain a contractor oversight file and to retain negative test result records 

for longer than the one year required. In fact, it may be in a system’s best 

interest to retain all records indefinitely. This would provide useful data for 

Chapter 4.Testing Program Implementation and Management Page 4-19 
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FTA Drug and Alcohol Testing Program 

Chapter 4.Testing Program Implementation and Management Page 4-20 

scheduling random tests, and would provide a complete history of the overall 

testing program. 

Record Keeping Methods 

Part 655 does not specify how to organize records. However, a logical system is 

needed. Simple methods have worked best for many employers. There are two 

basic record keeping methods: (1) by test category and (2) by individual 

employee (by name or by identification number). The first method is used by 

many large authorities, e.g., Oahu Transit and Kauai Transit in Hawaii and the 

Transit Authority of River City (TARC) in Louisville, Kentucky. Use of a master 

log for each test category is helpful when using the test category method. The 

individual employee method can be very cumbersome unless the employer is 

small and has a stable work force. A third option is to file the information by 

date and by employee within each date file. 

It is also useful to enter data from records into analysis files that can be used 

to evaluate the performance of the drug and alcohol testing program. For 

example, organizing the random test records so that the information can be 

easily collected and inserted into an Excel file to produce graphs will 

demonstrate whether the random tests were conducted across all hours of 

operation and across all service days. 

Records Security and Access Control 

To ensure compliance with FTA requirements for securing and controlling 

access to test records, employers should store all required records in locked 

filing cabinets in a locked room that can be entered only through a locked door. 

A combination lock should be used on the door to prevent unauthorized 

duplication of keys. 

Records should not be kept in a room with drop ceilings with removable tiles. 

A person can remove the ceiling tiles in the hall in front of the records room, 

climb over the wall, and drop through the opening. A truly secure records 

room has wall partitions that abut and attach to the roof or ceiling of the 

building, thereby preventing anyone from climbing over the walls. 
BEST PRACTICES 

FTA Drug and Alcohol Testing Program 

5. Referral, Evaluation, and Treatment 

Employers with policies that call for automatic termination of any employee 

who violates the DOT/FTA drug and alcohol rules (i.e., a zero-tolerance policy) 

may want to devise a standard form listing the names, addresses, and 

telephone numbers of FTA-compliant substance abuse professionals (SAPs) in 

the local area. The form should also include the name of the violator, the date 

and nature of the violation, the date of effective termination, the date that the 

form was issued to the terminated employee, and the signature of the person 

who issues the form. Maintenance of such information would provide evidence 

of compliance with the referral requirements in Parts 40 and 655. In compiling 

the list of SAPs, these employers may also want to refer to the discussion of 

SAP selection later in this chapter (in Section 5.2). 

Employers with second-chance policies, however, have much greater 

administrative responsibilities for referral, evaluation, and treatment of 

violators. This chapter discusses proven practices used by employers to 

manage this process, to select SAPs, and to monitor their performance. 

 

5.1 Managing the Referral, Evaluation, and Treatment Process

Standard forms have proved useful in managing and documenting the various 

functions in this area. Examples of forms used to assist with managing the 

referral, evaluation, and treatment process appear in Appendix F. 

 

To help employees better understand this process, employers with a secondchance policy may want to list the Part 40 requirements that pertain to the 

process and the role and responsibilities of SAPs, and to distribute the lists to 

all employees who violate the FTA drug and alcohol regulations. 

To better ensure compliant return-to-duty and follow-up tests, many employers 

add the requirement that these tests be observed collections. This can be 

stipulated in the drug and alcohol policy, included in a list of requirements 

given to employees who enter treatment, or communicated to SAPs when they 

begin work for the employer. 

Forms to document referrals provide records of employees referred to SAPs and 

the names and addresses of the SAPs. The City of Albuquerque uses a referral 

form (shown in Figure F-1) that informs the employee of the referral, lists the 

SAP referred to and an alternate SAP, designates the party responsible for 

payment, and requires a signature to acknowledge receipt of the referral. The 

Ohio Department of Transportation (DOT) uses the same form. The San 

Francisco Bay Area Rapid Transit (BART) District uses a form (shown in Figure 

Chapter 5. Referral, Evaluation, and Treatment Page 5-1 
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FTA Drug and Alcohol Testing Program 

F-2) that includes documentation of the circumstances surrounding the 

referral and the SAP’s findings and recommendations. 

Many employers require employees to sign contracts, or agreements, 

documenting the conditions of their rehabilitation and continued employment. 

Ohio DOT issues agreement forms to its subrecipients to use when an 

employee enters treatment as a condition for continued employment and when 

the employee is approved for return to duty following successful completion of 

treatment. These forms appear in Figures F-3 and F-4, respectively. 

The City of Albuquerque uses a form (shown in Figure F-5) to document all 

occurrences during the entire treatment and follow-up period, including the 

date and results of each rehabilitation test. This type of comprehensive form or 

a series of more specific forms documenting evaluations performed by SAPs 

and the treatment programs and tests that they order can be used as a case 

history summary of the SAP-client relationship. Such a summary can then be 

augmented with support documentation to complete the file. 

The Massachusetts Bay Transportation Authority (MBTA) issues a standard 

evaluation form containing 28 “yes/no” questions (shown in Figure F-6) to 

SAPs. The SAPs are required to ask the questions to all new clients, record the 

answers on the form, apply prescribed point values to each answer (as shown 

in Figure F-64), and tally the overall score. Another standard form, shown in 

Figure F-7, is used to document the specific requirements of the treatment plan 

devised for the client, who is required to sign the form. The form shown in 

Figure F-8 is used by the MBTA to document the SAP’s evaluation of the 

client’s performance during the treatment program, recommendations for 

further participation after the client returns to work, and the number of followup tests required of the client during the five years following return to duty. 

San Francisco BART uses a follow-up assessment form (shown in Figure F-9) to 

document information regarding the treatment plan completed by a returning 

employee, the results of the evaluation following treatment, the date and 

results of the return-to-duty test, the SAP’s recommendations for follow-up 

testing and treatment, and existence of a return to work contract. 

Flow charts showing procedures used by the West Virginia DOT Division of 

Public Transit for return-to-duty testing and for follow-up testing appear in 

Figures F-10 and F-11, respectively. 

 

4 The instructions for the answer scoring and the scores appear in this example as sheet 3 of 

Figure F-6. The MBTA uses two separate forms for the questions and the scoring key, and 

repeats the questions on the scoring key form. The scoring key has been added to the form 

containing the questions in this example for convenience of presentation.

Chapter 5. Referral, Evaluation, and Treatment Page 5-2 
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FTA Drug and Alcohol Testing Program 

5.2 Selection of Substance Abuse Professionals

Some large transit authorities, such as the MBTA, hire SAPs as employees. 

Most employers, however, contract out for SAP services, either directly or 

through a TPA or C/TPA. Prudent practices for selecting SAPs are the same 

regardless of the administrative mechanism used to procure them. 

There is no national registry of SAPs. However, the Substance Abuse Program 

Administration Association (800-672-7229) has many members who have the 

SAP qualifications required by FTA. Other employers have proved to be a good 

source for identifying local SAPs who have performed their duties well. Local 

SAPs are often most effective, since it is more convenient for them to meet faceto-face with their clients than it is for SAPs who are located a long distance 

from the employer’s facilities. There are very few SAPs in rural areas.

In addition to the practices discussed in Section 4.2 for selecting any service 

agent, employers should include the FTA qualification requirements in the 

procurement or solicitation device used to contract with SAPs or hire them as 

internal staff. Employers should also carefully examine the credentials of 

prospective SAPs, ask them to submit sample forms they currently use in their 

practice, and meet with them and discuss their experience and knowledge 

about substance abuse disorders and their understanding of Parts 40 and 655 

and how to interpret them. An important question to ask is whether they or 

the drug and alcohol program manager generates follow-up test programs. A 

number of audits have found that the employer devised the test schedule and 

imposed it on the SAP. A number of audits have also identified SAPs who do 

not understand their role as protector of public safety. Thus, prospective SAPs 

should be quizzed about their role. Another question to ask is how many tests 

are required of a rehabilitated employee during the first year of follow-up 

testing. 

5.3 Monitoring Performance of Substance Abuse Professionals 

To ensure compliant collection operations, program managers should regularly 

review the performance of SAPs, whether they are internal staff, contracted 

service agents, or contractor or subrecipient staff. All correspondence with 

SAPs should be reviewed as it is received, and all data in the SAP office files 

should be sampled and evaluated regularly, to ensure that the SAP monitors 

the clients throughout their treatment programs and to identify other 

questionable performance. One example of questionable performance is always 

prescribing six follow-up tests within a year of the client’s return to duty. If 

this is done consistently for a large number of clients, the SAP may not be 

tailoring the testing program to the individual’s needs. Another example is 

recommending a return-to-duty test soon after the employee tests positive on a 

Chapter 5. Referral, Evaluation, and Treatment Page 5-3 
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Chapter 5. Referral, Evaluation, and Treatment Page 5-4 

random, reasonable suspicion, or post-accident test. The SAP may not have 

performed the required evaluations before recommending the test. 

Additionally, program managers should ensure that all SAPs complete the 

continuing education units required by Part 40 within the required time frame. 

They should also establish a mechanism for receiving notification of all new 

hires of SAPs, and review their qualifications to ensure compliance with Part 

40. Newly hired SAPs should also be asked the questioned suggested in 

Section 5.2. Development of standard forms and certificates will help in 

tracking and documenting the continuing education completed by SAPs and in 

maintaining awareness of newly hired SAPs and documenting their 

qualifications.
Best Practices 

FTA Drug and Alcohol Testing Program 

Appendix A. Example Policies 

This appendix contains six compliant policies for entities that wish to develop 

their policy internally or oversee the work of consultants. Each of these 

examples is referenced and described in Chapter 2. The example policies are: 

(1) Southwestern Ohio Regional Transit Authority/Cincinnati Metro 

(2) Long Beach Transit (California) 

(3) Tri-County Metropolitan Transit District/Tri-Met (Portland, Oregon) 

(4) Des Moines Metropolitan Transit Authority (Iowa) 

(5) Ohio Department of Transportation 

(6) Georgia Department of Transportation 

Each of these policies was audited and judged to be compliant with Part 40 before 

it was recently revised and with Parts 653 and 654, and each of them has been 

updated to address the revised Part 40 and Part 655. However, no policies have 

been audited for compliance with the revised Part 40 and Part 655. 

The Cincinnati Metro and Long Beach Transit Policies included in this appendix 

have not been formally approved by their governing boards since they were revised.

Appendix A. Example Policies Page A-1

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FTA Drug and Alcohol Testing Program 

1. Southwestern Ohio Regional Transit Authority/Cincinnati Metro 

CINCINNATI METRO’S DRUG AND ALCOHOL PROGRAM--REV. 12/01 

TABLE OF CONTENTS 

 

PART I INTRODUCTION 

 

PART II DRUG FREE WORKPLACE POLICY 

PART III DRUG AND ALCOHOL TESTING POLICY 

1.0 Applicability 

 2.0 Drug and alcohol policy 

 3.0 Prohibited substances 

3.1 Illegal Drugs 

3.2 Legal Drugs 

3.3 Alcohol 

 4.0 Testing Procedures 

4.1 Collection process 

4.1.1 Drug test collection 

4.1.2 Urinalysis for drugs 

4.1.3 Split sample 

4.1.4 Role of the Medical Review Officer 

4.2 Alcohol testing process 

4.3 Return to work pending test results 

 5.0 Causes for Testing 

 5.1 Pre-employment 

5.2 Reasonable Suspicion 

5.3 Return to Work 

 5.4 Follow Up 

 5.5 Post Accident 

 5.51 Fatality 

5.52 Bodily injury or property damage 

 5.53 Reasonable Suspicion 

 5.54 Other requirements 

 5.6 Random 

5.7 Biennial physicals and testing 

6.0 Positive Test 

7.0 Refusals 

 8.0 Evaluations, Referrals, and Rehabilitation 

9.0 Training 

10.0 Specimen Retention 

11.0 Records Retention 

12.0 Confidentiality 

13.0 Contractors 

14.0 Questions 

 

 

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PART IV CONSEQUENCES 

 1.0 Intoxication/Under the Influence 

2.0 Positive Test 

 3.0 Alcohol concentration of 0.02 to 0.0399 

4.0 Refusal 

 5.0 Manufacture, trafficking, possession & use 

 6.0 Criminal drug conviction at workplace 

 7.0 Violation of last chance agreement 

 8.0 Alcohol prohibited after accident 

 9.0 Alcohol prohibited before work shift 

10.0 Duty to report 

11.0 Prescription/Over the counter 

PART V REHABILITATION 

 1.0 Employee assistance program (EAP) 

 2.0 Substance abuse professional (SAP)

 3.0 Rehabilitation process 

4.0 Confidentiality 

5.0 Literature 

APPENDICES 

 A. Safety-Sensitive Positions 

B. Contact Names and Numbers 

C. Federal Testing Forms 

D. Drug Screen Cutoff Levels 

E. Support Groups and Other Resources 

F. Sample Training Forms 

G. Contractor Information 

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PART I 

CINCINNATI METRO’S DRUG & ALCOHOL PREVENTION PROGRAM 

INTRODUCTION 

The Metro is dedicated to providing safe, dependable, and economical transportation services to the 

Cincinnati and Hamilton County community. The Metro is also dedicated to providing a healthy, 

satisfying drug-and alcohol-free work environment for its employees. These obligations are severely

jeopardized by an employee who is unfit for duty due to drug or alcohol usage. 

Drugs and/or alcohol usage can cause work performance problems such as accidents, run delays, missing, 

and excessive absenteeism. It can cause sickness and workplace injuries resulting in higher health care 

and workers’ compensation premiums. Drug and/or alcohol usage is also the cause of workplace 

accidents, damage to property and equipment, threats to public safety, including passengers and the 

general public and poor workplace decisions. Finally, drugs and/or alcohol usage can cause significant 

harm to the Metro’s public image. 

Drug and alcohol testing is mandated by the Federal Transit Administration (FTA) and the U.S 

Department of Transportation (DOT) in 49 CFR Part 40, and Part 655, as amended. In addition, drugs 

are prohibited in the workplace by the “The Drug-Free Workplace Act of 1988” located in 20 CFR Part 

29. 

Metro’s Drug & Alcohol Prevention Program has been created to protect both the public and the Metro 

employees. It mandates discipline up to and including discharge, depending upon circumstances.. At the 

same time, it offers free substance abuse evaluation services and a second chance to employees who 

voluntarily come forward to the Metro and seek professional rehabilitation services prior to being notified 

of a pending drug or alcohol test. Metro’s Drug and Alcohol program has been adopted by the SORTA 

Board of Trustees. This program is also intended to comply with all applicable federal regulations 

governing workplace anti-drug and alcohol abuse programs in the transit industry. 

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PART II 

DRUG-FREE WORKPLACE ACT

SORTA/THE METRO 

NOTICE TO EMPLOYEES 

Pursuant to the 

Drug-Free Workplace Act of 1988 

 

The unlawful manufacture, distribution, dispensing, possession or use of all controlled substances is 

prohibited in SORTA/The Metro’s workplace. Employees so found will be subject to discipline up to and 

including termination, depending upon circumstances. 

Substance abuse is a major focus of today’s society. The effect of this abuse on an employee’s job 

performance is costly to the employee, his/her family and to the employer. In place is a testing procedure 

whose purpose is to insure a drug-free and alcohol-free workplace. No employee who unlawfully uses, is 

impaired by, or under the influence of, drugs and/or alcohol ever will be permitted to function in a 

position where his/her actions could affect the safe operation of a motor vehicle or endanger the safety of 

fellow workers. 

Pamphlets on drug/alcohol abuse are available from the Nurse or Human Resources department. Also, 

SORTA/The Metro Employee Assistance Program is available to assist employees in receiving medical 

and rehabilitation treatment and counseling to help resolve substance abuse problems. 

Employees found unlawfully using, impaired by, or under the influence of, controlled substance(s) and/or 

alcohol in the workplace will be immediately discharged. The employee may be referred to the Employee 

Assistance Program. Employees engaged in the unlawful manufacture, distribution, or dispensation, or 

found in possession, of an unprescribed controlled substance(s) and/or alcohol in the workplace will be 

subject to discipline up to and including termination, depending upon circumstances. 

All employees must notify SORTA/The Metro of any criminal drug statute conviction for a violation 

occurring in the workplace no later than five days after any such conviction. Within 30 days, 

SORTA/The Metro will make a determination of action based on the incident. Employees will be subject 

to discipline up to and including termination, depending upon circumstances. 

All employees are expected to abide by SORTA/The Metro’s policy on a drug-free workplace.

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PART III 

CINCINNATI METRO’S DRUG & ALCOHOL TESTING POLICY 

Bold Type = Required by FTA 

1.0 APPLICABILITY

The Metro’s policy applies to all employees. Certain portions, however, apply strictly to “safetysensitive” employees (random testing) or “covered” employees (biennial testing, return-to-duty physical). 

“Covered” employees refer to applicants, bargaining unit personnel, Risk Management personnel, and 

any employees who drive or may drive Metro vehicles. “Safety-sensitive” employees refer only to 

employees who perform job duties related to the safe operation of mass transit service including the 

operation, dispatch and control, maintenance, and supervisors who perform a safety-sensitive 

function and any employee who holds a Commercial Driver’s License. A list of “safety-sensitive” 

employee job titles is provided at Appendix A. 

2.0 POLICY

The Metro is committed to a drug-free and alcohol-free workplace for the safety of its employees, its 

passengers and the public. That commitment is jeopardized every time an employee uses drugs or alcohol 

on the job, every time an employee reports to work with drugs or alcohol in his/her system, and every 

time an employee possesses, distributes, or sells unprescribed drugs. 

It is the employee’s responsibility to know and understand the Metro Drug & Alcohol Prevention 

Program. In undertaking this duty, the employee should pay close attention to Part IV, the 

consequences section, noting that termination may be a result of violation of the policy. The employee 

should also take advantage of the rehabilitation opportunities and awareness information available as 

explained in Part V. 

This policy incorporates all of the requirements and procedures set forth by federal regulations 49 CFR 

part 40, 655, and the “Drug Free Workplace Act”, as amended. 

3.0 PROHIBITED SUBSTANCES

The presence of any prohibited substances in an employee’s system is forbidden during working time. 

“Prohibited substances” addressed by this policy include the following: 

3.1 Illegal Drugs

The use at any time of illegal substances identified in Schedules I through V of Section 202 of the 

Controlled Substance Act (21 U.S.C. 812), and as further defined by 21 CFR 1300.11 through 1300.15, is 

prohibited. This includes Marijuana, Phencyclidine (PCP), Cocaine, Opiates, and Amphetamines, as 

well as any drug not approved for medical use by the U.S. Drug Enforcement Administration of the U.S. 

Food and Drug Administration is prohibited. 

3.2 Legal Drugs 

The misuse or abuse of legal drugs is prohibited if it causes a positive test which cannot be medically

explained and verified by the Medical Review Officer. All prescriptions must be administered properly,

issued in the employee’s name by a licensed doctor, and properly followed. 

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3.3 Alcohol

The use or ingestion of alcohol such that an employee has an alcohol concentration of 0.02 or above 

during working time is prohibited. (Refer to consequences section for the differences between a 0.02 

and a 0.04). Alcohol use means the consumption of any beverage, mixture, or preparation, 

including any medication containing alcohol. The ingestion of alcohol up to four hours before the 

performance of safety-sensitive functions is prohibited regardless of the resulting alcohol 

concentration level. The ingestion of alcohol for up to eight hours following an accident by any 

employee involved in the accident, as noted in part 5.5 of this policy, is prohibited unless the 

employee has already performed a post accident alcohol test in accordance with this policy. 

4.0 TESTING PROCEDURES

A prohibited substance may be detected through a drug or an alcohol test following the safeguards 

set forth by the Department of Transportation in 49 CFR Part 40, as amended. These safeguards 

are mandated to assure protection, integrity, validity, and the accuracy of the results. Discussion of 

collection procedures follows in Section 4.1. 

Testing requirements call for urine tests for five drugs (Marijuana, PCP, Cocaine, Opiates, and 

Amphetamines) and breath tests for alcohol. This is subject to change consistent with alterations to 

49 CFR Part 40, as amended. A separate test sample may be required for other prohibited substances 

based on individualized suspicion. 

All testing will be conducted in a manner which assures a high degree of accuracy and reliability 

consistent with the Department of Transportation safeguards set forth in 49 CFR Part 40, as 

amended. Drug testing will be conducted in laboratories certified by the National Laboratory 

Certification Program as listed on the Substance Abuse and Mental Health Services Administration 

(SAMHSA), Department of Health and Human Services (HHS) notice located at 59 FR 39774 (see 

Appendix B for specific laboratory used by Metro). Collection may be observed if there is reason to 

believe that a particular individual may alter or substitute the specimen to be provided, as further 

described in 49 CFR part 40.25(e) (2) (i) – (iv). 

Evidential Breath Testing (EBT) devices will meet the Model Specifications for Devices to Measure 

Breath Alcohol provided by the National Highway Traffic Safety Administration (NHTSA). Such 

EBTs will be listed on the NHTSA Conforming Products List publication found at 59 FR 18839. 

4.1 Collection Process 

The individual reporting to the test site must have some form of photographic identification to show 

to collection site personnel. If requested, the collector must show identification. The individual will 

be asked to remove unnecessary outer garments, such as coats and jackets, and to empty his or her 

pockets and display the items in them. Purses and briefcases remain with the outer garments, 

though wallets may be retained. 

4.1.1 Drug Test Collection

The collector will have only one urine specimen collection under his/her supervision at one time. 

Unauthorized persons are not permitted in the designated collection area. The collection procedure 

is complete when the urine bottle has been sealed and initialed and the individual has departed the 

collection area or, in the case of an individual who cannot provide a complete specimen, the 

procedure is complete when the person has entered a waiting area. 

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The collector will be present during urine specimen collection. He or she will not observe the actual 

collection process (in cases where observation is not required). To the extent possible, a private 

stall will be provided for privacy reasons. Should use of a public restroom be required, no other 

persons will be permitted in the restroom, bluing agent will be placed in the commode if possible; a 

collector of the same gender will stay in the restroom but not in the stall of the restroom. 

The individual will be asked to wash and dry his/her hands. After this is done, person must stay in 

the presence of the collector. The collector gives the person a sealed specimen bottle/cup and 

directs him/her to the lavatory. Nothing may be taken into the lavatory except the specimen 

bottle/cup. The individual will be told not to flush the commode. 

When the specimen is returned, the collector inspects it for signs of adulteration and measures the 

specimen’s temperature within four minutes of when the specimen was provided. A temperature in

the range of 90 – 100 degrees F/32-38 degrees C is acceptable. If temperature is out of acceptable 

range, individual may have his/her oral temperature taken. This reading may provide evidence to 

counter the reason to believe the individual may have altered or substituted the specimen.

4.1.2 Urinalysis for Drugs

An initial screen will be conducted on each sample. If the initial screen is positive (as defined in 

Part III, Section 6), the sample will be tested again by a confirmatory Gas Chromatography/Mass 

Spectrometry (GC/MS) test. 

4.1.3 Split Sample

The collector then divides the specimen into a 30ml primary specimen and a 15 ml split specimen 

(split sample). “Specimen A” bottle seal is placed over the 30ml bottle and the “Specimen B” seal is 

placed over the split sample bottle. The individual initials both seals. If the sample also tests 

positive during the GC/MS, or is determined by the laboratory to be adulterated or 

substituted, and the MRO verifies the laboratory findings after review with the employee, 

the employee may request a test of the split-specimen. Such a request must be made in 

writing or verbally to the Medical Review Officer (MRO) within 72 hours of the time the 

MRO provides the notification to the employee that the test is verified positive, adulterated 

or substituted. The employee is not required to pay for the test from his or her own funds 

before the test takes place, but Metro will seek reimbursement for the cost of the test. 

The second laboratory is only required to run a confirmatory test for the specific substance which 

appeared in the primary sample. The results of this test must be immediately forwarded to the 

MRO. The MRO will notify the Metro and the employee of the result. If the split sample reveals 

no measurable presence of the drug in question, the former positive test will be canceled and the 

employee will be reimbursed for the split sample HHS laboratory test. 

4.1.3.1 Completion of Drug Test Collection Process. The individual is asked to read and sign a 

statement on the appropriate “Federal Drug Testing Custody & Control Form” (Appendix C). 

This certifies that the specimen identified as having been collected from him/her is in fact the 

specimen he/she provided. All sections of the form are completed by the donor and the collector 

and the donor is given a copy of this form. The donor’s participation is now complete. 

The sealed specimens are placed in a secured refrigerator until pickup by the lab courier. The 

specimens are further sealed in a plastic pouch for transport to the testing lab. 

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4.1.4 Role of the Medical Review Officer (MRO)

An MRO is required to verify positive test results and facilitate the split sample process. An MRO 

is defined by the FTA as a licensed physician responsible for receiving laboratory results generated 

by an employer’s drug testing program who has knowledge of substance abuse disorders. The 

MRO shall communicate all verified positive test results to the employee and to the Metro (see 

Appendix B for name and phone number of Metro’s MRO). Upon the written consent of the 

employee, results received at the Metro will be forwarded to the President of the Union. 

4.2 Alcohol Testing Process 

Alcohol testing is performed by a Breath Alcohol Technician (BAT). An evidential breath testing 

(EBT)) machine is used to collect and analyze breath samples for any alcohol content. Results are 

read immediately. A screening test is given first; if results are greater than 0.02, a confirmation test 

is performed. One individual will be tested at a time and the BAT shall not leave the testing area. 

The procedure is as follows: 

The BAT explains testing process and completes Step 1 on DOT Breath Alcohol Testing form 

(Appendix C). The individual completes Step 2 on form and signs the certification form. Note: 

Refusal to sign the certification is regarded as a refusal to take the test. The BAT opens an 

individually sealed mouthpiece in view of the person and attaches it to the EBT. The individual 

blows forcefully into the mouthpiece for at least six seconds or until the EBT gives the signal to 

stop. The BAT shows the results of the test. If results are less than 0.02, the BAT dates the testing 

form and signs the certification in Step 3. The individual signs and dates the form in Step 4. 

Testing is completed. Step 4 is completed by the employee only if the test result is 0.02 or higher. 

If results are 0.02 or greater, a confirmation test must be performed. Prior to conducting the 

confirmation test, a waiting period of at least 15 minutes and not more than 30 minutes is observed. 

The BAT instructs the individual not to eat, drink or put any object or substance in his/her mouth 

and, to the extent possible, not belch during the waiting period. However, the test will be conducted 

even if these instructions are disregarded. A new mouthpiece is used for the confirmation test. 

Before confirmation testing begins, the BAT ensures that the EBT registers 0.00, if it does not 

register 0.00, testing must be done on another approved instrument. After the confirmation test is 

completed the individual is shown the readout of the results. NOTE: If confirmation results are 

0.02 or greater, Metro is notified immediately. If the test result printed by the EBT does not match 

the displayed result or if a sequential test number printed by the EBT does not match the sequential 

test number displayed by the EBT prior to the confirmation test, the BAT shall note the disparity in 

the “Remarks” section of the testing form. Both the BAT and the individual shall initial and sign 

the notation. The test is considered invalid and the employee is so advised. 

4.3 Return to Work Pending Test Results 

An employee can return to work pending the drug test results under the following circumstances: Return 

to work physicals (when cause of leave is unrelated to drugs and/or alcohol and employee is not returning 

from inactive status), biennials, follow-up testing, and random testing. 

An employee must await his/her negative test clearance under the following circumstances: return 

to work after a drug-and-alcohol-related leave, reasonable suspicion, post-accident testing, preemployment and transfer to safety sensitive position or while an employee is in an inactive status. 

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NOTE: Employees are encouraged to schedule the return to work physical and screens in advance of the 

return date to avoid being in a non-pay status while awaiting clearance to return to work. 

5.0 CAUSES FOR TESTING

Testing for drugs and alcohol will be conducted in the following circumstances: 

5.1 Pre-Employment 

All applicants are required to undergo pre-employment drug testing following the offer of 

employment. Employees are required to undergo drug & alcohol testing prior to transfer into a 

safety-sensitive position. Applicant screens will be offered with the pre-employment physical 

examination. If a pre-employment drug test is canceled, the covered employee or applicant is required to 

take another pre-employment drug test with a verified negative result. 

5.2 Reasonable Suspicion 

All employees are required to submit to drug and alcohol testing when at least one supervisor, 

manager or other company official who is trained in detecting the signs and symptoms of drug use 

and alcohol misuse reasonably questions the employee’s fitness for duty. Reasonable suspicion will 

be based on specific, contemporaneous, articulable observations concerning the appearance, 

behavior, speech or body odors of the employee. 

5.3 Return to Work/Return to Duty 

Return to work drug and alcohol testing is required of all employees who have been absent for 30 days or 

more and are returning to hourly operations positions. A return to duty test is required when a safetysensitive employee or covered employee returns from a drug and/or alcohol treatment program as 

explained in Part V “Rehabilitation”, or when the employer is made aware of an employee’s 

treatment program. 

5.4 Follow-Up 

A safety-sensitive or covered employee who returns to duty after a substance-related leave or after 

an evaluation made by a substance abuse professional is subject to unannounced follow-up testing. 

The frequency and duration of such testing will be solely determined by the substance abuse 

professional, but Metro will determine the actual days for follow-up testing. The duration could extend 

up to 60 months with a minimum requirement of at least 6 tests within the first 12 month period. 

5.5 Post-Accident 

This policy covers any accident involving either a revenue service vehicle, or a non-revenue service 

vehicle when the operator holds a Commercial Driver’s License. 

5.5.1 Fatality

Post-accident testing is required after accidents involving a fatality. As soon as possible, each 

surviving employee operating the mass transit vehicle at the time of the accident shall be tested. 

An employee will also be tested if his or her performance could have contributed to the accident, as 

determined by a supervisor using the best information available at the time of the decision. 

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5.5.2 Bodily Injury or Property Damage

Post-accident testing is also required after an accident involving bodily injury requiring immediate 

medical attention away from the scene, or after an accident involving a vehicle which suffers 

disabling damage. 

Such testing is required of all employees operating a vehicle at the time of the accident. As in the 

case of fatal accidents, other employees may be tested if a supervisor concludes, based on the best 

information available at the time, that the employee’s performance could have contributed to the 

accident. 

5.5.3 Reasonable Suspicion

Post-accident testing is always required after any accident that meets an FTA post accident 

threshold, if the supervisor reasonably believes that a driver’s performance could have contributed 

to the accident. 

5.5.4 Other Requirements

For post-accident testing, a urine specimen for drug testing must be collected as soon as 

possible but no later than 32 hours after the accident. 

The alcohol test should be administered within two hours of the accident. If testing cannot be 

completed in two hours a report must be filed documenting why attempts were unsuccessful and 

attempts to collect must continue. If unable to obtain an alcohol test within 8 hours, attempts to 

collect must cease and the two hour written report is updated with an explanation as to the failure 

to collect. 

The results of a urine test for the use of prohibited drugs, or the results of a breath test for the 

misuse of alcohol, conducted by Federal, State or local officials having independent authority for 

the test, shall be considered to meet the requirements of this section, provided such tests conform to 

the applicable Federal, State or local testing requirements, and that the test results are obtained by 

the employer. Such test results may be used only when the employer is unable to perform a postaccident test within the required period noted in paragraphs (a) and (b) of Section 655.44.

Except for the case of a fatality when the operator must be tested, a supervisor may decide, using 

the best information available at the time, that testing is unnecessary only when an employee’s 

conduct can be completely discounted as a contributing factor to the accident. 

5.6 Random

Random testing for drugs and alcohol will be performed on all employees filling safety-sensitive 

positions as listed in Appendix A which is hereby made a part of this program. Such random 

testing will be conducted at a minimum annual rate of 10% of the safety-sensitive workforce for 

alcohol and 50% for drugs, or at the rates set forth by the FTA in Part 655, as amended. 

Employees will be selected based on a computer-based random number generator that is matched 

with an employee name and identification number.

Random test dates are spread reasonably throughout the year (January – December) and are 

unannounced. Employees selected for random drug and/or alcohol testing are notified by a 

supervisor and must proceed immediately to the testing site with the supervisor. 

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Employees are on the clock and will be compensated at their applicable rate for the time spent in

undergoing such random testing. 

Metro shall provide to the Union, if requested, its scientifically-validated method of random selection for 

comment. 

5.7 Biennial Physicals & Testing 

An employee is required to take a drug and an alcohol test as part of his/her biennial fitness-for-duty

examination (also referred to as the “biennial physical”). 

6.0 POSITIVE TEST

The Metro will be notified by the MRO of a verified positive drug test result. A verified positive 

test means a prohibited substance appearing in the employee’s urine specimen which surpasses the 

thresholds established by the Department of Health and Human Services (HHS) as adopted by the 

Department of Transportation (DOT) in 49 CFR PART 40, as amended. These thresholds are 

determined by medical experts to be evidence that an illegal substance is in an employee’s system 

(see Appendix D for threshold levels). 

The Metro will be notified by the medical provider of an alcohol confirmation test result of 0.02 or 

more. 

7.0 REFUSALS

An employee must follow the instruction and directions of all Metro supervisors and medical 

personnel involved in the testing process. A refusal means that an employee fails to provide a drug 

or alcohol testing sample as required by this policy without a valid medical explanation from a 

doctor chosen by the Metro, or engages in conduct that obstructs the testing process. 

Refusals include, but are not limited to, the following: refusal to take the test, inability to provide 

sufficient quantities of breath or urine to be tested without a valid medical explanation from a 

doctor acceptable to the Metro, tampering with or attempting to adulterate the specimen or 

collection procedure, not reporting to the collection site in the time allotted, refusal to sign the 

testing form, or leaving the scene of an accident without a valid reason as determined by Metro 

before the tests have been conducted. A refusal constitutes a violation of Metro’s policy. 

Verbal or written refusal to provide a required breath specimen or to sign the DOT required 

testing form constitutes a refusal and is a violation of Metro’s policy. 

8.0 EVALUATIONS, REFERRALS, AND REHABILITATION

An employee concerned about his/her substance or alcohol usage should immediately seek assistance. 

Part V and Appendix E of this program discuss available resources.

9.0 TRAINING

All safety-sensitive employees are required to attend at least 60 minutes of training on the effects of 

prohibited drug use and the affects of alcohol misuse. 

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All managers responsible for covered employees are required to attend one hour of training for 

reasonable cause determinations for alcohol and one hour of reasonable cause determination 

training for drugs. 

All employees attending such training will be required to sign an attendance sheet/certification form (see 

Appendix F).

10.0 SPECIMEN RETENTION

All negative urine specimens will be maintained by the laboratory for a period of one week. 

Positive specimens must be maintained by the laboratory in frozen storage for a period of one year 

(or longer if litigation is pending). 

11.0 RECORDS RETENTION

The laboratory, unless otherwise instructed by the employer in writing, will maintain all records 

pertaining to a given urine specimen for a minimum of two years. 

The MRO shall review or consider any medical information provided by the tested employee when 

a confirmed positive test could have resulted from legally prescribed medication. The medical 

information provided by the employee to the MRO as part of the testing verification may not be 

disclosed to any third party except in the case of a grievance, lawsuit or other proceeding initiated 

by or on behalf of the employee. 

The employer shall maintain records of its anti-drug program for a minimum period as follows: 

Five years: verified positive test results, documentations of refusals to test, covered employees 

referral to the Substance Abuse Professional (SAP) and copies of annual Management 

Information System (MIS) reports submitted to the FTA. 

Two years: records related to the collection process and employee training. 

One year: records of negative drug test results. 

Such records shall be kept in a secured area with controlled access. 

Records may be destroyed after 5 years at the discretion of the employer. 

12.0 CONFIDENTIALITY 

All test results are forwarded to the Personnel Manager in a sealed confidential envelope and will be kept 

confidential. In the case of positive drug or alcohol results, the MRO or BAT immediately notifies the 

Personnel Manager by phone so the employee may be immediately removed from performance of safetysensitive duties. Test result information may only be released to the Employer, the employee, and to the 

President of the Union upon the employee’s written consent. In a grievance, hearing, lawsuit or other 

action involving the employee, the employer may release relevant information to the decisionmaker, and to those who need to know the information to assist with the case. Such information 

may also be released to representatives from state or federal agencies when required. 

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13 CONTRACTORS

Contractor organizations with persons who provide FTA-defined safety-sensitive functions for the Metro 

(including volunteers) will adopt an anti-drug and alcohol policy which complies with 49 CFR Part 655 

and 40. No contractor employee who is in violation of this policy may work on Metro property or 

provide safety-sensitive services unless he or she has met return to work requirements (see Appendix G 

for contractor information). 

14. QUESTIONS

Questions regarding any provisions of this policy should be directed to the Personnel Manager in the 

Human Resources Department (see Appendix B for contact name and phone number). 

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PART IV 

CONSEQUENCES 

NOTE: Circumstances not covered by policy will be dealt with on a case-by-case basis using a 

“reasonableness” standard.

The penalty for any violation of the “Substance Abuse Policy” or “Drug-Free Workplace Act” is 

discipline up to and including termination depending on circumstances. Violations include, but are not 

limited to the following: 

1.0 Intoxication/Under the Influence

Reporting to work intoxicated/under the influence of alcohol or drugs (including all substances defined in 

the drug and alcohol testing policy on page 4) is absolutely forbidden. Any employee who reports to 

work intoxicated/under the influence will be terminated. An employee who is called into work

unexpectedly has a responsibility to inform his/her supervisor immediately if he/she is unfit for duty. 

Otherwise, he/she will be treated the same as any other regularly scheduled or on-call employee. 

2.0 Positive Test Result

Any employee who tests positive for drugs (as defined in Part III, Section 6.0) or has a breath alcohol 

concentration of 0.04 or more for alcohol at a biennial physical examination, return-to-work physical, 

post-accident test, reasonable suspicion test, random test, transfer to safety-sensitive position test or 

follow up testing will be terminated for the first offense. 

3.0 Alcohol Concentration from 0.02 up to 0.0399

An employee who is on the clock, is tested and has an alcohol concentration of 0.02-0.0399 will be 

immediately removed from service and subject to a disciplinary suspension up to and including 30 days

without pay (including sick pay). The employee will be required to sign a last chance agreement before 

returning to work. Repeat offenders will be discharged. 

4.0 Refusal

Any employee who refuses to take a test (as defined in Part III, Section 7.0 of this Drug and Alcohol 

Program in the “Refusals” section) will be terminated. Such a refusal constitutes a violation of Metro’s 

policy. 

5.0 Manufacture, Trafficking, Possession and Use

The use, sale, manufacture, distribution or possession of drugs or alcohol while on the job, on Metro 

property, in a Metro uniform or while conducting transit authority business will be subject to discipline 

up to and including discharge, depending upon circumstances. 

6.0 Criminal Drug Conviction at Workplace

Any employee who fails to notify the Metro of any criminal drug conviction or drug-related offense will 

be subject to discipline up to and including discharge, depending upon circumstances. This notification 

must be provided by the fifth day after such offense. Any employee convicted of such an offense will be 

subject to discipline up to and including discharge, depending upon circumstances. 

Appendix A. Example Policies (Cincinnati Metro) Page A-16
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FTA Drug and Alcohol Testing Program 

7.0 Violation of Last Chance Agreement

Any employee who violates any term of a last chance agreement will be subject to discipline up to and 

including discharge, depending upon circumstances. 

8.0 Alcohol Prohibited After Accident

Any safety sensitive employee required to take a post accident alcohol test is prohibited from 

alcohol use for eight hours following the accident or until the employee undergoes a post-accident 

alcohol test, whichever occurs first. 

Any employee who is subject to post accident testing yet fails to remain readily available for such 

testing (including notifying employer representative of his or her location if he or she leaves the 

scene of the accident prior to submission to such test) is deemed to have refused to submit to testing

and will be subject to discipline up to and including discharge, depending upon circumstances. 

9.0 Alcohol Prohibited Before Workshift

Safety-sensitive employees are prohibited from consuming alcohol up to four hours before their 

workshift. Any employee found consuming alcohol within four hours of his/her workshift will be 

subject to discipline up to and including discharge, depending upon circumstances. (This does not imply

that an employee’s system will be free of alcohol after four hours of cessation). 

10.0 Duty to Report

All Metro employees have a duty to report violations of this Program to the proper Metro officials. Any

employee who has actual knowledge of a violation by any other Metro employee must report such 

violation. Failure to report is grounds for discipline up to and including discharge, depending upon

circumstances. 

11.0 Prescription/Over-the-Counter

Before beginning a work shift, an employee must report to his or her supervisor the use of prescription or 

over-the-counter drugs and other substances as described on page 4 of this drug and alcohol testing 

policy. It is the employee’s responsibility to determine from the physician, practitioner, or pharmacist 

whether or not job performance would be impaired. A positive result whether illegal substances, illegal 

use of prescriptions, or misuse of prescriptions will result in discipline up to and including discharge, 

depending upon circumstances. 

NOTE: There may be circumstances which arise that are not specifically covered by the above 

categories, yet, the severity of the offense warrants severe consequences. In these situations, the standard 

of “reasonableness” will apply and management shall determine the consequences based on this standard. 

Appendix A. Example Policies (Cincinnati Metro) Page A-17
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FTA Drug and Alcohol Testing Program 

PART V 

REHABILITATION 

1.0 EMPLOYEE ASSISTANCE PROGRAM (EAP)

An Employee Assistance Program (EAP) is offered to Metro employees and their families at no cost to 

the employee. This program includes professionals qualified in the area of substance abuse evaluations 

and referrals.

The EAP offers counseling, evaluations, and referrals to rehabilitation programs. Counselors are 

available 24 hours a day (see Appendix B for EAP contact information). 

2.0 SUBSTANCE ABUSE PROFESSIONAL (SAP)

Any safety-sensitive employee who tests positive for the presence of illegal drugs above the minimum 

thresholds set forth in 49 CFR Part 40 (see Appendix D), as amended, or who tests above 0.04 on an 

alcohol confirmation test will be subject to discipline up to and including discharge, depending upon 

circumstances. Even though discharged, the employee will be given a list of local and national resources 

specializing in the treatment of substance and alcohol abuse. Not all agencies may be qualified or willing 

to perform the duties of a Substance Abuse Professional (SAP). A Substance Abuse Professional (SAP) 

is a licensed or certified physician, psychologist, social worker, employee assistance professional, or 

addiction counselor (certified by one of the agencies in Part 40.281(a)(5) with knowledge of and clinical 

experience in the diagnosis and treatment of drug and/or alcohol-related disorders. Assessment by a SAP 

does not shield an employee from termination. (see Appendix B for contact name and information of 

Metro’s SAP). 

3.0 REHABILITATION

An employee who voluntarily comes forward to Metro (prior to notification of a pending drug/alcohol 

test) and seeks professional rehabilitation services for a substance abuse problem, either through the EAP 

or other bona fide treatment program, will be eligible for and required to sign a last-chance agreement. 

Any employee who signs a last-chance agreement cannot return to work until he/she receives a written 

release from a Substance Abuse Professional stating he/she has properly followed the rehabilitation 

program prescribed by the Substance Abuse Professional. 

Under the last-chance agreement, the employee must complete a rehabilitation program and remain 

drug/alcohol-free thereafter. The employee will be required to sign a release of information form. 

Follow up testing will be required after the employee returns to work. During this time, the 

employee is still subject to random testing.

The Metro provides access to an Employee Assistance Program. All costs for rehabilitation services over 

and beyond Metro’s EAP program shall be in accordance with the employee’s benefit guidelines or at the 

employee’s own expense. 

Appendix A. Example Policies (Cincinnati Metro) Page A-18
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FTA Drug and Alcohol Testing Program 

4.0 CONFIDENTIALITY

Confidentiality of employees referred to the EAP will be maintained: 

1. Employees must sign a release of information form authorizing EAP personnel and any

involved treatment facility to advise Human Resources personnel on the progress of 

treatment. 

2. Employees going through a substance abuse or alcohol detoxification program will be 

required to submit written documentation from the EAP as to the successful completion of 

the program. 

Those who voluntarily seek treatment in an external treatment program outside the EAP must submit 

regular progress reports during treatment and a statement from the Substance Abuse Professional showing 

successful completion of the program. 

5.0 LITERATURE

Drug and alcohol substance abuse prevention literature is available at a number of different sources. 

Through the Metro, employees can receive substance abuse literature from the occupational nurse, the 

EAP, and Human Resources. Additionally, material will be made available at the drug and alcohol 

prevention training courses as they occur. 

Outside of the Metro, employees may access national or local hotlines and helplines, support group phone 

directories, treatment facilities, and many other resources for substance abuse information and guidance. 

Attached to this section is Appendix E which is a listing of agencies and telephone numbers available to 

Metro employees. 

Appendix A. Example Policies (Cincinnati Metro) Page A-19
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FTA Drug and Alcohol Testing Program 

APPENDIX A: SAFETY-SENSITIVE 

A. “Safety-Sensitive” as defined by FTA 49 CFR 655:

Safety-sensitive function means any of the following duties: 

(1) Operating a revenue service vehicle, including when not in revenue service;

(2) Operating a non-revenue service vehicle, when required to be operated by a holder 

of a Commercial Driver’s License (CDL); 

(3) Controlling dispatch or movement of a revenue service vehicle; 

(4) Maintaining a revenue service vehicle or equipment used in revenue service;

(5) Carrying a firearm for security purposes. 

B. Metro’s Safety-Sensitive Matrix 

Gen. Repairperson Claims Agent 

P.M. Gen. Repairperson Transportation Safety Specialist 

Repairperson/Spotter Industrial Safety Specialist 

Gen. Serviceperson Fare Systems Supervisor and Technician 

Serviceperson Supervisor of Scheduling and Control

Facilities service person Maintenance Support Services - Manager 

Gen. Facilities service person/Technician Garage Managers

Repairperson (major shops) Foremen 

Electrician Operators (FT & PT) 

Unit Rebuilders/Transmission Transit Traffic Controllers 

Rebuilders/Engine Board & Division Clerks 

Unit Rebuilders/Electric Government Square Supervisor 

Repairperson – SR/CR Government Square RCC Supervisor 

Unit Rebuilders Training Specialists 

Machinist/Repairperson Group Managers

Gen. Serviceperson (major shops) Sector Managers 

Repairperson/brakes/align Division Directors

Repairperson/AC Instructing Operators

Fuel Island Attendant Line Instructors 

Painter/Body Repairperson Sub Clerks 

Body Repairperson Sub Supervisors 

Body Repairperson/Trainee Sub Dispatchers 

Repairperson – CR 

Repairperson – Suspension 

Appendix A. Example Policies (Cincinnati Metro) Page A-20
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FTA Drug and Alcohol Testing Program 

APPENDIX B: CONTACT NAMES & NUMBERS 

Drug & Alcohol Program Manager

Janice G. Smith 

Personnel Manager 

1014 Vine Street, 19th Floor 

Cincinnati, Ohio 45202 

(513) 632-7558 or ext. 558 

Drug Testing Laboratory

Health Alliance Laboratory Services 

Toxicology Lab 

3200 Burnet Avenue 

Cincinnati, Ohio 45229 

(513) 585-6615 

Substance Abuse Professional (SAP)

Dr. George Parsons 

Associates for Psychological Services 

Madison Road 

Cincinnati, Ohio 45209 

(513) 351-3334 

Medical Review Officer (MRO)

Dr. Mary Jo Wakeman 

OCCNET Health Alliance 

3200 Burnet Avenue 

Cincinnati, Ohio 45229 

(513) 585-6488 

or 

Dr. Janet Cobb 

OCCNET Health Alliance 

2702 East Kemper Road 

Cincinnati, Ohio 45241 

(513) 771-223

 

Appendix A. Example Policies (Cincinnati Metro) Page A-21
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FTA Drug and Alcohol Testing Program 

APPENDIX C: FEDERAL TESTING FORMS 

1. Sample DOT Drug Testing form 

2. Sample Dot Breath Alcohol Testing form

APPENDIX D: DRUG SCREEN CUTOFF LEVELS 

 INITIAL CUTOFF LEVELS CONFIRMATON CUTOFF LEVELS 

Marijuana Metabolites 50 ng/ml Marijuana Metabolites 15 ng/ml 

Cocaine Metabolites 300 ng/ml Cocaine Metabolites 150 ng/ml 

Opiate Metabolites 2000 ng/ml Opiate Metabolites 2000 ng/ml 

Phencyclidine 25 ng/ml Phencyclidine 25 ng/ml 

Amphetamines 1000 ng/ml Amphetamines 500 ng/ml 

Employees should note that thresholds are subject to change due to DOT requirements. Effort will 

be made to keep employees abreast of changes, however, it is the employee’s responsibility to keep 

abreast of changes. Information regarding the thresholds may be obtained by reviewing the drug 

& alcohol regulations available at most public libraries or on the Internet at 

http://www.access.gpo.gov.

Appendix A. Example Policies (Cincinnati Metro) Page A-22
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APPENDIX E: SUPPORT GROUPS AND OTHER RESOURCES 

SUPPORT GROUPS AND OTHER RESOURCES

Alcoholics Anonymous 491-7181 Central Community Health Board 

 Drug Services 

Children’s Hospital

559-2056

559-4200

AA Northern Kentucky 491-7181 Chaney Allen Center 556-4300

AAA Cincinnati Automobile Club 762-3111 Charlie’s 3⁄4 House 784-1853

Adult Children of Alcoholics, Central Psychiatric Clinic 558-5823 

 AL-ANON, AL-ATTUNE 771-4070 Childrens Hospital 559-4200 

Alcoholism Council 281-7880 Christ Hospital Alcohol/Drug Center 369-1116 

Alcoholic Drop Inn Center 721-0643 Christ Hospital - Milestones

(Outpatient) 

421-7837

Alternatives (Talbert House residential 

 treatment for adolescents) 761-9117

Cincinnati Union Bethel (CUB) 

City Gospel Mission 

921-5838

241-

5525/5526 

Behavioral Counseling Services of 

Butler County Inc. 

829-2121 Clermont Recovery Center 732-1710 

Bethesda Alcohol & Drug Treatment 

Programs

489-6011 Comprehensive Care Center – Northern 

Kentucky Family Alcohol and Drug

Counseling Services 

(606)

431-2225

Bethesda Hospital 569-6014 Deaconess Recovery Center 861-6070 

Bethesda Hospital Tel-Med 569-6231 CCHB-Drug Abuse Rehabilitation

Enrichment Center 

559-2053

 Sample Tapes Available

 #942 Alcoholism 

Drug & Poison Information Center 

East Indiana Treatment Center 

558-5111

(812) 537-

1668

 #943 Is Drinking a Problem Eighth Street House 291-

8261/8262 

 #944 To Drink or Not to Drink Emerson North Hospital 541-0135 

 #945 So You Love An Alcoholic Family Services (Main Site) 381-6300

 #946 How AA Can Help the 

Problem Drinker 

Family Service of Northern Kentucky 291-1121 

 #136 Amphetamines and 

Barbiturates 

Gateway Behavioral Health Network 861-4283 

 #137 Marijuana Group Health Associates 872-2077

 #138 Narcotics Horizon Outpatient Program 

 Middletown

 Hamilton County 

1-424-1193

851-2202

Brown Co. Counseling Service 1-378-

4811

Ikron Institute 

 Industrial Counseling & Human 

Resources Rehabilitation Center 

621-1118

621-1117

Brown & Adams Co. 

Substance Abuse Center 

(Outpatient) 

1-378-

6068

Intervention East 

 (Seven Hills Neighborhood Services) 321-5329

Outpatient Care Unit Hospital 772-6969 Jewish Hospital (Adolescent Chemical 

Dependence Unit) 569-2015

Care Unit Hospital of Cincinnati 481-8822 Kenwood Psychological Services 984-3099

Center for Chemical Addictions 

Treatment (CCAT) 

381-6672 Kids Helping Kids 575-7300

Center for Comprehensive Alcohol 

Treatment (CCAT) 

381-6660 LifeWay Counseling Centers, Inc. 769-4600 

Margaret Mary Hospital (Batesville, IN) (812) 934-

6630

Appendix A. Example Policies (Cincinnati Metro) Page A-23
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FTA Drug and Alcohol Testing Program 

Mental Health Services 

 East

 West

 North central 

 Northwest

321-8286

471-6000

761-6222

541-7577

NATIONAL HOTLINES AND HELP 

LINES 

800 Cocaine 

The American Council on Alcoholism 

 Helpline 

The National Council on Alcoholism 

 And Drug Dependency Helpline 

1-800-

COCAI

NE 

1-800-

527-5344

1-800-

NCACALL 

Norcen Behavioral Health Systems 761-6222 The National Institute on Drug Abuse 

Hotline 

1-800-

662-

HELP 

Northland Intervention Center 771-9112 Alcoholics Anonymous (A.A.) 212-686-

1100

Prospect House 921-1613 Narcotics Anonymous (N.A.) 818-780-

3951

Price Hill Clinic – LIFT 352-2538 Al-Anon 213-547-

5800

Reading Youth Service Bureau 733-

5623/4122 

Salvation Army 762-5600

Sojourner Home 868-7654 

St. Elizabeth Medical Center Behavioral 

Health Center

578-5900

St. Elizabeth North Adolescent & Adult 292-

4148/4150 

St. Luke Alcohol & Drug Treatment 

Center 

572-3500

Substance Abusing Mentally Ill (SAMI) 281-6071 

Talbert House 751-7747

Teen Challenge 221-2344 

Three Quarter House (Transitions) 491-4435 

Tough Love 232-0248 

Triple Outreach 

 (Archdiocese of Cincinnati) 421-3131

University Hospital 

 Psychiatric Emergency Service 

558-1000

558-8577

Urban Appalachian Council 251-0202 

Urban Minority Alcohol and Drug Abuse

Outreach 

 Program (UMADAOP) 

421-6005

V.A. Medical Center 861-3100 

V.A. Drug & Alcohol Programs 559-

5025/5027 

Volunteers of America 381-1954 

West End Health Center 621-2726 

Youth Counseling Program

 (Alcoholism Council) 281-7880

Appendix A. Example Policies (Cincinnati Metro) Page A-24
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FTA Drug and Alcohol Testing Program 

APPENDIX F: TRAINING CERTIFICATION FORMS 

1. Certification/sign in sheet for covered employees 

2. Certification/sign in sheet for supervisory employees 

APPENDIX G: CONTRACTOR INFORMATION 

1. First Group 

Dennis Daugherty, Program Manager 

1801 Transpark Drive 

Cincinnati, Ohio 45229 

(513) 531-6888 

2. Firestone Mileage Sales Division 

Anastasia Dreighton 

Human Resouce Representative 

17051 IH 35 North 

Schertz, TX 78154 

(210) 651-0214 

Appendix A. Example Policies (Cincinnati Metro) Page A-25

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FTA Drug and Alcohol Testing Program 

2. Long Beach Transit Authority (California) 

TABLE OF CONTENTS

Illegal Drug Policy 

 1. Statement of Policy

 2. Application of Policy

 3. Definition of Illegal Drugs 

 4. Use of an Illegal Drug(s) by an Employee is Prohibited and will Result in Termination 

 5. Testing of Illegal Drugs 

 6. Refusal to be Tested 

 7. Positive Tests 

 8. Disclosure of a Drug Problem 

 9. Prescriptions 

10. Possession of Drugs 

11. Application of FTA Drug Policy

Drug Policy Required by the Federal Transit Administration (FTA) 

12. FTA Policy

13. Application of Policy

14. Definition of Safety-Sensitive Employees

15. Testing of Safety-Sensitive Employees 

16. Termination 

Alcohol Policy of Long Beach Transit or as Required by FTA 

17. Use of Alcohol 

18. Testing 

19. Testing Results 

20. Refusal to be Tested for Alcohol 

21. Possession of Alcohol 

22. Alcohol Consumption 

Long Beach Transit/FTA Drug and Alcohol Program Guidelines

 I. Introduction 

 II. Contact Person 

 III. Affected Employees 

 IV. Definitions 

 V. Employee Education and Training 

VI. Responsibilities 

A. Employer 

B. Employee 

Appendix A. Example Policies (Long Beach Transit) Page A-27
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FTA Drug and Alcohol Testing Program 

C. Managers and Supervisors 

D. Union 

VII. Enforcement 

A. Consequences for Policy Violation 

1. Alcohol 

2. Illegal Drugs 

3. Refusal to be Tested 

B. Disputes 

VIII. Circumstances Requiring Testing 

A. Pre-Employment Testing 

B. Reasonable Suspicion Testing 

C. Post Accident Testing 

1. Definition of Accident 

2. Fatal Accident 

3. Non-Fatal Accident 

4. Testing Guidelines 

D. Random Testing 

1. Requirement for Random Testing 

2. Methodology for Random Testing 

E. Return-to-Duty and Follow-up Testing 

 IX. Drug Testing Procedures 

A. Drug Test Methodology

1. Initial Test 

2. Confirmation Test 

B. Applicant/Employee Drug Testing Requirements 

C. Observed Drug Collections 

D. Drug Testing Split Sample 

 X. Alcohol Testing 

A. Alcohol Testing Methodology

B. Breath Alcohol Technician 

C. Applicant/Employee Responsibilities 

D. Incomplete Tests 

 XI. Medical Review Officer 

XII. Substance Abuse Professional (SAP) 

XIII. Rehabilitation 

XIV. Confidentiality

 XV. Effective Date 

Attachment 1 Drug and Alcohol Abuse Information Helplines 

Attachment 2 Health and Safety Issues Related to Drug Abuse and Alcohol Misuse 

Attachment 3 List of Safety-Sensitive Employees 

Attachment 4 Minimum Thresholds 

Appendix A. Example Policies (Long Beach Transit) Page A-28

Attachment 5 List of Contacts 
Best Practices 

FTA Drug and Alcohol Testing Program 

Long Beach Transit Drug and Alcohol Policy

Bold = FTA requirements 

Italics = Drug-Free Workplace Act of 1988 requirements

As an essential element of its commitment to provide safe and reliable transit service and to 

maintain a safe and healthy work environment for its employees, Long Beach Transit has had a 

drug and alcohol policy in force for a number of years, which has been strictly enforced. 

The Federal Transit Administration (FTA) requires all transit systems to adopt a drug and alcohol 

policy that is almost identical with the existing policy of Long Beach Transit (the Company). While 

the policy of the Company applies to all employees, the FTA drug policy applies only to “safetysensitive employees.” It also gives additional grounds for the Company to test safety-sensitive 

employees. A list of safety-sensitive employees is included in Attachment 3. 

Therefore, the existing drug and alcohol policy of the Company, as supplemented by the drug 

and alcohol program requirements of the FTA, is hereby adopted and confirmed as the Drug 

and Alcohol Policy of Long Beach Transit. 

Illegal Drug Policy

The drug policy of the Company shall be as follows: 

1. Statement of Policy

The use of illegal drugs is prohibited.

2. Application of Policy

This policy applies to all employees of Long Beach Transit. 

3. Definition of Illegal Drugs

An “illegal drug” is any drug which is not legally obtainable, or which is legally obtainable but 

has not been legally obtained, or is not being used for its prescribed purposes. 

No person should interpret any document, handbook, rule, statute, or regulation to be in 

conflict with the definition of illegal drugs or the meaning of the term "use" of drugs. 

4. The Use of an Illegal Drug(s) by an Employee is Prohibited and will Result in 

Termination

The use of any illegal drug or substance identified in Schedules I through V of Section 202 

of the Controlled Substance Act (21 U.S.C. 812), as further defined by 21 CFR 1300.11 

through 1300.15 is prohibited at all times unless a legal prescription has been written for the 

substance. This includes, but is not limited to, marijuana, amphetamines, opiates, 

phencyclidine (PCP), and cocaine, as well as any substance which causes the presence of 

these drugs or drug metabolites such as hemp-related products, coca leaves or any 

substance not approved for medical use by the U.S. Drug Enforcement Administration or the 

U.S. Food and Drug Administration. Illegal use includes use of any illegal drug, misuse of 

legally prescribed drugs, and use of illegally obtained prescription drugs. 

Appendix A. Example Policies (Long Beach Transit) Page A-29
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FTA Drug and Alcohol Testing Program 

The "use" of drugs means presence in the body system while you are on duty. A positive 

test is sufficient to support a finding of "use." 

5. Testing for Illegal Drugs

When an employee does an unusual act, or has unusual behavior, which may suggest drug 

use, or has been off duty for an extended period of time, or has an attendance problem, or 

has an on-the-job injury, which requires medical attention, the employee will be tested. 

Applicants for employment will be tested before they are hired. All employees required to 

have a Commercial Driver’s License (CDL) will also be tested whenever they undergo a 

physical examination for a Department of Motor Vehicles medical certificate. 

6. Refusal to be Tested

A refusal to be tested will result in termination. 

7. Positive Tests

If the initial drug screen is positive, a confirmation test of the urine sample will be conducted 

by an HHS-certified laboratory selected by Long Beach Transit. If the laboratory confirms 

the positive test, the employee will be terminated. It is not necessary that the employee be 

under the influence of the drug(s). 

8. Disclosure of a Drug Problem

If an employee has a drug problem and voluntarily discloses it to the Company before a 

disciplinary matter develops and before being selected for testing, the Company will refer 

the employee to a substance abuse or chemical dependency program. 

9. Prescriptions

When given a prescription by a physician, an employee must consult with his or her 

physician to make certain that the medicine will not affect the employee’s ability to perform 

his or her duties and will not result in illegal drugs being in the body’s system. When taking 

any prescribed medication that could affect the employee's job performance, the employee 

must notify the Company in advance. 

10. Possession of Drugs 

 

Consistent with the Drug-free Workplace Act of 1988, all employees are prohibited from

engaging in the unlawful manufacture, distribution, dispensing, possession, or use of 

prohibited substances in the work place including Company premises, Company vehicles, 

while in uniform, or while on Company business. 

In addition, all employees are required to notify the Drug and Alcohol Program Manager in 

the Human Resources Department of any criminal drug statute conviction for a violation 

occurring in the workplace within five days after such conviction. 

Appendix A. Example Policies (Long Beach Transit) Page A-30

Within 10 calendar days of receiving notice that an employee has been convicted of a 

criminal drug offense occurring in the workplace, the Company must provide written notice 

of the conviction to the FTA. 
Best Practices 

FTA Drug and Alcohol Testing Program 

Violations of these provisions will result in termination. 

11. Application of FTA Drug Policy

The foregoing policy shall be in addition to the policy required by the FTA. 

Drug Policy Required by the Federal Transit Administration (FTA) 

12. FTA Policy

 

In addition to each of the foregoing provisions, Long Beach Transit shall also have the 

following drug policy required by the FTA which shall be applicable only to safetysensitive employees. 

13. Application of Policy

This policy shall apply to all employees who perform or are called upon to perform or 

may be called upon to perform a safety-sensitive function. Such employees shall be 

referred to as “safety-sensitive employees.” 

14. Definition of Safety-Sensitive Employees

A safety-sensitive employee is any employee whose duties relate to the safe 

operation of transportation services including: (a) operating a revenue vehicle, 

whether or not the vehicle is in service, (b) operating a non-revenue service vehicle, 

when required to be operated by a holder of a Commercial Driver's License (CDL); (c) 

controlling the dispatch or movement of a revenue service vehicle, (d) maintaining 

(including repairs, overhaul and rebuilding) a revenue service vehicle or equipment 

used in revenue service, (e) armed security personnel, or (f) supervisors who perform 

safety-sensitive duties. 

15. Testing of Safety-Sensitive Employees

A safety-sensitive employee shall be tested for drugs as follows: (a) before an 

applicant or a non-safety-sensitive employee is allowed to per-form a safety-sensitive 

function for the first time; (b) after an accident; (c) when there is reasonable 

suspicion to believe a test is necessary; (e) on a random unannounced basis; and (f) 

for return-to-duty and follow-up purposes. 

Safety-sensitive employees will be tested for marijuana, amphetamines, opiates, 

phencyclidine (PCP), and cocaine, as well as any substance which causes the 

presence of these drugs or drug metabolites, such as hemp-related products, coca 

leaves or any substance not approved for medical use by the U.S. Drug Enforcement 

Administration or the U.S. Food and Drug Administration. Illegal use includes the use 

of any illegal drug, misuse of legal prescribed drugs, and use of illegally obtained 

prescription drugs in accordance with DOT and FTA regulations. 

16. Termination

A verified positive urine test shall result in termination. A refusal to be tested shall result in 

termination. 

Appendix A. Example Policies (Long Beach Transit) Page A-31
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FTA Drug and Alcohol Testing Program 

Alcohol Policy of Long Beach Transit or as Required by FTA 

17. Use of Alcohol

The use of alcohol by any safety-sensitive employee, as defined in Sections 14 and 15 

relating to drugs, is prohibited and will result in termination. The “use” of alcohol by a 

safety-sensitive employee is defined as having an alcohol test result of 0.04 or greater 

while on duty, subject to duty, or just after performing a safety-sensitive function, as 

confirmed by an evidential breath testing device. 

18. Testing

The provisions of Section 5 and 15 relating to testing for drugs shall also apply to testing for 

alcohol. 

19. Testing Results

Performing safety-sensitive duties with an alcohol concentration of 0.02 or greater is 

prohibited. A test result of less than 0.02, as evidenced by a breath-testing device 

shall be considered a “negative” test. 

If the alcohol concentration is 0.02 or greater, as evidenced by a breath-testing 

device, a confirmation test will be performed. A confirmation test result equal to or 

greater than 0.02 but less than 0.04 will result in immediate removal of the employee 

from safety-sensitive functions for a period of eight hours or until a later re-test 

shows a concentration of less than 0.02. 

A confirmed alcohol test of 0.04 or greater is a "positive test." A positive test will result 

in termination. 

20. Refusal to be Tested for Alcohol

A refusal to be tested for alcohol will result in termination. 

21. Possession of Alcohol

Consistent with the Drug-Free Workplace Act of 1988, the possession, purchase, sale, 

distribution, or consumption of alcohol while on duty, or while on Company premises, in a 

Company uniform, or in a Company vehicle is prohibited. 

A violation of this provision will result in termination. 

22. Alcohol Consumption

The Company prohibits the consumption of alcohol by an employee within eight hours 

before reporting for duty. Any safety-sensitive employee involved in an accident must 

refrain from alcohol consumption for eight hours following the accident or until a 

post-accident alcohol test can be administered. 

Appendix A. Example Policies (Long Beach Transit) Page A-32
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FTA Drug and Alcohol Testing Program 

Long Beach Transit/ 

FTA Drug and Alcohol Program Guidelines 

I. Introduction

At Long Beach Transit, the safety of employees and customers is our number one priority. Both 

employees and customers have a right to expect a drug- and alcohol-free workplace. In 1991, 

the United States Congress passed the Omnibus Transportation Employee Testing Act, which 

requires drug and alcohol testing of safety-sensitive employees in the mass transit industry. In 

February 1994, the Department of Transportation published rules requiring agencies such as 

Long Beach Transit to implement specific drug and alcohol testing programs beginning January 

1, 1995. 

In response to these Federal requirements, and as a means of continuing our 

commitment to maintaining a safe and productive work environment, Long Beach Transit 

has revised its policies regarding drugs and alcohol to be in compliance with the Federal 

Transit Administration (FTA) rules on the Prevention of Prohibited Drug Use and Alcohol 

Misuse (49 CFR Part 655), and Procedures for Transportation Workplace Drug and 

Alcohol Testing Programs (49 CFR Part 40), as amended. 

It is the goal of Long Beach Transit and the Amalgamated Transit Union Local 1589 to establish 

a work environment that is free of drugs and alcohol, and to foster a sober and drug-free work 

force. To achieve the drug-free environment that every transit rider, community member, and 

employee of Long Beach Transit is entitled to will require the best efforts of employees, 

management, and union leadership. 

The following Guidelines have been developed as a help in administering Long Beach Transit's 

Drug and Alcohol Policy. As guidelines, they are not intended to be all-inclusive, nor are they 

intended to be used as hard fast rules regarding the application of the Company’s Drug and 

Alcohol Policy in any particular case. Cases where substance abuse is at issue may be 

evaluated on the circumstances of that case and the Drug and Alcohol Policy applied as 

warranted by those circumstances. However, in those situations governed by regulations 

promulgated under federal authority, such as the U.S. Department of Transportation, Federal 

Transit Administration, or as required by state or local law, the applicable law will govern. 

II. Contact Person

Questions regarding the Drug and Alcohol Policy or these guidelines should be referred to the 

Manager of Human Resources at (562) 591-8753. 

III. Affected Employees

All Long Beach Transit employees are subject to the Drug and Alcohol Policy, including drug 

and alcohol testing. The only exceptions are the random testing and certain alcohol

provisions which apply only to safety-sensitive employees. 

IV. Definitions

For purposes of these Guidelines, the following definitions of terms apply. The definitions are 

written for explanatory purposes to help in working with this document. 

Appendix A. Example Policies (Long Beach Transit) Page A-33
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Adulterated Specimen - A specimen that contains a substance that is not expected to be 

present in human urine, or contains a substance expected to be present but at a concentration 

so high that it is not consistent with human urine. 

Alcohol Concentration - is expressed in terms of grams of alcohol per 210 liters of breath as 

measured by an evidential breath testing device. 

Alcohol Use - The consumption of any beverage, mixture, or preparation, including medication, 

containing alcohol. 

Canceled Test - a drug test that has been declared invalid by a Medical Review Officer. A 

canceled test is neither positive nor negative. 

Chain of Custody - Procedures to account for the integrity of each urine specimen by tracking its 

handling and storage from point of specimen collection to final disposition. 

Confirmation Test - In drug testing, a second analytical procedure to identify the presence of a 

specific drug or metabolite. In alcohol testing, a second test that provides quantitative data of 

alcohol concentration. 

Dilute Specimen - A specimen with creatinine and specific gravity values that are lower than 

expected for human urine. 

Employee Assistance Program (EAP) - A program provided by Long Beach Transit through 

Managed Health Network to assist employees and their families in dealing with drug or alcohol 

dependency and other personal problems. Assistance may be obtained confidentially by calling 

(800) 227-1060, 24 hours a day, seven days a week. 

EBT - Evidential Breath Testing device used to measure breath alcohol concentration. 

EMIT - An immunoassay test used as the initial drug screening technique to eliminate “negative” 

urine specimens from further testing. 

FTA - Federal Transit Administration; an agency of the United States Department of 

Transportation. 

GC/MS - A drug testing technique called the gas chromatography/mass spectrometry; used to 

confirm the presence of a specific drug or metabolite in the specimen. 

Illegal Drugs - Any drug which is not legally obtainable, or which is legally obtainable but has not 

been legally obtained, or is not being used for its prescribed purpose or in the prescribed 

manner (this includes prescription drugs prescribed to someone else). 

Invalid Test - The result of a drug test for a urine specimen that contains an unidentified 

adulterant or an unidentified substance, has the physical characteristics of or has an 

endogenous substance at abnormal concentration that prevents the laboratory from completing 

or obtaining a valid drug test result. 

Legal Drugs - Legally obtained drugs (prescription and non-prescription remedies) used 

according to directions to alleviate a specific condition. 

Appendix A. Example Policies (Long Beach Transit) Page A-34
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FTA Drug and Alcohol Testing Program 

MRO (Medical Review Officer) - A licensed physician with knowledge of substance abuse 

disorders who is responsible for receiving laboratory results from drug tests; responsible for 

interpreting and evaluating an individual’s confirmed positive test results together with his or her

medical history and any other relevant biomedical information. 

Metabolite - The specific substance produced when the human body metabolizes a given 

prohibited drug as it passes through the body and is excreted in urine. 

Non-negative Test - A test result found to be adulterated, substitute, invalid, or positive for 

drug/drug metabolites. Non-negative results are considered a positive test or refusal to test if 

the MRO cannot determine legitimate medical explanation. 

Positive Alcohol Test -The confirmed presence of alcohol in the body system at a concentration 

of 0.04 or greater as measured by an Evidential Breath Testing (EBT) device. Refusal to take a 

breath test without a valid medical explanation also constitutes a positive alcohol test. 

Positive Drug Test - A confirmed test that shows the presence in the body system above the 

prescribed cut-off levels of a prohibited substance as verified by the MRO. A refusal to take a 

drug test without a valid medical explanation also constitutes a positive drug test. 

Safety-Sensitive Employee - A safety-sensitive employee is any employee whose duties relate 

to the safe operation of transportation services including: (a) operating a revenue vehicle, 

whether or not the vehicle is in service, (b) operating a non-revenue service vehicle, when 

required to be operated by a holder of a Commercial Driver's License (CDL); (c) controlling the 

dispatch or movement of a revenue service vehicle, (d) maintaining (including repairs, overhaul 

and rebuilding) a revenue service vehicle or equipment used in revenue service, (e) armed 

security personnel, or (f) supervisors who perform safety-sensitive duties. 

SAP (Substance Abuse Professional) - A licensed physician or a licensed and certified 

psychologist, social worker, employee assistance professional, or addiction counselor with 

knowledge of and clinical experience in the diagnosis and treatment of drug- and alcohol-related 

disorders. 

Screening Test - Initial test. In drug testing, an immuno-assay screen to eliminate “negative” 

urine specimens from further analysis. In alcohol testing, an analytical procedure to determine 

whether an employee may have a prohibited concentration of alcohol in a breath specimen. 

Substituted specimen - A specimen with creatinine and specific gravity values that are so 

diminished that they are not consistent with human urine. 

Use - Presence of a prohibited substance in the body. 

Validity Testing - The evaluation of the specimen to determine if it is consistent with normal 

human urine. The purpose of validity testing is to determine whether certain adulterants or 

foreign substances were added to the urine, if the urine was diluted, or if the specimen was 

substituted. 

Appendix A. Example Policies (Long Beach Transit) Page A-35
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FTA Drug and Alcohol Testing Program 

V. Employee Education and Training

Long Beach Transit believes that education and training of all employees in the effects and 

treatment of substance abuse will contribute to a safer and more efficient workplace for 

everyone. Therefore, educating and informing employees about the dangers of drug abuse or 

alcohol misuse and the possible penalties for violation of the Drug and Alcohol Policy are 

essential components of our program. 

Safety–sensitive employees are required to undergo at least 60 minutes of training on the 

effects and consequences of drug use. All supervisors making reasonable suspicion 

determinations shall undergo 60 minutes of training in the detection of probable drug 

use and 60 minutes of training on alcohol misuse. 

VI. Responsibilities

A. Employer

Long Beach Transit is responsible for developing and implementing substance abuse 

policies and programs that include drug and alcohol testing of employees and applicants 

for employment. The goals of these activities are to enhance productivity and safety for 

our employees and our customers, and to foster a sober and drug-free workforce. 

B. Employee

Employees at all levels are responsible for reading, understanding, and adhering to the 

Long Beach Transit Drug and Alcohol Policy. This policy will be made available to all 

employees and the ATU, Local 1589. 

C. Managers and Supervisors

Managers and supervisors will be held accountable for the consistent application and 

enforcement of the policy.

D. Union

Members of ATU, Local 1589, may have a Union representative present during any

meeting related to a job action as a result of suspected or confirmed substance abuse 

policy violations. 

VII. Enforcement

For any program to be effective, enforcement of policies is essential. Long Beach Transit will 

rigorously enforce its Drug and Alcohol Policy in order to protect the safety of our employees 

and customers, as well as to protect the efficiency of our operation. 

It is the responsibility of all employees to ensure that the standards of performance contained in 

the Drug and Alcohol Policy are met. Violations of the policy will result in removal from 

safety-sensitive duty and discipline up to and including discharge. 

Appendix A. Example Policies (Long Beach Transit) Page A-36
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FTA Drug and Alcohol Testing Program 

A. Consequences for Policy Violation

1. Alcohol 

Alcohol testing will be done by a National Highway Traffic Safety Administration (NHTSA) 

approved Evidential Breath Testing Device (EBT), which measures Breath Alcohol 

Concentration. 

 

If a safety-sensitive employee’s test result is equal to or greater than 0.02 but less than 

0.04, the employee will immediately be removed from performing safety-sensitive duties 

for at least eight (8) hours or until another breath test is administered, and the result is 

less than 0.02. 

Any safety-sensitive employee who has a test result equal to or greater than 0.02 but less than 

0.04 on more than one occasion may be subject to discipline up to and including discharge. 

Employees will receive no pay for time lost as a result of a test result of 0.02 or greater. 

If a safety-sensitive employee’s confirmed alcohol test result is equal to or greater than

0.04, the employee will be removed from duty, and will be subject to discharge. 

2. llegal Drugs

 

The presence of illegal drugs, as defined in the Policy section and Section IV of the guidelines, 

in the body system, while an employee is on duty is prohibited. 

A positive urine test as defined by the current cut-off limits (see Attachment 4) is 

sufficient to support a finding of “use” for safety-sensitive employees for the following 

substances: 

• Marijuana and metabolites 

• Cocaine and metabolites 

• Amphetamines and metabolites 

• Opiates 

• PCP (phencyclidine) 

 If test results are verified positive, the employee will be terminated. A positive dilute test result 

will be considered a positive test. 

3. Refusal to be Tested

If an employee refuses to be tested, he or she will be subject to termination. 

The following actions constitute a refusal to be tested by a safety-sensitive employee: 

• Failure to appear for any test within a reasonable time, as determined by the 

Company, after being directed to do so by the Company. 

• Failure to remain at the testing site until the testing process is complete; 

• Failure to provide a urine or breath specimen for any drug or alcohol test required 

by DOT or FTA regulations; 

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FTA Drug and Alcohol Testing Program 

• In the case of a directly observed or monitored collection in a drug test, failure to 

permit the observation or monitoring of your provision of a specimen; 

• Failure to provide a sufficient amount of urine or breath when directed, and it has 

been determined, through a required medical evaluation, that there was no 

adequate medical explanation for the failure; 

• Failure or decline to take a second test the Company or collector has directed 

you to take; 

• Failure to undergo a medical examination or evaluation, as directed by the MRO 

as part of the verification process, or as directed by Long Beach Transit as part of 

the "shy bladder'' procedures; or 

• Failure to cooperate with any part of the testing process (e.g., refusal to empty

pockets when so directed by the collector, behaving in a con-frontational way that 

disrupts the collection process) or verbal or written refusal to provide a required 

urine specimen. 

• Failure to refrain from consuming alcohol within eight (8) hours following 

involvement in an accident without first having submitted to post 

accident/drug/alcohol tests. 

• Failure to remain at the scene of an accident prior to submission to drug/alcohol 

tests without a legitimate explanation. 

• Providing false information in connection with a drug test, or if verified to have 

falsified test results through adulteration, or substitution of a urine specimen. 

• Failure or refusal to sign Step 2 of the Alcohol Testing Form. 

B. Disputes

Long Beach Transit and Amalgamated Transit Union 1589 will work cooperatively to resolve 

issues relating to the application, and enforcement of the Drug and Alcohol Policy. Nothing in 

this program shall be interpreted so as to limit Long Beach Transit’s right to assess disciplinary 

action, including termination, under the terms of the policy. 

VIII. Circumstances Requiring Testing

A. Pre-Employment Testing

Drug and alcohol tests will be performed as part of the medical examination of all selected 

applicants. In order to be hired, an individual must pass drug and alcohol tests with a negative 

test result. Individuals who apply for positions at Long Beach Transit will be notified of this 

requirement at the time of application. 

All applicants for safety-sensitive positions shall undergo urine drug testing and breath 

alcohol testing prior to hire or transfer into a safety-sensitive position. 

All offers of employment for safety-sensitive positions shall be extended conditional 

upon the applicant passing a drug test and alcohol test. An applicant shall not be hired 

into a safety-sensitive position unless the applicant takes a drug test with verified 

negative results, and an alcohol concentration below 0.02. 

Appendix A. Example Policies (Long Beach Transit) Page A-38
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FTA Drug and Alcohol Testing Program 

 A non-safety-sensitive employee shall not be placed, transferred or promoted into a 

covered position unless the employee takes a drug test with verified negative results and 

an alcohol concentration below 0.02. 

. 

If an applicant fails a pre-employment drug or alcohol test, the conditional offer of 

employment shall be rescinded 

If an employee being placed, transferred, or promoted from a non-safety-sensitive 

position to a safety-sensitive position fails to pass a drug and/or alcohol test, they shall be 

subject to disciplinary action. (Refer to Section VII, Enforcement). 

 

If a test is cancelled, the applicant/employee will be required to re-test with a negative 

test result. A negative dilute test result on a pre-employment test will require a re-test. 

 

Applicants are required to report the name and contact information for all DOT covered 

employers for the previous two years. The applicant is required to provide a consent 

statement permitting the previous DOT covered employers to release drug and alcohol 

test results to the Company. Failure to provide information or provision of inaccurate or 

misleading information will result in immediate termination and/or rescission of employment 

offer. The outcome of the investigation may also result in termination and/or rescission of 

employment. 

If more than 90 days have elapsed between the time of successfully completing preemployment tests and the assignment of safety-sensitive duties, another preemployment test will be required prior to the individual being assigned safety-sensitive 

duties. 

 Safety-sensitive employees who have been off duty for 90 days or more for any reason, 

and have been out of the random pool, must successfully pass a pre-employment drug 

test prior to the performance of a safety-sensitive function. 

B. Reasonable Suspicion Testing

Employees are subject to reasonable suspicion testing. Reasonable suspicion testing is 

designed to provide a tool to identify employees who may pose a danger to themselves and 

others in the performance of their job duties. 

 

Employees may be at work in a condition that raises concern regarding their safety or 

productivity. A supervisor must then make a decision as to whether reasonable suspicion exists 

to conclude that substance abuse may be causing the behavior. 

A safety-sensitive employee may be required to submit to a drug and/or alcohol test, 

when a trained supervisor or manager reasonably suspects the employee has used a 

prohibited drug or has misused alcohol. The request to undergo a reasonable suspicion 

test will be based on specific, contemporaneous, articulable observations concerning the 

appearance, behavior, speech, or body odor of the employee. 

Appendix A. Example Policies (Long Beach Transit) Page A-39
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FTA Drug and Alcohol Testing Program 

Examples of reasonable suspicion include but are not limited to: 

• Physical symptoms consistent with alcohol or drug abuse. 

• Evidence of illegal alcohol or drug use, possession, sale, or delivery. 

• Altercations (either physical or verbal) with others, or erratic or violent behavior. 

• Other unusual acts or unusual behavior that may suggest drug or alcohol use. 

C. Post-Accident Testing

1. Definition of Accident 

Testing for prohibited drugs and alcohol will be conducted in the case of certain mass 

transit accidents. An accident as defined by the FTA is an occurrence associated with 

the operation of a vehicle in which: 

• An individual dies, or 

• An individual receives injuries requiring immediate transport to a medical 

treatment facility, or 

• Any time one or more vehicles receive disabling damage. “Disabling damage” 

does not include damage to headlights, taillights, turn signals, horn, windshield 

wipers, and tires or other damage that could be remedied temporarily at the scene 

of the occurrence if special tools or parts were available.

This definition is not directed at vehicle collisions exclusively; it also includes incidents 

such as passenger or pedestrian injuries when the individual requires immediate 

transport to a medical treatment facility.

Testing for prohibited drugs and alcohol must be conducted when any of the above 

circumstances exist. The Company may send an employee for drug and alcohol testing 

following any accident, which does not meet the above thresholds if the supervisor makes a 

determination that a test is necessary. 

2. Fatal Accident 

Whenever there is a loss of human life, the surviving safety-sensitive employee operating 

the transit vehicle at the time of the accident must be tested. Safety-sensitive employees 

not on the vehicle (e.g., maintenance personnel) whose performance could have 

contributed to the accident (using the best information available at the time of the 

accident) must be tested. 

3. Non-Fatal Accident 

Following non-fatal accidents, the vehicle operator will be tested if one or more 

individuals receive injuries requiring immediate transport to a medical treatment facility

or any time one or more vehicles receive disabling damage. 

For non-fatal accidents, any other safety-sensitive employee whose performance could 

have contributed to the accident (as determined using the best information available at 

the time of the accident) will also be tested. However if an employee’s performance can 

be completely discounted as a contributing factor, then he or she will not be tested under 

FTA. 

Appendix A. Example Policies (Long Beach Transit) Page A-40
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FTA Drug and Alcohol Testing Program 

 4. Testing Guidelines 

FTA post-accident drug and alcohol tests will be performed as soon as possible. Drug 

tests will be performed within 32 hours following the accident. Alcohol tests will be 

performed within 8 hours. 

If an alcohol test is not administered within 2 hours following the accident, Long Beach 

Transit must document the reason the test was not performed and still attempt to 

administer the test. If an alcohol test is not administered within 8 hours following the 

accident, attempts to administer an alcohol test will be ended and a record will be filed 

explaining the circumstance surrounding the missed test. 

The requirement to test for drugs and alcohol following an accident will in no way delay

necessary medical attention for injured people or prohibit an employee from leaving the 

scene of an accident to obtain assistance in responding to the accident or to obtain 

necessary emergency medical care. However, the employee must remain readily

available, which means that Long Beach Transit knows the location of the employee. 

Failure to remain readily available will be considered a refusal to test. 

A safety-sensitive employee involved in an accident must refrain from alcohol 

consumption for eight (8) hours following the accident or until a post-accident alcohol 

test can be administered. A violation of this policy will result in termination. 

When the Company is unable to perform a post-accident test in accordance with FTA 

regulations, it will use the results of Post-Accident drug and alcohol tests administered 

by State or local law enforcement personnel under their independent authority. This is 

acceptable only under limited circumstances, and the test results must be obtained in 

conformance with State and local law. 

D. Random Testing

1. Requirement for Random Testing 

FTA regulations require random testing of drugs and alcohol for all safety-sensitive 

employees. Random testing identifies employees who are using drugs or misusing 

alcohol but are able to use the predictability of other testing methods to escape 

detection. More importantly, it is widely believed that random testing serves as a strong 

deterrent against employees beginning or continuing prohibited drug use and misuse of 

alcohol. 

2. Methodology for Random Testing 

A scientifically valid random-number selection method to select safety-sensitive

employees will be used. Long Beach Transit has purchased a computer program that 

will generate this selection. There is no discretion on the part of management or 

operations in the selection and notification of individuals for random testing. 

 The number of employees randomly selected for drug/alcohol testing during the 

calendar year shall be in accordance with FTA regulations. The current random testing 

rate for drugs established by FTA equals fifty percent of the number of covered 

Appendix A. Example Policies (Long Beach Transit) Page A-41
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FTA Drug and Alcohol Testing Program 

employees in the pool and the random testing rate for alcohol established by FTA equals 

ten percent of the number of covered employees in the pool. A slightly higher 

percentage may be tested to provide for canceled tests. The test dates will be spread 

reasonably throughout the year. Every effort will be made to conduct testing on different 

days of the week and at different times throughout the annual cycle. 

All safety-sensitive employees in the random pool will have an equal chance of being 

selected for testing and will remain in the pool, even after being tested. It is possible for 

some employees to be tested several times in one year, and other employees not to be 

tested for several years. 

The process for testing will be unannounced and unpredictable as well as random. Once 

the employee has been notified that he or she has been selected for testing, he or she 

must then report immediately to the collection site. 

E. Return-to-Duty and Follow-Up Testing

Under the Company’s authority, an employee who voluntarily discloses a substance abuse 

problem, before a disciplinary matter develops and before being selected for a test, will be 

subject to return-to-duty and follow-up testing by the Company. The employee must be

evaluated by a substance abuse professional, and pass a return-to-duty test. The purpose of 

this procedure is to provide some degree of assurance that the individual is presently free of 

alcohol and/or any prohibited drugs and is able to return to work without undue concern about 

continued substance abuse. 

A return-to-duty test will include testing for both prohibited drugs and alcohol. The employee 

must have a negative drug test result and an alcohol test result of less than 0.02 to return to a 

safety-sensitive function. In addition, the employee must complete all return-to-duty 

requirements of the Company. 

Once allowed to return to duty, an employee will be subject to unannounced follow-up testing for 

at least 12 but not more than 60 months. The frequency and duration of the follow-up testing 

will be recommended by a Substance Abuse Professional (refer to Section XII) with a minimum 

of six tests performed during the first twelve months after the employee has returned to duty. 

Follow-up testing is separate from and in addition to the regular random testing program. 

Employees subject to follow-up testing will remain in the standard random pool and must be 

tested whenever their names come up for random testing. 

IX. Drug Testing Procedures

It is not the intent of these guidelines to specify the requirements and protocol of the collection 

site personnel. These guidelines do, however, provide information about the requirements for 

employees and job applicants. 

Appendix A. Example Policies (Long Beach Transit) Page A-42
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FTA Drug and Alcohol Testing Program 

FTA-related testing procedures are as follows: 

A. Drug Testing Methodology

1. Initial Test 

Initial testing will be performed on the primary sample using the EMIT immunoassay

technique. If the results are negative, no further testing will be required and a report will 

be provided to the MRO. The MRO is responsible for collecting, interpreting, and 

recording results and communicating results to Long Beach Transit. 

2. Confirmation Test 

Whenever a positive result is obtained on initial testing, confirmation testing will be 

automatically performed. This testing will also utilize the primary sample. All 

confirmations will be by quantitative analysis, i.e., Gas Chromatography/Mass 

Spectrometry (GC/MS). Results of confirmation testing will be immediately phoned to the 

MRO. If the test is positive, the secondary sample will be kept in frozen storage for one 

year from the date of its receipt to allow re-testing (see Section D below). 

B. Applicant/Employee Drug Testing Requirements

1. Report to the specimen collection site as soon as possible after notification to 

report. Refusal to report for collection or refusal to cooperate with the collection 

process will result in a determination of a refusal to provide a specimen. 

2. Picture identification must be presented, i.e. driver’s license or employee ID. If

identity cannot be verified, the collection will not proceed. 

3. The individual will be required to check his or her belongings and remove any

unnecessary outer garments, including purses, briefcases, bulky outerwear 

(sweaters, jackets, vests, etc The collector will request that the individual empty

his or her pockets, display the items, and explain the need for them during the 

collection. The individual may retain his or her wallet. If any of the individual’s 

items could be used as a potential adulterant, the collector may check it with the

individual’s other personal belongings. 

4. The individual must rinse his or her hands with water and dry them. 

5. Under normal circumstances collection site personnel will not observe the 

specimen collection. A specimen of at least 45 milliliters (about 1-1⁄2 ounces) of 

urine is required. The donor must urinate into the collection cup. 

6. If the individual is unable to provide at least 45 ml, the collection site technician 

will instruct him or her to drink not more than 40 ounces of fluids during a period 

of up to three hours. The individual will then attempt to provide a complete 

sample using a fresh collection container. The original insufficient specimen will 

be discarded. If the individual is still unable to provide an adequate specimen, the 

insufficient specimen will be discarded, testing discontinued, and Long Beach 

Transit notified. The Medical Review Officer (MRO) will refer the individual for a 

Appendix A. Example Policies (Long Beach Transit) Page A-43
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FTA Drug and Alcohol Testing Program 

medical evaluation to determine whether the individual’s inability to provide a 

specimen is genuine or constitutes refusal to submit to a drug test. 

7. If the individual refuses to cooperate with the collection process, Long Beach 

Transit will be informed. 

8. The specimen will be sealed and labeled in the presence of the donor. It then will 

be processed according to specific chain of custody procedures to account for 

the integrity of the specimen. 

 C. Observed Drug Collections

Procedures for collecting urine specimens shall allow individual privacy unless there is a 

reason to believe that a particular individual may alter or substitute the specimen to be 

provided. In the following circum-stances, the collection personnel must observe the 

second collection in compliance with FTA regulations: 

1. The individual has presented a urine sample that falls outside the normal 

temperature range. 

2. The collection site person observes conduct clearly and unequivocally indicating 

an attempt to substitute or adulterate the sample (e.g. substitutes urine in plain 

view, blue dye in specimen presented, etc.). 

3. The laboratory reports to the MRO that a specimen is invalid, and the MRO reports 

to Long Beach Transit that there was not an adequate medical explanation for the 

result. 

4. The MRO reports to Long Beach Transit that the original positive, adulterated, or 

substituted test result had to be cancelled because the test of the split specimen 

could not be performed. 

Additionally, Long Beach Transit may authorize an observed collection when the test to be 

conducted is a return-to-duty or follow-up test. 

The direct observation must be by a collection site person of the same gender as the 

employee being tested. 

D. Drug Testing Split Sample

The urine specimen collected for FTA testing will be split and poured into two specimen 

bottles. This provides the employee or applicant with the option of having an analysis of 

the split sample performed at a second HHS laboratory should the primary specimen test 

result be verified positive. The employee or applicant has 72 hours after being informed 

by the MRO of a verified positive test to request a test of the split sample. All requests 

for split specimen analysis will be processed by the MRO, and sent to a second HHS 

laboratory. 

Appendix A. Example Policies (Long Beach Transit) Page A-44

Should the result of the second test be positive, Long Beach Transit will require the employee to

reimburse the Company. Applicants are directly responsible for the cost of split sample testing 

under this provision, if they choose to exercise it. 
Best Practices 

FTA Drug and Alcohol Testing Program 

X. Alcohol Testing

FTA regulations prohibit an employer from allowing an employee with an alcohol 

concentration of 0.04 or greater to perform any safety-sensitive duties. An employee 

with an alcohol concentration of 0.02 or greater but less than 0.04 must be removed from 

duty for eight (8) hours or until a re-test shows an alcohol concentration of less than 

0.02. 

An employee removed from work based on a violation of these conduct standards will not be 

paid for time missed. 

A confirmed alcohol test of 0.04 or greater is a "positive test." A positive test will result in 

termination. 

A. Alcohol Testing Methodology

A safety-sensitive employee may be tested just before, during, and following the 

performance of a safety-sensitive function, using an evidential breath-testing device 

(EBT). 

B. Breath Alcohol Technician

Alcohol tests will be performed by a breath alcohol technician (BAT) who is trained to 

proficiency in the operation of the EBT being used and in the alcohol testing procedures 

specified in the Federal regulations. 

C. Applicant/Employee Responsibilities

1. Present picture identification upon reporting for testing. 

2. After testing procedures are explained, the employee and the BAT will complete, 

date, and sign the alcohol testing form. The form indicates that the employee is

present and providing a breath specimen. The employee will receive a copy of the 

form. 

3. An individually sealed, disposable mouth-piece will be given to the employee. The 

employee will be instructed to blow into the mouthpiece for at least six seconds or 

until an adequate amount of breath has been obtained. This initial test is 

considered a “screening test.” The BAT will show the employee the result 

displayed on the EBT or the printed result. 

4. If the result of the screening test is an alcohol concentration of less than 0.02, no 

further testing is required and the test will be reported to Long Beach Transit as a 

negative test. The employee may return to his or her safety-sensitive position. 

5. If the result of the screening test is an alcohol concentration of 0.02 or greater, a 

confirmation test will be performed. The confirmation test will be conducted at 

least 15 minutes, but not more than 30 minutes, after the completion of the initial 

test. This delay prevents any accumulation of alcohol in the mouth from leading 

to an artificially high reading. The employee cannot eat, drink, or put any object 

Appendix A. Example Policies (Long Beach Transit) Page A-45
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FTA Drug and Alcohol Testing Program 

or substance in his or her mouth. The employee must not belch to the extent 

possible while awaiting the confirmation test. 

6. If the initial and confirmatory test results are not identical, the confirmation test 

result is deemed to be the final result. 

7. The BAT will sign and date the form. The employee will sign and date the 

certification statement, which includes a notice that the employee cannot perform 

safety-sensitive duties or operate a motor vehicle if the results are 0.02 or greater. 

8. In the event an individual must be removed from safety-sensitive duties, the BAT 

will notify Long Beach Transit’s representative immediately.

D. Incomplete Tests

If a screening or confirmatory test cannot be completed, the BAT must, if practicable,

begin a new test using a new alcohol test form and a new sequential test number. 

 

Refusal by an employee to complete and sign the alcohol testing form (at step 2), to 

provide breath, to provide an adequate amount of breath, or otherwise to cooperate with 

the collection process, will be noted on the form and the test will be terminated. 

If an employee attempts and fails to provide an adequate amount of breath, the BAT must 

note this on the form and immediately contact Long Beach Transit. If no valid medical 

reason is determined, the inadequate amount of breath will be considered a refusal to 

test. 

XI. Medical Review Officer

FTA drug testing laboratory results will be reviewed by a qualified Medical Review Officer 

(MRO). The purpose of this review is to verify and validate test results. The MRO is a 

licensed physician responsible for receiving laboratory results generated by Long Beach 

Transit’s drug testing program. The MRO has knowledge of substance abuse disorders 

and has appropriate medical training to interpret and evaluate an individual’s confirmed 

positive test result together with the individual’s medical history and any other relevant 

biomedical information. 

The MRO will perform various functions, including but not limited to the following: 

1. Receive the results of drug tests. 

2. Review and interpret an individual’s confirmed non- negative test by a) reviewing 

the individual’s medical history, including any medical records and biomedical 

information provided; b) affording the individual an opportunity to discuss the test 

results; and c) deciding whether there is a legitimate medical explanation for the 

result, including legally prescribed medication. 

3. Notify each employee who has a verified positive test that the employee has 72 

hours in which to request a test of the split specimen. 

Appendix A. Example Policies (Long Beach Transit) Page A-46
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FTA Drug and Alcohol Testing Program 

4. If, after the MRO makes all reasonable efforts, the MRO is unable to reach the 

individual directly, the MRO will contact the designated Long Beach Transit 

representative who will direct the individual to contact the MRO as soon as 

possible. If after making all reasonable efforts, the designated management 

official is unable to contact the employee, Long Beach Transit may place the 

employee on mandatory leave status. 

5. Report each verified test result to the person designated by Long Beach Transit to 

receive results. 

6. Maintain all necessary records and send test results to Long Beach Transit’s drug 

and alcohol program manager. 

7. Protect the employees’ privacy and testing program confidentiality.

XII. Substance Abuse Professional (SAP)

A SAP is a professional who can determine what assistance, if any, an individual needs in 

resolving problems associated with prohibited drug use and/or alcohol misuse. 

A safety-sensitive employee who has a verified positive drug and/or confirmed alcohol 

test result will be immediately removed from his or her safety-sensitive job duties. In 

addition, he or she will be advised of the resources available to evaluate and resolve 

problems associated with drug abuse, including the names, addresses, and telephone 

numbers of substance abuse professionals and counseling and treatment programs. 

Referral to a SAP does not shield an employee from disciplinary action or guarantee 

employment or reinstatement with Long Beach Transit. Appropriate disciplinary action will be 

taken for all policy violations. 

Employees may also be referred to a SAP after voluntarily disclosing a substance abuse 

problem. 

XIII. Rehabilitation

Drug and alcohol abusers must be encouraged to make every effort to overcome the abuse and 

addiction that comes from use. Successful rehabilitation hinges upon users voluntarily 

rehabilitating themselves, with the assistance of outside professionals. 

Employees of Long Beach Transit who have problems with drugs or alcohol misuse are strongly 

encouraged to seek help voluntarily. Long Beach Transit, through Managed Health Network, 

provides an Employee Assistance Program (EAP) to assist employees in dealing with drug- and 

alcohol-related problems. The EAP is one means for rehabilitation and can be contacted at 

(800) 227-1060 24 hours a day, 7 days a week. In addition, all employees are encouraged to 

make use of other available resources for treatment of substance abuse problems. 

Voluntary enrollment in a rehabilitation program does not excuse or exempt an employee from 

discipline if he or she tests positive for drugs while on duty or for alcohol just before, during, or 

following the performance of a safety-sensitive function. 

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FTA Drug and Alcohol Testing Program 

XIV. Confidentiality

Laboratory reports or test results for FTA testing will not appear in a safety-sensitive 

employee’s personnel file. Information of this nature, however, will be included in a 

separate confidential medical folder maintained in a confidential manner. The reports or 

test results may be disclosed to Long Beach Transit management on a strictly need-toknow basis and to the tested employee upon request by a written signed release. 

Disclosure, without employee consent, may also occur when: 

• The disclosure is compelled by legal proceedings, (civil or criminal). These 

proceedings include a lawsuit (e.g., a wrongful discharge action), grievance (e.g., 

an arbitration concerning disciplinary action taken by the employer), or 

administrative proceeding (e.g., an unemployment compensation hearing) brought 

by, or on behalf of, an employee and resulting from a positive DOT drug or alcohol 

test or a refusal to test (including, but not limited to, adulterated, or substituted 

test results). These proceedings also include a criminal or civil action resulting 

from an employee's performance of safety-sensitive duties. In such a proceeding, 

the release of information to the decision maker in the proceeding (e.g., the court 

in a lawsuit) will only be released with a binding stipulation that the decision 

maker to whom it is released will make it available only to parties to the 

proceeding. 

• The information is requested by the DOT, FTA or any DOT agency, or federal, 

state, or local safety agency with regulatory authority over Long Beach Transit or 

any of its employees. 

• The information is requested by a subsequent employer (if the employee has 

expressly authorized the particular records be transmitted to that employer); 

• The information has been placed at issue in a formal dispute between the tested 

employee or applicant and Long Beach Transit; 

• The information is needed by medical personnel for the diagnosis or treatment of 

the employee or applicant who is unable to authorize disclosure; 

• The information is requested by the National Transportation Safety Board during 

an accident investigation; or 

• In cases of a contractor or sub-recipient of a state department of transportation, 

records will be released when requested by such agencies that must certify

compliance with the regulation to the FTA. 

XV. Effective Date

The effective date of these revised guidelines is February 2002. 

Appendix A. Example Policies (Long Beach Transit) Page A-48
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Attachment 1 

Drug and Alcohol Abuse Information Helplines 

Mona Gillman 

Substance Abuse Professional 

(714) 567-4845 

Managed Health Network (EAP) 

(800) 227-1060 

Alcohol and Drug Referral Hotline 

(800) 252-6465 

American Council on Alcoholism Hot Line 

(800) 356-9996 

Al-Anon 

(800) 344-2666 

Center for Substance Abuse Treatment 

(800) 662-4357 

Mothers Against Drunk Driving (MADD) 

(800) 438-6233 

National Cocaine Hot Line 

(800) 262-2463 

National Institute on Drug Abuse Hot Line 

(800) 662-HELP 

Appendix A. Example Policies (Long Beach Transit) Page A-49
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Attachment 2 

Health and Safety Issues 

Related to Drug Abuse and Alcohol Misuse 

Substance abuse, the misuse of drugs and alcohol, is not a new issue, but it is one of growing 

concern to employers. Substance abuse is a problem in the workplace. Research has shown 

that substance abuse affects organizations, as evidenced by increased medical benefit claims, 

increased absenteeism, increased worker’s compensation claims, and decreased productivity. 

Substance abuse poses serious safety and health risks not only to the user, but also to those 

who work with or come into contact with the user. As a result, employers have become even 

more concerned about the misuse of drugs and alcohol by employees who perform safetysensitive functions in the organization, and in functions involving direct contact with the public. 

Alcohol Facts

Alcohol, when consumed primarily for its physical and mood-altering effects, is a substance of 

abuse. As a depressant it slows down physical responses and progressively impairs mental 

functions. Signs and symptoms of use include dulled mental processes, lack of coordination, 

odor of alcohol on the breath, slowed reaction rate, and slurred speech. The chronic 

consumption of alcohol over time may result in decreased sexual functioning, dependency, fatal 

liver disease, kidney disease, and birth defects. 

It takes one hour for the average person (150 pounds) to process one serving of an alcoholic 

beverage from the body. Impairment in coordination and judgement can be objectively 

measured with as little as two drinks in the body. A person who is legally intoxicated is six times 

more likely to have an accident than a sober person. 

Amphetamine Facts

Amphetamines are central nervous system stimulants that speed up the mind and body. Signs 

and symptoms of use include hyperexcitability, restlessness, confusion, panic, talkativeness, 

inability to concentrate, and heightened aggressive behavior. Regular use produces strong 

psychological dependence and increasing tolerance to the drug. 

Low-dose amphetamine use will cause short-term improvement in mental and physical 

functioning. With greater use, however, the effect reverses and has an impairing effect. 

Hangover effect is characterized by physical fatigue and depression, which may make operation 

of equipment or vehicles dangerous.

Cocaine Facts

Cocaine is abused as a powerful physical and mental stimulant; the entire central nervous 

system is energized. Signs and symptoms of use include financial problems, increased physical 

activity and fatigue, isolation and withdrawal from friends and normal activities, unusual 

defensiveness, anxiety, agitation, and wide mood swings. Cocaine use causes the heart to beat 

faster and harder and rapidly increases blood pressure. Cocaine causes spasms of blood 

vessels in the brain and heart and can lead to ruptured vessels causing strokes or heart attacks. 

Extreme mood and energy swings create instability. Work performance is characterized by 

forgetfulness, absenteeism, tardiness, and missed assignments. 

Appendix A. Example Policies (Long Beach Transit) Page A-50
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Marijuana Facts

People use marijuana for the mildly tranquilizing, mood altering and perception altering effects it

produces. Signs and symptoms of use include reddened eyes, slowed speech, chronic fatigue, 

and lack of motivation. Chronic smoking of marijuana causes emphysema-like conditions. 

Regular use can cause diminished concentration, impaired short-term memory, impaired signal 

detection, and impaired tracking (the ability to follow a moving object with the eye). 

Marijuana smoking has a long-term effect on performance. Combining alcohol and other 

depressant drugs and marijuana can produce a multiplied effect, increasing the impairing effect 

of both the depressant and marijuana. 

Opiates (Narcotics) Facts

Opiates (also called narcotics) are drugs that alleviate pain, depress body functions, and when 

taken in large doses, cause a strong euphoric feeling. Signs and symptoms of use include 

mood changes, impaired mental functioning, depression and apathy, impaired coordination, and 

physical fatigue and drowsiness. IV needle users have a high risk for contracting hepatitis and 

AIDS due to sharing of needles. 

Unwanted side effects of opiates such as nausea, vomiting, dizziness, mental clouding, and 

drowsiness place the legitimate user and abuser at higher risk for an accident. Workplace use 

may cause impairment of physical and mental functions. 

Phencyclidine (PCP) Facts

Phencyclidine acts as both a depressant and a hallucinogen, and sometimes a stimulant. Signs 

and symptoms of use include impaired coordination, severe confusion and agitation, extreme 

mood shifts, rapid heartbeat, and dizziness. The potential for accidents and overdose is high

due to the extreme mental effects combined with the anesthetic effect on the body. PCP use 

can cause irreversible memory loss, personality changes, and thought disorders. 

Appendix A. Example Policies (Long Beach Transit) Page A-51
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Attachment 3 

List of Safety-Sensitive Employees 

• Motor Coach Operator 

• Student Operator 

• Operations Supervisor 

• Operations Lead Supervisor 

• Maintenance Supervisor 

• “A” Mechanic 

• “B” Mechanic 

• “C” Mechanic 

• Utility Worker 

• Training Supervisors 

• Lead Training Supervisor 

• Safety Officer 

Appendix A. Example Policies (Long Beach Transit) Page A-52
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Attachment 4 

Minimum Thresholds 

INITIAL TEST CUT-OFF LEVELS 

(ng/ml) 

Marijuana metabolites 50 

Cocaine metabolites 300 

Opiate metabolites 2,000 

 Phencyclidine 25 

 Amphetamines 1,000 

CONFIRMATORY TEST CUT-OFF LEVELS 

 

(ng/ml) 

Marijuana metabolites 15 

Cocaine metabolites 150 

Opiates: 

 Morphine 2,000 

 Codeine 2,000 

Phencyclidine 25 

Amphetamines:

 Amphetamines 500 

 Methamphetamine 500 

 Delta-9-tetrahydrocannabinol-9-carboxylic acid. 

 Benzoylecgonine 

 Specimen must also contain amphetamine at a concentration greater than or equal to 

 200 ng/ml. 

Appendix A. Example Policies (Long Beach Transit) Page A-53
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Attachment 5 

List of Contacts 

Any questions regarding this policy or any other aspect of the substance abuse policy should be

directed to the following individual(s).

Drug and Alcohol Program Manager

Name: LaVerne David 

Title: Manager, Human Resources 

Address: Long Beach Transit 

Telephone No: (562) 591-8753 

Drug and Alcohol Program Administrator

Name: Jacqueline Gomez 

Title: Human Resources Assistant 

Address: Long Beach Transit 

Telephone No: (562) 591-8753 

Medical Review Officer

Name: Drs. Brian and Helen Tang 

Title: Medical Review Officers 

Address: Long Beach Medical Clinic 

Telephone No: (562) 437-0831 

Substance Abuse Professional

Name: Mona Gillman 

Title: Substance Abuse Professional 

Address: Long Beach, CA 

Telephone No: (714) 567-4845 

HHS Certified Laboratory

Name: Pacific Toxicology Laboratories 

Address: Woodland Hills, CA

Telephone No: (818) 598-3110

Appendix A. Example Policies (Long Beach Transit) Page A-54
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3. Tri-County Metropolitan Transit District/Tri-Met (Portland, Oregon)

TABLE OF CONTENTS

A. INTRODUCTION 

B. APPLICABILITY 

C. PURPOSE 

D. PROHIBITED SUBSTANCES 

E. PROHIBITED BEHAVIOR 

F. ALCOHOL 

1. Adverse Effects 

2. Use 

G. SAFETY-SENSITIVE FUNCTIONS

H. PRESCRIPTION DRUG USE 

I. COMPLIANCE WITH TESTING 

J. GENERAL PROVISIONS FOR DRUG AND ALCOHOL TESTING 

1. Types of Testing 

a. Post-Offer/Pre-Employment (Safety-Sensitive Positions Only) 

b. Reasonable Suspicion 

c. Post-Accident 

d. Random (Safety-Sensitive Positions Only) 

e. Return-To-Duty 

f. Follow-up 

2. Methodology 

3. Substance Abuse Professional Evaluations 

4. Confidentiality 

5. Notification of Criminal or Driving While Intoxicated Conviction 

K. EMPLOYEE ASSISTANCE PROGRAM 

L. EDUCATION AND TRAINING

M. DISCIPLINE 

N. RETURN-TO-WORK REQUIREMENTS 

O. MODIFICATIONS 

P. PROGRAM ADMINISTRATION 

Q. BOARD APPROVAL 

EXHIBIT A. TRI-MET DOT/FTA-DEFINED SAFETY-SENSITIVE POSITIONS AND CODES 

Appendix A. Example Policies (Tri-Met) Page A-55
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TRI-MET 

DRUG AND ALCOHOL ABUSE POLICY 

Effective March 27, 2002 

A. INTRODUCTION

The District has the responsibility to its customers and the general public to provide safe, efficient 

transportation services while insuring safe working conditions for its employees. To satisfy these 

responsibilities, the District must establish a work environment where its employees are free from the 

effects of drugs or alcohol.

B. APPLICABILITY

This Policy applies to all District employees and certain contracted employees. 

C. PURPOSE

The purpose of this Policy is to assure employee fitness for duty and to protect District employees, 

customers, and the public from risk posed by worker use of drugs or alcohol. This Policy is intended to 

comply with all applicable Federal regulations governing workplace drug use and alcohol misuse in the 

transit industry. Regulations issued by the U.S. Department of Transportation (DOT) and the Federal 

Transit Administration (FTA) mandate urine drug testing and evidential breath alcohol testing for safetysensitive positions. This Policy sets forth the District drug and alcohol abuse program and the testing and 

reporting guidelines for safety-sensitive employees as required by those regulations, and for employees in 

non-safety-sensitive positions.

It is the goal of this Policy to prevent substance abuse and rehabilitate rather than terminate the 

employment of workers. However, all persons covered by this Policy should be aware that violations of 

the Policy will result in discipline, up to and including termination, or in not being hired. 

Compliance with DOT/FTA drug and alcohol regulations and District policy is a condition of employment. 

D. PROHIBITED SUBSTANCES

The FTA Regulations prohibit the consumption of the following drugs and drug metabolites at any time: 

marijuana, amphetamines, opiates, phencyclidine (PCP), and cocaine. In addition to the aforementioned 

drugs, it is the District’s policy to prohibit any illegal controlled substance, as well as any drug not 

approved for medical use by the USDA or the USFDA. Illegal use includes use of, or impairment by, any 

illegal drug, misuse of legally prescribed or over-the-counter drugs, or illegally obtained prescription drugs. 

With respect to safety-sensitive employees, the FTA prohibits the consumption of any alcoholic

substance, beverage, or mixture, including any medication containing alcohol within four (4) hours of the 

employee's scheduled time to report for work, while on duty or within eight (8) hours following an 

accident or until the employee takes a post-accident alcohol and/or drug test, whichever occurs first. 

Under District policy, the aforementioned prohibition applies to all employees. 

Appendix A. Example Policies (Tri-Met) Page A-56
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E. PROHIBITED BEHAVIOR

The use, possession, distribution, sale, purchase, manufacture, dispensation of or intoxication by alcoholic 

substances or beverages, intoxicants, illegal drugs, controlled substances not medically authorized, related 

drug paraphernalia, or other substances including prescription drugs which impair job performance or 

mental or motor function by any employee or any other person to whom this Policy applies while on 

District premises or in the course of conducting District business during regular business hours, including 

while subject to being on-call in a paid status, at lunch or on breaks, is strictly prohibited. Safetysensitive employees are prohibited from the consumption of illegal drugs at all times. 

Employees performing safety-sensitive job functions are prohibited from reporting to or remaining on 

duty with an alcohol concentration level of 0.02 or greater. Safety-sensitive employees may not use 

alcohol from any source while on duty or within four (4) hours prior to performing safety-sensitive duty.

Safety-sensitive employees on call are prohibited from using alcohol during hours they are on on-call paid 

status. Any time an employee (not on paid status) is called to report for duty, and the employee has used 

alcohol within 4 hours of the call, the employee must turn down the work or acknowledge the use of 

alcohol and the inability to perform the safety-sensitive function. 

Employees who are reasonably suspected of engaging in a prohibited activity, or of not being fit for duty 

due to drug or alcohol misuse will be suspended from duty pending an investigation and verification. 

Employees who fail to pass a drug or alcohol test, or who engage in a prohibited activity will be removed 

from duty and subject to disciplinary action, up to and including discharge. 

F. ALCOHOL

1. ADVERSE EFFECTS 

It is recognized that alcohol is a legal, socially acceptable drug when consumed in moderation. However, 

when consumed primarily for its physical and mood-altering effects, it is a substance that is subject to 

abuse. As a depressant, it slows physical responses and progressively impairs mental functions, including 

the ability to safely operate a motorized vehicle or machinery. The chronic consumption of alcohol over 

time may result in critical health issues, including dependency, fatal liver diseases, ulcers, and increased 

possibility of cancers. Slurred speech, poor coordination, inability to walk straight, rapid eye movement, 

impaired attention or memory, stupor or coma are all signs of alcohol use and problems. 

If an alcohol problem is suspected the Employee Assistance Program and/or the Drug and Alcohol 

Coordinator should be contacted. 

2. USE 

The FTA requires that no safety-sensitive employee shall report for duty within four (4) hours of using 

any alcoholic substances or beverages, including medications, or use alcohol while subject to being oncall in a paid status. An employee who has a confirmed alcohol concentration of 0.02 or greater, but less 

than 0.04, on an evidentiary breath testing device, will result in removal from his/her position for eight (8)

hours or until the employee tests below a concentration level of less then 0.02, whichever is sooner. The 

employee will be placed in a non-pay status for the period of non-availability. A confirmed alcohol 

concentration of 0.04 or greater is considered a positive alcohol test and will result in disciplinary action 

for violation of this Policy. 

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G. SAFETY-SENSITIVE FUNCTIONS

In addition to the District's drug and alcohol testing program, employees who perform safety-sensitive 

functions, including contractors performing safety-sensitive functions on behalf of the District on or off 

District property, are required to participate in the federally mandated drug and alcohol testing program. 

A safety-sensitive function as defined by the FTA, is any duty related to the safe operation of mass transit 

service including the: 

1. Operation of revenue service vehicles, in or out of service, 

2. Operation of non-revenue service vehicles that require drivers to hold a Commercial Driving License 

(CDL), 

3. Controlling the dispatch or movement of revenue service vehicles,

4. Maintenance of revenue service vehicles or equipment used in revenue service, including parts repair, 

rebuilding and overhaul, and 

5. Carrying of a firearm for security purposes. 

A safety sensitive employee is considered to be performing a safety sensitive function when he or she is 

actually performing, ready to perform, or immediately available to perform such functions. 

Tri-Met has reviewed the actual duties performed by employees to determine which functions and 

positions are safety-sensitive. 

A list of safety-sensitive positions is attached (Exhibit A). The list will be up-dated as necessary. 

H. PRESCRIPTION DRUG USE 

The appropriate use of legally prescribed drugs and nonprescription medication is not prohibited. 

However, it is the policy of the District that each safety sensitive employee must report the use of 

medically authorized drugs that may impair job performance or mental function to her/his immediate 

supervisor prior to performing safety-sensitive duties. Employees must provide proper written medical 

authorization to work from a physician or dentist when using such authorized drugs. It is the employee's 

responsibility to inform the physician of the employee's job duties and determine from the physician, or 

other health care professional, whether or not the prescribed drug may impair their job performance, or 

mental or motor function. Legally prescribed drugs must be reported on the Notification of Prescription 

Drug form and must include the patient's name, the substance name, the quantity and frequency to be 

taken, the period of authorization, and name of authorizing health care professional. 

Any failure to report the use of such drugs, or failure to provide proper evidence of medical authorization, 

may result in disciplinary action. 

I. COMPLIANCE WITH TESTING

Any employee or applicant who refuses to comply with a request for testing, who provides false 

information in connection with a test, who modifies or alters test forms, or who attempts to falsify test 

results through tampering, contamination, adulteration, or substitution will be removed from duty

immediately or barred from employment. 

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Refusal will include: 

 an inability to provide a specimen or breath sample without a valid medical reason (confirmed by

a physician); 

 tampering, adulterating, or substituting specimen; 

 delaying arrival at a designated collection site; 

 leaving the collection site prior to test completion; 

 failure to permit an observed or monitored collection when required; 

 failure to take a second test when required; 

 failure to undergo a medical evaluation when required; 

 failure to cooperate with any part of the testing process; 

 once test in underway, failing to remain at site and provide a specimen; 

 failure to sign Step 2 of alcohol test form; and 

 leaving the scene of an accident without just cause prior to submitting to a test. 

Such refusals will be treated as insubordination and recorded as a positive test. The employee will be 

referred to the substance abuse professional, and will be subject to disciplinary action up to and including 

discharge. 

J. GENERAL PROVISIONS FOR DRUG AND ALCOHOL TESTING

In order to promote and maintain a drug and alcohol-free workplace, the District will utilize a program of 

drug and alcohol screening. It is the District policy that this program applies to all employees except 

where noted. 

All drug and alcohol testing will be in accordance with 49 CFR Part 40 (Procedures for Transportation 

Workplace Drug Testing Programs Sections), and Part 655 (Prevention of Alcohol Misuse and Prohibited 

Drug Use in Transit Operations). These regulations may be viewed on Tri-Net or obtained from Station 

Managers, Rail and Bus Maintenance Managers, and Managers of Rail Transportation, Field Operations 

and Facilities Maintenance, collection personnel and the Safety Department. 

1. TYPES OF TESTING 

a. Post-Offer/Pre-Employment (Safety Sensitive Positions Only)

Following a conditional offer of employment, applicants for all safety-sensitive positions will undergo 

urine drug testing as a condition of employment. As mandated by the FTA, applicants will be screened for 

the presence of marijuana, cocaine, opiates, phencyclidine (PCP), and amphetamines. In addition, under 

Tri-Met authority, applicants will be required to provide a second urine specimen for Non-DOT testing. 

The second specimen will be tested, using an extended testing panel for the presence of the 

aforementioned drugs as well as barbiturates, benzodiozepenes, methadone, and propoxyphene. 

Applicants will be notified of the testing requirement during the application process. Failure to appear, 

failure to remain at site prior to commencement of test and aborting the collection before the test 

commences is not considered a refusal of a pre-employment test. 

A verified negative test result is required prior to performing any safety-sensitive functions and is a condition 

of employment. If the test is cancelled, the applicant must re-take the test and pass before being hired. 

 

Failure to pass will result in the disqualification of the applicant. Applicants who fail to pass the drug 

screen will not be permitted to reapply for any position within the District for one year and must provide 

proof of having successfully completed a referral, evaluation and treatment plan. 

Appendix A. Example Policies (Tri-Met) Page A-59
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Current District employees transferring into safety sensitive positions will not be allowed to perform

safety sensitive duties until the employee takes a pre-employment drug test with a verified negative result. 

Additionally, current District employees returning to a safety sensitive position after a period of 90 days

or more, must take a pre-employment drug test with a verified negative result before performing safety

sensitive duties. 

b. Reasonable Suspicion

It is the District’s policy that all employees are subject to fitness-for-duty evaluation consisting of a drug 

and alcohol test when there is reason to suspect the employee is under the influence of alcohol or drugs on 

duty. A referral for testing will be made when a trained supervisor can articulate and substantiate 

physical, behavioral and performance indicators of probable drug use or alcohol misuse by observing the 

appearance, behavior, speech or body odors of the employee. 

The FTA drug testing regulations require that all supervisors must undergo a minimum of 60 minutes of 

training on the signs and symptoms of drug use before they are qualified to make a reasonable suspicion 

determination. A similar provision in the FTA alcohol testing regulation requires supervisors to undergo 

an additional 60 minutes of training on the signs and symptoms of alcohol misuse. 

The District provides and encourages refresher training for supervisory personnel. 

The FTA requires that all employees in safety-sensitive positions will be tested for on or off duty drug use 

when there is reasonable suspicion of such impairment or use. Reasonable suspicion testing of safetysensitive employees must be based on specific, contemporaneous, articulable observations concerning the 

appearance, behavior, speech, body odors, or direct observations of drug or alcohol use. In accordance 

with District policy, employees in non-safety-sensitive positions may be subject to the same criteria as 

employees in safety-sensitive positions, except that employees in non-safety-sensitive positions shall only 

be tested for reasonable suspicion of on duty drug or alcohol use or impairment. 

Testing under Tri-Met authority will be conducted as Non-DOT testing and on Non-DOT chain of 

custody forms. The same high standards in testing procedures will be maintained. 

Upon conclusion of the specimen collection, employees will be required to make arrangements for their 

own transportation home. If necessary, the District will make arrangements and pay for transportation. 

Under no circumstance will the employee be permitted to operate a motor vehicle for the trip home. 

c. Post-Accident 

All surviving safety-sensitive employees who have a direct or possible involvement in an accident while 

in the course and scope of their employment will be tested for the presence of drugs and alcohol under 

any of the following circumstances: 

• A fatality has occurred; 

• An individual suffers injury requiring immediate medical attention away from the scene; 

• A bus, van, or automobile suffers disabling damage and must be towed from the scene; or 

• A rail car or trolley car is removed from revenue service 

Employees involved in accidents must refrain from alcohol use for eight (8) hours following the accident 

or until an alcohol test is administered. Employees must remain readily available. Employees who leave 

the scene of an accident without authorization or cannot be located for testing following the accident will 

be considered to have refused the test and will be subject to discipline, up to and including discharge. 

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Post-accident testing is stayed while the employee assists at the scene of the accident. In the event the 

employee is hospitalized or treated for injury, the drug and alcohol screen will be ordered at the treating 

facility. 

In accordance with the FTA regulations, post accident tests administered by a law enforcement agency 

will be accepted in lieu of the FTA mandated tests, when the District is unable to perform the required 

tests due to law enforcement agency requirements. 

Additionally, it is District policy to test employees for the presence of drugs and alcohol under the 

following circumstances: 

 The employee receives a citation under State or local law, which impacts public safety, while in 

the course and scope of their employment; or 

 The employee is involved in an event which violates District rules or procedures which poses a 

threat to the safety of employees or to the public, or property, including, but not limited to, runaway vehicles, or allowing a vehicle to strike a fixed object. 

All testing under the District’s authority will be conducted as a Non-DOT test on Non-DOT chain of 

custody forms. 

Upon conclusion of the specimen collection, employees will be required to make arrangements for their 

own transportation home. If necessary, the District will make arrangements and pay for transportation. 

Under no circumstance will the employee be permitted to operate a motor vehicle home. 

d. Random (Safety-Sensitive Positions Only) 

Random testing of safety-sensitive employees will be conducted in a manner consistent with the requirements of 49 CFR Part 655 (Prevention of Alcohol Misuse and Prohibited Drug Use in Transit Operations) 

and 49 CFR Part 40 (Procedures for Transportation Workplace Drug and Alcohol Testing Programs). 

The District will maintain a listing of the names of all employees in safety-sensitive positions. During the 

calendar year, drug and alcohol tests will be administered to these employees on a random-selection basis. 

The District shall ensure that random drug and alcohol tests conducted will be unannounced, immediate 

and that the dates for administering random tests are spread reasonably throughout the calendar month 

and year. Testing will be conducted on all days and hours during which safety-sensitive work is 

performed. All random test notifications will occur while the employee is on the clock. In the event the 

random test collection extends beyond the end of the shift, the employee will be paid overtime for the 

additional time, in accordance with the Collective Bargaining Agreement. There is no discretion on the 

part of management or operations in the selection and notification of individuals for testing. 

A computer based random number generator, which is a scientifically valid method, is used for random

selections. All safety-sensitive employees shall have an equal chance of being selected each time 

selections are made. 

The FTA random testing rate requirement is to annually complete drug tests equivalent to 50% of the 

number of safety-sensitive employees and complete alcohol tests equivalent to 10% of the number of 

covered employees. It is the District's policy that the number of safety-sensitive employees selected 

annually for drug and alcohol testing will be equal to a rate of at least 50% of the total number of safetysensitive employees subject to testing. 

Appendix A. Example Policies (Tri-Met) Page A-61
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The FTA may increase or decrease the minimum annual percentage rate for random drug and alcohol 

testing. Any changes to this rate will be noted in future amendments. 

e. Return-To-Duty

All employees who test positive for drugs and/or alcohol, and who are allowed to return to work, must be 

evaluated for drug and alcohol use by a Substance Abuse Professional (SAP), must complete all 

disciplinary actions, and must test negative prior to being released for duty as outlined in 49 CFR Part 40. 

It is the goal of this Policy to prevent substance abuse and rehabilitate rather than terminate the 

employment of workers. However, all persons covered by this Policy should be aware that violations of 

the Policy will result in discipline, up to and including termination, or in not being hired.

f. Follow-up

Employees permitted to return to duty following a positive test for drugs and/or alcohol will be subject to 

unannounced follow-up testing as determined by the SAP. The testing will be in accordance with 49 

CFR Part 40, subpart O and will be in addition to the employee's selection for testing under the random

testing program. 

2. METHODOLOGY 

Procedures for specimen collection, chain of custody of specimens, laboratory analysis procedures, and 

quality control requirements will be in accordance with the United States Department of Health and 

Human Services Mandatory Guidelines for Federal Workplace Drug Testing Programs, Final 

Guidelines, and the provisions set forth in 49 CFR Part 40, Procedures for Transportation Workplace 

Drug and Alcohol Testing Programs to assure a high degree of accuracy and reliability. 

3. SUBSTANCE ABUSE PROFESSIONAL EVALUATIONS

An employee who tests positive for drugs or alcohol or refuses a test, will be removed immediately from

his or her safety-sensitive functions and evaluated by a District-designated Substance Abuse Professional 

(SAP). The SAP will evaluate each employee to determine what assistance the employee needs in 

resolving problems associated with substance abuse. The evaluation will consist of a clinical assessment, 

treatment recommendations, and referrals, as appropriate. At a minimum, the employee must participate 

in a substance abuse education and prevention class. The SAP will inform the District, in writing, of the 

clinical-assessment-based treatment recommendations, which must be complied with. In addition, the 

SAP will specify the duration and frequency of follow-up drug and/or alcohol tests. The SAP’s 

evaluations, assessment, treatment recommendations, referrals and follow-up testing recommendations 

will be in accordance with 49 CFR Part 40. 

The District has secured the services of a Licensed Clinical Social Worker (LCSW) to perform the SAP 

duties. This individual has knowledge of and clinical experience in the diagnosis and treatment of drug

and alcohol related disorders. Information regarding the current SAP is available from the Designated 

Employee Representative (DER). 

4. CONFIDENTIALITY 

Confidentiality will be maintained throughout the drug and alcohol testing process. To assure 

confidentiality, all test results will be sent only to the DER by means of a secure communication system. 

Appendix A. Example Policies (Tri-Met) Page A-62
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The Safety Office will maintain results in a medical file separate from the official personnel file. 

The employee has an unqualified right, upon written request, to obtain copies of any records pertaining to 

his or her drug or alcohol tests. 

Test results will be released without written consent only: 

• to those District personnel directly involved in the decision for the tested employee’s dismissal or 

disciplinary action; 

• to the decision-maker in a lawsuit, grievance, or other proceeding initiated by or on the behalf of 

the employee tested; 

• when an accident investigation is performed by the National Transportation Safety Board; or, 

• when records are requested by the DOT or any DOT agency with regulatory authority, including 

the state rail fixed guideway systems oversight agency. 

The District will carry out this policy in a manner that respects the dignity and confidentiality of those 

involved.

Records will be made available to a subsequent employer upon receipt of a written request from the 

employee. As directed by the specific, written consent of the employee, information regarding the 

employee’s record will be released to an identified person. 

5. NOTIFICATION OF CRIMINAL OR DRIVING WHILE INTOXICATED CONVICTION

The Drug Free Workplace Act of 1988 requires all employees to notify the Drug and Alcohol Program

Coordinator of any conviction under a criminal drug statute for violations occurring on District property

within five (5) days of conviction. Additionally, the District policy requires the employee to notify the 

Drug and Alcohol Program Coordinator of all convictions under a criminal drug statute for violations 

occurring off District property and of all moving violation causing the loss of driver's license by State or 

local law enforcement involving drugs or alcohol. This notification must occur within five (5) days of 

conviction or violation. Failure to report such conviction, or violation, will result in disciplinary action up 

to and including discharge. The District is a Drug Free employer. 

K. EMPLOYEE ASSISTANCE PROGRAM

The District recognizes its commitment and its responsibility to its employees by seeking to provide, 

through the Employee Assistance Program (EAP) and/or Substance Abuse Professional (SAP), an 

opportunity for employees to deal with drug and alcohol-related problems. Any employee who 

voluntarily requests assistance in dealing with a personal drug and/or alcohol problem may do so through 

the EAP and/or SAP in complete confidence and without jeopardizing his/her employment with the 

District solely because of the request for assistance. Telephone numbers for the EAP and SAP are 

available from the DER and/or the Human Resource Department. Other treatment programs for drug and 

alcohol problems are available through the health and welfare providers selected by individual employees. 

The discontinuation of any involvement with alcohol or drugs is an essential requisite for participation in 

any treatment program. 

Although employees are encouraged to receive help for drug or alcohol problems, participation in an 

Employee Assistance Program and/or SAP will not excuse an employee's failure to comply with the 

requirements of this Policy. 

Appendix A. Example Policies (Tri-Met) Page A-63
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L. EDUCATION AND TRAINING

DOT/FTA regulations require that all supervisors of safety-sensitive employees receive a minimum of 60 

minutes of instruction on the alcohol program and an additional 60 minutes on the drug program. 

Supervisors who make reasonable suspicion determinations must have training on physical, behavioral, 

and performance indicators of probable drug and alcohol misuse. 

Safety-sensitive employees will receive at least 60 minutes of drug awareness training. This training 

includes information on the effects and consequences of prohibited drug use on personal health, safety,

the work environment, and indicators of prohibited use. Employees will also receive information on the 

effects of alcohol misuse on personal health, safety, the work environment, and available methods of 

intervention. 

It is the policy of the District that training and education programs will be made available to all District 

employees and Union officials. 

M. DISCIPLINE

Any employee whose conduct is found to be in violation of this Policy will be subject to disciplinary

action, including immediate suspension or termination. Performance and other employment factors, and 

the nature of the violation will be taken into consideration in determining the degree of disciplinary 

action. Represented employees will be disciplined in accordance with the Collective Bargaining 

Agreement. All disciplinary action will be reviewable through the grievance procedures in the Collective 

Bargaining Agreement. 

With respect to non-represented individuals, management shall have sole discretion to determine the 

appropriate disciplinary action for violation of this Policy. 

N. RETURN-TO-WORK REQUIREMENTS

Prior to being allowed to return to work, all employees that test positive for drugs or alcohol, as defined 

under the terms of this Policy, and who, under the discipline policy, are allowed to return to work, will be 

required to successfully complete the following: 

1. Meet with a Substance Abuse Professional (SAP) for assessment. 

2. Abide by the treatment recommendations made by the Substance Abuse Professional (SAP), 

including successful completion of any treatment program or substance abuse prevention 

class, as applicable, and monitoring for a minimum of one year by the SAP to assure 

compliance with the aftercare plan. 

3. Complete suspensions, as they may apply, consistent with the Collective Bargaining 

Agreement. 

4. Undergo return-to-duty drug and alcohol tests. A verified negative result must be obtained 

before the employee will be permitted to return to work. 

5. Complete a Return-To-Work Agreement, in conjunction with the employee's manager, 

outlining the terms for returning to work. The Agreement will be based in part on the SAP's 

terms of compliance. At a minimum the Return-to-Work Agreement will include the 

following requirements: 

a) 

b) 

c) 

Successful compliance with, and completion of the treatment program and/or substance abuse

prevention class, as applicable; and 

Compliance with the after-care plan; and

Appendix A. Example Policies (Tri-Met) Page A-64

Participation in, and compliance with, the requirements of a follow-up testing program;
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d) Immediate termination following a positive drug or alcohol test under any testing 

circumstances within the Return-to-Work Agreement time period. For the purposes of the 

Return-to-Work Agreement, a positive test is any confirmed alcohol concentration of .02 or 

greater; refusal to test or any confirmed positive drug test, verified by a Medical Review 

Officer (MRO); and 

Employee signature on the Return-To-Work agreement acknowledging the acceptance and 

understanding of the conditions set forth within the agreement, in consideration of continued 

employment.

e) 

Failure to sign the Return-to-Work Agreement or failure to adhere to the any of the aforementioned 

requirements will result in termination of the employee. 

O. MODIFICATIONS 

The Designated Employer Representative (DER) is authorized and directed to promulgate modifications, 

amendments and revisions to the Tri-Met Drug and Alcohol Abuse Program and to enact any policies as 

may be necessary to ensure Tri-Met’s compliance with laws and regulations affecting drug and alcohol 

matters. 

P. PROGRAM ADMINISTRATION 

The Safety Office is responsible for administering the Drug and Alcohol Abuse Policy and with certifying

compliance with the FTA substance abuse program requirements. Any questions about the Policy, testing 

program or the drug and alcohol misuse prevention program may be addressed to the Manager, System

Safety Programs at (503) 962-4943, or the Designated Employer Representative (DER) at (503) 962-

4937. 

The DER is knowledgeable about the DOT and FTA regulations, company policies and internal 

procedures. The DER is accessible to collection site personnel, Breath Alcohol Technicians (BAT), and 

Medical Review Officers (MRO) and is prepared to address drug and alcohol testing issues, make 

decisions, and provide direction in a timely manner. The DER has the authority to take necessary and 

immediate actions (directly or through the employee’s direct supervisor) to remove employees from

safety-sensitive duties, send employees for retests, and to direct the actions of service agents. 

Q. BOARD APPROVAL

This policy has been approved and adopted by the Tri-Met Board of Directors. 

Appendix A. Example Policies (Tri-Met) Page A-65
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Appendix A. Example Policies (Tri-Met) Page A-66
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Exhibit A. Tri-Met DOT/FTA-Defined Safety-Sensitive Positions and Codes 

Tri-Met DOT/FTA-Defined Safety Sensitive Positions Position Codes 

Apprentice Vehicle Mechanic 0534 

Apprentice Mechanic 0934 

Assistant Supervisor 0529 

Assistant Supervisor 0930 

Assistant Supervisor 0964 

Assistant Supervisor/Signals 0556 

Assistant Supervisor/Track 0564 

Assistant Supervisor/Traction PWR 0566 

Bus Operator 0880 

Dispatcher 0836

Helper 0533

Journeyman Mechanic 0931 

Laborer/MOW 0561

Lead Road Supervisor 0839 

LRT Lift/Fare Equipment Technician 0542 

LRV Mechanic 0551 

LRV Operator 0580 

Maintenance Helper 0933 

Maintenance Trainer 0918 

Mini-Run Operator 0881 

Plant Maintenance Mechanic 0557 

Plant Maintenance Mechanic 0968 

Power Maintainer 0531 

Pressure Washer 0537 

Rail/Controller/Supervisor 0536

Rail Signals Technician 0541 

Rail Transportation Training Supervisor 0582 

Road Supervisor 0834 

Signal Maintainer Apprentice 0546 

Spotter 0936

Tire Servicer 0941 

Track Maintenance Technician 0540 

Traction Overhead Technician 0547 

Traction Power Substation 0545 

Training Supervisor 0832 

Appendix A. Example Policies (Tri-Met) Page A-67

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4. Des Moines Metropolitan Transit Authority (Iowa) 

TABLE OF CONTENTS

1.0 Policy Statement 

2.0 Purpose 

3.0 Applicability

4.0 Prohibited Substances 

4.1 Illegally Used Controlled Substances or Drugs 

4.2 Legal Drugs 

4.3 Alcohol 

5.0 Prohibited Conduct 

5.1 Manufacture, Trafficking, Possession and Use 

5.2 Intoxication/Under the Influence 

5.3 Alcohol Use

5.4 Compliance with Testing Requirements 

5.5 Treatment Requirements 

5.6 Notifying MTA of Criminal Drug Conviction 

5.7 Proper Application of the Policy

5.8 Voluntary Treatment 

5.9 Non-Safety-Sensitive Employees

5.10 Confidentiality 

6.0 Testing Procedures 

6.1 Compensation for Testing 

6.2 Split Specimen Testing 

6.3 Pre-Employment Testing 

6.4 Other Testing 

6.5 Reasonable Suspicion Testing 

6.6 Post-Accident Testing 

6.7 Random Testing 

6.8 Return-to-Duty Testing 

6.9 Follow-up Testing 

7.0 Employment Assessment 

8.0 Re-Entry Conditions 

9.0 Drug and Alcohol Program Manager (DAPM) and Designated Employer 

Representatives (DER) 

Safety-Sensitive Positions 

Appendix A. Example Policies (Des Moines MTA) Page A-69 

Board Resolution 
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FTA Drug and Alcohol Testing Program 

Des Moines Metro Transit Authority

Substance Abuse Policy

1.0 Policy Statement

The Board of Trustees adopted the Des Moines Metro Transit Authority’s Policy on Drug and 

Alcohol Abuse at its Board meeting on November 22, 1994, and revision of the original policy on 

November 18, 1997, August 22, 2000, and March 26, 2002. A copy of the latest Board approval 

is included in this policy. The Des Moines Metro Transit Authority (MTA) is dedicated to 

providing safe, dependable and economical transportation services to our transit system 

passengers. The MTA’s employees are our most valuable resource, and it is our goal to 

provide a healthy, satisfying work environment, which promotes personal opportunities for 

growth. In meeting these goals, it is our policy to: 

1. Assure that employees are not impaired in their ability to perform assigned duties in a 

safe, productive and healthy manner;

2. Create a workplace environment free from the adverse effects of drug abuse and alcohol 

misuse; 

3. Prohibit the unlawful manufacture, distribution, dispensing, possession or use of 

controlled substances; and 

4. To encourage employees to seek professional assistance any time personal problems, 

including alcohol or drug dependency, adversely affect their ability to perform their 

assigned duties. 

2.0 Purpose

The purpose of this policy is to assure worker fitness for duty and to protect our employees, 

passengers and the public from the risks posed by the misuse of alcohol and use of prohibited 

drugs. This policy is also intended to comply with all applicable federal regulations governing 

workplace anti-drug and alcohol programs in the transit industry. The Federal Transit 

Administration (FTA) has published 49 CFR Part 655, as amended, that mandates urine drug 

testing and breath alcohol testing for safety-sensitive positions and prohibits performance of 

safety-sensitive functions when there is a positive test result. The U. S. Department of 

Transportation (DOT) has also published 49 CFR Part 40, as amended, that sets standards for 

the collection and testing of urine and breath specimens. In addition, the federal government 

published 49 CFR Part 29, "The Drug-Free Workplace Act of 1988," which requires the 

establishment of drug-free workplace policies and the reporting of certain drug-related offenses 

to the FTA. This policy incorporates those requirements for safety-sensitive employees and 

others when so noted. 

3.0 Applicability

This policy applies to all safety-sensitive transit system employees, paid part-time employees, 

volunteers, contract employees and contractors when they are on transit property or when 

performing any transit-related, safety-sensitive business. This policy applies to off-site lunch 

periods or breaks when an employee is scheduled to return to work. Contract employees will 

not be permitted to conduct transit business if found to be in violation of this policy. Non-safetysensitive employees are subject to this policy as noted. 

Appendix A. Example Policies (Des Moines MTA) Page A-70 
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In addition to being subject to all other elements of this policy, employees who perform “safetysensitive functions” for MTA, as that term is defined in the FTA regulations (49 CFR Part 655), 

are subject to random drug and alcohol testing and other special requirements set forth in this 

policy. Generally, a safety-sensitive function occurs when an employee is performing, ready to 

perform or immediately available to perform any duty related to safe operation of mass transit 

services. The following are safety-sensitive functions: 

1. Operation of a revenue service vehicle, whether or not such vehicle is in revenue 

service. 

2. Controlling dispatch or movement of a revenue service vehicle. 

3. Maintaining revenue service vehicles or equipment used in revenue service. 

4. Operating a non-revenue service vehicle when required to be operated by a holder of a 

CDL. 

5. Carrying a firearm for security purposes. 

6. Supervising, where the supervisor performs any function listed in items 1-5 above. 

MTA has reviewed the actual duties performed by employees in all job classifications to 

determine which employees perform safety-sensitive functions, and has determined which job 

functions may require the performance of safety-sensitive duties. An analysis will be performed 

if any new job classifications are developed to determine if the new job classifications should be 

considered safety-sensitive. 

A list of safety-sensitive positions is included in this policy. 

4.0 Prohibited Substances

Prohibited substances addressed by this policy include the following: 

4.1 Illegally Used Controlled Substances or Drugs

Any illegal drug or any substance identified in Schedules I through V of Section 202 of the 

Controlled Substance Act (21 U.S.C. 812), and as further defined by 21 CFR 1300.11 through 

1300.15. This includes, but is not limited to: 

Marijuana Metabolite(1) 50 ng/ml 15 ng/ml 

Cocaine Metabolite(2) 300 ng/ml 150 ng/ml 

Amphetamines 1000 ng/ml ------------ 

 Amphetamine ------------ 500 ng/ml 

 Methamphetamine (3) ------------ 500 ng/ml 

Opiates 2000 ng/ml ------------ 

 ------------ ------------ 

 Morphine ------------ 2000 ng/ml 

 Codeine ------------ 2000 ng/ml 

Phencyclidine (PCP) 25 ng/ml 25 ng/ml 

(1) Delta 9-tetrahydrocannabinol-9 carboxylic acid: (2) Benzoylecgonine; (3) Specimen must also include 

amphetamine at a concentration greater than or equal to 200 ng/ml. 

Appendix A. Example Policies (Des Moines MTA) Page A-71 

Illegally used controlled substances include any drug not approved for medical use by the U.S. 

Drug Enforcement Administration or the U.S. Food and Drug Administration. Illegal use 

includes use of any illegal drug, misuse of legally prescribed drugs, and use of illegally obtained 

prescription drugs. 
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4.2 Legal Drugs

The appropriate use of legally prescribed drugs and non-prescription medications is not 

prohibited. However, the use of any substance which carries a warning label that indicates that 

mental functions, motor skills, or judgment may be adversely affected must be discussed by 

employees with their appropriate health care professional before performing work-related duties. 

Educational information regarding prescription and over-the-counter medications should be 

obtained from either a health care professional or pharmacist. Employees are urged strongly to 

seek and obtain medical advice prior to using prescription or over-the-counter drugs that may 

adversely affect his/her ability to safely operate or maintain vehicles. 

A legally prescribed drug means that the individual has a prescription or other written approval 

from a physician for the use of a drug in the course of medical treatment. If the employee tests 

positive for drugs, he/she must provide within 24 hours a valid prescription. A valid prescription 

includes the patient's name, the name of the substance, quantity/amount to be taken, and the 

time period of the authorization. The misuse or abuse of legal drugs while performing transit 

business, in uniform or on transit property, is prohibited. 

4.3 Alcohol

The use of beverages containing alcohol or substances including any medication, mouthwash, 

food, candy or any other substance such that alcohol is present in the body while performing 

transit business is prohibited. The concentration of alcohol is expressed in terms of grams of 

alcohol per 210 liter of breath as measured by a breath-testing device. 

5.0 Prohibited Conduct

5.1 Manufacture, Trafficking, Possession and Use

All transit system employees are prohibited from engaging in the unlawful manufacture, 

distribution, dispensing, possession or use of prohibited substances on transit authority 

premises, in transit vehicles, in uniform, or while on transit authority business. Employees who 

violate this provision will be terminated. Law enforcement shall be notified, as appropriate, 

where criminal activity is suspected.

5.2 Intoxication/Under the Influence

Any safety-sensitive or non-safety-sensitive employee who is reasonably suspected of being 

intoxicated, impaired, under the influence of a prohibited substance, or not fit for duty shall be 

suspended from job duties pending an investigation and verification of condition. Employees 

who fail to pass a drug or alcohol test shall be removed from duty and referred to a Substance 

Abuse Professional (SAP). Failure of an employee to obtain a SAP evaluation and/or failure to 

follow the SAP’s recommended treatment plan will be cause for termination of employment. A 

drug or alcohol test is considered positive if the individual is found to have a quantifiable 

presence of a prohibited substance in the body above the minimum thresholds defined in 49 

CFR Part 40, as amended. Non-safety-sensitive employees are exempt under FTA regulations, 

but are governed under the MTA’s own policy authority as noted. 

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5.3 Alcohol Use

No safety-sensitive or non-safety-sensitive employee should report for duty or remain on duty 

when his/her ability to perform assigned duties is adversely affected by alcohol or when his/her 

breath alcohol concentration is 0.04 or greater. No safety-sensitive or non-safety-sensitive 

employee shall use alcohol while on duty, in uniform, while performing safety-sensitive 

functions, or just before or just after (20 minutes) performing a safety-sensitive function. No 

safety-sensitive employee shall use alcohol within four hours of reporting for duty, or during the 

hours that they are on call. Violation of these provisions is prohibited and is cause for

termination of employment. Non-safety-sensitive employees are exempt under FTA regulations, 

but are governed under the MTA’s own policy authority as noted. 

Not Negative Alcohol Test - (0.02 - 0.04) If an employee tests between 0.02 and 0.04 on an 

alcohol test, the employee will be removed from service for eight hours or unless a retest results 

in a concentration of less than 0.02. This absence will be considered an unexcused absence or 

loseout subject to MTA's disciplinary procedures.

5.4 Compliance with Testing Requirements

Under FTA guidelines, all safety-sensitive employees will be subject to urine drug testing and 

breath alcohol testing. Any safety-sensitive employee who refuses to comply with a request for 

testing shall be removed from duty, and consequences will be assessed. The MTA will consider

the test refusal to be a positive test, and the employee will be provided with a list of Substance 

Abuse Professionals (SAP) for evaluation. Failure of an employee to obtain an SAP evaluation 

and/or failure to follow the SAP’s recommended treatment plan will be cause for termination of 

employment. Any safety-sensitive employee who is suspected of providing false information in 

connection with a test, or who is suspected of falsifying test results through tampering, 

contamination, adulteration, or substitution will be required to undergo an observed collection. 

Verification of these actions will result in the employee's removal from duty and his/her 

employment terminated. Refusal can include an inability to provide a sufficient urine specimen 

or breath sample without a valid medical explanation, as well as, a verbal declaration, 

obstructive behavior, or physical absence resulting in the inability to conduct the test.

5.5 Treatment Requirements

All employees are encouraged to make use of the available resources for treatment of alcohol 

misuse, legal, and illegal drug use problems. Under certain circumstances, employees may be 

required to undergo treatment for substance abuse or alcohol misuse as explained in this policy. 

Any safety-sensitive employee who refuses or fails to comply with the SAP’s requirements for 

treatment, after care or return-to-duty directives, will be cause for termination of employment. 

Non-safety-sensitive employees also must adhere to these same guidelines. Non-safetysensitive employees are exempt under FTA guidelines, but adherence is regulated by the 

MTA’s own policy authority. The employee’s insurance provider will coordinate the cost of the 

treatment or rehabilitation services. Employees who do not have health insurance coverage are 

responsible for the entire cost of any recommended treatment or rehabilitation services. 

5.6 Notifying MTA of Criminal Drug Conviction

Appendix A. Example Policies (Des Moines MTA) Page A-73 

Apart from FTA regulations, but under MTA’s own authority, all employees are required to notify 

MTA of any criminal drug statute conviction for a violation within five working days after such 

conviction. 
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5.7 Proper Application of the Policy

The MTA is dedicated to assuring fair and equitable application of this substance abuse policy. 

Therefore, supervisors/managers are required to use and apply all aspects of this policy in an 

unbiased and impartial manner. Any supervisor/ manager who knowingly disregards the 

requirements of this policy, or who is found to deliberately misuse the policy in regard to 

subordinates, shall be subject to disciplinary action, up to and including termination of 

employment. 

5.8 Voluntary Treatment

The Des Moines Metro Transit Authority encourages employees to seek treatment voluntarily. 

Any employee who comes forth and notifies the MTA of an alcohol or chemical abuse problem 

will be provided assistance. This assistance will include a mandatory referral to the MTA’s 

Substance Abuse Professional (SAP) at the MTA’s expense. Employees are encouraged but 

not mandated to follow the SAP’s recommended treatment plan. An appropriate leave of 

absence may be granted for treatment and rehabilitation. Payment for treatment will be 

coordinated through the employee’s health insurance provider. Employees who do not have 

health insurance coverage are responsible for the entire cost of any recommended treatment or 

rehabilitation services. 

 

Voluntary requests for treatment must be made prior to any pending drug/alcohol test or 

disciplinary action. Employees will not be disciplined for requesting treatment, but will be 

expected to observe job performance standards and work rules as they apply to every employee. 

Any decision to seek help through the MTA will not interfere with an employee’s eligibility for 

promotional opportunities. Confidentiality of information will be maintained at all times. 

5.9 Non-Safety-Sensitive Employees

Apart from FTA regulations, but under MTA’s own authority, non-safety-sensitive employees 

who have a positive drug or alcohol test will be referred to the MTA’s Substance Abuse 

Professional (SAP) for assessment. The MTA will assist and encourage non-safety-sensitive 

employees to comply with the SAP’s recommended treatment plan. Employees will be 

expected to observe job performance standards and work rules as they apply to every 

employee. Depending upon the non-safety-sensitive employee’s job duties, the MTA reserves 

the right to remove the employee from his/her position and place the employee on an 

appropriate leave of absence. The MTA’s Designated Employer Representative (DER) will 

determine if the non-safety-sensitive employee is capable of safely and satisfactorily performing 

his/her essential job functions as outlined in the employee’s job description. 

5.10 Confidentiality

The MTA affirms the need to protect individual dignity, privacy and confidentiality throughout the 

testing process. Laboratory reports or test results shall not appear in an employee's general 

personnel file. Information of this nature will be contained in a separate confidential medical 

folder that will be kept under the control of the Personnel Director. The reports or test results 

may only be disclosed without an employee’s consent when: 

1. The information is compelled by law or by judicial or administrative process; 

Appendix A. Example Policies (Des Moines MTA) Page A-74 

2. The information has been placed at issue in a formal dispute between the employee and 

employer. 
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Employee must sign a separate release every time substance testing information is to be 

disclosed. The employee must sign releases anytime information is to be released to the 

employee, union representatives, subsequent employers, and to any other third party 

designated by the employee. 

6.0 Testing Procedures

Urine drug testing and breath testing for alcohol may be conducted when circumstances warrant 

or as required by federal regulations. All safety-sensitive employees shall be subject to drug 

testing prior to employment, for reasonable suspicion, random, and following an accident as 

defined in Section 6.2, 6.3, 6.4, 6.5 and 6.6 of this policy. In addition, all safety-sensitive 

employees will be tested prior to returning to duty after failing a random drug or alcohol test. 

Follow-up testing will be conducted for a period of one to five years based on the SAP’s 

recommendation, with at least six tests performed during the first year. Non-safety-sensitive 

employees will be subject to all testing except follow-up, return-to-duty and random testing 

under the MTA’s own authority and not FTA regulations. 

Testing shall be conducted in a manner to assure a high degree of accuracy and reliability and 

using techniques, equipment, and laboratory facilities that have been approved by the U. S. 

Department of Health and Human Services (DHHS). All testing will be conducted consistent 

with the procedures put forth in 49 CFR Part 40, as amended. 

The drugs that will be tested for include marijuana, cocaine, opiates, amphetamines, and 

phencyclidine. An initial drug screen will be conducted on each urine specimen. For those 

specimens that are not negative, a confirmatory Gas Chromatography/Mass Spectometry 

(GC/MS) test will be performed. The test will be considered positive if the amounts present are 

above the minimum thresholds established in 49 CFR Part 40, as amended. In instances where 

there is reason to believe an employee is abusing a substance other than the five drugs listed 

above, apart from FTA regulations, MTA reserves the right to test for additional drugs under 

MTA's own authority using standard laboratory testing protocols. 

All drug testing laboratory results will only be released to and reviewed by a qualified Medical 

Review Officer (MRO) in order to verify and validate test results. The MRO will release findings 

only to a Designated Employer Representative (DER). A MRO shall be a licensed physician 

who has knowledge of substance abuse disorders and has appropriate medical training to 

interpret and evaluate an individual’s confirmed positive test result. Before verifying that an 

employee has a positive test result, the MRO is responsible for contacting any such employee, 

on a direct and confidential basis, to determine whether the employee wishes to discuss the test

or present a legitimate explanation for the positive result. An MRO staff person may make the 

initial contact, but they are prohibited from gathering medical information. If, after reasonable 

efforts, the MRO is unable to reach the employee directly, the MRO may contact MTA’s DER for 

assistance in contacting the employee. MTA’s DER will take maximum precautions to preserve 

the confidentiality to the MRO contact. 

Appendix A. Example Policies (Des Moines MTA) Page A-75 

If, after making all diligent and reasonable efforts, neither the MRO nor MTA’s DER are able to 

contact the employee within ten (10) days of the date the MRO received the confirmed positive 

test result from the laboratory, the MRO may verify the test result as positive. The MRO may 

also verify the test result as positive if the employee does not contact the MRO within three (3) 

days of being contacted by MTA’s DER or the employee expressly declines the opportunity to 

discuss the test result. The MRO may reopen the verification of positive test if the employee 

presents documentation of serious injury or illness or other circumstances that unavoidably 
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prevented the employee from being contacted within the designated time period, and if the 

employee then presents a legitimate (in the MRO’s opinion) explanation for the positive test, the 

MRO shall declare the test to be negative. 

The MRO will review and interpret an individual’s medical history, including any medical records 

and biomedical information provided; affording the individual an opportunity to discuss the test 

result; and decide whether there is a legitimate medical explanation for the result, including 

legally prescribed medication. 

The MRO can declare a test invalid or canceled based on the regulations specified in 49 CFR 

Part 40. A canceled/invalid test is considered neither a positive nor a negative test. An 

example of a canceled test is a urine sample being rejected by the laboratory. The MRO shall 

cancel the test and report the cancellation and the reasons for it to the FTA, employer, and 

employee. A negative dilute specimen will not require a retest. 

Tests for breath alcohol concentration will be conducted utilizing a National Highway Traffic 

Safety Administration (NHTSA) approved evidential breath-testing device (EBT) operated by a 

trained breath alcohol technician (BAT). All breath alcohol test results will be reported only by 

an MRO or BAT to a Designated Employer Representative (DER). If the initial test indicates an 

alcohol concentration of 0.02 or greater, a second test will be performed to confirm the results of 

the initial test. A safety-sensitive or non-safety-sensitive employee who has a confirmed alcohol 

concentration of greater than 0.02 but less than 0.04 will be removed from his/her position for 

eight hours unless a retest results in a concentration measure of less then 0.02. The inability to 

perform a safety-sensitive or non-safety-sensitive duty due to an alcohol test result greater than 

0.02 but less than 0.04 will be considered an unexcused absence or loseout subject to MTA's 

disciplinary procedures. An alcohol concentration of 0.04 or greater will be considered a 

positive alcohol test and in violation of this policy and a violation of the requirements set forth in 

49 CFR Part 655 for safety-sensitive employees. Any safety-sensitive or non-safety-sensitive 

employee that has a confirmed positive drug or alcohol test will be removed from his/her 

position, informed of educational and rehabilitation programs available, and referred to a 

Substance Abuse Professional (SAP) for assessment. Non-safety-sensitive employees are 

exempt under FTA regulations, but are governed under the MTA’s own policy authority. 

6.1 Compensation for Testing

The MTA will pay employees for drug or alcohol testing according to the following: 

Paid Testing: (random, reasonable suspicion, follow-up, post injury and post-accident testing) 

Employees will be paid from the time they are notified of the testing and relieved of job duties or 

from the time they leave MTA property until such time as they are released by the supervisor 

escorting the employee. 

In the case of alcohol testing at the MTA, the employee will be paid from the time they report to 

the appropriate office until they have completed the test. 

Unpaid Testing: (pre-employment, pre-promotion or transfer, and return-to-work) Preemployment, pre-promotion or transfer and return-to-work testing will not be compensable. 

Appendix A. Example Policies (Des Moines MTA) Page A-76 
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FTA Drug and Alcohol Testing Program 

6.2 Split Specimen Testing

Any safety-sensitive or non-safety-sensitive employee who questions the results of a required 

drug test under paragraphs 6.2 through 6.8 of this policy may request that an additional test be 

conducted. This test must be conducted at a different DHHS-certified laboratory. The test must 

be conducted on the split sample that was provided by the employee at the same time as the 

original sample. All costs for such testing are paid by the employee unless the result of the split

sample testing invalidates the result of the original test. Under MTA's authority, not the FTA's, 

the expense for the split specimen testing shall be borne by the employee and will be collected

via a one-time payroll deduction upon receipt of bill of the split sample results. The method of 

collecting, storing, and testing the split sample will be consistent with the procedures set forth in 

49 CFR Part 40, as amended. The employee's request for a split sample test must be made to 

the Medical Review Officer within 72 hours of notice of the original sample verified test result. 

Requests after 72 hours will only be accepted if the delay was due to documentable facts that 

were beyond the control of the employee. Non-safety-sensitive employees are exempt under 

FTA regulations, but adherence is regulated by the MTA’s own policy authority. 

6.3 Pre-Employment Testing

All safety-sensitive and non-safety-sensitive position applicants shall undergo urine drug testing 

immediately following the offer of employment or transfer into a safety-sensitive position. 

Receipt by the transit system of a negative drug test result is required prior to employment. Preemployment drug tests may be administered only after the applicant has signed a consent form. 

Non-safety-sensitive applicants are tested apart from FTA regulations, but under MTA’s own 

policy. Failure of a pre-employment drug test will disqualify an applicant for employment at the 

MTA for at least six months. The MTA will reconsider a safety-sensitive applicant's application

for employment under the following conditions: 

1. At least six months has lapsed between applications; 

2. The applicant can show proof of successfully completing a substance abuse treatment 

program; 

3. The applicant must pass a new drug test; 

4. The applicant must be willing to be subjected to the random testing program devised for 

employees who have tested positive. 

Should a safety-sensitive employee be unavailable to perform job duties for a period of ninety 

(90) days or more, the employee will be required to submit to a pre-employment drug screen 

prior to returning to their safety-sensitive job duties. Employee’s transferring into a safetysensitive position will be required to submit and pass a pre-employment drug test prior to the 

transfer. 

6.4 Other Testing

Under MTA’s own policy authority and not FTA’s regulation all safety-sensitive and non-safetysensitive employees may be required to submit to drug testing in conjunction with any required 

physical examination. Required physical examinations may include but are not limited to worker 

compensation injuries or any leave of absence of 30 days or more. 

Appendix A. Example Policies (Des Moines MTA) Page A-77 
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FTA Drug and Alcohol Testing Program 

6.5 Reasonable Suspicion Testing

All safety-sensitive and non-safety sensitive employees may be subject to a fitness-for-duty 

evaluation, and urine and/or breath testing when there are reasons to believe that drug or 

alcohol use is adversely affecting job performance. Apart from FTA regulations, non-safetysensitive employees are governed under MTA’s own policy authority. A reasonable suspicion 

referral for testing will be made on the basis of specific, contemporaneous, and articulable 

observations concerning appearance, behavior, speech, or body odors of the employee 

consistent with possible drug use or alcohol misuse. An employee is reasonably suspected of 

prohibited drug use or alcohol misuse when a trained supervisor or other MTA authorized official 

can: 

 Substantiate specific behaviors that may indicate drug use or alcohol misuse. 

 Identify job performance problems that may indicate prohibited drug use or alcohol 

misuse. 

 Actually observe physical indications that prohibited drug use or alcohol misuse may be 

occurring. 

A supervisor or other MTA authorized official must make reasonable suspicion referrals. To 

make reasonable suspicion determinations, supervisors must be trained on the facts, 

circumstances, physical evidence, physical signs and symptoms, or patterns of performance 

and/or behaviors associated with drug use and/or alcohol misuse. One supervisor will complete

the MTA’s “Reasonable Suspicion” form, but two or more trained supervisors may participate in

the reasonable suspicion determination process. A copy of the completed form will be provided 

to the employee Suspicion" form will be completed by one supervisor and a copy given to the 

employee. 

6.6 Post-Accident Testing

All safety-sensitive employees will be required to undergo a urine drug test and breath alcohol 

test if they are involved in an FTA accident with a MTA transit vehicle (regardless of whether or 

not the vehicle is in revenue service). An FTA accident is defined as an occurrence associated

with the operation of a revenue service vehicle that results in a fatality, in injuries requiring 

immediate transportation to a medical treatment facility; or one or more vehicles incur disabling 

damage that requires towing from the site. Safety-sensitive employees that are on duty in the 

vehicle and any safety-sensitive employee whose performance could have contributed to the 

accident will be tested. Accident does not necessarily mean collision. If an individual falls on a 

vehicle and needs to be transported to a hospital, then an accident has occurred and a postaccident test is required unless the driver can be completely discounted as a contributing factor 

to the accident. This definition only applies to non-fatal accidents. Fatal accidents will result in 

safety-sensitive employees being tested as outlined below. 

Following an FTA accident, the safety-sensitive employee will be required to submit to a drug 

and alcohol test. Post-Accident testing is stayed while an employee assists in resolution of the 

accident or receives medical attention following the accident. However, employees must remain

readily available during the time periods stated below. Post-accident testing will be done as 

soon as possible, and no later than (8) eight hours after the accident for alcohol testing and (32) 

thirty-two hours after the accident for drug testing. An employee involved in an accident must 

not use alcohol until after the employee undergoes alcohol testing or eight hours have elapsed, 

which ever comes first. 

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Nothing in this policy shall be construed to require the delay of necessary medical attention for 

the injured following an accident or to prohibit an employee from leaving the scene of an 

accident for the period necessary to obtain assistance in responding to the accident or to obtain 

necessary emergency medical care. However, any employee who under the above 

circumstance fails to remain available for drug and alcohol testing (including notifying MTA of 

his/her location), or who otherwise leaves the scene of the accident without appropriate 

authorization prior to drug and alcohol testing, will be considered to have refused the test. 

49 CFR Part 40 allows the MTA to acquire post-accident test results obtained by Federal, State, 

or local law enforcement personnel in instances where the MTA is unavailable to perform postaccident testing. The results of a blood, urine or breath test for the use of prohibited drugs and 

alcohol misuse, conducted by Federal, State or local officials having independent authority for 

the test shall be considered to meet the FTA requirements provided such tests conform to the 

applicable Federal, State or local testing requirements and that the test results are obtained by 

the MTA. 

6.7 Random Testing

In accordance with 49 CFR Part 655, employees in safety-sensitive positions will be subjected 

to random, unannounced testing. The selection of safety-sensitive employees for random drug 

and alcohol testing will be made using a scientifically-valid method that ensures each covered 

employee that they will have an equal chance of being selected each time selections are made. 

The random tests will be unannounced and spread throughout the year. The FTA determines 

the testing percentages annually. All safety-sensitive employees will be placed in a common 

selection pool. Each employee in this pool will be matched with a unique random selection 

number. Through the use of a computer-based random number generation program, the 

required number of persons will be selected for each testing cycle throughout the year. All 

employees in the pool will remain in the random selection pool at all times throughout the year 

regardless of whether or not they have been previously selected. Employees who are not 

available for testing during the testing period will be removed from the random pool prior to the 

random selection drawing occurring. The MTA's Personnel Director or DER will access the 

selection pool numbers. Notification will be made to those who must submit a specimen or 

complete an alcohol breath test. The test may be completed prior to, during or after the 

employee's work shift. The employee will be immediately escorted to the medical facility for the 

test. As soon as the urine specimen is collected or breath test is completed the employee will 

be required to return to work, unless the breath test is not negative. 

6.8 Return-To-Duty Testing

All safety-sensitive employees who previously tested positive on a random drug or alcohol test 

must test negative (below 0.02 for alcohol) and be evaluated and released to duty by the 

Substance Abuse Professional before returning to work. If an employee refuses the return-toduty test, he/she will be considered as having a second positive drug or alcohol test and his/her 

employment with the MTA will be terminated. 

6.9 Follow-Up Testing

Safety-sensitive employees that have tested positive on a random test will be required to 

undergo frequent, unannounced random urine and/or breath testing following their return to duty 

after a positive drug/alcohol test and treatment. The follow-up testing will be performed for a 

Appendix A. Example Policies (Des Moines MTA) Page A-79 
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period of one to five years based on the SAP’s recommendations, however, a minimum of six 

tests to be performed the first year. 

7.0 Employment Assessment

Any safety-sensitive employee, who tests positive for the presence of illegal drugs or alcohol 

above the minimum thresholds set forth in 49 CFR Part 40, as amended, will be referred for 

evaluation to a Substance Abuse Professional (SAP). A SAP is a licensed or certified 

physician, psychologist, social worker, employee assistance professional or addiction counselor 

with knowledge of and clinical experience in the diagnosis and treatment of alcohol or drugrelated disorders. The SAP will evaluate each employee to determine what assistance, if any, 

the employee needs in resolving problems associated with prohibited drug use or alcohol 

misuse. If a safety-sensitive employee is allowed to return to duty, he/she must properly follow 

the rehabilitation program prescribed by the SAP, he/she must have a negative return-to-duty 

drug or alcohol test, and can be subject to unannounced follow-up tests for a period of one to 

five years. At least six follow-up tests are required in the first year following treatment. The 

employee’s insurance provider will coordinate the cost of treatment or rehabilitation services. 

Employees who do not have health coverage are responsible for the entire cost of any 

treatment or rehabilitation services. 

7.1 Consequences of a Positive Test

Effective April 15, 2002, the MTA will institute and maintain a zero tolerance policy for the 

following types of tests: Pre-employment, post-accident, and reasonable suspicion. A verified 

positive test for either post-accident, or reasonable suspicion will result in an employee’s 

immediate termination of employment with the MTA. 

The MTA will allow employees the ability to continue employment or what is considered a 

second chance for random tests only. Following a verified positive random test, the employee 

will be required to adhere to sections 6.8 and 6.9 of this policy. An employee who tests positive 

on a follow-up test following a positive random will be immediately discharged. Employees who 

test positive under random testing and subsequently returns to safety-sensitive duty will not be 

allowed to bid on or drive designated contracted school routes. 

8.0 Re-Entry Conditions

Safety-sensitive employees who re-enter the workforce after a confirmed positive test must 

agree to re-entry conditions. Those conditions may include (but are not limited to): 

1. A release to work statement from the Substance Abuse Professional. 

2. A negative test for drugs and/or alcohol. 

3. An employee signed agreement to unannounced frequent follow-up testing for a period 

of one to five years with at least six tests performed the first year. 

4. An employee signed agreement to follow specified after-care requirements with the 

understanding that violation of the re-entry conditions is grounds for termination of 

employment. 

If an employee has a second positive drug/alcohol test during the five-year period following a 

previously confirmed positive test, their employment with the MTA will be immediately 

terminated. 

Appendix A. Example Policies (Des Moines MTA) Page A-80 
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FTA Drug and Alcohol Testing Program 

9.0 Drug and Alcohol Program Manager (DAPM) and Designated Employer Representative 

(DER)

Any questions regarding this policy or any other aspect of MTA's substance abuse program 

should be addressed to the following transit system representatives: 

Drug and Alcohol Program Manager and Designated Employer Representative: 

Name: Debbie Wainwright 

Title: Personnel Director 

Address: 1100 MTA Lane, Des Moines, IA 50309 

Telephone Number: (515) 283-8111 

FAX Number: (515) 283-8135 

Assistant Drug and Alcohol Program Manager and Designated Employer Representative: 

Name: Donna Grange 

Title: Director of Operations - Paratransit

Address: 1100 MTA Lane, Des Moines, IA 50309 

Telephone Number: (515) 283-8111 

FAX Number: (515) 283-8135 

A complete copy of regulation 49 CFR Part 40, as amended, is available for review in the 

Personnel Department.

Medical Review Officers: 

Name: Dr. David Berg 

Title: Physician 

Address: 2100 Dixon, Suite 3 

Des Moines, IA 50316 

Telephone Number: (515) 265-1020 

Name: Dr. Anthony J. Sciorrotta

Title: Physician 

Address: 717 Lyon St., Suite D 

Des Moines, IA 50309 

Telephone Number: (515) 288-2269 

Employee Assistance Program: 

Name: Employee & Family Resources 

Address: Ins. Exchange Bldg., 505 Fifth Ave., Suite 600 

 Des Moines, IA 50309 

Telephone Number: (515) 244-6090 

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FTA Drug and Alcohol Testing Program 

Substance Abuse Professionals 

SAPs: Tom Reynolds or Mark Eikenberry 

Name: Employee & Family Resources 

Address: Ins. Exchange Bldg., 505 Fifth Ave, Suite 600 

 Des Moines, IA 50309 

Telephone Number: (515) 244-6090 

Direct any questions regarding substance abuse to the following crisis hotline: 

Foundation Two Crisis Line 1-800-332-4224 

Appendix A. Example Policies (Des Moines MTA) Page A-82 
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FTA Drug and Alcohol Testing Program 

Des Moines Metro Transit Authority

Safety-Sensitive Positions 

Revised March 1, 2002 

Transportation: 

Fixed Route Bus Operator (Full-Time) 

Fixed Route Bus Operator (Part Time) 

Fixed Route Dispatcher

Fixed Route Supervisor 

Paratransit: 

Paratransit Bus Operator (Full-Time) 

Paratransit Bus Operator (Part-Time) 

Paratransit Dispatcher (Full-Time) 

Paratransit Dispatcher (Part-Time) 

Paratransit Route Supervisor 

Paratransit Scheduler 

Maintenance: 

Mechanic 

Maintenance Director 

Tireperson 

Utility Person 

Service/Cleaner (Full-Time) 

Service/Cleaner (Part-Time) 

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FTA Drug and Alcohol Testing Program 

Board Resolution 

The Board of Trustees of the Des Moines Metropolitan Transit Authority hereby adopts the 

following resolution: 

Substance Abuse Policy Statement Resolution

The Board of Trustees adopted the Des Moines Metropolitan Transit Authority’s Policy 

on Drug and Alcohol Abuse at its board meeting on November 22, 1994, and revision of 

the original policy on November 18, 1997, August 22, 2000. A copy of the latest board 

approval is included in this policy. The Des Moines Metropolitan Transit Authority (MTA) 

is dedicated to providing safe, dependable and economical transportation services to our 

transit system passengers. MTA employees are our most valuable resource, and it is 

our goal to provide a healthy, satisfying work environment, which promotes personal 

opportunities for growth. In meeting these goals, it is our policy to: 

1. Assure that employees are not impaired in their ability to perform assigned duties 

in a safe, productive and healthy manner. 

2. Create a workplace environment free from the adverse effects of drug abuse and 

alcohol misuse. 

3. Prohibit the unlawful manufacture, distribution, dispensing, possession or use of 

controlled substances. 

4. Encourage employees to seek professional assistance anytime personal 

problems, including alcohol or drug dependency, adversely affects their ability to 

perform their assigned duties. 

Signed by Chair Jacqueline Easley, this ________ day of March, 2002. 

____________________________________ 

Jacqueline Easley

Chair 

Des Moines Metropolitan Transit Authority

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5. Ohio Department of Transportation 

 TABLE OF CONTENTS

A. PURPOSE 

B. APPLICABILITY 

C. DEFINITIONS 

D. EDUCATION AND TRAINING 

E. PROHIBITED SUBSTANCES 

F. PROHIBITED CONDUCT 

G. DRUG STATUTE CONVICTION

H. TESTING REQUIREMENTS 

I. DRUG TESTING PROCEDURES 

J. ALCOHOL TESTING PROCEDURES 

K. PRE-EMPLOYMENT TESTING 

L. REASONABLE SUSPICION TESTING 

M. POST-ACCIDENT TESTING 

N. RANDOM TESTING 

O. RETURN-TO-DUTY TESTING 

P. FOLLOW-UP TESTING 

Q. RESULT OF DRUG/ALCOHOL TEST 

R. GRIEVANCE AND APPEAL 

S. PROPER APPLICATION OF THE POLICY 

T. INFORMATION DISCLOSURE 

U. SYSTEM CONTACTS 

Attachment 1 Safety-Sensitive Positions 

Attachment 2 Alcohol Fact Sheet 

Appendix A. Example Policies (Ohio DOT) Page A-85 

Attachment 3 Minimum Thresholds 
Best Practices 

FTA Drug and Alcohol Testing Program 

DRUG AND ALCOHOL TESTING POLICY

_________________ Insert name of 

transit agency in 

the blanks. Adopted , 2001 

Underlined text = Transit Authority requirements

Regular text = FTA requirements 

A. PURPOSE

The _________________ provides public transit and paratransit services for 

the residents ______________________________. Part of our mission is to 

ensure that this service is delivered safely, efficiently, and effectively by 

establishing a drug and alcohol-free work environment, and to ensure that

the workplace remains free from the effects of drugs and alcohol in order to 

promote the health and safety of employees and the general public. In 

If your company 

policy is zero

tolerance, state so 

on this page.

keeping with this mission, _________________ declares that the unlawful 

manufacture, distribution, dispense, possession, or use of controlled 

substances or misuse of alcohol is prohibited for all employees.

All Underlined

sections are 

suggested 

employer 

provisions and not 

required by the 

FTA. Transit 

system’s must

decide if the 

sections are to be 

deleted, if they

remain, or if the 

provisions need to 

be changed to

reflect current 

transit system

policy, (i.e.,

disciplinary 

actions). 

Additionally, the purpose of this policy is to establish guidelines to maintain a 

drug and alcohol-free workplace in compliance with the Drug-Free 

Workplace Act of 1988, and the Omnibus Transportation Employee Testing 

Act of 1991. This policy is intended to comply with all applicable Federal 

regulations governing workplace anti-drug and alcohol programs in the 

transit industry. Specifically, the Federal Transit Administration (FTA) of the 

U.S. Department of Transportation has published 49 CFR Part 655, as 

amended, that mandates urine drug testing and breath alcohol testing for 

safety-sensitive positions, and prohibits performance of safety-sensitive 

functions when there is a positive test result. The U. S. Department of 

Transportation (USDOT) has also published 49 CFR Part 40, as amended, 

that sets standards for the collection and testing of urine and breath 

specimens. 

Any provisions set forth in this policy that are included under the sole 

authority of _________________ and are not provided under the authority of 

the above named Federal regulations are underlined. 

B. APPLICABILITY

This Drug and Alcohol Testing Policy applies to all safety-sensitive employees (full- or part-time) 

when performing any transit-related business. _________________ employees that do not

perform safety-sensitive functions are also covered under this policy under the sole authority of 

_________________. A safety-sensitive function is any duty related to the safe operation of 

mass transit service including the operation of a revenue service vehicle (whether or not the 

vehicle is in revenue service), maintenance of a revenue service vehicle or equipment used in 

revenue service, security personnel who carry firearms, dispatchers or person controlling the 

movement of revenue service vehicles and any other transit employee who is required to hold a 

Commercial Drivers License. Maintenance functions include the repair, overhaul, and rebuild of 

engines, vehicles and/or equipment used in revenue service. A list of safety-sensitive positions

who perform one or more of the above mentioned duties is provided in Attachment A. 

Supervisors are only safety sensitive if they perform one of the above functions.

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C. DEFINITIONS

Accident means an occurrence associated with the operation of a revenue service vehicle even 

when not in revenue service in revenue service or which requires a Commercial Drivers License 

to operate, if as a result--

(1) A person dies; 

(2) An individual suffers a bodily injury and immediately receives medical treatment away 

from the scene of the accident; or, 

(3) One or more vehicles incurs disabling damage as the result of the occurrence and is 

transported away from the scene by a tow truck or other vehicle. For purposes of this 

definition, disabling damage means damage which precludes departure of any vehicle from 

the scene of the occurrence in its usual manner in daylight after simple repairs. Disabling 

damage includes damage to vehicles that could have been operated but would have been 

further damaged if so operated, but does not include damage which can be remedied 

temporarily at the scene of the occurrence without special tools or parts, tire disablement 

without other damage even if no spare tire is available, or damage to headlights, taillights, 

turn signals, horn, mirrors or windshield wipers that makes them inoperative. 

Adulterated specimen. A specimen that contains a substance that is not expected to be present 

in human urine, or contains a substance expected to be present but is at a concentration so 

high that it is not consistent with human urine. 

Alcohol means the intoxicating agent in beverage alcohol, ethyl alcohol, or other low molecular 

weight alcohols contained in any beverage, mixture, mouthwash, candy, food, preparation or 

medication.

Alcohol Concentration is expressed in terms of grams of alcohol per 210 liters of breath as 

measured by an evidential breath testing device.

Canceled Test is a drug test that has been declared invalid by a Medical Review Officer. A 

canceled test is neither positive nor negative. 

Covered Employee means an employee who performs a safety-sensitive function including an 

applicant or transferee who is being considered for hire into a safety-sensitive function (See 

Attachment A for a list of covered employees), and other employees, applicants, or transferee 

that will not perform a safety-sensitive function but falls under the policy of the company’s own 

authority.

 

Designated Employer Representative (DER) An employee authorized by the employer to take 

immediate action to remove employees from safety-sensitive duties and to make required 

decisions in testing. The DER also receives test results and other communications for the 

employer, consistent with the requirements of 49 CFR Parts 40 and 655.

Department of Transportation (DOT) Department of the federal government which includes the 

US Coast Guard, Federal Transit Administration, Federal Railroad Administration, Federal 

Highway Administration, Federal Motor Carrier Safety Administration, Research and Special 

Programs, and the Office of the Secretary of Transportation. 

Dilute specimen. A specimen with creatinine and specific gravity values that are lower than 

expected for human urine. 

Appendix A. Example Policies (Ohio DOT) Page A-87 
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Disabling damage means damage which precludes departure of any vehicle from the scene of 

the occurrence in its usual manner in daylight after simple repairs. Disabling damage includes 

damage to vehicles that could have been operated but would have been further damaged if so 

operated, but does not include damage which can be remedied temporarily at the scene of the 

occurrence without special tools or parts, tire disablement without other damage even if no 

spare tire is available, or damage to headlights, taillights, turn signals, horn, mirrors or 

windshield wipers that makes them inoperative. 

Evidentiary Breath Testing Device (EBT) A Device approved by the NHTSA for the evidential 

testing of breath at the 0.02 and the 0.04 alcohol concentrations. Approved devices are listed 

on the National Highway Traffic Safety Administration (NHTSA) conforming products list. 

Medical Review Officer (MRO) means a licensed physician (medical doctor or doctor of 

osteopathy) responsible for receiving laboratory results generated by the drug testing program 

who has knowledge of substance abuse disorders, and has appropriate medical training to 

interpret and evaluate an individual's confirmed positive test result, together with his/her medical 

history, and any other relevant bio-medical information. 

Negative Dilute A drug test result which is negative for the five drug/drug metabolites but has a 

specific gravity value lower than expected for human urine. 

Negative test result for a drug test means a verified presence of the identified drug or its 

metabolite below the minimum levels specified in 49 CFR Part 40, as amended. An alcohol 

concentration of less than 0.02 BAC is a negative test result.

Non-negative test result is a test result found to be adulterated, substitute, invalid, or positive 

for drug/drug metabolites. 

 

Performing (a safety-sensitive function) means a covered employee is considered to be 

performing a safety-sensitive function and includes any period in which he or she is actually 

performing, ready to perform, or immediately available to perform such functions. 

Positive test result for a drug test means a verified presence of the identified drug or its 

metabolite at or above the minimum levels specified in 49 CFR Part 40, as amended. A positive 

alcohol test result means a confirmed alcohol concentration of 0.04 BAC or greater. 

Prohibited drug means marijuana, cocaine, opiates, amphetamines, or phencyclidine at levels 

above the minimum thresholds specified in 49 CFR Part 40, as amended. 

Revenue Service Vehicles include all transit vehicles that are used for passenger transportation 

service or that require a CDL to operate. Include all ancillary vehicles used in support of the 

transit system. 

Safety-sensitive functions include (a) the operation of a transit revenue service vehicle even 

when the vehicle is not in revenue service; (b) the operation of a non-revenue service vehicle by 

an employee when the operation of such a vehicle requires the driver to hold a Commercial 

Drivers License (CDL); (c) maintaining a revenue service vehicle or equipment used in revenue 

service; (d) controlling the movement of a revenue service vehicle; and (e) carrying a firearm for 

security purposes. 

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Substance Abuse Professional (SAP) means a licensed physician (medical doctor or doctor of 

osteopathy) or licensed or certified psychologist, social worker, employee assistance 

professional, or addiction counselor (certified by the National Association of Alcoholism and 

Drug Abuse Counselors Certification Commission or by the International Certification

Reciprocity Consortium/Alcohol and other Drug Abuse) with knowledge of and clinical 

experience in the diagnosis and treatment of drug and alcohol related disorders. 

Substituted specimen. A specimen with creatinine and specific gravity values that are so 

diminished that they are not consistent with normal human urine. 

Test Refusal The following are considered a refusal to test if the employee: 

• Fails to appear for any test (excluding pre-employment) within a reasonable time, as 

determined by the employer, after being directed to do so by the employer 

• Fails to remain at the testing site until the testing process is complete; 

• Fails to provide a urine or breath specimen for any drug or alcohol test required by Part 

40 or DOT agency regulations; 

• In the case of a directly observed or monitored collection in a drug test, fails to permit the 

observation or monitoring of your provision of a specimen 

• Fails to provide a sufficient amount of urine or breath when directed, and it has been 

determined, through a required medical evaluation, that there was no adequate medical 

explanation for the failure 

• Fails or declines to take a second test the employer or collector has directed you to take; 

• Fails to undergo a medical examination or evaluation, as directed by the MRO as part of 

the verification process, or as directed by the DER as part of the ``shy bladder'' or “shy 

lung” procedures 

• Fails to cooperate with any part of the testing process (e.g., refuse to empty pockets 

when so directed by the collector, behave in a confrontational way that disrupts the 

collection process). 

• If the MRO reports that there is verified adulterated or substituted test result 

• Failure or refusal to sign Step 2 of the alcohol testing form. 

Verified negative test means a drug test result reviewed by a medical review officer and 

determined to have no evidence of prohibited drug use above the minimum cutoff levels 

established by the Department of Health and Human Services (HHS). 

Verified positive test means a drug test result reviewed by a medical review officer and 

determined to have evidence of prohibited drug use above the minimum cutoff levels specified

in 49 CFR Part 40 as revised. 

Validity testing is the evaluation of the specimen to determine if it is consistent with normal 

human urine. The purpose of validity testing is to determine whether certain adulterants or 

foreign substances were added to the urine, if the urine was diluted, or if the specimen was 

substituted.

D. EDUCATION AND TRAINING

Every covered employee will receive a copy of this policy and will have ready access to the 

corresponding federal regulations including 49 CFR Parts 655 and 40, as amended. In addition, 

all covered employees will undergo a minimum of 60 minutes of training on the signs and 

symptoms of drug use including the effects and consequences of drug use on personal health, 

Appendix A. Example Policies (Ohio DOT) Page A-89 
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safety, and the work environment. The training also includes manifestations and behavioral 

cues that may indicate prohibited drug use. 

All supervisory personnel or company officials who are in a position to determine employee 

fitness for duty will receive 60 minutes of reasonable suspicion training on the physical, 

behavioral, and performance indicators of probable drug use and 60 minutes of additional 

reasonable suspicion training on the physical, behavioral, speech, and performance indicators

of probable alcohol misuse. Under the _________________’s own authority, supervisory 

personnel will also be trained on how to intervene constructively, and how to effectively 

integrate an employee back into his/her work group following intervention and/or treatment.

Information on the signs, symptoms, health effects, and consequences of alcohol misuse is 

presented in Attachment B of this policy. 

E. PROHIBITED SUBSTANCES

Prohibited substances addressed by this policy include the following. 

(1) Illegally Used Controlled Substance or Drugs Under the Drug-Free Workplace Act of 1988 

any drug or any substance identified in Schedule I through V of Section 202 of the 

Controlled Substance Act (21 U.S.C. 812), and as further defined by 21 CFR 1300.11 

through 1300.15 is prohibited at all times in the workplace unless a legal prescription has 

been written for the substance. This includes, but is not limited to: marijuana, 

amphetamines, opiates, phencyclidine (PCP), and cocaine, as well as any drug not 

approved for medical use by the U.S. Drug Enforcement Administration or the U.S. Food 

and Drug Administration. Illegal use includes use of any illegal drug, misuse of legally 

prescribed drugs, and use of illegally obtained prescription drugs. Also, the medical use of 

marijuana, or the use of hemp related products, as which cause drug or drug metabolites 

to be present in the body above the minimum thresholds is a violation of this policy. 

Federal Transit Administration drug testing regulations (49 CFR Part 655) require that all 

covered employees be tested for marijuana, cocaine, amphetamines, opiates, and 

phencyclidine as described in Section H of this policy. Illegal use of these five drugs is 

prohibited at all times, and thus covered employees may be tested for these drugs anytime 

that they are on duty. 

(2) Legal Drugs: The appropriate use of legally prescribed drugs and non-prescription 

medications is not prohibited. However, the use of any substance which carries a warning 

label that indicates that mental functioning, motor skills, or judgment may be adversely 

affected must be reported to a _________________ supervisor and the employee is 

required to provide a written release from his/her doctor or pharmacist indicating that the 

employee can perform his/her safety-sensitive functions.

(3) Alcohol: The use of beverages containing alcohol (including any mouthwash, medication, 

food, candy) or any other substances such that alcohol is present in the body while 

performing safety-sensitive job functions is prohibited. An alcohol test can be performed on 

a covered employee under 49 CFR Part 655 just before, during, or just after the 

performance of safety-sensitive job functions. Under _________________ authority, an

alcohol test can be performed any time a covered employee is on duty.

Appendix A. Example Policies (Ohio DOT) Page A-90 
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FTA Drug and Alcohol Testing Program 

F. PROHIBITED CONDUCT

(1) All covered employees are prohibited from reporting for duty or remaining on duty any time 

there is a quantifiable presence of a prohibited drug in the body above the minimum 

thresholds defined in 49 CFR PART 40, as amended. 

(2) Each covered employee is prohibited from consuming alcohol while performing safetysensitive job functions or while on-call to perform safety-sensitive job functions. If an on-call 

employee has consumed alcohol, they must acknowledge the use of alcohol at the time that 

they are called to report for duty. The covered employee will subsequently be relieved of 

his/her on-call responsibilities and subject to discipline. 

(3) The Transit Department shall not permit any covered employee to perform or continue to 

perform safety-sensitive functions if it has actual knowledge that the employee is using 

alcohol. 

(4) Each covered employee is prohibited from reporting to work or remaining on duty requiring 

the performance of safety-sensitive functions while having an alcohol concentration of 0.04 

or greater regardless of when the alcohol was consumed. 

(5) No covered employee shall consume alcohol for eight (8) hours following involvement in an 

accident or until he/she submits to the post-accident drug/alcohol test, whichever occurs 

first. 

(6) No covered employee shall consume alcohol within four (4) hours prior to

the performance of safety-sensitive job functions. 

The four hours 

may be

increased under 

the company’s 

own authority.

(7) _________________, under its own authority also prohibits the 

consumption of alcohol all times employee is on duty, or anytime the 

employee is in uniform. 

(8) Consistent with the Drug-Free Workplace Act of 1988, all _________________ employees 

are prohibited from engaging in the unlawful manufacture, distribution, dispensing, 

possession, or use of prohibited substances in the work place including Transit Department 

premises, transit vehicles, while in uniform or while on _________________ business. 

G. DRUG STATUTE CONVICTION

Consistent with the Drug Free Workplace Act of 1998, all employees are required to notify the 

_________________ management of any criminal drug statute conviction for a violation 

occurring in the workplace within five days after such conviction. Failure to comply with this 

provision shall result in disciplinary action as defined in Section Q.10 of this policy. 

H. TESTING REQUIREMENTS

If you are a 

zero-tolerance 

company, 

restate it at the 

end of this 

section. 

Analytical urine drug testing and breath testing for alcohol will be conducted 

as required by 49CFR part 40 as amended. All covered employees shall be 

subject to testing prior to employment, for reasonable suspicion, following an 

accident, and random as defined in Section K, L, M, and N of this policy. All 

covered employees who have tested positive for drugs or alcohol on a 

random, reasonable suspicion, or post-accident will be tested prior to returning 

to duty after completion of the Substance Abuse Professional's recommended 

treatment program and subsequent release to duty. Follow-up testing will also 

be conducted following return-to-duty for a period of one to five years, with at 

least six tests performed during the first year. The duration and frequency of 

the follow-up testing above the minimum requirements will be at the discretion 

of the Substance Abuse Professional. 

Appendix A. Example Policies (Ohio DOT) Page A-91 
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FTA Drug and Alcohol Testing Program 

A drug test can be performed any time a covered employee is on duty. An alcohol test can be 

performed just before, during, or after the performance of a safety-sensitive job function.

Under _________________ authority, an alcohol test can be performed any time a covered 

employee is on duty.

All covered employees will be subject to urine drug testing and breath alcohol testing as a 

condition of ongoing employment with _________________. Any safety-sensitive employee 

who refuses to comply with a request for testing shall be removed from duty and subject to 

discipline as defined in Section Q.3 of this policy. Any covered employee who is suspected of 

providing false information in connection with a drug test, or who is suspected of falsifying test 

results through tampering, contamination, adulteration, or substitution will be required to 

undergo an observed collection. Verification of the above listed actions will be considered a test 

refusal and will result in the employees removal from duty and disciplined as defined in Section 

Q.3 of this policy. Refer to Section C 3 for behavior that constitutes a refusal to test. 

I. DRUG TESTING PROCEDURES

Testing shall be conducted in a manner to assure a high degree of accuracy and reliability and 

using techniques, equipment, and laboratory facilities which have been approved by the U.S. 

Department of Health and Human Service (HHS). All testing will be conducted consistent with 

the procedures set forth in 49 CFR Part 40, as amended. The procedures will be performed in a 

private, confidential manner and every effort will be made to protect the employee, the integrity 

of the drug testing procedure, and the validity of the test result. 

The drugs that will be tested for include marijuana, cocaine, opiates, amphetamines, and 

phencyclidine. After the identity of the donor is checked using picture identification, a urine 

specimen will be collected using the split specimen collection method described in 49 CFR Part 

40, as amended. Each specimen will be accompanied by a DOT Chain of Custody and Control 

Form and identified using a unique identification number that attributes the specimen to the 

correct individual. The specimen analysis will be conducted at a HHS certified laboratory. An 

initial drug screen and validity test will be conducted on the primary urine specimen. For those 

specimens that are not negative, a confirmatory Gas Chromatography/Mass Spectrometry 

(GC/MS) test will be performed. The test will be considered positive if the amounts of the 

drug(s) and/or its metabolites identified by the GC/MS test are above the minimum thresholds 

established in 49 CFR Part 40, as amended. 

The test results from the HHS certified laboratory will be reported to a Medical Review Officer 

(MRO). An MRO is a licensed physician with detailed knowledge of substance abuse disorders 

and drug testing. The MRO will review the test results to ensure the scientific validity of the test 

and to determine whether there is a legitimate medical explanation for a confirmed positive, 

substitute , or adulterated test result. The MRO will attempt to contact the employee to notify 

the employee of the non-negative laboratory result, and provide the employee with an 

opportunity to explain the confirmed laboratory test result. The MRO will subsequently review 

the employee’s medical history/medical records as appropriate to determine whether there is a 

legitimate medical explanation for a non-negative laboratory result. If no legitimate medical 

explanation is found, the test will be verified positive or refusal to test and reported to the 

_________________ Drug and Alcohol Program Manager (DAPM). If a legitimate explanation 

is found, the MRO will report the test result as negative to the DAPM and no further action will 

be taken. If the test is invalid with out a medical explanation, a retest will be conducted under 

direct observation. 

Appendix A. Example Policies (Ohio DOT) Page A-92 
Best Practices 

FTA Drug and Alcohol Testing Program 

Any covered employee who questions the results of a required drug test under paragraphs L 

through P of this policy may request that the split sample be tested. The split sample test must 

be conducted at a second HHS-certified laboratory with no affiliation with the laboratory that 

analyzed the primary specimen. The test must be conducted on the split sample that was 

provided by the employee at the same time as the primary sample. The method of collecting,

storing, and testing the split sample will be consistent with the procedures set forth in 49 CFR 

Part 40, as amended. The employee's request for a split sample test must be made to the 

Medical Review Officer within 72 hours of notice of the original sample verified test result. 

Requests after 72 hours will only be accepted at the discretion of the MRO if the delay was due 

to documentable facts that were beyond the control of the employee. _________________ will 

ensure that the cost for the split specimen are covered in order for a timely analysis of the 

sample, however _________________will seek reimbursement for the split sample test from 

the employee. 

If the analysis of the split specimen fails to confirm the presence of the drug(s) detected in the 

primary specimen, if the split specimen is not able to be analyzed, or if the results of the split 

specimen are not scientifically adequate, the MRO will declare the original test to be canceled 

and will direct _________________ to retest the employee under direct observation. 

The split specimen will be stored at the initial laboratory until the analysis of the primary 

specimen is completed. If the primary specimen is negative, the split will be discarded. If the 

primary is positive, the split will be retained for testing if so requested by the employee through 

the Medical Review Officer. If the primary specimen is positive, it will be retained in frozen 

storage for one year and the split specimen will also be retained for one year. 

Observed collections: 

 

Consistent with 49 CFR part 40, as amended, collection under direct observation (by a person 

of the same gender) with no advance notice will occur if: 

 (1) The laboratory reports to the MRO that a specimen is invalid, and the MRO reports to 

____________________ that there was not an adequate medical explanation for the result; or 

 (2) The MRO reports to _______________________ that the original positive, adulterated, or 

substituted test result had to be cancelled because the test of the split specimen could not be 

performed. 

 (3) The collector observes materials brought to the collection site or the employee's conduct 

clearly indicates an attempt to tamper with a specimen or 

 (4) The temperature on the original specimen was out of range. 

 

In addition, _________________________ may direct a collection under direct observation of 

an employee if the drug test is a return-to-duty test or a follow-up test. 

J. ALCOHOL TESTING PROCEDURES

Appendix A. Example Policies (Ohio DOT) Page A-93 

Tests for breath alcohol concentration will be conducted utilizing a National Highway Traffic 

Safety Administration (NHTSA)-approved Evidential Breath Testing device (EBT) operated by a 

trained Breath Alcohol Technician (BAT). Alcohol screening tests may be performed using a 

non-evidential testing device which is also approved by NHSTA. If the initial test indicates an 

alcohol concentration of 0.02 or greater, a second test will be performed to confirm the results of 

the initial test. The confirmatory test must occur on an EBT. The confirmatory test will be 

conducted at least fifteen minutes after the completion of the initial test. The confirmatory test 

will be performed using a NHTSA-approved EBT operated by a trained BAT. The EBT will 
Best Practices 

FTA Drug and Alcohol Testing Program 

identify each test by a unique sequential identification number. This number, time, and unit 

identifier will be provided on each EBT printout. The EBT printout, along with an approved 

alcohol testing form, will be used to document the test, the subsequent results, and to attribute 

the test to the correct employee. The test will be performed in a private, confidential manner as 

required by 49 CFR Part 40, as amended. The procedure will be followed as prescribed to 

protect the employee and to maintain the integrity of the alcohol testing procedures and validity 

of the test result. 

An employee who has a confirmed alcohol concentration of 0.04 or greater will be considered a 

positive alcohol test and in violation of this policy. The consequences of a positive alcohol test 

are described in Section Q.4-5 of this policy. Even though an employee who has a confirmed 

alcohol concentration of 0.02 to 0.039 is not considered positive, the employee shall still be 

removed from duty for at least eight hours or for the duration of the work day whichever is 

longer and will be subject to the consequences described in Section Q.9 of this policy. An 

alcohol concentration of less than 0.02 will be considered a negative test. 

The Transit Department affirms the need to protect individual dignity, privacy, and confidentiality 

throughout the testing process. If at any time the integrity of the testing procedures or the 

validity of the test results is compromised, the test will be canceled. Minor inconsistencies or 

procedural flaws that do not impact the test result will not result in a cancelled test. 

The alcohol testing form (ATF) required by 49 CFR Part 40 as amended, shall be used for all 

FTA required testing. Failure of an employee to sign step 2 of the ATF will be considered a 

refusal to submit to testing. 

K. PRE-EMPLOYMENT TESTING

All applicants for covered transit positions shall undergo urine drug testing and breath alcohol 

testing prior to performance of a safety-sensitive function. 

(1) All offers of employment for covered positions shall be extended conditional upon 

the applicant passing a drug and alcohol test test. An applicant shall not be hired 

into a covered position unless the applicant takes a drug test with verified 

negative results, and an alcohol concentration below 0.02.

(2) A non-covered employee shall not be placed, transferred or promoted into a 

covered position until the employee takes a drug test with verified negative 

results and an alcohol concentration below 0.02.

(3) If an applicant fails a pre-employment drug or alcohol test, the conditional offer 

of employment shall be rescinded. Failure of a pre-employment drug and/or 

alcohol test will disqualify an applicant for employment for a period of at least one 

year. Evidence of the absence of drug dependency from a Substance Abuse 

Professional that meets with 49 CFR part 40 as amended and a negative preemployment drug test and an alcohol concentration below 0.02 will be required 

prior to further consideration for employment. The cost for the assessment and 

any subsequent treatment will be the sole responsibility of the applicant.

(4) When an employee being placed, transferred, or promoted from a non-covered 

position to a covered position submits a drug test with a verified positive result,

and an alcohol concentration below 0.02 the employee shall be subject to

disciplinary action in accordance with Section Q.4-5 and 9 herein. 

(5) If a pre-employment/pre-transfer test is canceled, _________________ will 

require the applicant to take and pass another pre-employment drug test. 

Appendix A. Example Policies (Ohio DOT) Page A-94 
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FTA Drug and Alcohol Testing Program 

(6) In instances where a covered employee is on extended leave for a period of 90 

days or more regardless of reason, the employee will be required to take a drug 

and alcohol test under 49 CFR Part 655 and have negative test results prior to 

the conduct of safety-sensitive job functions. 

(7) An applicant with a dilute negative test result will be required to retest.

(8) Applicants are required to report previous DOT covered employer drug and 

alcohol test results—Failure to do so will result in the employment offer being 

rescinded. 

L. REASONABLE SUSPICION TESTING

All _________________ covered employees will be subject to a reasonable suspicion drug 

and/or alcohol test when there are reasons to believe that drug or alcohol use is impacting job 

performance and safety. Reasonable suspicion shall mean that there is objective evidence, 

based upon specific, contemporaneous, articulable observations of the employee's appearance, 

behavior, speech or body odor that are consistent with possible drug use and/or alcohol misuse. 

Reasonable suspicion referrals must be made by one supervisor who is trained to detect the 

signs and symptoms of drug and alcohol use, and who reasonably concludes that an employee 

may be adversely affected or impaired in his/her work performance due to possible prohibited 

substance abuse or alcohol misuse. A reasonable suspicion alcohol test can only be conducted 

just before, during, or just after the performance of a safety-sensitive job function. However, 

under _________________’s authority, a reasonable suspicion alcohol test may be performed 

any time the covered employee is on duty. A reasonable suspicion drug test can be performed 

any time the covered employee is on duty. 

_________________ shall be responsible for transporting the employee to the testing site. 

Supervisors should avoid placing themselves and/or others into a situation which might 

endanger the physical safety of those present. The employee shall be placed on administrative 

leave pending disciplinary action described in Section Q.4-5 and 9 of this policy. An employee 

who refuses an instruction to submit to a drug/alcohol test shall not be permitted to finish his or 

her shift and shall immediately be placed on administrative leave pending disciplinary action as 

specified in Section Q.3 of this policy. 

A written record of the observations which led to a drug/alcohol test based on reasonable 

suspicion shall be prepared and signed by the supervisor making the observation prior to the 

release of the test results. This written record shall be submitted to the _________________ 

management and shall be attached to the forms reporting the test results. 

When there are no specific, contemporaneous, articulable objective facts that indicate current 

drug or alcohol use, but the employee (who is not already a participant in a treatment program) 

admits the abuse of alcohol or other substances to a supervisor in his/her chain of command, 

the employee shall be referred to the SAP for an assessment. _________________ shall place 

the employee on administrative leave in accordance with the provisions set forth under Section 

Q.9 of this policy. Testing in this circumstance would be performed under the direct authority of 

the _________________. Since the employee self-referred to management, testing under this 

circumstance would not be considered a violation of this policy or a positive test result under 

Federal authority. However, self-referral does not exempt the covered employee from testing

under Federal authority as specified in Sections L through N of this policy or the associated 

consequences as specified in Section Q.9. 

Appendix A. Example Policies (Ohio DOT) Page A-95 
Best Practices 

FTA Drug and Alcohol Testing Program 

M. POST-ACCIDENT TESTING

All covered employees will be required to undergo urine and breath testing if they are involved 

in an accident with a transit revenue service vehicle regardless of whether or not the vehicle is 

in revenue service that results in a fatality. This includes all surviving covered employees that 

are operating the vehicle at the time of the accident and any other whose performance cannot 

be completely discounted as a contributing factor to the accident. 

In addition, a post-accident test will be conducted if an accident results in injuries requiring 

immediate transportation to a medical treatment facility; or one or more vehicles incurs disabling 

damage, unless the operators performance can be completely discounted as a contributing 

factor to the accident. 

(1) As soon as practicable following an accident, as defined in this policy, the transit 

supervisor investigating the accident will notify the transit employee operating the 

transit vehicle and all other covered employees whose performance could have 

contributed to the accident of the need for the test. The supervisor will make the 

determination using the best information available at the time of the decision. 

(2) The appropriate transit supervisor shall ensure that an employee, required to be 

tested under this section, is tested as soon as practicable, but no longer than 

eight (8) hours of the accident for alcohol, and within 32 hours for drugs. If an 

alcohol test is not performed within two hours of the accident, the Supervisor will 

document the reason(s) for the delay. If the alcohol test is not conducted within 

(8) eight hours, or the drug test within 32 hours, attempts to conduct the test 

must cease and the reasons for the failure to test documented. 

(3) Any covered employee involved in an accident must refrain from alcohol use for 

eight (8) hours following the accident, or until he/she undergoes a post-accident 

alcohol test. 

(4) An employee who is subject to post-accident testing who fails to remain readily 

available for such testing, including notifying a supervisor of his or her location if 

he or she leaves the scene of the accident prior to submission to such test, may 

be deemed to have refused to submit to testing. 

(5) Nothing in this section shall be construed to require the delay of necessary 

medical attention for the injured following an accident, or to prohibit an employee 

from leaving the scene of an accident for the period necessary to obtain 

assistance in responding to the accident, or to obtain necessary emergency 

medical care. 

(6) In the rare event that _________________ is unable to perform an FTA drug and 

alcohol test (i.e., employee is unconscious, employee is detained by law 

enforcement agency), _________________ may use drug and alcohol postaccident test results administered by local law enforcement officials in lieu of the 

FTA test. The local law enforcement officials must have independent authority 

for the test and the employer must obtain the results in conformance with local 

law. 

N. RANDOM TESTING

All covered employees will be subjected to random, unannounced testing. The selection of 

employees shall be made by a scientifically valid method of randomly generating an employee 

identifier from the appropriate pool of safety-sensitive employees. 

Appendix A. Example Policies (Ohio DOT) Page A-96 
Best Practices 

FTA Drug and Alcohol Testing Program 

(1) The dates for administering unannounced testing of randomly selected 

employees shall be spread reasonably throughout the calendar year. 

(2) The number of employees randomly selected for drug/alcohol testing during the 

calendar year shall be not less than the percentage rates established by Federal 

regulations for those safety-sensitive employees subject to random testing by 

Federal regulations. The current random testing rate for drugs established by 

FTA equals fifty percent of the number of covered employees in the pool and the 

random testing rate for alcohol established by FTA equals ten percent of the 

number of covered employees in the pool. 

(3) Each covered employee shall be in a pool from which the random selection is 

made. Each covered employee in the pool shall have an equal chance of 

selection each time the selections are made. Employees will remain in the pool 

and subject to selection, whether or not the employee has been previously 

tested. There is no discretion on the part of management in the selection and 

notification of the individuals who are to be tested. 

(4) Covered transit employees that fall under the Federal Transit Random test pools 

can include any 

DOT covered 

employee. If you 

have both FTA and

FMCSA covered 

employees, they 

can be in the same 

pool. 

Administration regulations will be included in one random 

pool maintained separately from the testing pool of 

employees that are included solely under 

_________________ authority. 

(5) Random tests can be conducted at any time during an 

employee’s shift for drug testing. Alcohol random tests can 

be performed just before, during, or just after the 

performance of a safety sensitive duty. However, under the 

_________________’s authority, a random alcohol test may 

 be performed any time the covered employee is on duty. 

Testing can occur during the beginning, middle, or end of an

employee’s shift. 

Each employer

defines a 

reasonable time for 

reporting for a 

random test. (6) Employees are required to proceed immediately to the 

collection site upon notification of their random selection. 

O. RETURN-TO-DUTY TESTING

All covered employees who previously tested positive on a drug or alcohol 

test or refused a test, must test negative for drugs, alcohol (below 0.02 for 

alcohol), or both and be evaluated and released by the Substance Abuse 

Professional before returning to work. For an initial positive drug test a 

Return-to-Duty drug test is required and an alcohol test is allowed. For an 

initial positive alcohol test a Return-to-Duty alcohol test is required and a

drug test is allowed. Following the initial assessment, the SAP will 

recommend a course of rehabilitation unique to the individual. The SAP 

will recommend the return-to-duty test only when the employee has 

successfully completed the treatment requirement and is known to be drugand alcohol-free and there is no undo concerns for public safety. 

If you are a zerotolerance company, 

restate so before 

this section.

P. FOLLOW-UP TESTING

Appendix A. Example Policies (Ohio DOT) Page A-97 

Covered employees will be required to undergo frequent, unannounced drug and alcohol testing 

following their return-to-duty. The follow-up testing will be performed for a period of one to five 

years with a minimum of six tests to be performed the first year. The frequency and duration of 

the follow-up tests (beyond the minimums) will be determined by the SAP reflecting the SAP’s 
Best Practices 

FTA Drug and Alcohol Testing Program 

assessment of the employee’s unique situation and recovery progress. Follow-up testing 

should be frequent enough to deter and/or detect a relapse. Follow-up testing is separate and 

in addition to the random, post-accident, reasonable suspicion and return-to-duty testing. 

Q. RESULT OF DRUG/ALCOHOL TEST

Any covered employee that has a verified positive drug or alcohol test will be removed from 

his/her safety-sensitive position, informed of educational and rehabilitation programs available, 

and referred to a Substance Abuse Professional (SAP) for assessment. No employee will be 

allowed to return to duty requiring the performance of safety-sensitive job functions without the 

approval of the SAP. 

A positive drug and/or alcohol test will also result in disciplinary action as specified herein. 

(1) As soon as practicable after receiving notice of a verified positive drug test result, 

a confirmed alcohol test result, or a test refusal, the _________________ Drug 

and Alcohol Program Manager will contact the employee’s supervisor to have the 

employee cease performing any safety-sensitive function. 

(2) The employee shall be referred to a Substance Abuse Professional for an

assessment. The SAP will evaluate each employee to determine what 

assistance, if any, the employee needs in resolving problems associated with 

prohibited drug use or alcohol misuse. 

(3) Refusal to submit to a drug/alcohol test shall be considered a positive test result 

and a direct act of insubordination and shall result in termination. A test refusal 

includes the following circumstances. 

(a) A covered employee who consumes alcohol within eight (8) hours following

involvement in an accident without first having submitted to post-accident 

drug/alcohol tests. 

(b) A covered employee who leaves the scene of an accident without a legitimate 

explanation prior to submission to drug/alcohol tests. 

(c) A covered employee who is suspected of providing false information in 

connection with a drug test. 

(d) A covered employee who provides an insufficient volume of urine specimen 

or breath sample without a valid medical explanation. The medical evaluation 

shall take place within 5 days of the initial test attempt. 

(e) A verbal or written declaration, obstructive behavior, or physical absence

resulting in the inability to conduct the test within the specified time frame.

(f) A covered employee whose urine sample has been verified by the MRO as 

substitute or adulterated.

(g) A covered employee fails to appear for any test within a reasonable time, as 

determined by the employer, after being directed to do so by the employer 

(h) A covered employee fails to remain at the testing site until the testing process 

is complete;

(i) A covered employee fails to provide a urine specimen for any drug test 

required by Part 40 or DOT agency regulations; 

(j) A covered employee fails to permit the observation or monitoring of a 

specimen collection 

(k) A covered employee fails or declines to take a second test the employer or 

collector has directed you to take; 

Appendix A. Example Policies (Ohio DOT) Page A-98 
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FTA Drug and Alcohol Testing Program 

(l) A covered employee fails to undergo a medical examination or evaluation, as 

directed by the MRO as part of the verification process, or as directed by the 

DER as part of the “shy bladder” or “shy lung” procedures 

(m) A covered employee fails to cooperate with any part of the testing process 

(e.g., refuse to empty pockets when so directed by the collector, behave in a 

confrontational way that disrupts the collection process). 

(n) Failure to sign Step 2 of the Alcohol Testing form 

 (4) For the first instance of a verified positive test from a sample 

submitted as the result of a random, drug/alcohol test (≥

0.04 BAC), disciplinary action against the employee shall 

include:

If your policy is 

zero tolerance this

section must be 

removed.

(a) Mandatory referral to Substance Abuse Professional 

for assessment, formulation of a treatment plan, and 

execution of a return to work agreement;

(b) Failure to execute, or remain compliant with the 

return-to-work agreement shall result in termination 

from _________________ employment.

♦ Compliance with the return-to-work agreement 

means that the employee has submitted to a 

drug/alcohol test immediately prior to returning to

work; the result of that test is negative; in the 

judgement of the SAP the employee is 

cooperating with his/her SAP recommended 

treatment program; and, the employee has 

agreed to periodic unannounced follow-up testing 

as defined in Section P of this policy;

(c) Refusal to submit to a periodic unannounced followup drug/alcohol test shall be considered a direct act 

of insubordination and shall result in termination.

(d) A periodic unannounced follow-up drug/alcohol test 

which results in a verified positive shall result in 

termination from __________ employment. 

(5) The second instance of a verified positive drug or alcohol (≥ 0.04 BAC) test result 

including a sample submitted under the random, reasonable suspicion, return-toduty, or follow-up drug/alcohol test provisions herein shall result in termination 

from _________________ employment.

(6) A verified positive post-accident, or reasonable suspicion drug and/or alcohol (≥

0.04) test shall result in termination. 

(7) An alcohol test result of ≥0.02 to ≤ 0.039 BAC shall result in the removal of the 

employee from duty for eight hours or the remainder or the work day whichever is 

longer. The employee will not be allowed to return to safety-sensitive duty for 

his/her next shift until he/she submits to an alcohol test with a result of less than 

0.02 BAC. If the employee has an alcohol test result of ≥ 0.02 to ≤ 0.039 two or 

more times within a six month period, the employee will be removed from duty 

and referred to the SAP for assessment and treatment consistent with Section 

Q.9 of this policy.

(8) The cost of any treatment or rehabilitation services will be paid directly by the 

employee or their insurance provider. The employee will be permitted to take 

accrued sick leave or administrative leave to participate in the SAP prescribed 

treatment program. If the employee has insufficient accrued leave, the 

Appendix A. Example Policies (Ohio DOT) Page A-99 
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employee shall be placed on leave without pay until the SAP has determined 

that the employee has successfully completed the required treatment program 

and releases him/her to return-to-duty. Any leave taken, either paid or unpaid, 

shall be considered leave taken under the Family and Medical Leave Act. 

(9) In the instance of a self-referral or a management referral, disciplinary action 

against the employee shall include:

(a) Mandatory referral to a Substance Abuse Professional for assessment, 

formulation of a treatment plan, and execution of a return to work 

agreement;

(b) Failure to execute, or remain compliant with the return-to-work agreement 

shall result in termination from _________________ employment.

♦ Compliance with the return-to-work agreement means that the 

employee has submitted to a drug/alcohol test immediately prior to 

returning to work; the result of that test is negative; in the judgment of 

the SAP the employee is cooperating with his/her SAP recommended 

treatment program; and, the employee has agreed to periodic 

unannounced follow-up testing as defined in Section P of this policy;

(c) Refusal to submit to a periodic unannounced follow-up drug/alcohol test 

shall be considered a direct act of insubordination and shall result in 

termination. 

(d) A self-referral or management referral to the SAP that was not 

precipitated by a positive test result does not constitute a violation of the 

Federal regulations and will not be considered as a positive test result in 

relation to the progressive discipline defined in Section Q.4-5 of this 

policy. 

(e) Periodic unannounced follow-up drug/alcohol test conducted as a result 

of a self-referral or management referral which results in a verified 

positive shall be considered a positive test result in relation to the 

progressive discipline defined in Section Q.4-5 of this policy.

(f) A Voluntary Referral does not shield an employee from disciplinary action

or guarantee employment with _________________.

(g) A Voluntary Referral does not shield an employee from the requirement 

to comply with drug and alcohol testing.

(10) Failure of an employee to report within five days a criminal drug statute 

conviction for a violation occurring in the workplace shall result in termination.

R. GRIEVANCE AND APPEAL

The consequences specified by 49 CFR Part 655 for a positive test or test refusal are not 

subject to arbitration. 

S. PROPER APPLICATION OF THE POLICY

_________________ is dedicated to assuring fair and equitable application of this substance 

abuse policy. Therefore, supervisors/managers are required to use and apply all aspects of this 

policy in an unbiased and impartial manner. Any supervisor/manager who knowingly disregards 

the requirements of this policy, or who is found to deliberately misuse the policy in regard to 

subordinates, shall be subject to disciplinary action, up to and including termination. 

Appendix A. Example Policies (Ohio DOT) Page A-100 
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FTA Drug and Alcohol Testing Program 

T. INFORMATION DISCLOSURE

Drug/alcohol testing records shall be maintained by the _________________ Drug and Alcohol 

Program Manager and, except as provided below or by law, the results of any drug/alcohol test 

shall not be disclosed without express written consent of the tested employee. 

(1) The employee, upon written request, is entitled to obtain copies of any records 

pertaining to their use of prohibited drugs or misuse of alcohol including any drug 

or alcohol testing records. Covered employees have the right to gain access to 

any pertinent records such as equipment calibration records, and records of 

laboratory certifications. Employees may not have access to SAP referrals and 

follow-up testing plans. 

(2) Records of a verified positive drug/alcohol test result shall be released to the 

Drug and Alcohol Program Manager, Department Supervisor and Personnel 

Manager on a need to know basis. 

(3) Records will be released to a subsequent employer only upon receipt of a written 

request from the employee. 

(4) Records of an employee's drug/alcohol tests shall be released to the adjudicator 

in a grievance, lawsuit, or other proceeding initiated by or on behalf of the tested 

individual arising from the results of the drug/alcohol test. The records will be 

released to the decision maker in the preceding. The information will only be 

released with binding stipulation from the decision maker will make it available 

only to parties in the preceding. 

(5) Records will be released to the National Transportation Safety Board during an 

accident investigation. 

(6) Records will be released to the DOT or any DOT agency with regulatory authority 

over the employer or any of its employees. 

(7) Records will be released if requested by a Federal, state or local safety agency 

with regulatory authority over ___________________or the employee. 

(8) If a party seeks a court order to release a specimen or part of a specimen 

contrary to any provision of Part 40 as amended necessary legal steps to contest 

the issuance of the order will be taken. 

(9) In cases of a contractor or sub-recipient of a state department of transportation, 

records will be released when requested by such agencies that must certify 

compliance with the regulation to the FTA. 

U. SYSTEM CONTACTS

Any questions regarding this policy or any other aspect of the substance abuse policy should be 

directed to the following individual(s):

_________________ Drug and Alcohol Program Manager: 

Name: 

Title: 

Address: 

Telephone Number: 

Appendix A. Example Policies (Ohio DOT) Page A-101 
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FTA Drug and Alcohol Testing Program 

Medical Review Officer

Name: 

Title: 

Address: 

Telephone Number: 

Substance Abuse Professional

Name: 

Title: 

Address: 

Telephone Number:

HHS Certified Laboratory Primary Specimen

Name: 

Address: 

Telephone Number: 

HHS Certified Laboratory Split Specimen

Name: 

Address: 

Telephone Number:

This Policy was adopted by the ____________________________________ 

 on ____________,2002. 

_______________________________________________ 

Appendix A. Example Policies (Ohio DOT) Page A-102 
Best Practices 

FTA Drug and Alcohol Testing Program 

Attachment A 

Safety-Sensitive Positions 

_________________—Administration Covered Classifications

Title Testing Authority

_________________— Job Classifications

Title Testing Authority

Appendix A. Example Policies (Ohio DOT) Page A-103 
Best Practices 

FTA Drug and Alcohol Testing Program 

Attachment B 

Alcohol Fact Sheet 

Alcohol is a socially acceptable drug that has been consumed throughout the world for 

centuries. It is considered a recreational beverage when consumed in moderation for 

enjoyment and relaxation during social gatherings. However, when consumed primarily

for its physical and mood-altering effects, it is a substance of abuse. As a depressant, it 

slows down physical responses and progressively impairs mental functions. 

Signs and Symptoms of Use 

 Dulled mental processes 

 Lack of coordination 

 Odor of alcohol on breath 

 Possible constricted pupils 

 Sleepy or stupor us condition 

 Slowed reaction rate 

 Slurred speech 

(Note: Except for the odor, these are general signs and symptoms of any depressant 

substance.)

 Health Effects 

The chronic consumption of alcohol (average of three servings per day of beer [12 ounces], 

whiskey [1 ounce], or wine [6 ounce glass]) over time may result in the following health hazards: 

 Decreased sexual functioning 

 Dependency (up to 10 percent of all people who drink alcohol become physically 

and/or mentally dependent on alcohol and can be termed “alcoholic”) 

 Fatal liver diseases 

 Increased cancers of the mouth, tongue, pharynx, esophagus, rectum, breast, and 

malignant melanoma 

 Kidney disease 

 Pancreatitis 

 Spontaneous abortion and neonatal mortality 

 Ulcers 

 Birth defects (up to 54 percent of all birth defects are alcohol related). 

 Social Issues

 Two-thirds of all homicides are committed by people who drink prior to the crime. 

 Two to three percent of the driving population is legally drunk at any one time. This 

rate is doubled at night and on weekends. 

 Two-thirds of all Americans will be involved in an alcohol-related vehicle accident 

during their lifetimes. 

 The rate of separation and divorce in families with alcohol dependency problems is 7 

times the average. 

 Forty percent of family court cases are alcohol problem related. 

Appendix A. Example Policies (Ohio DOT) Page A-104 
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FTA Drug and Alcohol Testing Program 

 Alcoholics are 15 times more likely to commit suicide than are other segments of the 

population. 

 More than 60 percent of burns, 40 percent of falls, 69 percent of boating accidents, 

and 76 percent of private aircraft accidents are alcohol related. 

 The Annual Toll 

 24,000 people will die on the highway due to the legally impaired driver. 

 12,000 more will die on the highway due to the alcohol-affected driver. 

 15,800 will die in non-highway accidents. 

 30,000 will die due to alcohol-caused liver disease. 

 10,000 will die due to alcohol-induced brain disease or suicide. 

 Up to another 125,000 will die due to alcohol-related conditions or accidents. 

 Workplace Issues 

 It takes one hour for the average person (150 pounds) to process one serving of an 

alcoholic beverage from the body. 

 Impairment in coordination and judgment can be objectively measured with as little 

as two drinks in the body. 

 A person who is legally intoxicated is 6 times more likely to have an accident than a 

sober person. 

Appendix A. Example Policies (Ohio DOT) Page A-105 
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FTA Drug and Alcohol Testing Program 

Attachment C 

Minimum Thresholds

INITIAL TEST CUTOFF LEVELS 

(ng/ml) 

Marijuana metabolites 50 

Cocaine metabolites 300 

Opiate metabolites 2,000 

Phencyclidine 25

Amphetamines 1,000

CONFIRMATORY TEST CUT/OFF 

LEVELS (ng/ml) 

Marijuana metabolites 15 

Cocaine metabolites 150 

Opiates: 

 Morphine 2,000 

 Codeine 2,000 

Phencyclidine 25

Amphetamines:

 Amphetamines 500 

 Methamphetamine 500 

Appendix A. Example Policies (Ohio DOT) Page A-106 
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FTA Drug and Alcohol Testing Program 

6. Georgia Department of Transportation 

TABLE OF CONTENTS

1.0 POLICY 

2.0 PURPOSE 

3.0 APPLICABILITY 

4.0 PROHIBITED SUBSTANCES 

4.1 Illegally Used Controlled Substances or Drugs 

4.2 Legal Drugs 

4.3 Alcohol 

5.0 PROHIBITED CONDUCT 

5.1 Manufacture, Trafficking, Possession, and Use 

5.2 Intoxication/Under the Influence

5.3 Alcohol and Drug Use 

5.4 Compliance with Testing Requirements 

5.5 Treatment Requirements 

5.6 Notifying the Transit System of Criminal Drug Conviction

5.7 Proper Application of the Policy 

6.0 TESTING PROCEDURES 

6.1 Employee Requested Testing 

6.2 Pre-Employment Testing 

6.3 Reasonable Suspicion Testing 

6.4 Post-Accident Testing 

6.5 Random Testing 

6.6 Return-to-Duty Testing 

6.7 Follow-Up Testing 

 7.0 EMPLOYMENT ASSESSMENT 

 8.0 INFORMATION DISCLOSURE

 9.0 EMPLOYEE AND SUPERVISOR TRAINING

10.0 RE-ENTRY CONTRACTS 

11.0 SYSTEM CONTACT 

Attachment 1 Safety-Sensitive and Non-Safety-Sensitive Functions 

Attachment 2 Alcohol Fact Sheet 

Attachment 3 Minimum Thresholds

Appendix A. Example Policies (Georgia DOT) Page A-107 
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FTA Drug and Alcohol Testing Program 

Georgia Department of Transportation Insert date of last 

revision. Fitness for Duty Policy 

Drug and Alcohol Testing Program1

Bold = FTA requirements

Italics = Drug-Free Workplace Act of 1988 requirements

1.0 POLICY 

Note 1. Insert name 

of transit system. 

 

Note 2. Insert 

discussion of purpose 

and objectives of your 

program, i.e., ensure

worker fitness for duty

and to protect our 

employees, passengers, 

and the public from the 

risks posed by the misuse

of alcohol and use of 

prohibited drugs. 

Note 3. List covered

employees, i.e., safetysensitive and/or nonsafety-sensitive 

employees.

Note 4. Expand 

applicability to reflect 

additional employees, 

time periods, etc. to

which the policy will 

apply, i.e., visitors, 

vendors, and contractor 

employees are governed 

by this policy while on 

transit premises and will

not be permitted to 

conduct transit business if 

found to violate this 

policy.

The See Note 1 is dedicated to providing safe, dependable, and economical 

transportation services to our transit system passengers. Transit system

employees are our most valuable resource and it is our goal to provide a healthy, 

satisfying working environment which promotes personal opportunities for 

growth. In meeting these goals, it is our policy (1) to ensure that employees are 

not impaired in their ability to perform assigned duties in a safe, productive, and 

healthy manner; (2) to create a workplace environment free from the adverse 

effects of drug abuse and alcohol misuse; (3) to prohibit the unlawful 

manufacture, distribution, dispensing, possession, or use of controlled 

substances; and (4) to encourage employees to seek professional assistance 

anytime personal problems, including alcohol or drug dependency, adversely

affect their ability to perform their assigned duties. 

2.0 PURPOSE 

The purpose of this policy is to See Note 2 . This policy is also intended to 

comply with all applicable Federal regulations governing workplace anti-drug 

and alcohol programs in the transit industry. The Federal Transit Administration

(FTA) of the U.S. Department of Transportation has published 49 CFR Part 655 

as amended, that mandate urine drug testing and breath alcohol testing for safetysensitive positions and prohibits performance of safety-sensitive functions when

there is a positive test result. The U.S. Department of Transportation (DOT) has 

also published 49 CFR Part 40, as amended, which sets standards for the 

collection and testing of urine and breath specimens. In addition, the Federal 

government published 49 CFR Part 29, "The Drug-Free Workplace Act of 

1988," which requires the establishment of drug-free workplace policies and the 

reporting of certain drug-related offenses to the FTA. This policy incorporates 

those requirements for safety-sensitive employees and others when so noted. 

3.0 APPLICABILITY 

This policy applies to all See Note 3 and contractors when they are 

on transit property or when performing any transit-related safety-sensitive or 

non-safety-sensitive business. This policy applies to off-site lunch periods or 

breaks when an employee is scheduled to return to work. See Note 4 .

A safety-sensitive function is any duty related to the safe operation of mass 

transit service including the operation of a revenue service vehicle 

 

1

 All provisions in bold face print are consistent with requirements in 49 CFR Part 655 or 

Appendix A. Example Policies (Georgia DOT) Page A-108 

Part 40, as amended. Provisions in italics are set forth in the Drug-Free Workplace Act (49 CFR Part 29).

All other provisions are set forth under the authority of the transit system. 
Best Practices 

FTA Drug and Alcohol Testing Program 

(whether or not the vehicle is in revenue service), dispatch, maintenance of a 

revenue service vehicle or equipment used in revenue service, security 

personnel who carry firearms, and any other employee who holds a 

Commercial Driver's License. Maintenance functions include the repair, 

overhaul, and rebuild of engines, vehicles and/or equipment. A list of safetysensitive positions who perform one or more of the above mentioned duties is 

attached. See Note 5 Note 5. Attach list 

of safety-sensitive 

positions specific 

to your system. 

4.0 PROHIBITED SUBSTANCES 

"Prohibited substances" addressed by this policy include the following: 

4.1 Illegally Used Controlled Substances or Drugs

The use of any illegal drug or any substance identified in Schedules I through V of Section 202 of the 

Controlled Substance Act (21 U.S.C. 812), as further defined by 21 CFR 1300.11 through 1300.15 is 

prohibited at all times unless a legal prescription has been written for the substance. This includes, but is 

not limited to: marijuana, amphetamines, opiates, phencyclidine (PCP), and cocaine, as well as any drug 

not approved for medical use by the U.S. Drug Enforcement Administration or the U.S. Food and Drug 

Administration. Illegal use includes use of any illegal drug, misuse of legal prescribed drugs, and use of 

illegally obtained prescription drugs. Safety-sensitive employees will be tested for marijuana, cocaine, 

amphetamines, opiates, and phencyclidine as described in Section 6.0 of this policy.

4.2 Legal Drugs 

Note 6. Describe 

local policy on the 

prohibition of legal

drugs and 

performancealtering

prescription drugs 

i.e., However, the use 

of any substance 

which carries a 

warning label that 

indicates that mental 

functioning, motor 

skills, or judgment 

may be adversely

affected must be 

reported to

supervisory personnel 

and medical advice 

and written authorization from the 

attending physician 

must be sought by the 

employee, as

appropriate, before 

performing workrelated duties. 

 The appropriate use of legally prescribed drugs and non-prescription medications is 

not prohibited. See Note 6 .

A legally prescribed drug means that individual has a prescription or other written 

approval from a physician for the use of a drug in the course of medical treatment. 

It must include the patient's name, the name of the substance, quantity/amount to be 

taken, and the period of authorization. The misuse or abuse of legal drugs while 

performing transit business is prohibited. 

Also the use of medical marijuana and hemp products which present levels of drugs 

or drug metabolites above the DOT minimum thresholds, is considered a violation 

of this policy.

4.3 Alcohol 

The use of beverages containing alcohol or substances including any medication, 

mouthwash, food, candy, or any other substance such that alcohol is present in the 

body while performing transit business is prohibited. The concentration of alcohol 

is expressed in terms of alcohol per 210 liters of breath as measured by an 

evidential breath testing device. 

Appendix A. Example Policies (Georgia DOT) Page A-109 
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FTA Drug and Alcohol Testing Program 

5.0 PROHIBITED CONDUCT 

5.1 Manufacture, Trafficking, Possession, and Use 

 

Transit system employees are prohibited from engaging in the unlawful 

manufacture, distribution, dispensing, possession, or use of prohibited substances 

on transit authority premises, in transit vehicles, in uniform or while on transit 

authority business. Employees who violate this provision will be subject to

See Note 7 . Law enforcement shall be notified, as appropriate, where criminal 

activity is suspected. 

Note 7. Insert 

transit system 

discipline

Note 8. List 

covered employees,

i.e., safety-sensitive 

and/or non-safetysensitive.

Note 9. Insert 

transit system 

discipline. 

Note 10. List 

covered employees,

i.e., safety-sensitive 

and/or non-safetysensitive.

Note 11. Insert

transit system 

discipline. 

Note 12. List 

covered employees,

i.e., safety-sensitive 

and/or non-safetysensitive.

Note 13. Insert

transit system 

discipline. 

5.2 Intoxication/Under the Influence 

Any See Note 8 employee who is reasonable suspected of being 

intoxicated, impaired, under the influence of a prohibited substance, or not fit for 

duty shall be suspended from job duties pending an investigation and verification of 

condition. Employees found to be under the influence of a prohibited substance or 

who fail to pass a drug or alcohol test shall be removed from duty and 

See Note 9 . A drug or alcohol test is considered positive if the individual is

found to have a quantifiable presence of a prohibited substance in the body 

above the minimum thresholds defined in 49 CFR Part 40, as amended.

5.3 Alcohol and Drug Use 

No See Note 10 employee should report for duty or remain on duty 

when his/her ability to perform assigned safety-sensitive functions is adversely 

affected by alcohol or when his/her breath alcohol concentration is 0.04 or 

greater. No See Note 10 employee shall use alcohol while on duty, in 

uniform, while performing safety-sensitive functions, or just before or just after 

performing a safety-sensitive function. No See Note 10 employee shall 

use alcohol within four hours of reporting for duty, or during the hours that 

they are on call. 

All safety sensitive employees are prohibited from reporting for duty or 

remaining on duty any time there is a quantifiable presence of a prohibited 

substance in the body above the minimum thresholds defined in 49 CFR Part 

40, as amended. Violation of these provisions is prohibited and punishable

See Note 11 . 

5.4 Compliance with Testing Requirements 

All See Note 12 employees will be subject to urine drug testing 

and breath alcohol testing as a condition of employment. Any 

See Note 12 employee who refuses to comply with a request for testing 

shall be removed from duty and See Note 13 . 

Appendix A. Example Policies (Georgia DOT) Page A-110 

Any See Note 12 employee who is suspected of providing false 

information in connection with a test, or who is suspected of falsifying test 

results through tampering, contamination, adulteration, or substitution will be 

required to undergo an observed collection. Verification of falsifying test 

results will result in See Note 13 The following are also considered a 

refusal to test if the employee: 
Best Practices 

FTA Drug and Alcohol Testing Program 

• Fails to appear for any test within a reasonable time, as determined by the employer, after 

being directed to do so by the employer 

• Fails to remain at the testing site until the testing process is complete 

• Fails to provide a urine or breath specimen for any drug test required by this part or DOT 

agency regulations

• In the case of a directly observed or monitored collection in a drug test, fails to permit the 

observation or monitoring of your provision of a specimen 

• Fails to provide a sufficient amount of urine or breath when directed, and it has been 

determined, through a required medical evaluation, that there was no adequate medical

explanation for the failure 

• Fails or declines to take a second test the employer or collector has directed you to take; 

• Fails to undergo a medical examination or evaluation, as directed by the MRO as part of the 

verification process, or as directed by the DER as part of the “shy bladder”' or “shy lung” 

procedures 

• Fails to cooperate with any part of the testing process (e.g., refuse to empty pockets when so 

directed by the collector, behave in a confrontational way that disrupts the collection process). 

• If the MRO reports that there is verified adulterated or substituted test result, 

Drug tests can be performed any time a safety-sensitive employee is on duty. An alcohol test can be 

performed when the safety sensitive employee is actually performing a safety-sensitive duty, just 

before, or just after the performance of a safety-sensitive duty.

5.5 Treatment Requirements See Note 14 Note 14. Section 

5.5 is optional. If 

included, reflect 

local situation for 

treatment, selfreferrals, 

management 

referrals, who pays, 

and potential use of

leave.

Note 15. Insert

transit system 

discipline. 

Note 16. Section 

5.7 is optional. If 

included, state the 

local decision as to

manager/supervisor 

responsibility and

subsequent 

discipline. 

All employees are encouraged to make use of the available resources for treatment 

for alcohol misuse and illegal drug use problems. Under certain circumstances, 

employees may be required to undergo treatment for substance abuse or alcohol 

misuse. Any employee who refuses or fails to comply with transit system

requirements for treatment, after care, or return to duty shall be subject to 

disciplinary action, up to and including termination. The cost of any treatment or 

rehabilitation services will be paid for directly by the employee or their insurance 

provider. Employees will be allowed to take accumulated sick leave and vacation 

leave to participate in the prescribed rehabilitation program. 

5.6 Notifying the Transit System of Criminal Drug Conviction

All employees are required to notify the transit system of any criminal drug statute 

conviction for a violation occurring in the workplace within five days after such 

conviction. Failure to comply with this provision shall result in 

See Note 15 . 

5.7 Proper Application of the Policy See Note 16 

The transit system is dedicated to assuring fair and equitable application of this 

substance abuse policy. Therefore, supervisors/managers are required to use and 

apply all aspects of this policy in an unbiased and impartial manner. Any

supervisor/manager who knowingly disregards the requirements of this policy, or

who is found to deliberately misuse the policy in regard to subordinates, shall be 

subject to disciplinary action in accordance with the provisions set forth in the 

personnel manual. 

Appendix A. Example Policies (Georgia DOT) Page A-111 
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FTA Drug and Alcohol Testing Program 

6.0 TESTING PROCEDURES 

Analytical urine drug testing and breath testing for alcohol may be conducted when 

 circumstance warrant or as required by Federal regulations. All See Note 17 

employees shall be subject to drug testing prior to employment, for reasonable 

suspicion, and following an accident as defined in Section 6.2, 6.3, and 6.4 of 

this policy. All See Note 17 employees shall be subject to alcohol 

testing for reasonable suspicion and following an accident as defined in 

Section 6.2, 6.3, and 6.4. In addition, all See Note 17 employees will 

be tested prior to returning to duty after failing a drug or alcohol test and 

after completion of the Substance Abuse Professional's recommended 

treatment program and subsequent release to duty. Follow-up testing will also 

be conducted following return to duty for a period of one to five years, with at least six tests 

performed during the first year. 

Note 17. List 

covered employees, 

i.e., safety-sensitive 

and/or non-safetysensitive.

Those employees who perform safety-sensitive functions as defined in the Attachment 1 shall also 

be subject to testing on a random, unannounced basis. 

Testing shall be conducted in a manner to assure a high degree of accuracy and reliability and 

using techniques, equipment, and laboratory facilities which have been approved by the U.S. 

Department of Health and Human Service (DHHS). All testing will be conducted consistent with 

the procedures put forth in 49 CFR Part 40, as amended. The procedures will be performed in a 

private, confidential manner and every effort will be made to protect the employee, the integrity of 

the drug testing procedure, and the validity of the test result. 

The drugs that will be tested for include marijuana, cocaine, opiates, amphetamines, and 

phencyclidine. Urine specimens will be collected using the split specimen collection method 

described in 49 CFR Part 40. Each specimen will be accompanied by a DOT Chain of Custody and 

Control Form and identified using a unique identification number that attributes the specimen to 

the correct individual. An initial drug screen will be conducted on the primary urine specimen. 

For those specimens that are not negative, appear to be substitute, or adulterated, a confirmatory 

Gas Chromatography/Mass Spectrometry (GC/MS) test will be performed. The test will be 

considered positive if the amounts present are above the minimum thresholds established in 49 

CFR Part 40, as amended. Attachment 3 lists the minimum thresholds established for each drug 

and/or its metabolites. The test results from the laboratory will be reported to a Medical Review 

Officer. A Medical Review Officer (MRO) is a licensed physician with detailed knowledge of 

substance abuse disorders and drug testing. The MRO will review the test results to ensure the 

scientific validity of the test and to determine whether there is a legitimate medical explanation for 

a confirmed positive test result, substitution or adulteration. The MRO will contact the employee, 

notify the employee of the positive, substitute, or adulterated laboratory result, and provide the 

employee with an opportunity to explain the confirmed test result. The MRO will subsequently 

review the employee’s medical history/medical records to determine whether there is a legitimate 

medical explanation for a positive, substitute or adulterated laboratory result. If no legitimate 

medical explanation is found, the test will be verified positive, substitute, or adulterated and 

reported to the company program manager. If a legitimate explanation is found, the MRO will 

report the test result as negative. 

The split specimen will be stored at the initial laboratory until the analysis of the primary specimen 

is completed. If the primary specimen is negative, the split will be discarded. If the primary is 

Appendix A. Example Policies (Georgia DOT) Page A-112 
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FTA Drug and Alcohol Testing Program 

positive, the split will be retained for testing if so requested by the employee 

through the Medical Review Officer. See Note 18 Note 18. Indicate if 

you want to test for

additional drugs, or

if you want to 

reserve the right to, 

i.e., in instances where 

there is a reason to 

believe an employee is

abusing a substance 

other that the five

drugs listed above, the

transit system reserves

the right to test for 

additional drugs under 

the transit system's 

own authority using 

standard laboratory

testing protocols. 

Observed collections: 

 

Consistent with 49 CFR part 40 collection under direct observation (by a 

person of the same gender) with no advance notice will occur if:

 (1) The laboratory reports to the MRO that a specimen is invalid, and the 

MRO reports to ____________________ that there was not an adequate 

medical explanation for the result; or

 (2) The MRO reports to _______________________ that the original 

positive, adulterated, or substituted test result had to be cancelled because the 

test of the split specimen could not be performed. 

(a) _________________________ may direct a collection under direct 

observation of an employee if the drug test is a return-to-duty test or a 

follow-up test. 

(b) The collector, must immediately conduct a collection under direct 

observation if: 

 They are directed by ____________________________ to do so; or 

 (3)The collector observes materials brought to the collection site or the 

employee's conduct clearly indicates an attempt to tamper with a specimen; or 

 (4) The temperature on the original specimen was out of range; or 

 (5) The original specimen appeared to have been tampered with. 

Tests for breath alcohol concentration will be conducted utilizing a National Highway Traffic 

Safety Administration (NHTSA)-approved testing device operated by a trained technician. If the 

initial test indicates an alcohol concentration of 0.02 or greater, a second test will be performed to 

confirm the results of the initial test. The confirmatory test will be performed using a NHTSAapproved evidential breath testing device (EBT) operated by a trained breath alcohol technician 

(BAT). The EBT will identify each test by a unique sequential identification number. This 

number, time, and unit identifier will be provided on each EBT printout. The EBT printout along 

with an approved alcohol testing form will be used to document the test, the subsequent results, and 

to attribute the test to the correct employee. The test will be performed in a private, confidential 

manner as required by 49 CFR Part 40 as amended. The procedure will be followed as prescribed 

to protect the employee and to maintain the integrity of the alcohol testing procedures and validity

of the test result. 

Note 19. List 

covered employees,

i.e., safety-sensitive 

and/or non-safetysensitive.

Note 20. Insert

consequences for

alcohol test results 

of 0.02 - 0.039.

Note 21. List 

covered employees,

i.e., safety-sensitive 

and/or non-safetysensitive.

Note 22. Insert

transit discipline. 

A See Note 19 employee who has a confirmed alcohol concentration 

of greater than 0.02 but less than 0.04 will be removed from his/her position 

for eight hours unless a retest results in a concentration measure of less than

0.02. See Note 20 An alcohol concentration of 0.04 or greater will be 

considered a positive alcohol test and in violation of this policy and a violation 

of the requirements set forth in 49 CFR Part 655 for safety-sensitive 

employees. 

Any See Note 21 employee that has a confirmed positive drug or alcohol 

test will be removed from his/her position, informed of educational and 

rehabilitation programs available, and referred to a Substance Abuse 

Professional (SAP) for assessment. A positive drug and/or alcohol test will also 

result in See Note 22 . 

Appendix A. Example Policies (Georgia DOT) Page A-113 
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FTA Drug and Alcohol Testing Program 

6.1 Employee Requested Testing 

 

Any See Note 23 employee who questions the results of a required drug 

test under paragraphs 6.2 through 6.7 of this policy may request that the split 

sample be tested. This test must be conducted at a different DHHS-certified 

laboratory. The test must be conducted on the split sample that was provided 

by the employee at the same time as the original sample. See Note 24 . 

The method of collecting, storing, and testing the split sample will be 

consistent with the procedures set forth in 49 CFR Part 40, as amended. The 

employee's request for a split sample test must be made to the Medical Review 

Officer within 72 hours of notice of the original sample verified test result. 

Requests after 72 hours will only be accepted if the delay was due to 

documentable facts that were beyond the control of the employee. 

Note 23. List 

covered employees,

i.e., safety-sensitive 

and/or non-safetysensitive.

Note 24. Indicate 

that the split 

sample test will 

occur regardless of 

up-front payment, 

but that the transit 

system reserves the 

right to seek 

reimbursement 

from the employee. 

Note 25. List 

covered employees,

i.e., safety-sensitive 

and/or non-safetysensitive.

Note 26. Insert

period of

disqualification and 

re-application 

process. 

6.2 Pre-Employment Testing 

All See Note 25 position applicants shall undergo urine drug testing 

prior to hire or transfer into a safety-sensitive position. Receipt by the transit 

system of a negative drug test result is required prior to employment. Failure 

of a pre-employment drug test will disqualify an applicant for employment for a 

period of See Note 26 . Evidence of the absence of drug dependency 

from a Substance Abuse Professional that meets with the approval of the DOT 

and negative pre-employment drug tests will be required prior to further 

consideration for employment. The cost for assessment and any subsequent 

treatment will be for the sole responsibility of the individual. 

In addition, FTA requires all safety sensitive employees who have been off duty for 90 or more days 

for any reason are required to successfully pass a pre-employment drug test prior to the 

performance of a safety-sensitive function. 

A pre-employment/pre-transfer test will also be performed anytime an employee’s status changes 

from an inactive status in a safety-sensitive position to an active status in a safety-sensitive position 

(i.e., return from Worker’s Comp., return from leave of absence).

6.3 Reasonable Suspicion Testing 

 

All See Note 27 employees may be subject to a fitness for duty

evaluation, and urine and/or breath testing when there are reasons to believe 

that drug or alcohol use is adversely affecting job performance. A reasonable 

suspicion referral for testing will be made on the basis of documented 

objective facts and circumstances which are consistent with the short-term 

effects of substance abuse or alcohol misuse. Examples of reasonable suspicion 

include, but are not limited to, the following: 

Note 27. List 

covered employees,

i.e., safety-sensitive 

and/or non-safetysensitive.

1. Physical signs and symptoms consistent with prohibited substance use or alcohol misuse. 

2. Evidence of the manufacture, distribution, dispensing, possession, or use of controlled 

substances, drugs, alcohol, or other prohibited substance. 

3. Occurrence of a serious or potentially serious accident that may have been caused by

prohibited substance abuse or alcohol misuse. 

Appendix A. Example Policies (Georgia DOT) Page A-114 

4. Fights (to mean physical contact), assaults, and flagrant disregard or violations of 

established safety, security, or other operating procedures. 
Best Practices 

FTA Drug and Alcohol Testing Program 

Reasonable suspicion referrals must be made by a supervisor who is trained to detect the signs and 

symptoms of drug and alcohol use and who reasonably concludes that an employee may be 

adversely affected or impaired in his/her work performance due to possible prohibited substance 

abuse or alcohol misuse.

6.4 Post-Accident Testing 

All safety-sensitive employees will be required to undergo urine and breath testing if they are 

involved in an accident with a _____________________ Transit vehicle (regardless of whether or 

not the vehicle is in revenue service) that results in a fatality. This includes all surviving safetysensitive employees that operated the vehicle and any other whose performance could have 

contributed to the accident. In addition, a post-accident test will be conducted if an accident results 

in injuries requiring immediate transportation to a medical treatment facility or one or more 

vehicles incurs disabling damage, unless the operator can be completely discounted as a 

contributing factor to the accident. The accident definition may include some incidents where an 

individual is injured even though there is no vehicle collision.

 

Following an accident, the safety-sensitive employees will be tested as soon as 

possible, but no to exceed eight hours for alcohol testing and 32 hours for drug 

testing. Any safety-sensitive employee involved in an accident must refrain 

from alcohol use for eight hours following the accident or until he/she 

undergoes a post-accident alcohol test. Any safety-sensitive employee who 

leaves the scene of the accident without justifiable explanation prior to 

submission to drug and alcohol testing will be considered to have refused the 

test See Note 28 . Employees tested under this provision will 

include not only the operations personnel, but any other covered employee 

whose performance could have contributed to the accident. 

Note 28. Insert 

transit system 

discipline. 

If the Transit system is unable to perform a FTA drug and alcohol test (i.e., employee is

unconscious, employee is detained by law enforcement agency), the transit system may use drug 

and alcohol post-accident test results administered by State and local law enforcement officials. 

The State and local law enforcement officials must have independent authority for the test and the 

employer must obtain the results in conformance with state and local law. 

6.5 Random Testing 

Employees in safety-sensitive positions will be subjected to random, unannounced testing. The 

selection of safety-sensitive employees for random drug and alcohol testing will be made using a 

scientifically valid method that ensures each covered employee that they will have an equal chance 

of being selected each time selections are made. The random tests will be unannounced and spread 

throughout the year. Tests can be conducted at any time during an employee’s shift (i.e. beginning, 

middle, end). Employees are required to proceed immediately to the collection site upon 

notification of their random selection. 

6.6 Return-To-Duty Testing Note 29. List 

covered employees,

i.e., safety-sensitive 

and/or non-safetysensitive.

Note 30. Insert 

employee discipline. 

Appendix A. Example Policies (Georgia DOT) Page A-115 

All See Note 29 employees who tested positive on a drug or alcohol 

test will be See Note 30 . However, in the event an employee returns to 

duty, he/she must test negative on both a return-to-duty test and a drug and

alcohol test (below 0.02 for alcohol) and be evaluated and released to duty by 

the Substance Abuse Professional before returning to work. A Substance 
Best Practices 

FTA Drug and Alcohol Testing Program 

Abuse Professional (SAP) is a licensed physician or certified psychologist, social worker, employee 

assistance professional, or addiction counselor certified by the National Association of Alcoholism 

and Drug Abuse Counselors Certification Commission or by the International Certification 

Reciprocity Consortium/Alcohol and Other Drug Abuse. The SAP must also have clinical 

experience in the diagnosis and treatment of drug and alcohol related diseases. Before scheduling 

the return to duty test, the SAP must assess the employee and determine if the required treatment 

has been completed. 

6.7 Follow-Up Testing 

 See Note 31 employees will be required to undergo frequent 

unannounced urine and/or breath testing following their return to duty. The 

follow-up testing will be performed for a period of one to five years with a 

minimum of six tests to be performed the first year. The frequency and 

duration of the follow-up tests beyond the minimum will be determined by a 

qualified Substance Abuse Professional.

Note 31. List covered

employees, i.e., safetysensitive and/or nonsafety-sensitive.

Note 32. Modify to 

reflect local decisions 

on assessment, EAPs, 

and treatment.

Note 33. List covered

employees, i.e., safetysensitive and/or nonsafety-sensitive.

Note 34. Refer to

employee assistance 

program if you have 

one in place. 

Note 35. Refer to

transit system’s 

disciplinary code. 

Note 36. List covered

employees, i.e., safetysensitive and/or nonsafety-sensitive.

Note 37. Who will 

pay for treatment and 

rehabilitation services 

and will time off be

granted, i.e., the cost of 

any treatment or

rehabilitation services 

will be paid directly by

the employee or the 

insurance provider. 

Employees will be 

allowed to take

accumulated sick leave

and vacation leave to

participate in prescribed

rehabilitation program. 

7.0 EMPLOYMENT ASSESSMENT See Note 32 

Any See Note 33 employee who tests positive for the presence of 

illegal drugs or alcohol above the minimum thresholds set forth in 49 CFR 

Part 40, as amended, will be referred for evaluation by a Substance Abuse 

Professional (SAP). A SAP is a licensed or certified physician, psychologist, 

social worker, employee assistance profession, or addiction counselor with 

knowledge of and clinical experience in the diagnosis and treatment of 

alcohol and drug-related disorders. If the employee is eligible for a second 

chance, a SAP will evaluate him/her to determine what assistance is needed to 

resolve problems associated with prohibited drug use or alcohol misuse. 

Assessment by a SAP See Note 34 does not shield an employee 

from disciplinary action or guarantee employment or reinstatement with the 

transit system. The See Note 35 should be consulted to determine the 

penalty for performance-based infractions and violation of policy provisions. 

If a See Note 36 employee is allowed to return -to-duty, he/she must 

properly follow the rehabilitation program prescribed by the SAP, the 

employee must have negative return-to-duty drug and alcohol tests, and be 

subject to unannounced follow-up testing for a period of one to five years. 

See Note 37 .

8.0 INFORMATION DISCLOSURE

To be considered for employment, all applicants will be asked to give consent 

to (Insert Transit System Name) for a background check of their previous 

DOT covered employer over the past two years. Information requested will 

include: 

1. Alcohol test results of 0.04 or higher alcohol concentration. 

2. Verified positive drug tests. 

3. Refusals to be tested (including verified adulterated or substituted 

drug test results.) 

Appendix A. Example Policies (Georgia DOT) Page A-116 
Best Practices 

FTA Drug and Alcohol Testing Program 

4. Other violations of DOT agency drug and alcohol testing regulations. 

5. With respect to any employee who violated a DOT drug and alcohol regulation, 

documentation of the employee’s successful completion of DOT return-to-duty 

requirements (including follow-up tests). 

All drug and alcohol testing records will be maintained in a secure manner so that disclosure of 

information to unauthorized persons does not occur. Information will only be released in the 

following circumstances:

1. To a third party only as directed by specific, written instruction of the employee 

2. To the decision-maker in a lawsuit, grievance, or other proceeding initiated by or on the 

behalf of the employee tested 

3. To a subsequent employer upon receipt of a written request from the employee 

4. To the National Transportation Safety Board during an accident investigation 

5. To the DOT or any DOT agency with regulatory authority over the employer or any of its 

employees, or to a State oversight agency authorized to oversee rail fixed-guideway systems 

6. To the employee, upon written request

7. Records will be released if requested by a Federal, state or local safety agency with 

regulatory authority over ___________________or the employee. 

8. If a party seeks a court order to release a specimen or part of a specimen contrary to any 

provision of Part 40 necessary legal steps to contest the issuance of the order will be taken. 

9.0 EMPLOYEE AND SUPERVISOR TRAINING

All safety sensitive employees will undergo a minimum of 60 minutes of training on the signs and 

symptoms of drug use including the effects and consequences of drug use on personal health, safety, 

and the work environment. The training must also include manifestations and behavioral cues that 

may indicate prohibited drug use. 

Supervisors will also receive 60 minutes of reasonable suspicion training on the physical, 

behavioral, and performance indicators of probable drug use and 60 minutes of additional 

reasonable suspicion training on the physical, behavioral, speech, and performance indicators of 

probable alcohol misuse.

Information on the signs, symptoms, health affects and consequences of alcohol misuse is presented in 

Attachment 2. 

Note 38. Include 

Section 10.0 only if you 

allow employees to

return to duty and you 

require re-entry

contracts. Be sure the 

items listed reflect the 

items typically included 

in your re-entry

contracts. If you do 

not use re-entry

contracts, this portion

of the policy should be 

omitted.

10.0 RE-ENTRY CONTRACTS See Note 38 

Employees who re-enter the workforce must agree to a re-entry contract. That 

contract may include (but is not limited to): 

1. A release to work statement from the Substance Abuse Professional. 

2. A negative test for drugs and/or alcohol.

3. An agreement to unannounced frequent follow-up testing for a period of one 

to five years with at least six tests performed the first year. 

4. A statement of work-related behaviors. 

Appendix A. Example Policies (Georgia DOT) Page A-117 

5. An agreement to follow specified after care requirements with the understanding that violation of the re-entry contract is grounds for termination. 
Best Practices 

FTA Drug and Alcohol Testing Program 

11.0 SYSTEM CONTACT 

Any questions regarding this policy or any other aspect of the drug free and alcohol-free transit 

program should contact the following transit system representative: 

 Program Manager: 

Note 39. Insert name

and address of program 

manager.

Note 40. Insert name

and address of medical

review officer.

Note 41. Insert name 

and address of

substance abuse 

professional. 

Name: See Note 39 

 Title:

 Address: 

 Telephone Number: 

 FAX Number:

Medical Review Officer :

Name: See Note 40 

 Address: 

 Telephone Number: 

 FAX Number:

Substance Abuse Professional : 

Name: See Note 41 

 Title:

 Address: 

 Telephone Number: 

 FAX Number:

Appendix A. Example Policies (Georgia DOT) Page A-118 
Best Practices 

FTA Drug and Alcohol Testing Program 

Attachment 1 

Safety-Sensitive and Non-Safety-Sensitive Functions 

Every transit system employee should be included on one of the following lists. You must be able to 

defend why each position is placed in its respective lists:

Safety-Sensitive Functions 

List specific job titles of those who 

perform safety-sensitive job functions. 

Non-Safety-Sensitive Functions 

List specific job titles of those who do not 

perform safety-sensitive job functions. 

Appendix A. Example Policies (Georgia DOT) Page A-119 
Best Practices 

FTA Drug and Alcohol Testing Program 

Attachment 2 

Alcohol Fact Sheet 

Alcohol is a socially acceptable drug that has been consumed throughout the world for centuries. It is 

considered a recreational beverage when consumed in moderation for enjoyment and relaxation during 

social gatherings. However, when consumed primarily for its physical and mood-altering effects, it is a 

substance of abuse. As a depressant, it slows down physical responses and progressively impairs mental 

functions. 

Signs and Symptoms of Use 

♦ Dulled mental processes 

♦ Lack of coordination 

♦ Odor of alcohol on breath 

♦ Possible constricted pupils

♦ Sleepy or stuporous condition 

♦ Slowed reaction rate 

♦ Slurred speech 

(Note: Except for the odor, these are general signs and symptoms of any depressant substance.) 

Health Effects 

The chronic consumption of alcohol (average of three servings per day of beer [12 ounces], whiskey [1

ounce], or wine [6 ounce glass]) over time may result in the following health hazards: 

♦ Decreased sexual functioning 

♦ Dependency (up to 10 percent of all people who drink alcohol become physically and/or mentally 

dependent on alcohol and can be termed “alcoholic”) 

♦ Fatal liver diseases 

♦ Increased cancers of the mouth, tongue, pharynx, esophagus, rectum, breast, and malignant melanoma 

♦ Kidney disease 

♦ Pancreatitis 

♦ Spontaneous abortion and neonatal mortality

♦ Ulcers 

♦ Birth defects (up to 54 percent of all birth defects are alcohol related). 

Appendix A. Example Policies (Georgia DOT) Page A-120 
Best Practices 

FTA Drug and Alcohol Testing Program 

Social Issues

♦ Two-thirds of all homicides are committed by people who drink prior to the crime. 

♦ Two to three percent of the driving population is legally drunk at any one time. This rate is doubled 

at night and on weekends. 

♦ Two-thirds of all Americans will be involved in an alcohol-related vehicle accident during their 

lifetimes. 

♦ The rate of separation and divorce in families with alcohol dependency problems is 7 times the 

average. 

♦ Forty percent of family court cases are alcohol problem related. 

♦ Alcoholics are 15 times more likely to commit suicide than are other segments of the population. 

♦ More than 60 percent of burns, 40 percent of falls, 69 percent of boating accidents, and 76 percent of 

private aircraft accidents are alcohol related. 

The Annual Toll 

♦ 24,000 people will die on the highway due to the legally impaired driver. 

♦ 12,000 more will die on the highway due to the alcohol-affected driver. 

♦ 15,800 will die in non-highway accidents. 

♦ 30,000 will die due to alcohol-caused liver disease. 

♦ 10,000 will die due to alcohol-induced brain disease or suicide. 

♦ Up to another 125,000 will die due to alcohol-related conditions or accidents. 

Workplace Issues 

♦ It takes one hour for the average person (150 pounds) to process one serving of an alcoholic beverage 

from the body. 

♦ Impairment in coordination and judgment can be objectively measured with as little as two drinks in 

the body. 

♦ A person who is legally intoxicated is 6 times more likely to have an accident than a sober person. 

Appendix A. Example Policies (Georgia DOT) Page A-121 
Best Practices 

FTA Drug and Alcohol Testing Program 

Appendix A. Example Policies (Georgia DOT) Page A-122 

Attachment 3 

Minimum Thresholds

 Initial Test Initial test cutoff levels

Marijuana metabolites 50 ng/ml 

 Cocaine metabolites 300 ng/ml 

 Opiate metabolites 2,000 ng/ml 

 Phencyclidine (PCP) 25 ng/ml 

 Amphetamines 1,000 ng/ml 

 Confirmatory Test Confirmatory test cutoff levels

Marijuana metabolites (1) 15 ng/ml 

 Cocaine metabolites (2) 150 ng/ml 

 Opiates: 

 Morphine 2,000 ng/ml 

 Codeine 2,000 ng/ml 

 Phencyclidine (PCP) 25 ng/ml 

 Amphetamines: 

 Amphetamine 500 ng/ml 

 Methamphetamine (3) 500 ng/ml 

(1) Delta-9-tetrahydrocannabinol-9-carboxlic acid 

(2) Benzoylecgonine 

(3) Specimen must also contain amphetamine at a concentration greater than or equal to 

200 ng/ml. 

These cutoff levels are subject to change by the Department of Health and Human Services as advances in 

technology or other considerations warrant identification of these substances at other concentrations. 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists 

This appendix contains best practice examples of forms and lists that have 

been used successfully to assist with general administrative issues and 

concerns and the issues related to each of the four types of testing required for 

all employers: pre-employment, reasonable suspicion, post accident, and 

random. Each of these examples is referenced and described in Section 4.1. 

The examples appear in the following figures, by the aforementioned groups: 

General Administrative Duties 

 B-1. MBTA Employee Certification of Receipt of Policy 

 B-2. WMATA Employee Certification of Receipt of Policy 

 B-3. Tri-Met Employee Certification of Receipt of Policy 

 B-4. Log of Covered Employees who Complete Substance Abuse Training 

 B-5. Log of Employees who Complete Reasonable Suspicion Training 

 B-6. Certificate for Completion of Reasonable Suspicion Training 

 B-7. Roles and Responsibilities of Department Substance Abuse Program Manager 

 B-8. Roles and Responsibilities of Department Program Coordinator 

 B-9. Roles and Responsibilities of Departmental Divisional Contacts 

B-10. Roles and Responsibilities of Front-Line Supervisors 

B-11. Drug and Alcohol Testing Log 

B-12. Drug Test Result Summary Form 

B-13. Supervisor Log for Drug and Alcohol Testing 

B-14. Order for Testing 

B-15. Notification of Testing 

B-16. Notice of Positive Drug Test 

B-17. Notice of Positive Alcohol Test 

B-18. Employee Notification of Positive Test Result

B-19. Supervisor Notification of Positive Test Result

Pre-Employment Testing 

B-20. Flow Chart for Pre-Employment Testing Process 

B-21. Pre-Employment Documentation Summary Sheet 

B-22. Pre-Employment Test Tracking Log 

B-23. Applicant Notification of Positive Test Result 

Appendix B. Example Administrative Forms and Lists Page B-1 
Best Practices 

FTA Drug and Alcohol Testing Program

Reasonable Suspicion Testing 

B-24. Flow Chart for Reasonable Suspicion Testing Process 

B-25. Reasonable Suspicion Process and Documentation 

B-26. Reasonable Suspicion Short-Term Indicators 

B-27. Reasonable Suspicion Evaluation and Checklist 

B-28. Fitness for Duty 

B-29. Observation/Incident Report 

B-30. Accident/Incident/Reasonable Cause Report 

B-31. Reasonable Suspicion Individual Test Summary 

B-32. Reasonable Suspicion Tracking Master Log 

B-33. Failure To Administer Reasonable Suspicion Drug Test Form 

Post-Accident Testing 

B-34. Post-Accident Test Decision Tree 

B-35. Flow Chart for Post-Accident Testing Process 

B-36. Post-Accident Testing Decision Report 

B-37. Post-Accident Testing Procedure 

B-38. Post-Accident Drug and Alcohol Testing Decision Maker Form 

B-39. Post-Accident Testing Record of Decision 

B-40. Post-Accident Documentation Summary Form 

B-41. Failure To Administer Post-Accident Drug Test 

B-42. Post-Accident Test Master Log 

Random Testing 

B-43. Flow Chart for Random Testing Process 

B-44. Random Testing Procedure 

B-45. Random Drug/Alcohol Testing Notification Form 

B-46. Employee Notice for Random Substance Abuse Test 

B-47. Random Selection Instructions 

B-48. Roles and Responsibilities of Random Selector 

B-49. Random Testing Schedule 

B-50. Random Testing Selection Documentation Form 

B-51. Individual Random Test Summary Sheet 

B-52. Random Test Master Log 

B-53. Employee Status Form

Appendix B. Example Administrative Forms and Lists Page B-2 
Best Practices 

FTA Drug and Alcohol Testing Program

GENERAL ADMINISTRATIVE DUTIES

Figure B-1. MBTA Employee Certification of Receipt of Policy 

MASSACHUSETTS BAY TRANSPORTATION AUTHORITY 

DRUG AND ALCOHOL POLICY 

VERIFICATION OF EMPLOYEE NOTICE 

I have received a copy of the August 1, 2001 Massachusetts Bay Transportation

Authority Drug and Alcohol Policy which outlines the rights, duties, and responsibilities of 

the Massachusetts Bay Transportation Authority and all employees of the Massachusetts 

Bay Transportation Authority. 

____________________ __________________________________ 

Employee Number Area Department

_______________________ ________________________________________ 

Class Number Class Title 

_______________________________________ 

Name 

_____________________________________________________________________ 

Employee Signature Date 

____________________________________________________________________ 

MBTA Witness Signature Date 

Appendix B. Example Administrative Forms and Lists Page B-3 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-2. WMATA Employee Certification of Receipt of Policy 

Washington Metropolitan Area Transit Authority

Certification Statement 

Drug and Alcohol Testing Program

I have received a copy of the Policy Instruction, P/I 7.21/2 

Drug and Alcohol Testing, and a copy of the Substance 

Abuse Policy and Employee Assistance Program. I 

understand that it is my responsibility to read and abide by 

the rules contained in these Policies. 

_____________________ ________________ Signature Date

________________________ 

Print Name

________________________ 

Employee Number

Figure B-3. Tri-Met Employee Certification of Receipt of Policy1

TRI-MET DRUG & ALCOHOL

ABUSE PROGRAM

Yes, I have received Tri-Met’s packet of information containing a copy of the revised 

drug and alcohol policy, EAP brochure, and Question & Answer information. 

Name:________________________________________

Employee No.: __________________

Signature:___________________________ Date: _______________

Appendix B. Example Administrative Forms and Lists Page B-4 

 

1

 Tri-County Metropolitan Transit District, Portland, Oregon
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-4. Log of Covered Employees who Complete Substance Abuse Training2

DRUG AND ALCOHOL TRAINING FOR COVERED EMPLOYEES 

I certify that I have received 60 minutes of training on the effects and

consequences of alcohol misuse and prohibited drug use on health, safety,

personal life, and the work environment, and on the signs and symptoms which 

may indicate such use in accordance with Title 49 CFR § 655.14 (b) (1). 

NAME DEPARTMENT DATE

____________________________ ___________________ 

INSTRUCTOR DATE

 

Appendix B. Example Administrative Forms and Lists Page B-5 

2

 Cincinnati Metro
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-5. Log of Employees who Complete Reasonable Suspicion Training3

REASONABLE SUSPICION TRAINING FOR SUPERVISORY EMPLOYEES 

I certify that I have received 60 minutes of training describing the physical, 

behavioral, speech and performance indicators of alcohol misuse and 60 minutes 

of training on the performance indicators of probable drug use constituting the 

grounds for a reasonable suspicion test in with Title 49 CFR § 655.14 (b) (2). 

NAME DEPARTMENT DATE

____________________________ ___________________ 

INSTRUCTOR DATE

 

Appendix B. Example Administrative Forms and Lists Page B-6 

3

 Cincinnati Metro
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-6. Certificate for Completion of Supervisor Training4

The Government of The Virgin Islands 

Certifies That 

 Supervisor 

Has completed Supervisor Reasonable 

Suspicion Training for Drug Use and 

Alcohol Misuse in Accordance with 49 CFR 

Part 655

On _______________(date) 

_______________________________________ Instructor 

 

Appendix B. Example Administrative Forms and Lists Page B-7 

4 The Government of The Virgin Islands
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-7. Roles and Responsibilities of Department Substance Abuse Program Manager 5

ROLES AND RESPONSIBILITIES: SUBSTANCE ABUSE PROGRAM MANAGER 

 Directs and manages the City’s Substance Abuse program

 Supervises the City’s Substance Abuse Program staff including the City personnel that perform the following:

 Random number pool management and selection 

 Substance abuse professional services 

 Manages, monitors, and enforces contracts for testing services, including:

 Collection sites 

⇒ 

⇒ 

 

Urine specimen collection 

Breath specimen collection (BATs) 

 SED testing laboratory 

 Split specimen laboratory 

 Medical Review Officer 

 Performs quality control checks on testing services: 

 Mock audits 

 Blind sample quality control checks 

 Periodic inspections

 Review policies/procedures, checklists for being complete, up-to-date, and compliant with 49CFR Part 40

 Monitor/investigate employee complaints 

 Periodic assessment of service provider credentials 

 Maintains a thorough, current knowledge of all Federal drug and alcohol testing regulations including testing

procedures (49CFR Part 40); FTA regulations (49CFR Part 655); and FHWA regulations (49CFR Part 382). 

 Maintain a thorough and current knowledge of all other Federal, State, and Municipal legislation, regulations

and case law regarding substance abuse testing that may pertain to City employee. 

 Maintain a thorough and current knowledge of testing procedures, protocols, adulterants, and other relevant

issues relating to drug and alcohol testing.

 Assist Department Program Coordinators with the successful, compliant, implementation of the City’s 

Substance Abuse Policy. 

 Advise Department Program Coordinators as they implement the program including policy implementation, 

discipline, and other issues as they arise. 

 Recommend modifications to the City’s Substance Abuse Policy as appropriate to reflect changes in 

regulations, operating environments, practical experience, and program administration. Present

recommendations to the CAO and City Council, as appropriate. 

 Develop training modules to train supervisors and other City employees on the City’s policy and testing procedures. 

 Coordinate training activities for/between City departments for supervisory Reasonable Suspicion and Drug

Abuse/Alcohol misuse awareness training. 

 Maintain a computerized database of testing records to facilitate the preparation/submission of MIS report 

required by Federal regulations. 

 Maintain manual paper files to facilitate response to employee actions, lawsuits, grievances, audits, or other proceedings. 

 Ensure confidentiality and security of all drug and alcohol testing records. 

 Testify as necessary regarding the testing procedures and policies in administrative grievance procedures and lawsuits. 

 Perform other duties as directed. 

Appendix B. Example Administrative Forms and Lists Page B-8 

5

 City of Albuquerque 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-8. Roles and Responsibilities of Department Program Coordinator6

ROLES AND RESPONSIBILITIES 

DEPARTMENT PROGRAM COORDINATOR 

 Coordinates with SAPM on program implementation. 

 Responsible for policy implementation in department. 

 Knowledgeable of regulatory compliance requirements as appropriate (Transit mandatory). 

 Schedules random tests and works with Division Contact to ensure tests are performed. 

 Re-schedules test in testing period if employee is unavailable on the testing day. 

 Approves legitimate excuses for no test; takes corrective action when explanation is not legitimate. 

 Notifies Random Selector when tests are not completed in the testing period. 

 Tracks tests for department. 

 Ensures that employees are properly coded as safety-sensitive or not. 

 Works with Division Contacts to ensure that testing is performed within the regulatory guidelines –

 Alcohol test only performed just before, during, just after the performance of a safety-sensitive job 

function 

 Drug test any time the covered employee is on duty

 Tests performed as soon as possible following employee notification, accident, or reasonable suspicion 

determination

 Document test delays of greater than 2 hours; discontinue alcohol test attempts after 8 hours; 

discontinue drug test attempt after 32 hours. 

 Investigate procedural violations and take corrective actions as necessary

 Ensure appropriate department level documentation is completed accurately and in a timely manner; take 

corrective action as necessary. 

 Maintain departmental records in a secure location. 

 Schedule return-to-duty, and follow-up test consistent with SAP recommendation. 

 Notify employees and department of positive test results; remove employee from duty; notify and refer to

department for discipline; refer to SAP. 

 Coordinate with SAP regarding employee’s progress and return-to-duty status. 

 Coordinate with SAPM regarding preparation and submission of annual MIS reports. 

 Provide input to SAPM regarding quality of testing services; bring issues or problems to immediate attention of

SAPM. 

 

Appendix B. Example Administrative Forms and Lists Page B-9 

6

 City of Albuquerque 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-9. Roles and Responsibilities of Departmental Divisional Contacts7

ROLES AND RESPONSIBILITIES 

DEPARTMENTAL – DIVISION CONTACTS

 

 Upon notification of employees to be tested – check to make sure available on tests date. If not, inform DPC of

need for alternate test date within testing period

 Arrange for employee to be removed from duty (schedule substitute as necessary), and notify of need for test 

 Arrange for immediate transportation to collection site 

 Notify DPC of post-accident and reasonable suspicion tests 

 Ensure tests are complete consistent with regulatory requirements 

 Ensure that all necessary documentation is complete and submitted to the DPC within 24 hours of the incident

Figure B-10. Roles and Responsibilities of Front-Line Supervisors 8

ROLES AND RESPONSIBILITIES 

FRONT-LINE SUPERVISORS 

 

 Determine employee fitness for duty; make reasonable suspicion determination as appropriate; transport 

employee to collection site; notify Division Contact/DPC; prepare documentation. 

 Determine if accident meets regulatory definition of an accident; if so transport employee to collection site or 

arrange for collections to be made; document test decision; notify Division Contact/DPC. 

 

7

 City of Albuquerque 

Appendix B. Example Administrative Forms and Lists Page B-10 

8

 City of Albuquerque 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-11. Drug and Alcohol Testing Log9

DRUG AND ALCOHOL TESTING LOG

SS# EE# CLASS AREA DATE SCREENED LOCATION REASON

NAME: 

DRUG SCREEN/RESULTS DATE COMMENTS ALCOHOL SCREEN RESULTS DATE COMMENTS 

SS# EE# CLASS AREA DATE SCREENED LOCATION REASON

NAME: 

DRUG SCREEN/RESULTS DATE COMMENTS ALCOHOL SCREEN RESULTS DATE COMMENTS 

SS# EE# CLASS AREA DATE SCREENED LOCATION REASON

NAME: 

DRUG SCREEN/RESULTS DATE COMMENTS ALCOHOL SCREEN RESULTS DATE COMMENTS 

SS# EE# CLASS AREA DATE SCREENED LOCATION REASON

NAME: 

DRUG SCREEN/RESULTS DATE COMMENTS ALCOHOL SCREEN RESULTS DATE COMMENTS 

SS# EE# CLASS AREA DATE SCREENED LOCATION REASON

NAME: 

DRUG SCREEN/RESULTS DATE COMMENTS ALCOHOL SCREEN RESULTS DATE COMMENTS 

SS# EE# CLASS AREA DATE SCREENED LOCATION REASON

NAME: 

DRUG SCREEN/RESULTS DATE COMMENTS ALCOHOL SCREEN RESULTS DATE COMMENTS 

 

Appendix B. Example Administrative Forms and Lists Page B-11 

9

 Massachusetts Bay Transportation Authority (MBTA) 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-12. Drug Test Result Summary Form10

DRUG TEST RESULT SUMMARY FORM 

Company:

Location:

Employee Name: 

Identification #: 

Reported for Test: Date Time

Specimen Collection: Date Time

Type of Test: Pre-Employment Return-to-Duty

Random Post-Accident

Reasonable Suspicion Follow-up

Re-Test Other

Type of Test: DOT Safe 10 Safe 5 Other 

Date Lab Received: 

Date Lab Reported: 

Date MRO Verifies Results: 

Specimen Collection Site: 

Name:

Location:

Technician:

Testing Laboratory: 

Name:

Location:

Certifying Scientist:

Split Analysis Laboratory:

Name:

Location:

Certifying Scientist:

Medical Review Officer: 

Name:

Location:

Signature:

Test Result: 

Negative Positive Unsuitable Not Performed

Cancelled Insufficient Volume Adulterated

Substance Detected: 

Marijuana Cocaine Phencyclidine

Opiates Amphetamine Other, Specify:

Codeine Amphetamine

Morphine Methamphetamine

Date Employee Informed: 

Action Taken:

Referred to SAP (Date) Employee Terminated

Assigned to non-safety-sensitive duties Not Hired

Removed from Duty Other 

To Be Com

pleted B

y MRO 

Appendix B. Example Administrative Forms and Lists Page B-12 

 

10 City of Albuquerque 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-13. Supervisor Log for Drug and Alcohol Testing11 (Front) 

 SUPERVISOR LOG – DRUG & ALCOHOL TESTING 

DATE __________________ EMPLOYEE NAME __________________________________________________________ 

SSN / ID# OF EMPLOYEE _____________________________________________________ 

EMPLOYEE WORK SITE______________________________________________________ 

TYPE OF TEST 

 DRUG ALCOHOL BOTH DRUG & ALCOHOL 

REASON FOR TESTING 

 RANDOM REASONABLE SUSPICION

 POST-ACCIDENT FOLLOW-UP (per return-to-work agreement)

TESTING FACILITY 

 MEDWORK (SR-84) ON-SITE (employee’s work location)

FAMILY HEALTH CENTER OTHER_________________________________ 

(am/pm) SEQUENCE OF EVENTS

_____ Time when testing facility was called/notified to coordinate testing of a Mass Transit Division employee. 

_____ Time when employee was first notified of the testing requirement. 

_____ Time when union/other employee representative was contacted (person notified) _______________ ). 

_____ Departure time from employee’s work site to the testing facility, if applicable. 

_____ Arrival time at the testing facility, or time the mobile testing team arrives at the testing location.

_____ Arrival time of union representative, if applicable. 

_____ Time testing started. 

_____ Time testing concluded.

_____ Time of return to work location, or time employee is released to return to duty or is secured from duty. 

OTHER NOTIFICATION

(post-accident, reasonable suspicion testing, or as otherwise required)

_____ Time when Superintendent/Assistant Superintendent was notified. 

_____ Time when Program Manager for Drug & Alcohol Testing was called/alerted. 

_____ Time when Director/Assistant Director was notified, if applicable. 

_____ Other _____________________________________________________________________________ 

Appendix B. Example Administrative Forms and Lists Page B-13 

 

11 Broward County (Florida) Transit 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-13. Supervisor Log for Drug and Alcohol Testing (Back) 

POST-ACCIDENT TESTING 

(Complete this section only if post-accident testing criteria applies.)

____________________ ______________________________ BODILY INJURY

(Date/Time of Accident) (Location of Accident)

 DISABLING DAMAGE 

 NO-TEST DECISION (WAIVED PER _______________________________________________________ ) 

________________________________________________________________________________________________________ 

REASONABLE SUSPICION TESTING 

(Complete this section to describe when, where, and what specific, observed behavior, speech, appearance, or other

characteristic results in a reasonable suspicion testing determination. Be specific. Use amplifying comments or separate sheet 

of paper if more space is needed.)

________________________ _____________________________ ODOR OF ALCOHOL

(Date/Time of Observation) (Location of Observation)

____________________________________________________________________________________________

AMPLIFYING COMMENTS 

(Complete this section to note any problem or unusual circumstance associated with the testing process, any delay in testing 

beyond two hours of notifying employee of a testing requirement, or to provide additional information, if needed. Use 

continuation sheet if more space is needed.)

________________________________________________________________________________________________________ 

________________________________________________________________________________________________________ 

________________________________________________________________________________________________________ 

________________________________________________________________________________________________________ 

________________________________________________________________________________________________________ 

________________________________________________________________________________________________________ 

________________________________________________________________________________________________________ 

 ________________________________________________________ 

 (Signature of Supervisor) 

Note. Post-Accident and Reasonable Suspicion testing must be substantiated by completing the appropriate section above. Return this form 

within 24 hours of testing to the Program Manager for Drug and Alcohol Testing, Broward County Transit, 3201 West Copans Road, Pompano 

Beach, Florida 33069. Contact the Program Manager at 357-830., After regular business hours call 497-8327 (24-hour pager) if there is 

question concerning this form or assistance is needed in determining whether a particular situation requires testing for the use of prohibited 

drugs or misuse of alcohol.

Appendix B. Example Administrative Forms and Lists Page B-14 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-14. Order for Testing12

ORDER FOR TESTING 

Name: ______________________________________________________________________________

Number: ____________________________________________________________________________

Supervisor Authorizing Test: ____________________________________________________________

Collection Site: _______________________________________________________________________

 __________________________________________________________________________

Transported: ____ Yes ____ No 

Name of Transport 

Supervisor: ____________________________________________________________________

Date & Time Sent: _________________________ (Date) _______________________ (Time) 

Test Authority: ___ DOT ____ Non-DOT ____ Other (Specify) 

Test Category:

___ Pre-employment ____ Random 

___ Post-Accident ____ Reasonable Suspicion 

___ Return-to-Duty ____ Follow-up 

___ Retest 

Observed Collection: ___ Yes ____ No 

Other __________________________________________________________________________

 __________________________________________________________________________

Special 

Instructions: _________________________________________________________________________ 

Date & Time Sent: ____________ Date ____________ Time

Date & Time Reported: ____________ Date ____________ Time

Date & Time of Test: ____________ Date ____________ Time

Appendix B. Example Administrative Forms and Lists Page B-15 

 

12 Ohio Department of Transportation (ODOT)
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-15. Notification of Testing 

MV TRANSPORTATION 

DRUG & ALCOHOL TESTING 

NOTIFICATION FORM

Employee Identification 

Employee Name: 

Employee ID No: (ss#) 

Department: 

Supervisor: 

TYPE OF TEST DRUG __________ ALCOHOL ____________________ 

RANDOM 

POST ACCIDENT DOT NON-DOT 

REASONABLE SUSPICION 

RETURN TO STUDY 

FOLLOW UP 

Selection, Notification, and Testing 

For MVT Use This side to be filled out by collection site staff 

Date Selected: Date Tested:

Date Notified: Time Tested: 

 am/pm

Time Notified: 

 am/pm

Location: 

______________________________________ ______________________

 Employer Signature Date 

______________________________________ ______________________

Collection Person Signature Date 

Appendix B. Example Administrative Forms and Lists Page B-16 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-16. Notice of Positive Drug Test13

HUMAN RESOURCES - DEPARTMENT #6210

 NOTICE OF POSITIVE DRUG TES 

CONFIDENTIAL 

DATE: June 5, 2002

TO: ____, Manager, _____

FROM: ______ Drug and Alcohol Program Coordinator

SUBJ: ____, Badge #___

____, Badge #___, had a drug test on ____, 2001 at ____ Medical Clinic. The test results for both were verified

positive for Marijuana (THC) on ____, 2001. A copy of the Medical Review Officer’s (MRO) Status Report is 

attached. 

To assist you with preparing for disciplinary action, the following checklist of mandatory actions is included: 

 Remove the employee from duty. Date of removal from duty: _________

 Notify the employee of the test result. 

 Refer employee to Employee Assistance Program (EAP) for assessment by a Substance Abuse Professional 

(SAP) and treatment resource information (Initial referral), this must be done regardless of disciplinary

action to be taken, in order to be in compliance with DOT/FTA regulations and the MTA/PTSC 

Alcohol-and Drug-Free Work Environment Policy.) 

 Schedule a disciplinary hearing. Date of hearing: ______________________ 

 Ask if employee requested the Split Sample test. (As this test can only be performed at the employee’s written 

request, this serves only as a reminder.) Have employee sign the Authorization to Release Drug Test Result

to Union, (required by some unions in order to pay for the Split Sample test.) 

 Contact _____ to schedule a meeting with the Discipline Committee, as soon as the hearing date is set. 

A copy of this completed form and of the final disciplinary action taken must be sent to this office, 

as soon as a decision has been made and all parties notified. 

 

Thanks for your cooperation. If you have any questions regarding this matter, please call me at _____.

Attachments 

Appendix B. Example Administrative Forms and Lists Page B-17 

13 Los Angeles County Metropolitan Transportation Authority (LACMTA) 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-17. Notice of Positive Alcohol Test14

HUMAN RESOURCES - DEPARTMENT #6210

NOTICE OF POSITIVE ALCOHOL TEST 

CONFIDENTIAL 

DATE: June 5, 2002

TO: _____, Manager, Division ____

FROM: _____, Drug and Alcohol Program Coordinator

SUBJ: _____, Badge #___

____, Badge #___ had a Breathalyzer test ___day, ____, 2001, at _____ Industrial Medical Clinic. The initial test 

result had an alcohol concentration of 0. 0___ and was confirmed positive by a second test at 0.0__. A copy of the 

test results is attached. We are still awaiting drug test results and they will be reported to you, as soon as they are 

available. 

To assist you with preparing for disciplinary action, the following checklist of mandatory actions is included: 

 Remove the employee from duty. Date of removal from duty _______________

 Notify the employee of the test result. 

 Refer employee to Employee Assistance Program (EAP) for assessment by a Substance Abuse Professional 

(SAP) and treatment resource information (Initial referral), this must be done regardless of disciplinary action to 

be taken, to be in compliance with the MTA/PTSC Alcohol-and Drug-Free Work Environment Policy.) 

 Schedule a disciplinary hearing. Date of hearing: _________________________

 Contact ____ to schedule a meeting with the Discipline Committee, as soon as the hearing date is set. 

A copy of this completed form and of the final disciplinary action taken must be sent to this office, as soon as 

a decision has been made and all parties notified. 

Thanks for your cooperation. If you have any question regarding this matter, please call me at ____. 

Attachments 

Appendix B. Example Administrative Forms and Lists Page B-18 

 

14 Los Angeles County Metropolitan Transportation Authority (LACMTA) 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-18. Employee Notification of Positive Test Result15

Employee Notification of a Positive Drug/Alcohol Screen

Employee Name: ____________________________________________________________ 

Employee Identification Number: _____________________ 

Attached is a copy of your positive drug and/or alcohol screen. This information (not the 

actual test result) is being forwarded to your supervisor for appropriate action. 

YOU MUST REPORT TO YOUR SUPERVISOR ______________________________, AT 

 (Supervisor’s Name) 

______________________________________________IMMEDIATELY UPON RELEASE 

 (Location employee must report to.) 

FROM THE CLINIC. 

If you fail to report to the supervisor, additional disciplinary action may be imposed, up to 

and including discharge. 

Notice of Availability of Substance Abuse Professional Evaluation

A Substance Abuse Professional evaluation is available for you. Please contact the MBTA 

Employee Assistance Program (EAP) to schedule an appointment. (617) 222-5381. The 

MBTA EAP is located at 120 Boylston Street, 6th Floor, Boston, MA. (across the hall from 

the MBTA clinic. ) In the case of an emergency, contact the 24-hour pager (781) 553-0001. 

___________________________________ ______________ ________________ 

Employee Signature Date Time 

____________________________________ ____________________________________ 

Print Employee Name Witness 

Appendix B. Example Administrative Forms and Lists Page B-19 

 

15Massachusetts Bay Transportation Authority (MBTA) 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-19. Supervisor Notification of Positive Test Result16

DRUG AND/OR ALCOHOL SCREEN INFORMATION FORM 

SUPERVISOR NOTIFICATION 

The following information is considered strictly confidential. It is being forwarded to you to 

ensure the employee is removed from safety-sensitive duties and to initiate the appropriate 

disciplinary action. Each supervisor is responsible for ensuring that this information is filed 

in a confidential and secure area. It may be released to additional management personnel on a

need to know basis only. 

EMPLOYEE IDENTIFICATION NUMBER: 

DATE OF DRUG AND/OR ALCOHOL SCREEN: 

 (INDICATE DRUG OR ALCOHOL) 

REASON FOR DRUG/ALCOHOL SCREEN: 

(FTA REQUIRED TEST ONLY) 

MRO VERIFICATION DATE: 

 

Authorized Medical Clinic Signature Date 

Pursuant to the MBTA Drug and Alcohol Policy and Testing Program, effective August 1, 2001. 

An employee must be instructed to comply with Section V, Enforcement of Policy Through 

Discipline. This section includes, but is not limited to, the supervisor instructing the employee 

that he or she must report to the MBTA Employee Assistance Program for a Substance Abuse 

Professional Evaluation as required by 49 CFR part 40. 

As a supervisor you may contact the MBTA Employee Assistance Program to schedule an 

evaluation or you must instruct the employee that he/she must complete the evaluation within 

seven (7) days of the discipline being issued. 

Please contact the MBTA Employee Assistance Program, 120 Boylston Street, 6th Floor, Boston, 

MA. (617) 222-5381, to schedule a Substance Abuse Professional Evaluation. 

 

Employee Signature Date 

 

Witness 

Appendix B. Example Administrative Forms and Lists Page B-20 

 

16Massachusetts Bay Transportation Authority (MBTA) 
Best Practices 

FTA Drug and Alcohol Testing Program

PRE-EMPLOYMENT TESTING

Figure B-20. Flow Chart for Pre-Employment Testing Process17

FTA DRUG & ALCOHOL TESTING PROGRAM 

Pre-Employment Testing 

 

Applicant instructed to report testing

Applicant reports to Lab Applicant not 

readily available 

for testing 

Applicant provides specimen Applicant fails to provide specimen Applicant informed 

that failure to 

provide specimen 

= RESUSAL = 

POSITIVE

Test NEGATIVE

= OK 

to schedule for

work

Test POSITIVE = 

MAY NOT WORK

Applicant informed that failure to 

Provide specimen = REFUSAL = 

POSITIVE 

Applicant may not 

be scheduled to

work in safetysensitive position 

Applicant may not 

be scheduled to

work in

safety-sensitive 

position 

Applicant may not be scheduled to 

work in safety-sensitive position

Applicant advised 

to contact 

Substance Abuse 

Professional 

(SAP) 

Applicant advised 

to contact 

Substance 

Abuse 

Professional 

(SAP) 

Applicant advised to contact 

Substance Abuse Professional

(SAP) 

Appendix B. Example Administrative Forms and Lists Page B-21 

17 West Virginia Department of Transportation (DOT), Division of Public Transit
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-21. Pre-Employment Documentation Summary Sheet18

PRE-EMPLOYMENT DOCUMENTATION 

SUMMARY SHEET 

Applicant Name: 

Address: 

City/State/Zip: 

Telephone:

Date of Application: 

Position Applied For:

CDL, Specify

Public Safety

Police

Fire

Correction

Other, Specify

Transit

Operator

Dispatcher

Mechanic

Security w/ Firearm

Other, Specify

Other, Specify

For Transit Only: 

Safety-Sensitive Job Function:

Operate a revenue service vehicle 

CDL for non-revenue service vehicle 

Maintenance of revenue service vehicle 

Controlling movement of revenue service vehicle 

Security with firearm

Date of Applicant Notification: 

Date of Test: 

Date Reported to Department: 

Date of Hire: 

Test Result: Positive Negative Canceled

Attachments:  Notification (F-3)  Chain of Custody (COC7) 

 Test Result Summary Form (F-4)  Order to Test (F-22) 

Appendix B. Example Administrative Forms and Lists Page B-22 

 

18 City of Albuquerque 
Best Practices 

FTA Drug and Alcohol Testing Program

Comment Hire Date

Date Result

Reported Test Result COC For

m

Consent 

Form Date of Test

Notification

of Test

Fi

gure B-22. Pre-Em

plo

yment T

est Trackin

g Lo

g 19

PRE –

E

M

P

L

O

Y

M

E

N

T TEST 

TRACKING LOG

Na

me of Applicant

Appendix B. Example Administrative Forms and Lists Page B-23 

 

19 City of Albuquerque 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-23. Applicant Notification of Positive Test Result20

Applicant Notification of a Positive Drug/Alcohol Screen

Applicant Name: ____________________________________________________________ 

Applicant Identification Number: _____________________ 

 (Social Security #) 

Attached is a copy of your positive drug and/or alcohol screen. This information (not the 

actual test result) is being forwarded to the Human Resources Department for appropriate

action. 

Human Resources Representative ________________________________________________ 

Telephone # ______________________ 

Notice of Availability of Substance Abuse Professional Evaluation

A Substance Abuse Professional evaluation is available for you. Please contact the MBTA 

Employee Assistance Program (EAP) to schedule an appointment. (617) 222-5381. The 

MBTA EAP is located at 120 Boylston Street, 6th Floor, Boston, MA. (across the hall from 

the MBTA clinic. ) In the case of an emergency contact the 24-hour pager (781) 553-0001. 

___________________________________ ______________ ________________ 

Applicant Signature Date Time 

____________________________________ ____________________________________ 

Print Applicant Name Witness 

Appendix B. Example Administrative Forms and Lists Page B-24 

 

20Massachusetts Bay Transportation Authority (MBTA) 
Best Practices 

FTA Drug and Alcohol Testing Program

REASONABLE SUSPICION TESTING

Figure B-24. Flow Chart for Reasonable Suspicion Testing Process21

FTA DRUG & ALCOHOL TESTING PROGRAM 

Reasonable Suspicion Testing 

 

Employee instructed to report testing

Employee reports to Lab Employee not 

readily available 

for testing 

Employee provides specimen Employee fails to provide 

specimen 

Employee

informed that 

failure to provide 

specimen =

RESUSAL = 

POSITIVE

Test NEGATIVE =

OK 

to return to work

Test POSITIVE = 

MAY NOT

RETURN TO

WORK

Employee informed that 

failure to provide specimen =

REFUSAL = POSITIVE

Employee

removed from 

safety sensitive 

position 

Employee

removed from 

safety-sensitive 

position 

Employee removed from 

safety-sensitive position

Employee

instructed to 

contact Substance 

Abuse 

Professional (SAP) 

Employee

instructed to 

contact Substance 

Abuse 

Professional 

(SAP)

Employee instructed to 

contact Substance Abuse 

Professional (SAP) 

Determination made by trained supervisor to test under FTA Drug and Alcohol Testing Program 

Appendix B. Example Administrative Forms and Lists Page B-25 

21 West Virginia Department of Transportation (DOT), Division of Public Transit
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-25. Reasonable Suspicion Process and Documentation22 (Sheet 1) 

REASONABLE SUSPICION 

PROCESS

 

EMPLOYEE 

RETURNED TO 

DUTY 

EMPLOYEE TAKEN FOR 

DRUG/ALCOHOL 

TESTING 

 ADMIN. LEAVE 

 UNTIL RESULTS 

DEPUTY/GENERAL

SUPER, EMPLOYEE 

MEET/CONFER. 

NOTIFY OPERATIONS

DIRECTOR 

OR DEPUTY/GENERAL 

MANAGER 

CONFIRMED

SUSPICIONS

NO FURTHER 

CAUSE 

OBSERVED BEHAVIOR 

OR 

SIGNS/SYMPTOMS 

EMPLOYEE/SUPERVISOR

MEETING 

IMMEDIATELY 

Appendix B. Example Administrative Forms and Lists Page B-26 

22 Western Maine Transportation Services 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-25. Reasonable Suspicion Process and Documentation (Sheet 2) 

Western Maine Transportation Services

REASONABLE SUSPICION DOCUMENTATION FORM 

EMPLOYEE NAME DATE OF OBSERVATION (MONTH, DAY, YEAR) 

LOCATION TIME OF OBSERVATION 

FROM AM 

PM TO AM PM

OBSERVED PERSONAL BEHAVIOR (CHECK ALL APPROPRIATE ITEMS) 

BREATH: 

(Odor of alcoholic beverage)

 STRONG ٱ

 NONE ٱ

MODERATE ٱ FAINT ٱ

EYES: 

 BLOODSHOT ٱ

 CLEAR ٱ

ٱ DILATED PUPILS

GLASSY ٱ

ٱ HEAVY EYELIDS 

 NORMAL ٱ

ٱ FIXED PUPILS 

SPEECH: 

 CONFUSED ٱ

 ACCENT ٱ

 SLURRED ٱ

ٱ NOT UNDERSTANDABLE

 STUTTERED ٱ

 MUMBLED ٱ

 GOOD ٱ

ٱ COTTON MOUTHED 

ٱ THICK TONGUED

 FAIR ٱ

ٱ MUSH MOUTHED 

 :OTHER ٱ

 EXCITED ٱ

 INDIFFFERENT ٱ

ٱ CARE FREE 

 COOPERATIVE ٱ

 COMBATIVE ٱ

 TALKATIVE ٱ

 COCKY ٱ

 PROFANE ٱ

 HILARIOUS ٱ

 INSULTING ٱ

 SLEEPY ٱ

 POLITE ٱ

ATTITUDE: 

OTHER: 

UNUSUAL 

ACTION:

HICCOUGHING ٱ

FIGHTING ٱ

 :OTHER ٱ

 BELCHING ٱ

 CRYING ٱ

 VOMITING ٱ

LAUGHING ٱ

BALANCE: ٱ FALLING 

 SWAYING ٱ

ٱ NEEDS SUPPORT

 :OTHER ٱ

 WOBBLING ٱ

WALKING: ٱ FALLING 

 SWAYING ٱ

 STAGGERING ٱ

 OTHER ٱ

 STUMBLING ٱ

TURNING ٱ FALLING 

 SWAYING ٱ

 STAGGERING ٱ

HESITANT ٱ

 STUMBLING ٱ

 :OTHER ٱ

ANY OTHER UNUSUAL ACTIONS OR STATEMENTS: 

SIGNS OR COMPLAINTS OF ILLNESS OR INJURY:

SUPERVISOR’S OPINION 

EFFECTS OF

ALCOHOL/DRUG

INTOXICATION

 NONE ٱ

 EXTREME ٱ

 OBVIOUS ٱ SLIGHT ٱ

OPERATION OF

EQUIPMENT 

 YES ٱ

 NO ٱ

COMMENTS: 

ADDITIONAL COMMENTS: 

SUPERVISOR SIGNATURE DATE TIME

WITNESS WITNESS WITNESS

Appendix B. Example Administrative Forms and Lists Page B-27 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-26. Reasonable Suspicion Short-Term Indicators 

LOS ANGELES COUNTY METROPOLITAN TRANSPORTATION AUTHORITY 

REASONABLE SUSPICION SHORT-TERM INDICATORS 

Manager/Supervisor: This form is to be used to substantiate and document the objective facts and 

circumstances leading to a reasonable suspicion determination. After careful observation of the 

employee’s behavior, please check all of the short-term indicators that denote a possible link to the 

employee’s use of prohibited alcohol or drugs. 

Employee Name___________________________ Badge _______Job Title ___________Dept._____ 

Supervisor Name__________________________ Badge _______Telephone ___________________ 

Second Supervisor_________________________(if applicable) Badge_______ 

A. Incident/Cause for Suspicion D. Body Movements 

 Apparent drug or alcohol intoxication  Unsteady walk, poor coordination 

 Abnormal or erratic behavior  Shaking hands/body, tremors, twitches 

 Observed/reported possession, dispensation 

or use of a prohibited substance 

 



Breathing irregularly, or with difficulty

Loss of physical control 

 Arrest or conviction for drug-related offense(s) E. Eyes 

B. Body Behavior  Bloodshot or watery

 Nausea or vomiting  Dilated or constricted pupils 

 Extreme fatigue/sleeping on job F. Speech

 Dizziness or fainting  Slurred or incoherent speech 

 Highly excited or nervous  Repetitious, rambles 

 Odor of alcohol G. Behavioral Indicators Noted 

C. Body Appearance  Verbal abusiveness 

 Either very flushed or very pale  Physical abusiveness 





Excessive sweating or skin clamminess 

Dry mouth, frequent swallowing, wetting lips 

frequently

 



Extreme aggressiveness or unresponsiveness 

Inappropriate response to questioning or

instructions 

 Disheveled appearance/out of uniform  Erratic/inappropriate behavior, 

hallucinations, disorientation, confusion, 

talkativeness, euphoric - (Circle all that apply)

Written summary including any pertinent information not noted above_______________________________

Reasonable Suspicion Test Performed Yes No Date ___/___/___ Time _______________

 Clinic__________________________________

Reasonable Suspicion Test Refused Yes No Date ___/___/___ Time _________________

Signature of Supervisor ___________________________ Date ___/___/___ Time ____________

 

Appendix B. Example Administrative Forms and Lists Page B-28 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-27. Reasonable Suspicion Evaluation and Checklist23 (Sheet 1)

This form is required to be completed by the supervisor of a safety-sensitive employee as a guideline for 

the determination to order a drug and/or alcohol test screen for the employee when reasonable suspicion 

exists subject to the MBTA‘s Drug and Alcohol Policy. The supervisor or a responsible company official 

shall independently complete this form in its entirety. 

Name of safety-sensitive employee: ________________________________________________. 

Employee identification number: _________________________ 

Position description of employee: ________________________ 

Date and time of evaluation: ______________________________

Location of employee when reasonable suspicion evaluation was made: ____________________

____________________________________________________________________(be specific) 

Evaluating supervisor: _________________________________________________________

Other supervisors at the location: ___________________________________________________ 

______________________________________________________________________________ 

I. CIRCUMSTANCES OCCURRING AT THE TIME OF THE EVALUATION

S Employee is reporting for duty: Yes No (circle one) 

S Employee is already on duty: Yes No (circle one) 

II. OBSERVATIONS OF EMPLOYEE’S PHYSICAL CONDITION

Check below any/all applicable behaviors and describe: 

Slurred speech

Confusion / disorientation 

Odor of alcohol on breath or person 

Odor of marijuana on breath or person 

Unsteady gait or lack of balance 

Glassy eyes 

Rapid or continuous eye movement or inability

to focus 

Drowsiness 

Appendix B. Example Administrative Forms and Lists Page B-29 

 

23Massachusetts Bay Transportation Authority (MBTA) 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-27. Reasonable Suspicion Evaluation and Checklist (Sheet 2) 

Inattentiveness

Apparent intoxicated behavior (without the 

odor of alcohol or marijuana 

 

Apparent intoxicated behavior (without the 

odor of alcohol or marijuana) 

Physical injury. Indicate location on body: 

______________________________________ 

Tremors or bodily shaking

Poor concentration 

Runny nose or sores around nostrils 

Very large or very small eye pupils 

Slow or inappropriate reactions 

III. OBSERVATIONS OF EMPLOYEE’S BEHAVIOR

Check below any/all applicable behaviors and describe: 

Inability to respond to questions or to respond 

correctly

Complaints of racing or irregular heart beating 

Marked irritability

Aggressiveness (attempts at physical contact) 

Inappropriate laughter, crying, etc. 

Sleeping on the job 

Fainting or repeated loss of consciousness 

Inappropriate job performance and/or violation 

of Authority rule(s) 

Appendix B. Example Administrative Forms and Lists Page B-30 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-27. Reasonable Suspicion Evaluation and Checklist (Sheet 3) 

IV. DETERMINATION OF REASONABLE SUSPICION 

Based on the above documented information, I have determined that there is is not (supervisor 

to circle only one ) reasonable suspicion for sending _______________________________ for a FTA 

drug and alcohol screening test. 

The drug and alcohol screening tests have been ordered by:____________________________________. 

To be conducted at: ______MBTA Medical Services

 ______ Charlestown Garage 

 ______ Cabot Garage 

Signature of supervisor/official conducting the evaluation: ____________________________________ 

Printed name of the supervisor conducting the evaluation and employee identification number: 

________________________________________________________________________ 

Date: ________________ (month, day, year). 

Appendix B. Example Administrative Forms and Lists Page B-31 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-28. Fitness for Duty24 (Sheet 1) 

FITNESS FOR DUTY 

CONFIDENTIAL 

EMPLOYEE DATE/TIME OF INCIDENT 

SUPERVISOR NAME AND TELEPHONE 

This checklist is to be completed when an observation has occurred which provides reasonable suspicion that 

an employee is under the influence of a prohibited drug substance or alcohol. You should note all pertinent 

behavior and physical signs or symptoms, which lead you to reasonably believe that the employee has 

recently used or is under the influence of a prohibited substance. Mark each applicable item on this form and

any additional facts or circumstances which you have noted. 

A. Nature of Incident/Cause for Suspicion 

______1. Observed/reported possession or use of a prohibited substance (including passenger complaint)

______2. Apparent drug or alcohol intoxication 

______3. Observed abnormal or erratic behavior

______4. Arrest or conviction for drug-related offense

______5. Other (e.g., flagrant violation of safety or serious misconduct, accident, or “near miss”, fighting or 

argumentative/abusive language, refusal or supervisor instruction, unauthorized absence on the job). 

Please specify. 

B. Behavioral Indicators Noted 

______1. Verbal abusiveness 

______2. Physical abusiveness 

______3. Extreme aggressiveness or agitation 

______4. Withdrawal, depression, tearfulness, or responsiveness 

______5. Inappropriate verbal responses to questioning or instructions

______6. Paranoid 

______7. Lethargic

______8. Other erratic or inappropriate behavior (e.g., hallucinations, disorientation, excessive euphoria, 

talkativeness, confusion). Please explain. 

Appendix B. Example Administrative Forms and Lists Page B-32 

 

24 City of Albuquerque and Ohio Department of Transportation 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-28. Fitness for Duty (Sheet 2) 

C. Physical Signs or Symptoms 

______1. Possession, dispensing, or using prohibited substance 

______2. Slurred or slowed speech 

______3. Incoherent, confused speech 

______4. Silent or whispering

______5. Swaying, falling, staggering

______6. Stumbling, reaching for support

______7. Arm raised for balance 

______8. Unsteady gait or other loss of physical control, poor coordination 

______9. Dilated or constricted pupils or unusual eye movement

______10. Bloodshot or watery eyes 

______11. Extreme aggressiveness or agitation 

______12. Excessive sweating or clamminess of skin

______13. Flushed or very pale face 

______14. Highly excited or nervous 

______15. Nausea or vomiting 

______16. Odor of alcohol 

______17. Odor of marijuana 

______18. Disheveled appearance or out of uniform

______19. Dry mouth (frequent swallowing/lip wetting)

______20. Dizziness or fainting 

______21. Shaking hands or body tremors/twitching 

______22. Breathing irregularity or difficulty breathing

______23. Runny nose or sores around nostrils 

______24. Inappropriate wearing of sunglasses 

______25. Puncture marks or “tracks” 

______26. Other (please specify) 

D. Observation Summary 

Speech: 

 

Coordination:

 

Standing: 

 

Walking/Turning:

 

Hand Movement: 

 

Balance: 

Appendix B. Example Administrative Forms and Lists Page B-33 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-28. Fitness for Duty (Sheet 3) 

D. Observation Summary (Continued) 

Disorientation: 

 

Judgment/Decision Making: 

 

Appearance: 

 

Nose: 

 

Eyes: 

 

Skin: 

 

Clothing: 

 

Odor: 

 

Other:

E. Written Summary 

Please summarize the facts and circumstances of the incident, employee response, supervisor 

actions taken, and any other pertinent information not previously noted. Please note the date, 

times, and locations of reasonable suspicion testing or note if the employee refused the test. 

Attach additional sheets as needed. 

 

Signature of Supervisor Date/Time 

Signature of Witness (if possible) Date/Time 

Appendix B. Example Administrative Forms and Lists Page B-34 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-29. Observation/Incident Report25 (Front) 

SUBSTANCE ABUSE PROGRAM 

OBSERVATION / INCIDENT REPORT

ٱ REASONABLE CAUSE ٱ POST-ACCIDENT ٱ RANDOM (Check One)

Date of Report________________________________ Date and Time of Incident___________________________________ 

Location of Observation _____________________________________________________________________________________

Observing Supervisor _______________________________________________________________________________________

Name of Observed Employee_________________________________________________________________________________

Reasonable Cause Testing

Reasonable cause for testing means suspicion based on specific personal observation by a supervisor or other company official 

trained in detecting the signs and symptoms of drug or alcohol abuse. The observer shall determine whether the employee is being

tested under DOT/FTA mandate or District Policy and shall describe and document his/her findings. 

DOT FTA Safety-Sensitive Employee Policy: 

ٱ Specific persons and articulable observations concerning

the appearance, behavior, speech, or body odors of the

employee. 

District Policy All Employees:

ٱ Violation of a safety rule, other unsafe work incident that 

leads supervisor to believe that drug/alcohol use may be 

a factor. 

ٱ Other physical, circumstantial or contemporaneous

indicators of drug or alcohol use.

Post-Accident Testing

Any employee must submit to drug and/or alcohol testing after an accident, whenever a supervisor determines he/she contributed to 

the accident or cannot be completely discounted as a contributing factor to the accident. Supervisor must indicate whether test

is being conducted under DOT/FTA mandate or District Policy as defined below:

DOT FTA Safety-Sensitive Employee Policy: 

ٱ A person dies testing is mandatory 

ٱ A person must be taken to a medical treatment facility

ٱ Mass Transit vehicle removed from service due to damage 

District Policy All Employees:

ٱ A fatality

ٱ A medical injury

ٱ District property damage of $5,000 or more

Associated with the above mentioned kinds of behavior are a variety of “warning signs” that usually appear on the job. 

PLACE A CHECK MARK √ NEXT TO THE SYMPTOM(S) OBSERVED IN THE ABOVE NAMED EMPLOYEE

SYMPTOMS 

ٱ Euphoria ٱ Exaggerated Sense of Ability ٱ Constricted Pupils

ٱ Relaxed Inhibitions ٱ Drowsiness ٱ Dilated Pupils

ٱ Slow/Depressed Breathing ٱ Depressed/Mood Changes ٱ Wandering Aimlessly

ٱ Observed Use of Drugs ٱ Observed Use of Alcohol ٱ Disoriented Behavior

ٱ Drunken Behavior ٱ Staggering Walk ٱ Odor of Alcohol

(with or without smell of alcohol) ٱ Slurred Speech ٱ Odor of Marijuana

ٱ Rapid Breathing ٱ Excessively Talkative ٱ Hand Tremors

ٱ Violent Behavior ٱ Combative/Argumentative ٱ Excessive Irritability

ٱ Watery, Glassy, Red Eyes ٱ Staring into Space ٱ Poor Hand/Eye Coordination

ٱ Hallucinations ٱ Poor Time Perception ٱ Other

 

25 San Francisco Bay Area Rapid Transit (BART) District 

Appendix B. Example Administrative Forms and Lists Page B-35 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-29. Observation/Incident Report (Back) 

IF EMPLOYEE WILL BE TESTED:

1. If the employee is represented, the on-scene supervisor advises him/her of the right to have a union representative present

prior to testing. Call for a union representative and document that union representation was called by the supervisor. 

2. Order the employee to submit to a drug and alcohol test and to sign the consent and release forms. Advise him/her that failure

to submit to a drug or alcohol test or failure to cooperate with the procedure is considered to be gross insubordination for failure 

to follow a direct order and will be cause for discipline up to and including discharge from District employment. 

3. For Reasonable Cause Testing Only: Inform the employee of the availability of rehabilitation at the employee’s own expense 

if the employee admits to drug or alcohol use prior to the test, if the employee is eligible, and inform the employee that a

positive test will result in disciplinary action up to and including termination if the employee has not elected the rehabilitation

option prior to the test. 

4. Advise the employee that he/she will be in a paid status until the test sample is collected and the breath alcohol test is

completed. The employee will then be placed in an unpaid status and relieved from duty until the District receives the drug test 

results. If both tests are negative, the District will make the employee whole. 

DID EMPLOYEE ADMIT TO DRUG OR ALCOHOL USE: ٱ YES ٱ NO 

IF REASONABLE CAUSE, DID EMPLOYEE REQUEST REHABILITATION: ٱ YES ٱ NO 

COMMENTS:________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

DESCRIBE INCIDENT: ________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

ACTION TAKEN: ____________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

 _______________________________

 SIGNATURE 

ORIGINAL OF THIS REPORT TO MANAGER OF EMPLOYEE SERVICES 

COPY OF THIS REPORT TO DEPARTMENT HEAD

Appendix B. Example Administrative Forms and Lists Page B-36 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-30. Accident/Incident/Reasonable Cause Report26 (Front) 

Accident/Incident/Reasonable Cause Report 

 

26 Denver Regional Transit District

PLEASE COMPLETE ALL AREAS NECESSARY 

ON THIS SIDE OF FORM

(X) areas that do not apply. 

Employee:__________________________________

Employee I.D. No. ___________________________

Division/Department: _________________________

Date of Accident/Incident: _____________________

Time: Location: 

REVIEW THE REVERSE SIDE OF THIS FORM TO 

DETERMINE WHETHER THE TEST IS UNDER FTA

OR RTD. 

ٱ FTA-DOT ٱ RTD NON-DOT

Remember, it is your responsibility to inform the person 

performing the test whether it is under FTA or RTD.

****************************************************** 

If you determine a test is not necessary, explain below: 

A. Other than a fatality, if the accident falls within one of the 

categories on the reverse side, but you think the employee 

can be totally discounted you must complete the area below, 

explaining the accident and why you decided not to test. 

_______________________________________________

_______________________________________________

_______________________________________________

_______________________________________________

****************************************************** 

B. Accidents or incidents where you believe negligence or 

carelessness may be involved. Briefly describe the accident/ 

incident and why the employee may be under the influence 

of alcohol, drugs or a controlled substance. Complete the 

Reasonable Cause, Post Accident Section on the right side. 

_____________________________________________________

_____________________________________________________

_____________________________________________________

_____________________________________________________

C. On-the-job accidents where serious injuries may have 

been caused by negligence or where more than one 

employee is involved, both the employee who caused the 

injury and the injured employee may be tested. Briefly

describe the accident and why you believe the employee 

may be under the influence of alcohol, drugs, or controlled 

substances. Complete the Reasonable Cause/Post 

Accident section on the right.

_____________________________________________________

_____________________________________________________

_____________________________________________________

_____________________________________________________

ٱ Reasonable Cause ٱ Post Accident 

Whether testing or not, this side must be completed. 

Complete each area on this side of the form. 

Do Not Use N/A, O.K. or Leave Blank

If possible, a second supervisor should be retained as an 

additional witness. 

________________________________________________

 (Employee Name) 

Speech: 

________________________________________________

________________________________________________

Dexterity: (Standing/Walking) 

________________________________________________

________________________________________________

Judgment/Decision Making: 

________________________________________________

________________________________________________

Appearance: (eyes, clothing, etc.) 

________________________________________________

________________________________________________

Odor: (alcoholic beverage, marijuana, etc.) 

________________________________________________

________________________________________________

Interpersonal interactions: (sudden outburst, mood swings, 

incoherent speech, etc.) 

________________________________________________

________________________________________________

Other: (physical, verbal altercations, drug paraphernalia, 

etc.) 

________________________________________________

________________________________________________

RTD Representative:_______________________________

Date: 

ٱ Sent for Testing ٱ Not Sent for Testing 

Appendix B. Example Administrative Forms and Lists Page B-37 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-30. Accident/Incident/Reasonable Cause Report (Back) 

Under Federal regulations an incident is considered an accident if: 

A. An individual dies. 

B. An individual suffers bodily injury and is transported from the scene for immediate 

medical treatment. 

C. The mass transit vehicle involved is a bus, electric bus, van, or automobile in which 

one or more vehicles incurs disabling damage as the result of the accident and must 

be transported from the scene by a tow truck or other vehicle. 

D. The mass transit vehicle involved is a railcar, trolley car, trolley bus, or vessel, and is 

removed from revenue service. 

*IF THE RTD EMPLOYEE INVOLVED IN THE ACCIDENT CAN BE TOTALLY 

DISCOUNTED AS A CONTRIBUTING FACTOR IN ITEMS B, C, AND D ONLY, 

THE EMPLOYEE DOES NOT HAVE TO BE TESTED. HOWEVER, FULL 

DOCUMENTATION MUST BE PROVIDED AS TO WHY THE TEST WAS NOT 

CONDUCTED. 

Reasonable Suspicion Testing 

The trained supervisors observe the employee and determines if testing is necessary based on 

specific, contemporaneously articulable observations concerning appearance, behavior, speech, or 

body odor of the employee. 

ANYTIME TESTING IS NOT COMPLETED WITHIN TWO HOURS AFTER THE ACCIDENT OR 

INCIDENT YOU MUST DOCUMENT THE REASON. 

Appendix B. Example Administrative Forms and Lists Page B-38
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-31. Reasonable Suspicion Individual Test Summary27

REASONABLE SUSPICION INDIVIDUAL TEST SUMMARY

TO BE COMPLETED BY SUPERVISOR 

Employee Name: 

Safety Sensitive Position: 

Observation Date: Time:

Circumstances

of Observation: 

(Attach additional sheets as necessary) 

Objective Facts Identified (Attach additional sheets as necessary)

Behavior:

Appearance: 

Speech: 

Odor:

Other: 

Safety-Sensitive Function Performed: 

Notification Date: Time:

Drug Test Date: Time:

Alcohol Test Date: Time:

Type of Test Conducted: _______ Drug _________ Alcohol 

Supervisor Name: 

Supervisor’s Signature: 

Did the alcohol test occur more than two hours from the time of the reasonable suspicion observation?

Yes No If yes, explain:

TO BE COMPLETED BY SUPERVISOR 

If no alcohol test occurred because more than eight hours elapsed from the time of the

reasonable suspicion observation, please explain: 

If no drug test was performed because more than 32 hours had passed since the time of the 

reasonable suspicion observation, please explain: 

 

Return the Form to your Department Program Coordinator within 24 hours. 

TO BE COMPLETED BY THE SAPM 

Date of Supervisor Training: 

Test Results: Drug: Positive Negative Canceled

Alcohol: Positive Negative 0.02 - 0.039

Comment: 

Attachments:  Test Result Summary Form (F4)  Order to Test (F22)  Other 

 Chain of Custody  Alcohol Test Form

 

Appendix B. Example Administrative Forms and Lists Page B-39

 

27 City of Albuquerque 
Best Practices 

FTA Drug and Alcohol Testing Program

Alcohol Test 

Result (BAT1)**

Test 

Result (F-4)**

Type Of 

Test*

Supervisor Notify

SAPM (F-11) 

Date 

Test 

Time Date 

Notification 

Time Date 

Observation 

Time

Figure B-32. Reasonable Suspicion Tracking Master Log 28

REASONABLE SUSPICIO

N TRACKING 

MASTER LOG 

Employee Name

* Type Of Test: D - Drug; A - Alcohol 

** Test Result: P - Positive; N - Negative; C - Cancelled 

Appendix B. Example Administrative Forms and Lists Page B-40

 

28 City of Albuquerque 
Best Practices 

FTA Drug and Alcohol Testing Program

Figure B-33. Failure To Administer Reasonable Suspicion Drug Test Form29

PREPARE THIS FORM ONLY WHEN THE EMPLOYEE IS NOT TESTED 

WITHIN 32 HOURS OF THE DETERMINATION OF REASONABLE 

SUSPICION. 

Name of safety-sensitive employee: _______________________________________ 

(first name, middle initial, last name) 

Date of determination: ___________________________ (month, day, year) 

Time: ____________________ AM PM (circle one) 

Location of employee when reasonable suspicion determination was made: 

________________________________________________________________________

______________________________________________________ 

______________________________________________________ (be specific) 

Reason why the drug test was not administered (check all that apply): 

S Safety-sensitive employee refused to be tested. 

S Safety-sensitive employee was medically incapacitated. 

S Safety-sensitive employee was arrested.

S Safety-sensitive employee was detained by law enforcement official. 

S Other: ____________________________________________________ 

Specific disciplinary action (if any) taken by ____________________ (insert name of 

transit system, state, contractor or sub-recipient): 

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________ 

Date on which this report is completed: _________________ (month, day, year).

Name of company official completing and filing report: 

__________________________________ (first name, middle initial, last name). 

Title of company official completing and filing report: 

________________________________________________________________ 

NOTE: _______________________________________ (INSERT NAME OF 

TRANSIT SYSTEM, STATE, CONTRACTOR, OR SUB-RECIPIENT) IS

REQUIRED, WHEN THE ACCIDENT SATISFIES ONE OR MORE OF THE 

FTA THRESHOLDS, TO CONDUCT THE APPROPRIATE DRUG TEST. THE 

RESULTS OF A DRUG TEST CONDUCTED BY A LAW ENFORCEMENT 

OFFICIAL CAN BE SUBSTITUTED ONLY IF THE EMPLOYEE IS BEING 

DETAINED BY A LAW ENFORCEMENT OFFICIAL AND CAN NOT BE

ACCESSED BY ___________________________________________________ 

(INSERT NAME OF TRANSIT SYSTEM, STATE, CONTRACTOR, OR SUBRECIPIENT). 

Appendix B. Example Administrative Forms and Lists Page B-41

 

29 SuTran Transit System, Sioux Falls, South Dakota
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-42 

POST-ACCIDENT TESTING 

Figure B-34. Post-Accident Test Decision Tree30 (Front) 

FTA D&A 

 TESTING

 Yes Yes

 No 

 Yes 

 

 

 

 No 

 Yes 

 No 

 

 - Yes 

 No 

 

 No 

 Yes 

 Yes 

 

 

 

 No 

 Yes 

 

30 Greater Cleveland Regional Transit Authority 

Was 

there a 

death?

Did an injury 

require 

immediate 

transport for 

treatment?

Was a 

rail 

vehicle 

involved?

For Bus & 

CRT, was 

there 

disabling 

damage 

to any 

vehicle?

“START” 

Accident 

occurs? 

Was 

rail car 

removed 

from 

service?

Was 

employee’s 

performance 

a contributing 

factor? 

FTA TEST 

REQUIRED 

FTA 

test NOT 

required; 

see 

other 

side
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-43

Figure B-34. Post-Accident Test Decision Tree (Back) 

RTA REQUIRED TESTING 

(Safety Sensitive Only) 

The following incidents require drug and 

alcohol testing by GCRTA policy when an 

employee either contributed to or cannot 

immediately be discounted from 

contributing to the accident, involving: 

• A pedestrian 

• A fixed object 

• Two or more GCRTA vehicles 

• A GCRTA vehicle striking the rear end 

of another vehicle 

• A head-on collision 

• A GCRTA vehicle sideswiping or broadsiding another vehicle 

• Physical damage greater than $5,000 

GREATER CLEVELAND RTA REGIONAL TRANSIT AUTHORITY 01/05/98
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-44

Figure B-35. Flow Chart for Post-Accident Testing Process31

FTA DRUG & ALCOHOL TESTING PROGRAM 

Post-Accident Testing 

 

Employee instructed to report for testing

Employee reports to Lab Employee not 

readily available 

for testing

Employee provides specimen Employee fails to provide 

specimen 

Employee informed 

failure to provide 

specimen=

RESUSAL= 

POSITIVE

Test NEGATIVE =

OK to return to 

work

Test POSITIVE = 

MAY NOT RETURN 

TO WORK

Employee informed that failure

to provide specimen =

REFUSAL = POSITIVE 

Employee removed 

from safety-sensitive 

position 

Employee removed 

from safety-sensitive 

position

Employee removed from 

safety-sensitive position

Employee instructed 

to contact 

Substance Abuse 

Professional (SAP) 

Employee instructed 

to contact Substance 

Abuse Professional 

(SAP)

Employee instructed to 

contact Substance Abuse 

Professional (SAP)

ALCOHOL TEST AS SOON AS POSSIBLE

--If not tested within 2 hours, document why 

--If not tested within 8 hours, cease attempts 

and update documentation

DRUG TEST 

WITHIN 32 HOURS 

YES: Driver and other employees whose performance could have contributed to 

accident are tested

NO: Testing not 

required by FTA

Accident Occurs Causing: 

Fatality – OR – 

Bodily injury requiring medical attention away from the scene – OR – 

Any vehicle involved must be towed

31 West Virginia Department of Transportation (DOT), Division of Public Transit
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-45

Figure B-36. Post-Accident Testing Decision Report32

POST ACCIDENT TESTING DECISION REPORT 

Note: Accident does not necessarily mean collision. If an individual falls on a vehicle and needs to be taken to the hospital, an 

accident has occurred, and a post-accident test is required unless the driver can be discounted as a contributing factor. (Spring 

1996, FTA D & A Updates, p. 5) 

System Name: ______________________________________________________________________ 

Date of accident: Time of accident: ___________________________________ 

Location of accident: ___________________________________________________________________________ 

Driver of Vehicle: Driver ID No. _______________________________ 

WV Uniform Traffic Crash Report Attached ٱ Yes ٱ No 

1. Was there loss of life as a result of the accident? 

ٱ Yes (Requires Testing – No exceptions) ٱ No 

2. Did an individual suffer a bodily injury and immediately receive medical treatment away from the scene of 

the accident? 

ٱ Yes (Requires Testing unless question 4 applies.) ٱ No (Requires no testing under FTA authority.) 

3. Was there disabling damage to any of the vehicles involved? Disabling damage means damage which precludes 

the departure of any vehicle from leaving the scene of the occurrence in its usual manner in daylight after simple repairs; or 

damage to any vehicle that could have been operated but which would have further damaged the vehicle if so operated. Disabling 

damage does not include damage that could be remedied temporarily at the scene of the occurrence without special tools or parts; 

tire disablement even if no spare tire is available; or damage to headlights, tail-lights, turn signals, horn, or windshield wipers that 

makes them inoperative. 

ٱ Yes (Requires Testing unless question 4 applies.) ٱ No (Requires no testing under FTA Authority. 

4. Can the driver or any other covered employee on the vehicle be completely discounted as a contributing 

factor to the accident? Note: If you discount the driver as a contributing factor, it should be well documented.

ٱ Yes ٱ No Even if you answer No, under FTA regulations you must also meet the criteria questions 1, 2, 

and/or 3 to require testing. 

5. If drug and alcohol testing is required, can the performance of any other safety sensitive employees (e.g., 

maintenance personnel, dispatcher, etc.), whose performance may have contributed to the accident (as determined 

by the transit agency at the time of the accident), be completely discounted as contributing to the accident? 

ٱ Yes ٱ No Even if you answer No, under FTA regulations you must also meet the criteria questions 1, 2, 

and/or 3 to require testing. List other employees tested on back of form.

6. Did you perform a drug and/or alcohol test? ٱ Yes ٱ No If No, complete #6 and sign and submit a report.

Name of Supervisor making this determination _____________________________________________________ 

Time Employee was informed of this determination _________________________________________________ 

7. Decision to Test: FTA Authority ٱ Company Authority ٱ

8. Was an alcohol test performed within 2 hours? ٱ Yes Date & Time:____________________ 

ٱ No Why, Not? __________________________________________________________________________ 

9. If no alcohol test was performed and more than eight hours elapsed from the time of the accident, please 

explain.____________________ __________________________________________________________________ 

10. Was a drug test performed within 32 hours? ٱ Yes Date & Time:____________________ 

ٱ No Why, Not? __________________________________________________________________________ 

11. Did the driver leave the scene of the accident without just cause? ٱ Yes ٱ No 

If Yes, please explain ____________________________________________________________________________ 

Report Submitted By: 

___________________________________________________________ ______________________________ 

 Signature & Title Date 

For your files, attach test results summary, order to test, chain of custody (USDOT), and alcohol test form (USDOT) WVDPT 11/00

 

32 West Virginia Department of Transportation (DOT), Division of Public Transit 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-46

Figure B-37. Post Accident Testing Procedure33

Substance Abuse Program 

Post Accident Testing Procedure

 NO TEST TEST 

 

33 San Francisco Bay Area Rapid Transit District (BART)

On the job accident occurs. 

On-scene communications coordinator stabilizes situation, and 

designates a first on-scene supervisor. 

Employee reports accident to supervisor. 

First on-scene supervisor escorts employee to private area to 

determine if the employee contributed to the accident. 

On-scene supervisor decides whether to test or not to test. 

Supervisor must keep employees in sight until procedure is completed. 

Employee returns to work, if supervisor determines 

employee is fit to work. 

Document action taken on the Observation/Incident 

Report. 

Forward original of Report to Employee Services 

Administrator (ESA) and copy to Department Head. 

If indicated, complete Supervisor’s Report of Injury

to initiate Trauma Response Program. Call ESA. 

Direct the employee to do the same. 

Advise the employee of required test. 

Supervisor calls Central to notify the collection agent and 

the Employee Services Administrator (ESA) that an

employee is to be tested. THE EMPLOYEE IS NOT 

IDENTIFIED BY NAME.

Union Representative is called. 

Order employee drug and alcohol test. (Read 

the Post Accident Instructions to the Em

to submit to 

ployee.)

Advise the employee that failure to submit to testing or 

failure to fully cooperate with the testing procedures is 

considered to be gross insubordination for failure to follow

a direct order, and for violation of the post accident 

provision of the District’s Substance Abuse Program, and 

will be cause for discipline up to and including discharge 

from District employment. 

Advise employees that he/she will be on paid status until 

the breath alcohol test is conducted and the drug test 

sample is collected. The employee will then be placed on 

unpaid status and relieved from duty until the District 

receives results of both tests. If the result of both tests is 

negative, the District will make the employee whole.

Document the action taken on observation/Incident Report. 

Alcohol breath test conducted, drug test sample collected. 

Employee is transported home. 

Forward the original of the Observation/Incident Report to 

the ESA and a copy to the Department Head. 

If indicated, complete a Supervisor’s Report of Injury to 

initiate the Trauma Response Program. Call the ESA. 

Direct employee to do same. 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-47

Figure B-38. Post-Accident Drug and Alcohol Testing Decision Maker Form (Front) 

LOS ANGELES COUNTY 

METROPOLITAN TRANSPORTATION AUTHORITY

POST-ACCIDENT DRUG AND ALCOHOL TESTING 

DECISION MAKER FORM 

The MTA Alcohol & Drug Abuse Policy (HR 4-2) and the Federal Transit Administration (FTA) regulations (49 

CFR Parts 653 and 654) require that employees involved in a vehicle accident (as outlined in the Policy) submit to 

tests for alcohol and prohibited drugs as soon as possible following the accident. The Policy also requires the testing 

of any other employee whose performance could have contributed to the accident, as determined by the manager or 

supervisor at the scene using the best information available at the time of the decision. The testing of non-safety 

sensitive employees comes under the MTA’s own authority. 

Accident Information: 

Date of Accident____________________________ Time of Accident: __________________ 

Employee Name: ______________________________ Badge _________ Div/Dept. _________ 

Decision Questions: 

• Was there a fatality? Yes ____ No ____. If Yes, Post-Accident tests are required. 

• If there was no fatality, ask the following questions: 

1. Has any individual suffered a bodily injury and immediately received medical treatment away from the 

scene of the accident? Yes _____ No _____ 

2. If the vehicle involved was a bus, electric bus, van, or automobile, was there a disabling damage as a 

result of the occurrence and the vehicle was transported away from the scene by a tow truck or other 

vehicle? Yes ____ No ____ 

3. If the vehicle involved was a rail car, trolley car, or trolley bus, was the vehicle removed from revenue 

service as a result of the accident? Yes____ No _____ 

If you checked Yes for questions 1, 2 or 3, a Post-Accident test is required unless you determine, using the 

best information available at the time of the decision, that the employee’s performance can be completely 

discounted as a contributing factor to the accident. (Any reason for NOT conducting a Post-Accident test after 

you’ve answered Yes to any of the above questions MUST be documented on the reverse side of this form.) 

Employee taken to ___________________________________ Clinic (nearest medical facility) 

by __________________________ Title_______________________ at__________ a.m./p.m. 

 

FTA regulations also require that alcohol testing must be done as soon as possible following the accident. If alcohol 

testing is not conducted within 2 hours after the accident, you must document the reason for the delay on the 

reverse side of this form. If the alcohol test is not administered within 8 hours, and the drug test within 32 

hours, you must cease all efforts to administer the tests and document the reason(s) why the tests were not 

administered within the FTA-prescribed time frames. 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-48

Figure B-38. Post-Accident Drug and Alcohol Testing Decision Maker Form (Back) 

Reason Test Was Not Completed or Delayed: 

_____________________________________________________________________________________________

_____________________________________________________________________________________________

_____________________________________________________________________________________________

_____________________________________________________________________________________________

_____________________________________________________________________________________________

_____________________________________________________________________________________________

_____________________________________________________________________________________________ 

Testing Procedures: 

____ Determine if employee requires medical attention. 

_____ Notify Operations Dispatch that the employee will be sent for 10-58 and briefly state the reason for testing. 

_____ Bring employee into a private setting if possible and inform him/her that (s)he will be transported to an 

MTA-authorized medical clinic for a drug and alcohol test, in accordance with DOT-mandated procedures 

outlined as Attachment 3 to the Alcohol & Drug Abuse Policy.

_____ Complete the Medical Authorization for Services form and mark Post-Accident for test type. 

_____ Escort the employee to the nearest medical clinic and inform him/her that (s)he will be removed from any 

safety-sensitive function pending the outcome of the tests. 

_____ If employee refuses to submit to testing, inform employee that refusal to comply or cooperate is considered 

an admission of guilt, treated as a positive test, and will result in discipline up to and including termination. 

Suspend employee pending disciplinary hearing.

Notify Human Resources: 

FTA regulations require the Drug & Alcohol Program Manager to keep copies of all documents pertaining to FTAmandated tests in a centralized location. Upon completion of this form, send the original to Jessica Gil in Human 

Resources (99-4-4) in a confidential envelope and keep a copy in the employee’s department/division personnel 

file. 

Please respect the privacy of the employee and the integrity of the testing program. Keep all matters 

confidential and discuss only with those who “have a need to know.” 

________________________________________ ________________________________________ 

On-Scene Decision Maker Title 

________________________________________ ________________________________________ 

Date Department/Division 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-49

Figure B-39. Post-Accident Testing Record of Decision (Front) 

Southeastern Pennsylvania Transportation Authority 

RECORD OF DECISION 

FTA/SEPTA POST-ACCIDENT DRUG AND ALCOHOL TEST 

DATE OF ACCIDENT: DAY: LOCATION: 

NAME OF EMPLOYEE: OCCUPATION: 

ACCOUNT NUMBER: SOCIAL SECURITY NUMBER INCIDENT NUMBER: 

MM DD YY 

VEHICLE NUMBER: ROUTE: BLOCK: 

TYPE OF VEHICLE: 

 Bus ٱ

 LRV ٱ

 -5N ٱ

ٱ Trackless Trolley 

ٱ Subway/Elevated 

ٱ Supervisor T-Car 

ٱ Non-Revenue Service Vehicle 

ٱ Transit Police Vehicle 

_____________________ Other ٱ

TEST DETERMINATION 

Use this table to indicate the results of the accident and the type of test that is required. Check one of the boxes that specifies the 

results of the accident. Do not check more than one box. 

VEHICLE ACCIDENT RESULTS TYPE OF TEST 

1. ٱ Revenue vehicle with fatality FTA 

POST-ACCIDENT 

2. ٱ Revenue vehicle with injury requiring medical treatment away from scene AND

employee could have contributed

FTA 

POST-ACCIDENT 

3. ٱ Revenue vehicle with any vehicle towed OR disabling damage AND employee 

could have contributed

FTA 

POST-ACCIDENT 

4. ٱ Non-revenue vehicle operated by CDL holder with fatality FTA 

POST-ACCIDENT 

5. ٱ Non-revenue vehicle operated by CDL holder with injury requiring medical 

treatment away from scene AND employee could have contributed

FTA 

POST-ACCIDENT 

6. ٱ Non-revenue vehicle operated by CDL holder with any vehicle towed AND

employee could have contributed

FTA 

POST-ACCIDENT 

7. ٱ Non-revenue vehicle operated by non-CDL holder with fatality SEPTA 

POST-ACCIDENT 

8. ٱ Non-revenue vehicle operated by non-CDL holder with injury requiring medical 

treatment away from scene AND employee could have contributed

SEPTA 

POST-ACCIDENT 

9. ٱ Non-revenue vehicle operated by non-CDL holder with disabling damage AND

 employee could have contributed

SEPTA 

POST-ACCIDENT 

10. ٱ Post-accident criteria NOT met. Go to Record of Decision, Reasonable Suspicion 

Drug and Alcohol Test (Form F0189)

FINAL DETERMINATION (CHECK [√] ONE FROM ABOVE DETERMINATION.) 

ٱ FTA Post-Accident Test 

ٱ SEPTA Post-Accident Test 

ٱ No Post-Accident Test 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-50

Figure B-39. Post-Accident Record of Decision (Back) 

RECORD OF DECISION 

FTA/SEPTA POST-ACCIDENT DRUG AND ALCOHOL TEST 

STATUS OF THIS EMPLOYEE (CHECK [√] ONE.)

ٱ Operating the Vehicle 

ٱ On duty on the Vehicle at the time of the accident 

ٱ Other Covered Employee

ACCIDENT INFORMATION 

ARE ANY OTHER EMPLOYEES TO BE TESTED BECAUSE OF THIS ACCIDENT? 

ٱ Yes ٱ No ٱ Unknown, Investigation indicates possible involvement by others. 

Name: Location: 

HOW WAS THIS EMPLOYEE INVOLVED IN THE ACCIDENT? 

TIME OF ACCIDENT: TIME OF TEST (Medical): ELAPSED TIME (Medical): 

 AM 

 PM 

 AM 

 PM HR(S) MINS 

ALCOHOL TEST GIVEN WITHIN TWO HOURS?: 

 ٱ Yes ٱ No If no, state reason below, if known. 

SUPERVISOR’S NAME (PRINT): WORK LOCATION: ACCOUNT NUMBER: 

SUPERVISOR’S SIGNATURE: WORK EXTENSION: 

NOTE: This document must accompany the employee to Medical and be retained on file as a record of decision on whether to 

administer a post-accident test. 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-51

Figure B-40. Post-Accident Documentation Summary Form34 (Front) 

POST-ACCIDENT 

DOCUMENTATION SUMMARY

1) Accident Report #: __________________________________________________________________

2) Incident Report #: __________________________________________________________________

3) Location of Accident: __________________________________________________________________ 

____________________________________________________________________________________ 

____________________________________________________________________________________ 

4) Brief Description: ________________________________________________________________________

____________________________________________________________________________________ 

____________________________________________________________________________________ 

5) Accident Date: __________________ Time: ___________________

6) Report Date: __________________ Time: ___________________

7) Name of Employee: ___________________________________________________________________

8) Identification Number: __________________________________________________________________

9) Position: __________________________________________________________________

10) Result of Accident:

10)a) Was there a fatality? ____Yes ____No

10)b) Was there disabling damage* to City or other vehicles? ____Yes ____No 

10)c) Was anyone transported from the scene for medical attention? ____Yes ____No

 If yes, what category? ____ Employees 

 ____ Passengers 

 ____ Other Vehicle 

 ____ Other

11) Was the employee sent for a post-accident drug and alcohol test? ____Yes ____No 

12) If no, explain: _____________________________________________________________________________ 

_____________________________________________________________________________________________

_____________________________________________________________________________________________

 13) Decision to Test: 

13)a) DOT Authority (transit revenue service or commercial motor vehicles) ____Yes ____No

13)b)Company Authority (other City equipment, machines, or vehicles) ____Yes____No

*Disabling damage means damage which precludes departure of any vehicle from the scene of the occurrence in its usual 

manner in daylight after simple repairs. Disabling damage includes damage to vehicles that could have been operated but 

would have been further damaged if so operated, but does not include damage which can be remedied temporarily at the

scene of the occurrence without special tools or parts, tire disablement without other damage even if no spare tire is

available, or damage to headlights, taillights, turn signals, horn, mirrors or windshield wipers that makes them inoperative. 

 

34 City of Albuquerque 

To Be Completed by Supervisor 

Return to Department Program Coordinator 

within 24 Hours of the Accident.
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-52

Figure B-40. Post-Accident Documentation Summary Form (Back) 

14) Type of Test: ____ Drug ____Alcohol 

15) Supervisor Making Determination: 

16) Notification of Test: Date: Time: 

17) Drug Test Conducted: Date: Time: 

18) Alcohol Test Conducted: Date: Time 

19) Did the employee refuse the test? ____Yes ____No 

If yes, please explain: 

 

 

20) Did the alcohol test occur more than two hours from the time of the accident? ____ Yes ____No 

If Yes, Explain: 

 

21) If no alcohol test occurred because more than eight hours elapsed from the time of the accident, please 

explain: 

 

22) Did the employee leave the scene of the accident without just cause? ____ Yes ____ No 

If Yes, explain: 

 

 

 

23) If no drug test was performed because more than 32 hours had passed since the time of the accident, 

explain why: 

To Be Completed By SAPM 

24) Test Result: ____ Positive ____ Negative ____Test Cancelled 

25) Attachments: 

# Test Result Summary 

# Order to Test 

# Chain of Custody 

# Alcohol Testing Form 

# Return Form to Supervisor Within 24 Hours of Accident 

______________________________________________________ 

 Supervisor’s Signature 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-53

Figure B-41. Failure To Administer Post-Accident Drug Test35

PREPARE THIS FORM ONLY WHEN THE EMPLOYEE IS NOT TESTED 

WITHIN 32 HOURS OF THE DETERMINATION THAT A POST-ACCIDENT 

DRUG TEST IS REQUIRED. 

Names of ____________________________________________________ (insert name 

of transit system, state, contractor or sub-recipient) safety-sensitive employees involved 

in the accident/incident: 

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________ 

(first names, middle initials, last names). 

Date of accident/incident satisfying at least one of the FTA thresholds requiring postaccident drug testing: ____________________________________ (month, day, year) 

Time of qualifying accident/incident: __________________ AM PM (circle one) 

Specific location of the qualifying accident/incident: _______________________ 

________________________________________________________________________

________________________________________________________________________

________________________________________________ 

Reason why the drug test was not administered (check all that apply): 

S Safety-sensitive employee refused to be tested. 

S Safety-sensitive employee was medically incapacitated. 

S Safety-sensitive employee was arrested. 

S Safety-sensitive employee was detained by law enforcement official. 

S Other: ____________________________________________________ 

Specific disciplinary action (if any) taken by _________________________ (insert name 

of transit system, state, contractor or sub-recipient): 

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________ 

Date on which this report is completed: _________________ (month, day, year). 

Name of company official completing and filing report: 

__________________________________ (first name, middle initial, last name). 

Title of company official completing and filing report: 

________________________________________________________________. 

 

35 Sioux Falls [South Dakota] Transit System (SuTran). 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-54 Reason If No Test Alcohol Test Result (BAT1)*** Date Alcohol Test Time Drug Test Result (F-4)*** Date Drug Test Time Date Notification Time Date Accident Time Test Authority  Notify SAPM (F-9) Accident Result**  Position* Employees Involved Figure B-42. Post-Accident Test Master Log 36 POST-ACCIDENT TEST MASTER LOG Accident Number * Position: O - Operator; D - Dispatcher; M - Maintenance; S - Security; C - CDL Holder, F - Fire, P - Police, R - Correction 

 

36 City of Albuquerque 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-55

RANDOM TESTING 

Figure B-43. Flow Chart for Random Testing Process 37

FTA DRUG & ALCOHOL TESTING PROGRAM 

RANDOM TESTING 

Employee instructed to report for testing

Employee reports to Lab Employee not 

readily available 

for testing 

Employee provides specimen Employee fails to provide 

specimen 

Employee informed 

that failure to 

provide specimen =

RESUSAL = 

POSITIVE

Test NEGATIVE =

OK to return to 

work

Test POSITIVE = 

MAY NOT

RETURN TO

WORK

Employee informed that 

failure to provide specimen =

REFUSAL = POSITIVE

Employee removed 

from safety-sensitive 

position 

Employee

removed from 

safety-sensitive 

position 

Employee removed from 

safety-sensitive position

Employee instructed 

to contact 

Substance Abuse 

Professional (SAP) 

Employee

instructed to 

contact Substance 

Abuse 

Employee instructed to 

contact Substance Abuse 

Professional (SAP) 

 

Professional (SAP)

37 West Virginia Department of Transportation (DOT), Division of Public Transit
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-56

Figure B-44. Random Testing Procedure38

Substance Abuse Program 

Random Testing Procedure 

 

Supervisor notified of employee selection for testing. 

Notify the employee of selection for random testing, and 

have the employee stop work.

Order the employee to submit to drug and alcohol tests. 

(Read the Random Selection Instructions to Employee.) 

Advise the employee that failure to submit to or cooperate 

with drug or alcohol tests, and to sign a consent to test or 

a release of information form is considered gross 

insubordination and violation of the random testing

provision of the District’s Substance Abuse Program, and 

will be cause for discipline up to and including discharge 

from District employment. 

Inform the employee of availability of rehabilitation at the 

employee’s expense, no need to admit with first positive 

random test, must admit to drug or alcohol use prior to the 

second positive test. 

Inform the employee that a positive drug or alcohol (0.04%

or greater) or refused test will result in disciplinary action 

up to and including discharge for gross insubordination and 

violation of the random testing provision of the District’s 

Substance Abuse Program, if the employee has not 

elected the rehabilitation option prior to the second random 

positive test. 

Escort employee to collection area, and wait for the 

collection agent to arrive. 

Document any unusual activity relating to the drug or 

alcohol test on the Observation/Incident Report. Forward 

the original to the Employee Services Administrator (ESA), 

and a copy to the Department Head. 

The supervisor remains with employee and collector until 

the collection is completed. 

NEGATIVE ALCOHOL TEST

The employee returns to work. 

LEVEL 1 – ALCOHOL TEST 

0.02% TO 0.039%

Advise the employee he/she is relieved of duty for at least 

eight (8) hours without pay.

LEVEL 2 – POSITIVE 

ALCOHOL TEST ABOVE 0.04%

Advise the employee he/she is relieved of duty or is on 

unpaid leave. Transport the employee home. Direct the 

employee to call ESA for an appointment. The employee 

will not be allowed to return to duty until released by ESA. 

38 San Francisco Bay Area Rapid Transit (BART) District 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-57

Figure B-45. Random Drug/Alcohol Testing Notification Form39

RANDOM DRUG / ALCOHOL TESTING NOTIFICATION FORM 

Employee Identification 

Employee Name: 

Employee ID No. Social Security No.: 

Department Location: 

Selection, Notification, and Testing 

Date Test Scheduled: / / Test Scheduled: ALCOHOL / DRUG 

Supervisor: Time Employee Notified: am / pm 

Date Supervisor Notified: / / Date Tested: / / 

Time Supervisor Notified: am / pm Time Tested: am / pm 

You have been selected for random testing for the presence of prohibited drugs and/or to participate in a 

breath alcohol test in accordance with Federal regulations for the random drug and alcohol testing of 

safety sensitive employees. Under District policy, the first time you test positive on a random drug or 

alcohol (0.04% or greater) test, you may elect rehabilitation at your own expense if you are eligible. It is 

not necessary for you to admit to drug or alcohol use prior to the test. However, with a second random

positive test, you must admit to drug use and/or alcohol abuse prior to the test in order to be eligible for 

rehabilitation. Even if you admit to drug use and/or alcohol abuse, you may elect rehabilitation at your 

own expense only if you are eligible. If you do not admit to drug and/or alcohol use prior to the test and 

either test is positive, it will be cause for disciplinary action, up to and including discharge from District 

employment. 

You will remain in paid status until after the breath alcohol test is conducted and the drug test sample is 

collected. If the alcohol breath test is negative, you will be released to return to duty. If the breath test 

reveals a confirmed result between 0.02% and 0.039%, you will be relieved from duty on non-pay status 

for 8 hours or until your next shift. If the breath alcohol test is confirmed positive (0.04% or greater), you 

will be relieved from duty, placed in non-pay status, and directed to the Employee Services division of the 

Human Resources Department for evaluation. If your test result(s) indicate drug use or alcohol abuse, 

you may be required to participate in a substance abuse rehabilitation treatment program as a condition 

of continued employment. 

Refusing to provide a specimen, tampering with your specimen, or providing false information on a 

specimen collection or breath alcohol chain of custody form constitutes insubordination and is grounds for 

disciplinary action, up to and including termination from employment. 

________________________________ ________________________ 

 Employee Signature Date/Time 

__________________________________________ ________________________________ 

 Witness Signature Date/Time 

Original – Employee Services 

Yellow - Employee 

Pink - Collector 

 

39 San Francisco Bay Area Rapid Transit (BART) District 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-58

Figure B- 46. Employee Notice for Random Substance Abuse Test 

Massachusetts Bay Transportation Authority 

EMPLOYEE NOTICE FOR SCHEDULED SUBSTANCE ABUSE TEST 

DATE: 

FROM: MBTA Random Drug & Alcohol Program 

 Drug and Alcohol Program Administrator 

TO: 

 

AT: 

TEST DATE: (Random Drug Test) 

Urine Collection Location: 

Appointment Time: _____________________________________________________________________ 

Authority for Test: __ DOT/FTA Regulations ___MBTA Regulations 

================================================================================== 

Your name has been selected for a urinalysis drug testing by a computerized program of random selection. Your 

selection does not imply that this company has a specific cause to suspect you of using illegal drugs. Nonetheless, 

the DOT Anti-Drug regulations and this company’s Anti-Drug Program require that the random testing urine 

specimen be collected. 

You may provide the 60 ml (2 oz) urine specimen in the privacy of a stall. If you are unable to provide a specimen 

of sufficient quantity, you will be given a waiting period and encouraged to drink water. If you are unable to 

provide the specimen within the waiting period, you will be deemed to have refused to provide the specimen. 

If you refuse to provide the specimen, adulterate the sample, substitute the urine of another person, or fail the drug 

test, you will be relieved of your employment duties and referred to this company’s Employee Assistance Program. 

You may also be subject to disciplinary action, possibly including termination. 

This copy will be retained in your confidential drug testing files, together with the Medical Review Officer’s final 

determination of the drug test results. 

Please sign the bottom of this notice to acknowledge its receipt. 

Please list any/all medications here. 

_______________________________ 

_______________________________ 

NOTIFICATION RECEIVED ______________________________ _________________________ 

 Employee Signature Date and Time 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-59

Figure B-47. Random Selection Instructions40

Random Selections 

1. Risk Management – Random Selector - Maintains random pools – (FTA, FHWA, other). When put in 

payroll system Department Program Coordinator (DPC) indicates who is “safety-sensitive” by job code. 

2. Biweekly (consistent with payroll period), the Random Selector will determine the number of tests to be drawn 

from each pool. The numbers will be drawn and reported on form R-1 for each DPC. The report will also 

include the type of tests to be conducted. 

3. The DPC will research the work schedule of each employee drawn and schedule the tests over the biweekly 

testing period. The DPC will be careful to distribute the tests throughout the day, day of the week, and 

testing period. The DPC will keep the list confidential and will not provide any advance notice to the 

employee. On the day before the test the DPC will notify the appropriate Division Contact to schedule the 

test using form R-2. If the employee is not working on that day, the DPC and division contact will select 

another time within the testing period. The employee will not be notified of the test until he/she is 

instructed to immediately proceed to the collection site. 

4. The Division Contact person will ensure that the employee is tested at the scheduled date and time. The 

Division Contact will complete form R-2 and return it the DPC. 

5. The DPC will record on R-1 the date and time the test was scheduled, if the test was completed or cancelled, 

and the explanation if no test was performed. The DPC will keep a copy of R-1 and send the original to the 

Random Selector within one week of the period end. 

6. The Random Selector notes the number of completed tests and will adjust the number of tests to be conducted 

during the next testing period to account for any missed tests. 

7. The DPC will complete a, “Random Individual Test Summary Sheet” (R-3), for each random test; will attach 

appropriate documentation, and will file in the DPC’s file. 

 

40 City of Albuquerque 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-60

Figure B-48. Roles and Responsibilities of Random Selector41

ROLES AND RESPONSIBILITIES 

RANDOM SELECTOR 

 Maintains random pools for FTA, FHWA, and other City employees 

 Coordinates with payroll to ensure pools are accurate and up-to-date, and that all employees are in the right pool 

 Determines the number of draws to be performed for each pool reflecting required testing rates adjusted for 

incomplete tests from prior testing period 

 Performs biweekly draws and informs appropriate DPC of numbers selected 

 Documents draws and tracks which tests were conducted 

 Notifies DPC/SAPM of any procedural violations that compromise the integrity of the random process 

Figure B-49. Random Testing Schedule42

Transit Department: Random Testing Schedule 

Draw 

Date: 

Division 

Contact: 

Division Notification 

Date: 

Draw Scheduled Employee Notified Tested 

No. 

Employee Name Test Date Test Time Date Time Date Time Comments 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

11. 

12. 

13. 

14. 

15. 

16. 

 

41 City of Albuquerque 

42 City of Albuquerque 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-61

Figure B-50. Random Testing Selection Documentation Form43

Random Testing Number Selection Documentation Form 

 FTA  FHWA  Public Safety  Other 

Department: 

 Test Period Number 

(A) Number of Safety-Sensitive Functions (B) Number of Testing Period Per Year 

(C) Number of Drug Tests this Period ((A) * 50% ÷ (B)) (D) Adjusted Number of Tests from Previous Period 

 Alcohol Tests this Period ((A) * 10% ÷ (B)) Drugs Alcohol 

(E) Total Tests (C + D) Drugs Alcohol Reason for Adjustment: 

Driver Name or I.D Number Type of Test Completion * 

Test 

D/A/B 

Collection 

Date 

Time of 

Collection Drug Alcohol 

If No Test 

Explanation 

Total Drug *Y= Yes; N= No; C= Cancelled 

Total Alcohol 

Confidential – For Internal Use Only

 

43 City of Albuquerque 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-62

Figure B-51. Individual Random Test Summary Sheet 44

RANDOM TESTING 

INDIVIDUAL TEST SUMMARY SHEET 

Employee Name: 

Employee Number: 

Testing Period: 

Selection Date: Selector: 

Test Type: Drug Alcohol 

Notification: Date: Time: 

Test: Date Time: 

Shift Placement: Begin Middle End 

Drug 

Test Result: Negative Positive Cancelled 

Alcohol 

Test Result: Below 0.02 0.02 - 0.039 0.04 or greater 

Consequences: 

Removal from 

SS Duty 

Referral 

to SAP 

Second 

Chance Termination 

Attachments:  Test Result Summary Form 

 Consent Form 

 Chain of Custody 

 Alcohol Test Form 

 Test Result Documentation 

 SAP Referral Form 

 Other

 

44 City of Albuquerque 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-63 Comments Results Reason if no Test was Conducted Shift Placement Time of Test Date of Test Time of Notification Date of Notification Date of Selection Type of Test Alcohol Type of Test Drug Testing Period Employee Number Figure B-52. Random Test Master Log45 RANDOM TEST MASTER LOG Name of Individual Selected 

 

45 City of Albuquerque 
Best Practices 

FTA Drug and Alcohol Testing Program

Appendix B. Example Administrative Forms and Lists Page B-64 

Figure B- 53. Employee Status Form46

This form must be used to add/delete employees to/from the drug and alcohol testing pool 

for the Rhode Island Public Transit Authority and to change employee information. 

Employee Name: 

_________________________________________________________________________ 

Employee Social Security Number: 

_________________________________________________________________________ 

Employee Identification Number: 

_________________________________________________________________________ 

ADD EMPLOYEE TO DRUG AND ALCOHOL TESTING POOL (NOTE THAT 

A NEGATIVE PRE-EMPLOYMENT DRUG TEST RESULT MUST BE 

RECEIVED BEFORE A PERSON BEING CONSIDERED FOR A SAFETYSENSITIVE ROLE CAN BE PLACED ON THE PAYROLL AND INCLUDED IN 

THE DRUG AND ALCOHOL TESTING POOL): 

Date Employee Added to Payroll (Hire Date): 

________________________________________________________________________ 

Date Employee Added to Pool of Safety-Sensitive Employees: 

________________________________________________________________________ 

Date of Birth: ________________________________________ (month, day, year) 

Home Telephone Number: 

________________________________________________________________________ 

Safety-Sensitive Job/Position Title: 

________________________________________________________________________ 

DELETE EMPLOYEE FROM DRUG AND ALCOHOL TESTING POOL:

Date Employee Removed from Payroll (Termination Date): 

_________________________________________________________________________ 

Date Employee Removed from Pool of Safety-Sensitive Employees: 

_________________________________________________________________________ 

Date of Birth: ______________________________________________ (month, day, year) 

Home Telephone Number: 

_________________________________________________________________________ 

Safety-Sensitive Job/Position Title: 

_________________________________________________________________________ 

CHANGE CURRENT EMPLOYEE INFORMATION: 

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

 

46 Rhode Island Public Transit Authority (RIPTA) 
Best Practices 

FTA Drug and Alcohol Testing Program 

Appendix C. Example Oversight Forms and Lists 

This appendix contains best practice examples of forms and lists that have 

been used successfully to assist with oversight of service agents, contractors, 

and subrecipients. Each of these examples is referenced and described in 

Section 4.2. The examples appear in the following figures, by group: 

Service Agent Oversight 

C-1. Third-Party Administrator Monitoring Form 

C-2. Consortium Monitoring Form 

Contractor/Subrecipient Oversight 

C-3. Contractor Compliance Guidelines 

C-4. Contractor Monitoring Form 

C-5. Contractor Monitoring Checklist

Appendix C. Example Oversight Forms and Lists Page C-1 
Best Practices 

FTA Drug and Alcohol Testing Program 

SERVICE AGENT OVERSIGHT 

Figure C-1. Third-Party Administrator Monitoring Form1 (Sheet 1) 

FTA Drug and Alcohol Third Party Contractor Checklist

for Compliance with FTA Requirements

Transit System:___________________________________________

Name of Person Completing Form: ______________________________________________________________

Review Date: _________________________________________________________________________________

Contractor: ___________________________________________________________________________________

Address: _____________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

Substance Abuse Program Manager: _______________________________________________________________

Telephone Number: ____________________________________________________________________________

Management Training 

 YES NO

1. Have all pertinent safety-sensitive supervisors received the required reasonable 

suspicion training, 60 minutes for signs and symptoms of alcohol abuse and 

60 minutes for signs and symptoms of drug abuse?

 

2. Are training certificates in Drug and Alcohol Program files? Information should 

include type of training, date of training, location of training, and name of instructor.

 

3 Does contractor have procedures in place to train all new 

hires and transfers into supervisory positions prior to the 

time they actually perform duties where reasonable 

suspicion determinations might be required? 

Safety-Sensitive Employee Training

4. Have all FTA covered safety-sensitive employees received at least 60 minutes 

of training on the effects of drug use and the indicators of drug use?

 

5. Are training certificates in Drug and Alcohol Program files? Information 

should include type of training, date of training, location of training, 

and name of instructor. 

6. Are there procedures in place to ensure that all new hires or transfers 

receive the training as soon as possible after hire date of transfer

(i.e., at employee orientation?) 

Appendix C. Example Oversight Forms and Lists Page C-2 

 

1

 Minnesota Department of Transportation 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure C-1. Third-Party Administrator Monitoring Form (Sheet 2) 

Policy 

YES NO 

7. If policy was not standard Mn/DOT developed policy, was company 

policy presented to Office of Transit for review and approval?

 

8. Which contractor representative/staff reviewed the policy (include titles)?

 _____________________________________________________________________________________

 _____________________________________________________________________________________

 _____________________________________________________________________________________

 _____________________________________________________________________________________

9. Has policy been signed and dated by contractor governing board/owner?

 

10. Are previous signed and dated policies on file?

11. Has policy been distributed to all safety-sensitive 

employees covered by FTA requirements?

Services 

Collection Site: 

Name _______________________________________________________________________________________

Address______________________________________________________________________________________

____________________________________________________________________________________________

Phone number_________________________________________________________________________________

DHHS certified Lab: 

Name _______________________________________________________________________________________

Address______________________________________________________________________________________

____________________________________________________________________________________________

Phone number_________________________________________________________________________________

Medical Review Officer (MRO) 

Name _______________________________________________________________________________________

Address______________________________________________________________________________________

____________________________________________________________________________________________

Phone number_________________________________________________________________________________

Does contractor have a file copy of the MRO’s license and other qualifications?

Appendix C. Example Oversight Forms and Lists Page C-3 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure C-1. Third-Party Administrator Monitoring Form (Sheet 3) 

Substance Abuse Professional (SAP) 

Name _______________________________________________________________________________________

Address______________________________________________________________________________________

____________________________________________________________________________________________

Phone number_________________________________________________________________________________

 YES NO

Does contractor have a file copy of the SAP’s license and other qualifications?

12. Are blind sample tests performed? If so, how are they performed?

 

 _____________________________________________________________________________________

 _____________________________________________________________________________________

 _____________________________________________________________________________________

 YES NO

13. Are collection site facilities inspected?

14. Date of last inspection:__________________________________________

15. Are canceled tests monitored?

16. Number of canceled tests: _______________________________________

Reasons for canceled tests: _________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

17. What corrective measures have been taken to minimize the number of canceled tests?

___________________________________________________________________________ 

_________________________________________________________________________________________

_________________________________________________________________________________________

Random Selection Process 

Describe the random selection process. 

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

18. Who selects the numbers: _________________________________________________________________

_________________________________________________________________________________________

19. How often are selections made? Circle one (daily, weekly, monthly, quarterly) _______________________

Appendix C. Example Oversight Forms and Lists Page C-4 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure C-1. Third-Party Administrator Monitoring Form (Sheet 4) 

20. How soon after selections are made are the tests performed? ______________________________________

_________________________________________________________________________________________

_________________________________________________________________________________________

21. Who notifies the employee of the test requirement? _____________________________________________

22. During what part of the employees’ shifts are tests conducted?

Beginning?___________ Middle?_____________ End?______________ Combination?___________

23. What type of employee identification is being used for random testing?

_________________________________________________________________________________________

_________________________________________________________________________________________

_________________________________________________________________________________________

24. Number of safety-sensitive employees _______________________________________________________ 

25. Required number of tests needed to be performed to meet the regulatory requirement for both drug testing 

(50%) _______ and alcohol testing (10%) _______

Consortium Participants

26. If contractor is part of a consortium, provide the following information. 

Consortium name __________________________________________________________________________

Address __________________________________________________________________________________

_________________________________________________________________________________________

Contact person_____________________________________________________________________________

Telephone number__________________________________________________________________________

Record Keeping

27. Where are the drug and alcohol testing records stored? __________________________________________

_________________________________________________________________________________________

_________________________________________________________________________________________

_________________________________________________________________________________________

28. Who has access to these records? ___________________________________________________________

_________________________________________________________________________________________

_________________________________________________________________________________________

 YES NO

29. Do files contain all required FTA information?

Appendix C. Example Oversight Forms and Lists Page C-5 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure C-2. Consortium Monitoring Form2 (Sheet 1) 

“Sample” 

Drug and Alcohol Consortium Monitoring for Compliance 

with FTA Requirements

Transit Agency: ______________________________________________________________________________

Name of Person Completing Form: ______________________________________________________________

Review Date: _________________________________________________________________________________

Consortium 

Name of Consortium: ___________________________________________________________________________

Address of Consortium: _________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

Contact Person: _________________________ Telephone: ____( )__________________

Date Contract Signed with Consortium:_____________________________________________________________

Contract Timeframe:____________________________________________________________________________

Is signed contract in Transit Agency’s files? ___________

Procedures and description of how the consortium complies with blind sample requirements: 

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

Procedures consortium uses to monitor canceled tests: _________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

 

2

 Minnesota Department of Transportation 

Appendix C. Example Oversight Forms and Lists Page C-6 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure C-2. Consortium Monitoring Form (Sheet 2) 

Procedure consortium uses to ensure scientifically valid random-number selection method to select safety-sensitive 

employees to be tested:__________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

Are the test dates spread evenly throughout the year and the draw period in a pattern that is not predictable, 

including weekend and holiday testing if a safety function is performed?

______________________________________________________________________________ 

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

Is testing evenly distributed throughout the day (i.e., early morning, afternoon, late evening) and shift times (i.e., 

beginning, middle, end)? ________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

Collection Site(s) 

Identify all collection sites and days and hours of operation 

(attach additional pages if needed) 

Name of Collection Site(s): ______________________________________________________________________

____________________________________________________________________________________________

Address: Address of Collection Site(s):_____________________________________________________________

____________________________________________________________________________________________

Days and Hours of Collection Site Operation: ________________________________________________________

____________________________________________________________________________________________

Name of Collection Site(s): ______________________________________________________________________

____________________________________________________________________________________________

Address: Address of Collection Site(s):_____________________________________________________________

____________________________________________________________________________________________

Days and Hours of Collection Site Operation: ________________________________________________________

Appendix C. Example Oversight Forms and Lists Page C-7 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure C-2. Consortium Monitoring Form (Sheet 3) 

DHHS Certified Laboratory –Name of Primary and Back-up DHHS certified Laboratories

Name of Primary Laboratory:_____________________________________________________________________

Address: _____________________________________________________________________________________

____________________________________________________________________________________________

Contact Person: ____________________________ Telephone Number: ( )_____________________

Name of Back-up Laboratory: ____________________________________________________________________

Address: _____________________________________________________________________________________

____________________________________________________________________________________________

Contact Person: ____________________________ Telephone Number: ( ) ____________________

Medical Review Officer (MRO) 

Name of MRO(s):______________________________________________________________________________

Business Address of MRO(s): ____________________________________________________________________

____________________________________________________________________________________________

Business Telephone Number: ( ) _________________________________________

Credentials of MRO verified and on file (Yes/No)__________________________________________

Substance Abuse Professional (SAP)

Name of SAP(s):_______________________________________________________________________________

Business Address of SAP(s): _____________________________________________________________________

____________________________________________________________________________________________

Business Telephone Number: ( ) _________________________________________

Credentials of SAP verified and on file (Yes/No) __________________________________________

Evidential Breath Testing (EBT) Device

Name and Model of EBT:________________________________________________________________________

Location of EBT: ______________________________________________________________________________

____________________________________________________________________________________________

Documentation that EBT has been calibrated: ________________________________________________________

Breath Alcohol Technician (BAT)

Names of Certified BATs: _______________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

Credentials of BATs verified and on file (Yes/No) _________________________________________

Appendix C. Example Oversight Forms and Lists Page C-8 
Best Practices 

FTA Drug and Alcohol Testing Program 

CONTRACTOR/SUBRECIPIENT OVERSIGHT 

Figure C-3. Contractor Compliance Guidelines (Sheet 1)

LOS ANGELES COUNTY METROPOLITAN TRANSPORTATION AUTHORITY 

FEDERAL DRUG AND ALCOHOL TESTING REGULATIONS 

 CONTRACTOR COMPLIANCE GUIDELINES 

All contract service providers that perform safety-sensitive functions (as defined by Federal Transit Administration

{FTA} rules) for the MTA must comply with the FTA drug and alcohol testing regulations (49 CFR Part 655) and

the U.S. Department of Transportation (DOT) Procedures for Transportation Workplace Drug and Alcohol Testing 

Programs (49 CFR Part 40). Non-compliance shall result in suspension or termination of contract and/or nonpayment of outstanding invoices. 

For purposes of this compliance program, safety sensitive employees are defined as follows:

Those employees whose job functions are, or whose job descriptions include the performance of functions, 

related to the safe operation of mass transportation service. 

The following are categories of safety-sensitive functions: 

1. operating a revenue service vehicle, including when not in revenue service; 

2. operating a non-revenue service vehicle when required to be operated by a holder of a Commercial

Driver’s License (CDL);

3. controlling dispatch or movement of a revenue service vehicle or equipment used in revenue service; 

4. maintaining (including repairs, overhaul, and rebuilding) revenue service vehicles or equipment used in 

revenue service; and 

5. carrying a firearm for security purposes. 

Any supervisor who performs or whose job description includes the performance of any function listed above is

also considered a safety-sensitive employee. 

IMPLEMENTATION GUIDELINES

1. The Materiel Department shall ensure that all bids or Requests for Proposals (RFPs) for services that 

include the performance of safety-sensitive functions as defined above shall include a provision requiring

compliance with mandated DOT/FTA drug and alcohol testing regulations. The MTA reserves the right to

audit the proposer’s drug and alcohol testing program prior to awarding the contract. 

 

2. Prior to start of work, the successful bidder must certify to the Chairperson of the Source Selection 

Committee (SSC) that his/her firm is in compliance with the DOT/FTA regulations. (Compliance can be 

achieved through an in-house program or through a consortium.) The certification shall remain in effect

during the term of the contract. A copy of the signed certification shall be sent by the SSC Chair to the 

Drug and Alcohol Program Manager in Human Resources. 

Appendix C. Example Oversight Forms and Lists Page C-9 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure C-3. Contractor Compliance Guidelines (Sheet 2)

3. Using the EZ format prescribed by the FTA for the annual report (see Appendix B to 49 CFR Part 653 and

Part 654), each covered contractor shall send a quarterly drug and alcohol testing report to the Project

Manager, with a copy to the Drug and Alcohol Program Manager in Human Resources. The quarterly

report must be submitted no later than the 15th of the month following the close of each quarter. Continued 

payment of contractor invoices by the MTA is contingent upon contractor submission of the required

reports on a timely basis and compliance with FTA-mandated rules. 

 

4. On an annual basis, and no later than February 15 of each year, each covered contractor shall submit to the 

MTA Human Resources Department annual drug and alcohol testing data using the appropriate FTA 

prescribed forms. The report shall cover testing conducted during the previous calendar year. It shall be

addressed as follows: 

MTA Human Resources Department 

One Gateway Plaza 

Los Angeles, CA 90012-293 

Attn: Drug and Alcohol Program Manager 

 

5. The Human Resources Department shall be responsible for filing the contractors’ annual reports with the 

FTA, along with MTA’s own testing data. The reports shall be submitted to the FTA no later than March

15 of each year. 

6. The Project Manager for each covered contract shall be responsible for the ongoing monitoring of

contractor compliance with DOT/FTA regulations, including ensuring that the quarterly and annual reports 

as described above are submitted on time. 

7. On an annual basis, designated staff from the Management Audit Services and Human Resources 

departments shall audit contractor compliance, which may include site visits, and report their findings to

the Executive Officer, Procurement; Deputy Executive Officer, Human Resources; and the Project 

Manager responsible for the contract and his/her Department Head. 

8. The Project Manager shall be responsible for coordinating contractor responses to the audit findings and 

ensuring that corrective actions are taken on a timely basis. 

___________________________________ _________________________________

Office of the CEO Executive Officer, Human Resources 

Revised: 04/23/99

 

 

Appendix C. Example Oversight Forms and Lists Page C-10 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure C-4. Contractor Monitoring Form 

GREATER CLEVELAND REGIONAL TRANSIT AUTHORITY

Contractor Monitors 

Contractor: 

Month: Date: 

 GCRTA Representative Contract Representative 

Identified Monitor Met Incomplete

Monthly Report with dates of tests performed, type of testing performed and results

Quarterly Collection Site Review 

Quarterly Laboratory QA records on file 

The following items will be reviewed by the contract representative. Signature above

verifies compliance with FTA regulations. 

Quarterly on-site Records Review

• Each drug screen has correct Chain of custody 

• Collection times are monitored to determine that employee goes to the 

collection site immediately after notification

• The collection site performed the correct test using the correct forms. All 

discrepancies have documentation of the problem and resolution.

• Random Selection is spread out throughout the selection period and there 

is no pattern

• All documentation is on file for each Reasonable Suspicion test 

• Documentation is available for all Post Accident Decisions

• Documentation is available for all MRO notifications

• The MRO process is in written procedure and is currently used. 

Quarterly review of collection site certification

Annual certification check of SAP 

Annual certification check of MRO 

Annual certification check of Laboratory 

Annual review of Policy & Procedure 

Annual review of Collection site Policy & Procedure 

Annual review of MRO Policy & Procedure 

Annual review of SAP Policy & Procedure 

Appendix C. Example Oversight Forms and Lists Page C-11 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure C- 5. Contractor Monitoring Checklist3 (Sheet 1) 

FTA Drug and Alcohol Contractor Checklist ____________________________________________________________________________________________________________________

Contractor: ___________________________________________________________________________________

Substance Abuse Program Manager: _______________________________________________________________

Address: _____________________________________________________________________________________

____________________________________________________________________________________________

Telephone Number: ____________________________________________________________________________

Management Training

1. Did a representative of your company attend any management training on how to set up a substance abuse 

testing program? If so, please provide the following information:

Type of 

Training 

Date of

Training 

Location of 

Training 

Name of 

Instructor 

Policy

2. Was your company policy presented to the FTA Grantee for review and approval?

3. Which Company representative/staff reviewed the policy (include titles)?

____________________________________________________________________________________________

____________________________________________________________________________________________

4. Did legal counsel review your policy? Yes _____ No _____

5. Please attach a copy of your recent policy. 

6. Has your Governing Board approved your revised policy? Yes _____ No _____

If yes, when ___________________

Please attach a copy of your Governing Board approval. 

Reasonable Suspicion Training

7. Did any of your transit supervisors attend a qualified Reasonable Suspicion Training Program:

Yes _____ No _____

(60 minutes of the signs and symptoms of drugs and 60 minutes on the signs and symptoms of alcohol)

If yes, please list attendees below. 

 

3

 Ohio Department of Transportation 

Appendix C. Example Oversight Forms and Lists Page C-12 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure C-5. Contractor Monitoring Checklist (Sheet 2) 

Employee Length of

Training 

Date & Location of 

Training 

Name of 

Instructor 

Employee Training

Please provide the following information on the substance abuse awareness training program to your employees. 

(Please attach agenda) 

Employee Length of

Training 

Date & Location of 

Training 

Name of 

Instructor 

8. Have you had new hires since employee training was conducted? Yes _____ No _____

9. Did you provide the new hires with substance abuse awareness training?

Yes _____ No _____ If yes, please provide the following information for each new hire. 

Employee Length of

Training 

Date & Location of 

Training 

Name of 

Instructor 

If no, when will the training be conducted? __________________________________________________________

10. Please describe the method of instruction and content of new hires’ substance abuse awareness training. 

Collection Site:

Name _______________________________________________________________________________________

Address______________________________________________________________________________________

____________________________________________________________________________________________

Phone number_________________________________________________________________________________

DHHS certified Lab:

Name _______________________________________________________________________________________

Address______________________________________________________________________________________

____________________________________________________________________________________________

Phone number_________________________________________________________________________________

(Please attach copy of DHHS certificate) 

Appendix C. Example Oversight Forms and Lists Page C-13 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure C-5. Contractor Monitoring Checklist (Sheet 3) 

Medical Review Officer (MRO) 

Name _______________________________________________________________________________________

Address______________________________________________________________________________________

____________________________________________________________________________________________

Phone number_________________________________________________________________________________

(please attach resume and a copy of license and other qualifications) 

Substance Abuse Professional (SAP) 

Name _______________________________________________________________________________________

Address______________________________________________________________________________________

____________________________________________________________________________________________

Phone number_________________________________________________________________________________

(please attach resume and a copy of license and other qualifications) 

11. How are blind sample tests performed?

12. Do you inspect your collection site facilities? Yes _____ No _____

13. Date of last inspection: _______________

14. Do you monitor canceled tests? Yes _____ No _____

15. Number of canceled tests _____________

16. Reasons for canceled tests: ___________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

17. What corrective measures have been taken to minimize the number of canceled tests?

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

Equipment

18. Is alcohol testing contracted out? Yes _____ No _____

If yes, please provide the following information on the vendor/agency.

Name _______________________________________________________________________________________

Address______________________________________________________________________________________

____________________________________________________________________________________________

Phone number_________________________________________________________________________________

Appendix C. Example Oversight Forms and Lists Page C-14 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure C-5. Contractor Monitoring Checklist (Sheet 4) 

Type of device used (specify Make and Model #) _____________________________________________________

____________________________________________________________________________________________

19. Are non-evidential testing devices being used? Yes _____ No _____

20. Describe the procedures used for conducting alcohol testing:_________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

21. Type and location of primary EBT:_____________________________________________________________

22. Type and location of backup EBT: _____________________________________________________________

23. Provide list of certified Breath Alcohol Technicians (BAT) or Screen Test Technicians (STT): 

Name Date of Certification Date of Last Training 

24. Please attach a copy of the BAT/STT training certificate. 

Random Selection Process

Please describe the random selection process.

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

25. Who selects numbers?

26. How often are selections made (daily?, weekly?, Monthly?, Quarterly?)

27. How soon after selections are made are the tests performed?

28. Who notifies employee of test requirement? During what part of the employees’ 

Shift are tests conducted? Beginning? _____ Middle? ___________ Combination? __________

29. What type of employee identification is being used for random testing? ________________________________

____________________________________________________________________________________________

30. Number of safety-sensitive employees __________________________________________________________

31. Required number of tests needed to be performed to meet the regulatory requirement for both drug testing

(50%) __________________ and alcohol testing (10%) _____________

Appendix C. Example Oversight Forms and Lists Page C-15 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure C- 5. Contractor Monitoring Checklist (Sheet 5) 

32. Please list all agencies or departments that are included in your random testing pool. For each agency indicate 

the name, title, and phone number of the person who oversees it: 

Agency/Department Contact Person Title Phone # 

Turnkey Participants

33. If you hired a contractor to provide all or part of the testing services for you, please identify the service provider: 

Company_____________________________________________________________________________________

Contact Name _________________________________________________________________________________

Address______________________________________________________________________________________

____________________________________________________________________________________________

Phone Number ________________________________________________________________________________

34. Please describe the procedures for monitoring turnkey contractor:_____________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

Consortium Participants

35. If you are part of a consortium. Please provide the following information. 

Consortium Program Manager ____________________________________________________________________

Address______________________________________________________________________________________

_______________________________________________________________Phone Number __________________

36. Please provide a description of the consortium (who is involved, who oversees, etc.) 

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

Consortium Participants

37. If you are part of a consortium, please provide the following information.

Consortium Program Manager ____________________________________________________________________

Address______________________________________________________________________________________

_______________________________________________________________ Phone Number_________________ 

Appendix C. Example Oversight Forms and Lists Page C-16 
Best Practices 

FTA Drug and Alcohol Testing Program 

Appendix C. Example Oversight Forms and Lists Page C-17 

Figure C-5. Contractor Monitoring Checklist (Sheet 6) 

38. Please describe the consortium (who is involved, who oversees, etc.) 

____________________________________________________________________________________________ 

____________________________________________________________________________________________ 

____________________________________________________________________________________________ 

39. Please describe the distribution of responsibilities within the consortium (who is responsible for what). 

____________________________________________________________________________________________ 

____________________________________________________________________________________________ 

____________________________________________________________________________________________ 

Record Keeping

40. Where are the drug and alcohol testing records stored? _____________________________________________ 

____________________________________________________________________________________________ 

____________________________________________________________________________________________ 

____________________________________________________________________________________________ 

41. Who has access to these records? ______________________________________________________________ 

____________________________________________________________________________________________ 

____________________________________________________________________________________________ 

____________________________________________________________________________________________ 

42. Do you maintain the following records? 

a. Data on test results that have a BAC of 0.02 or greater 

b. Employer’s copy of the alcohol test form 

c. Data on test refusals 

d. Documents presented by a covered employee to dispute the result of an alcohol test 

e. Data on referrals to SAP 

f. Record pertaining to determination by a SAP concerning a covered employee’s need for assistance 

g. Records concerning a covered employee’s compliance with the recommendations of the SAP 

h. Calibration documentation for evidential breath testing device 

i. Annual MIS report 

j. Records pertaining to evaluations 

k. Data regarding training of employees 

l. Data regarding training of BATs 

m. Collection process (including logbooks, if used) 

n. Data on test results that are less than 0.02 

Reporting

43. Please indicate the dates the annual MIS reports were sent to the grantor. 

Certification of Compliance

44. Please attach your certification of compliance. 

Best Practices 

FTA Drug and Alcohol Testing Program 

Appendix D. Example Specimen Collection Forms and Lists 

 

This appendix contains best practice examples of forms and lists that have 

been used successfully to assist with management of urine and breath 

collection operations. Each of these examples is referenced and described in 

Section 4.3. The examples appear in the following figures: 

D-1. Employee Instructions for Collection Process 

D-2. Drug Test Collection Form 

D-3. Shy Bladder Form 

D-4. Shy Lung Form 

D-5. Collection Site Checklist 

Appendix D. Example Specimen Collection Forms and Lists Page D-1 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure D-1. Employee Instructions for Collection Process

1

Employee Instructions for Collection Process 

 

PLEASE TAKE A FEW MINUTES TO READ THE 

FOLLOWING INFORMATION THAT DESCRIBES 

YOUR ROLE IN THE COLLECTION PROCESS 

1. Present a required Photo I.D. to the Collector. If you do not have a Photo I.D., an 

employer representative will be asked to identify you. 

2. Remove any unnecessary garments (coats, jackets, hats, etc.). All purses and briefcases 

must remain with outer garments. 

3. Empty your pockets, and show the contents to the Collector. 

4. You will be provided a sealed specimen bottle, and the Collector will unwrap it in your 

presence. 

5. You should observe the entire collection procedure. The Collector will check the 

specimen for its volume, temperature, and color. The Collector will then seal the bottle. 

6. Make sure you have initialed the seal on the specimen bottle. 

7. You should complete the information on the Custody form as instructed by the Collector. 

You will be given a copy after completion. 

8. The results of the laboratory analysis will be forwarded to the Medical Review Officer 

(MRO). If the lab results are negative, the MRO will notify your employer. If the lab 

results are positive, the MRO will contact you at the phone number(s) you provided, to 

give you the opportunity to discuss the test results and to submit information concerning 

the authorized use of the drug(s) in question. 

THANK YOU. YOUR COOPERATION IS 

GREATLY APPRECIATED.

1

 Ohio Department of Transportation 

Appendix D. Example Specimen Collection Forms and Lists Page D-2 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure D-2. Drug Test Collection Form 

SAN FRANCISCO BAY AREA RAPID TRANSIT DISTRICT 

NIDA DRUG TEST COLLECTION CHECKLIST

COLLECTOR DONOR 

___ 1. Donor identify verified by photo I.D. or employer representative ___

___ 2. Procedure explained to donor. ___

___ 3. Donor removed coat, hat, etc. left outside collection area and emptied pockets, 

but retained wallet. 

___

___ 4. Donor washed hands prior to collection, in view of collector. ___

___ 5. Collector placed bluing in toilet bowl and tank, and secured all water sources 

and possible adulterants from donor access. 

___

___ 6. Collection kit was opened in front of donor. ___

___ 7. Donor was asked to furnish urine specimen. Collector waited outside 

restroom/stall door until donor exited. Donor was told not to flush toilet. 

___

___ 8. Specimen remained in full sight of BOTH collector and donor until completely 

packaged. If the specimen was transferred from one container to another, 

transfer was done in THE PRESENCE AND FULL VIEW OF THE DONOR. 

___

___ 9. In the presence of the donor, the collector checked the specimen for color, 

sign of contamination, temperature, and quantity. All of the above were 

conducted within 4 minutes of collection and documented on the chain of 

custody form. 

___

___ 10. Collector placed lid on container, and tightened it securely IN THE 

PRESENCE AND FULL VIEW OF THE DONOR. 

___

___ 11. Container was sealed with tamper evident tape in the donor’s presence and 

full view. Donor initialed tape. Collector verified the information on the label 

as identical to the chain of custody form attached to the specimen bottles. 

DONOR MUST SIGN NAME THE SAME WAY EACH TIME. 

___

___ 12. Chain of custody form was signed by donor, and donor was given a copy. ___

___ 13. Donor was allowed to wash hands. ___

Donor and collector agree that all of the above procedures have been completed, and 

the urine submitted is that of the donor signed below and has not been tampered with. 

__________________________________ _________________________________________ 

Collector Signature Date Donor Signature Date 

__________________________________ _________________________________________ 

Print Collector Name Print Donor Name

Appendix D. Example Specimen Collection Forms and Lists Page D-3 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure D-3. Shy Bladder Form2

SHY BLADDER CHECK LIST 

DOT 3 Hour Time Limit Check List

Donor’s Name: _________________________________________ 

Collector’s Initials:___________ 

1. __________The start time should be indicated on the COC. This starts with your first attempt. 

(Example: donor arrives at 12:00; he/she has until 3:00 to void.) 

2. __________The donor can have up to 40 ounces of fluids. The actual total mount must be 

recorded under the remarks section, as well as the time of each attempt to void. 

3. __________If the donor cannot void in three hours, call the company representative and 

explain to them that the DOT regulations require the donor have a physical 

examination to determine if there is a physical reason for this. 

4. __________Can the evaluation be performed at the testing facility? If so, schedule the 

evaluation as soon as possible. 

5. __________If the inability to void is not a result of a physical or pre-existing psychological 

disorder, the test will be considered a test refusal. If there is a medical condition, 

the test is cancelled unless it is a pre-employment test. The doctor should 

determine if the medical problem is a result of a long-term or permanent 

disability. If a disability is found, the MRO should conduct an exam to identify 

any signs of illegal drug use (a blood test is permitted). If no illegal drug use is 

found, the test should be designated as negative. 

If no Doctor is available: 

1. __________Make an appointment for the evaluation at a later date, but as soon as possible. 

2. __________Ask the employer what their procedure is. 

 

2

 Ohio Department of Transportation 

Appendix D. Example Specimen Collection Forms and Lists Page D-4 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure D-4. Shy Lung Form3

SHY LUNG CHECKLIST 

You need to try and get the donor to complete testing before getting this far. You may even want 

to let another BAT try and speak with and instruct the donor. Sometimes, another person’s view 

can help. 

Donor’s Name: _________________________________________ 

Collector’s Initials:___________ 

1. __________Call the company contact and explain the situation. Just as in a drug screen 

situation, the donor must be examined to determine if there is a medical problem. 

Can the evaluation be performed at the testing facility? 

2. __________If it can be performed at the collection site, schedule the examination as soon as 

possible. 

3. __________If Doctor finds a medical problem, the test will be cancelled and the company 

informed. The Doctor must provide written documentation to the company 

 explaining the reason. 

If no Doctor is available: 

1. __________Make an appointment for the evaluation at a later date, but as soon as possible. 

2. __________Ask the employer what their procedure is. 

 

3

 Ohio Department of Transportation 

Appendix D. Example Specimen Collection Forms and Lists Page D-5 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure D-5. Collection Site Checklist4 (Sheet 1) 

COLLECTION SITE CHECKLIST 

System Name __________________________________________________________________ 

Collection Site _________________________________________________________________ 

Date ___________________ 

Drug Testing Procedures 

SPECIMEN COLLECTION

 

Does the collection site(s) meet the Department of Transportation requirements published in 49 

CFR Part 40, 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 a bluing agent to the toilet water to prevent dilution of the specimen; 

 Secure the toilet tank top or blue tank water; 

 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; 

 Remove all potential adulterants; and 

 Secure areas suitable for concealing contaminants such as trash receptacles, paper 

towel holders, etc.?

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?

Do you have a procedure to notify the collection site of the identity and contact information of 

the Designated Employer Representative (DER)? 

Does the collection site use the correct USDOT Chain of Custody and Control forms for 

DOT/FTA tests (and only DOT tests)?

 

4

 Ohio Department of Transportation 

Appendix D. Example Specimen Collection Forms and Lists Page D-6 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure D-5. Collection Site Checklist (Sheet 2) 

Is the specimen and CCF under the control of the collector throughout the collection process? Is 

the collector the only person that handles the specimen before it is sealed? 

Are “limited access” signs posted in areas of public access?

Does the collection site restrict access to specimens and specimen collection materials?

Are collection sites available to perform collections during all days and hours that the transit 

system performs safety-sensitive job duties? 

Do collectors recheck the privacy enclosure following the collection process?

Split Sample

Is the split specimen procedure being utilized at the collection site? After the specimen has been 

collected, it must be divided into two specimen bottles (30 ml of urine in one primary specimen 

bottle and 15 ml in the split specimen bottle) in the presence of the donor. If the primary test

returns a positive test result, the employee can request that the split sample be tested at a separate 

DHHS laboratory. 

Are procedures in place to have a split sample transferred to a second HHS lab for analysis? 

Have you established a business relationship with the second HHS lab to ensure that split 

specimens will be processed in a timely manner and that the employer will provide payment for 

the split analysis (subject to reimbursement by the employee)?

Insufficient Volume of Specimen

Is the collection site following the correct procedures if the employee being tested is unable to 

produce a sufficient amount of urine for the test? 

 Discard the original specimen. 

 Obtain another urine sample within three hours of the previous test. The employee 

cannot drink more than 40 ounces of fluid during the three hours. 

Does the employer direct the employee to have a medical examination within 5 days if 45 ml

cannot be provided within three hours?

Does the medical physician provide the MRO with a statement indicating whether or not the 

insufficient specimen was the result of a genuine medical condition?

Does the MRO notify the employer in writing of the medical examination conclusion? 

If there is no medical explanation for the insufficient specimen, is the test regarded as a refusal to 

be tested?

Appendix D. Example Specimen Collection Forms and Lists Page D-7 
Best Practices 

FTA Drug and Alcohol Testing Program 

Appendix D. Example Specimen Collection Forms and Lists Page D-8 

Figure D-5. Collection Site Checklist (Sheet 3) 

For a pre-employment test that results in insufficient volume, is a contingent offer of 

employment made prior to the medical evaluation? 

For a pre-employment insufficient volume test, does the medical evaluation determine if the shy 

bladder was due to a long-term or permanent disability? Does the medical examination look for 

signs of illegal drug use? If no signs of illegal drug use are found, does the MRO verify the test 

as negative? 

Observed Collections

Are procedures in place to require the collection site personnel to conduct a mandatory observed 

collection immediately after the first collection in the following circumstances? 

 The employee’s urine sample is outside the normal temperature range; 

 The collection site person observes conduct that clearly and unequivocally indicates 

an attempt to adulterate or substitute the sample; 

 Following a positive, adulterated, or substituted test, the split sample is not available 

for testing; or 

 The specimen is invalid with no medical explanation. 

Does the transit system, at its option, have a procedure to determine if an observed collection 

will be conducted in the following circumstances? 

 The employee has previously been determined to have used a controlled substance 

without medical authorization and the particular test is being conducted under the 

FTA regulation as a return to duty or follow-up test. 

Does the collection site have both genders available in case an observed collection is necessary? 

Is the employee told the reason for an observed collection if one is performed? 

Privacy/Confidentiality

Does the collection site have adequate measures in place to protect the privacy of the employee 

and the integrity of the collection process? 

Does the collection site and Medical Review Officer have adequate measures in place to 

communicate confidential matters to designated individuals at the employer? 
Best Practices 

FTA Drug and Alcohol Testing Program 

Appendix E. Example Medical Review Forms and Lists 

 

This appendix contains best practice examples of forms and lists that have 

been used successfully to assist with management of the medical review 

process. Each of these examples is referenced and described in Section 4.4. 

The examples appear in the following figures: 

E-1. Roles and Responsibilities of Medical Review Officer

E-2. MRO Checklist

E-3. MRO/Donor Interview Checklist

E-4. Request To Test Split Sample 

E-5. Failure To Make Contact Notification 

E-6. MRO Verification Flow Chart 

Appendix E. Example Medical Review Forms and Lists Page E-1 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure E-1. Roles and Responsibilities of Medical Review Officer 1

ROLES AND RESPONSIBILITIES 

MEDICAL REVIEW OFFICER 

 

 Detailed knowledge of testing procedures defined in 40 CFR Part 40, as amended. 

 Detailed knowledge of laboratory analysis procedures and report interpretation

 Receive test results from the laboratory and verify lab report and assessments- 

 Specimen identification

 Certifications (donor, collector, certifying scientist) 

 Chain-of-custody complete

 Administration items complete

 Review and interpret each confirmed positive test result. 

 Notify donor of positive test result and provide an opportunity for donor to discuss positive test results, and 

discuss as needed. 

 Review donor’s medical history and medical records as appropriate. 

 Notify DPC and SAPM of verified positive test. 

 Process donor’s request for analysis of the split specimen.

 When applicable, provide input to SAP on return-to-duty decision.

 Conduct medical assessment on applicants with insufficient volume due to a long-term or permanent disability. 

 Conduct physical examinations for evidence of illegal drug use on employee with an opiate positive test when

analytical results are inconclusive. 

 Administratively review each negative test result. 

 Order re-tests as appropriate when the accuracy or validity of a positive test result is questionable. 

 As appropriate, order a full adulteration panel including specific gravity, creatinine concentration, and PH when

the integrity of the specimen is in question (i.e., temperature out of range, collector observes questionable 

behavior).

Request laboratory to conduct confirmatory analysis for methamphetamine to distinguish 

use with the active ingredient in over-the-counter medications. 

 

1

 City of Albuquerque 

Appendix E. Example Medical Review Forms and Lists Page E-2 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure E- 2. MRO Checklist2 (Sheet 1) 

Donor’s Name: ID#: 

Specimen ID#: Date of Collection: 

Positive Result Reported: Date Time 

 A. REVIEW DOCUMENTS 

 Yes  No 1. Are the Chain-of-Custody (COC) forms filled out correctly? 

 Yes  No 2. Does the information that appears on the lab COC form match the 

information on the MRO form? 

• Compare the specimen identification number contained on the both the 

laboratory copy and the MRO copy of the COC. 

• Compare the employee ID # and SS# on both forms to insure they are the same. 

If No,  Request the laboratory records regarding the specimen to determine if the correct 

laboratory procedures were followed; or

 Require the retest of the specimen 

Lab Contact:

Phone #:

Date:

Comment:

If the specimen identification number or employee ID# is not the same, the result 

should not be reported at this time. Do not verify the positives until you are fully 

satisfied that the results reported are those for the specimen identified to the 

subject donor. If unsure, order a retest and have the certifying scientist personally

inspect the original specimen container to ensure it was properly accessioned. 

 Yes  No 3. Did the collector complete the required certification of the COC? 

 Yes  No 4. Did the donor complete the require certification on the COC? 

 Yes  No 5. Did the certifying scientist complete the required certification on the COC?

 Yes  No 6. If the donor did not sign the COC, did the collector properly note the 

declination and record the explanation (if any)?

 Yes  No 7. Is the COC block completely and legibly completed? 

 Yes  No 8. Is all other information completed properly? 

B. VERIFY LABORATORY RESULT AND ASSESSMENT 

 Yes  No 9. If methamphetamine positive, request isomer concentrations (d = Rx, l = otc). 

 Yes  No 10. If opiate positive, request codeine and morphine concentrations. 

If over 2000 ng/ml, order 6-MAM.

Lab Contact Person:

Phone #:

Date:

Comment:

 Yes  No 11. As necessary request: Concentration Data

Validity Tests Adulteration Panel 

Other, Specify:

 

2

 City of Albuquerque 

Appendix E. Example Medical Review Forms and Lists Page E-3 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure E-2. MRO Checklist (Sheet 2) 

C. DONOR CONTACT 

 Yes  No 12. Document attempts to contact donor. 

Date Time Phone # Contact Comment Initials

1.

2.

3.

4.

5. 

 Yes  No 13. If unable to contact donor, contact employer representative. 

Employer Contact: Date Time 

 Yes  No 14. If more than 72 hours have passed since the employee was notified by 

employer or 10 days have passed from the date the result was reported, verify the 

result as positive. 

D. EMPLOYEE INTERVIEW 

 Yes  No 15. Hello, my name is Dr. Christenson, the Medical Review Officer for the 

City of Albuquerque.

 Yes  No 16. Verify Employee Identity

 ?

Am I talking to (employee name) Yes No

 ?

Did you have a drug screen on (date) at (location) Yes No 

Were you satisfied that the specimen you gave was collected, 

labeled, and sealed in your presence? Yes No

Can you tell me your SS# and birth date? SS#:

Birth Date:

 Yes  No 17. “The reason I am speaking to you personally is because the results of the drug 

test have been received and it is a positive test. The purpose of this interview is to 

provide you an opportunity to voluntarily share information with me that might 

explain a positive result, such as anything from your medical history, prescriptions, 

recent treatment or something in your diet. Before I ask you any further questions, I 

want to tell you that any information that you may disclose will be TREATED 

CONFIDENTIALLY and will not be released unless a DOT regulation requires or 

permits such a disclosure. (Information obtained that indicates you are not fit for 

duty will be reported to your employer.) You have the option of not discussing the 

matter with me if you choose. Do you have any questions at this point?” 

 Yes  No 18. Did the employee refuse to discuss the test result or decline the interview 

with the MRO? Yes No 

If yes, verify the test as positive and explain: 

 Yes  No 19. “I need to ask you some questions about your medical history to determine 

whether or not your drug test results could have been caused by medication you may

have been taking.” 

Appendix E. Example Medical Review Forms and Lists Page E-4 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure E-2. MRO Checklist (Sheet 3) 

Prescription Drugs: 

Rx Rx Rx Rx

Rx # 

Date

Doctor

Quantity

Drug

Pharmacy

Phone

Rx Phone 

Over-the-Counter Drugs: 

Drug Name

Quantity

Usage 

Comment 

Diet: 

Product 

Quantity

Usage 

Comment 

Dental, ENT, Opthalmolopic, Other Procedure:

Procedure 

Date 

Doctor 

Comment 

Phone 

 Yes  No 20. Inquire about illicit drug usage: 

 

 Yes  No 21. Request for Medical Records when appropriate: 

 

 Yes  No 22. Request an exam on in-person interview when appropriate - 

Appointment Date: 

Appointment Time: 

Physician: 

 Yes  No 23. If there is no legitimate medical explanation, tell the donor your conclusion: 

Notification Date: Time:

Appendix E. Example Medical Review Forms and Lists Page E-5 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure E-2. MRO Checklist (Sheet 4) 

 Yes  No 24. Notify the donor that they may request analysis of the split specimen at 

their expense. The request must be made within 72 hours. 

 Yes  No 25. Did you tell the donor the procedure for requesting the split analysis 

(i.e., telephone numbers, contact person)? Yes No

 Yes  No 26. Notify the donor that if requested, the split specimen will be sent to 

Another certified laboratory and tested for presence of the same drug(s). 

The cost of the test is $ * 

Split Analysis Declined Laboratory 

Requested Date Requested

Specimen ID# Result

*Note: If the donor requests the split analysis, but indicates they cannot afford to pay, proceed with the test.

 Yes  No 26. Inform the donor of consequences of a positive test and where to obtain 

a list of resources for resolving problems associated with alcohol or 

drugs and where to receive a referral for an assessment by a substance 

abuse professional. 

 Yes  No 27. Offer to answer any questions; give name and phone number. 

 Yes  No 28. Notify donor of split analysis and of verified test result. 

Date: Time: Result:

E. MRO VERIFICATION 

Employee Name: SS#:

City/Department: Dept. Contact:

Date of Interview: Contact Phone #:

Verification completed & employee notified of results: Date Time

Employee Notified of Results: Date Time

Employer Contact If Other Than Above:

Test Result Report Form Sent to Employee Contact:

Results Reported As: Positive, Drug

Negative, (Scientifically Insufficient)

Negative

Cancelled, Specify

Comments:

MRO’s Signature: 

MRO Name:

MRO Date:

 Complete Chain-of-Custody Form

Appendix E. Example Medical Review Forms and Lists Page E-6 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure E-3. MRO/Donor Interview Checklist

3

 

MRO/Donor INTERVIEW CHECKLIST 

1. Identify yourself as a physician serving as the Medical Review Officer (MRO) for the City of 

Albuquerque with the duty of receiving and reviewing drug test results. Clearly state 

that you have been designated the MRO for the City of Albuquerque drug testing program. 

2. Establish identity of the donor (i.e., full name, social security number of donor I.D. number,

date of birth.) 

3. Inform donor that medical information discussed during the interview is confidential, and may 

only be disclosed under very special circumstances. 

4. If the donor holds a medical certificate under a DOT agency rule, advise the donor that 

information regarding test results and information supplied by the donor will be provided to 

the DOT Agency as required by appropriate regulations. 

5. Tell the donor are calling about the specific drug test he/she underwent on the specific date 

and at the specific location. Inform the donor what drug(s) the specimen tested positive for. 

6. Briefly explain the testing process, discussing screening and confirmation testing, and 

laboratory reporting. 

7. If the donor request the quantitative levels of the confirmed results, provide them if 

available. If the quantitative levels are unavailable, the MRO should request them. However,

this does not delay his/her verifications decision pending receipt of the quantitative data. 

8. Ask for recent medical history, when appropriate. 

Prescription drugs

OTC Drugs

Dental, ENT, Ophthalmologic, or other medical procedures. 

Food Ingestion 

9. Request donors provide medical records or documentation of prescription for controlled 

substance when appropriate. Set a specific deadline for receipt of the medical records. 

10. Request donors undergo a medical examination or evaluation, when appropriate. Make 

arrangements for medical evaluation. 

11. Notify the donor that he/she may request the split specimen be tested, and 

Explain this process to him/her. Provide information about payment for the split specimen 

test in accordance with employer’s policy, if appropriate. Tell the donor that the split 

specimen test will not delay reporting of the initial test result to their employer. 

12. If the verification process is complete, inform the donor that they are to report to their 

Department Program Coordinator. 

13. If the test result was verified positive, inform the donor that they are to report to their 

Department Program Coordinator. 

14. Offer to answer any further questions. 

15. Give your name and phone number in case the donor has any further questions. 

USE THE MRO VERIFICATION WORKSHEET TO DOCUMENT INTERVIEW

 

3

 City of Albuquerque 

Appendix E. Example Medical Review Forms and Lists Page E-7 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure E-4. Request To Test Split Sample4

Split Sample Date___________________

Medical Review Officer 

Request to Retest Form 

Medical Review Officer: ________________________________________________________________________

Agency Name: ________________________________________________________________________________

Address: _____________________________________________________________________________________

Telephone: ___________________________________________________________________________________

Manager’s Name: ______________________________________________________________________________

Employee Name: ______________________________________________________________________________

Employee SS #: _______________________________________________________________________________

Employee Address:_____________________________________________________________________________

Employee Telephone No: (Work) (Home)

Date of original test: ____________________________________________________________________________

I request that the split specimen of my urine sample provided on _________________________________________

be tested for the presence of the following drugs: marijuana, cocaine, opiates, phencyclidine (PCP), and

amphetamines consistent with the requirements specified in 49 CFR Part 40. 

The split specimen will be packaged and sent to the following DHHS laboratory for analysis: 

(note: This is a different lab than the one which performed the analysis on the primary lab.) 

 ____________________________

 ____________________________

 ____________________________

I understand that I may be responsible for all costs of collection, storage, shipment, and examination relating to this 

retest. 

____________________________________________________________________________________________

Employee’s Signature 

____________________________________________________________________________________________

Agency Drug Program Coordinator’s Signature 

 

4 Ohio Department of Transportation.

Appendix E. Example Medical Review Forms and Lists Page E-8 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure E-5. Failure To Make Contact Notification 5

DATE FAXED TO COMPANY ______________________________ 

COMPANY NAME: ______________________________ 

ATTENTION: ______________________________

PHONE NUMBER: ______________________________ 

DONOR NAME: ______________________________ 

SSN / EMPLOYEE NUMBER ______________________________ 

The above listed employee must speak to an MRO and we have failed to 

make contact. Therefore, we need your assistance. Please have the donor 

contact ___________________ (name of MRO) at ________________ 

(telephone number of the MRO) as soon as possible. It is important that 

the employee knows the name of the correct doctor for whom to ask. 

In accordance with Federal Regulations, we are not permitted to start the 

“72-hour clock” until we know the donor has been successfully notified. 

However, in the event the MRO and the employer have been unsuccessful 

in contacting the donor, the result may be reported as a no contact result 

after 10 days. In order to start the “72-hour clock”, we need to know that 

you have successfully made contact with the donor advising him/her to 

contact the MRO. Verbal contact must be made directly with the donor. 

Messages left with spouses and/or family members do not qualify as 

notification. Additionally, please note that leaving messages on 

answering machines, voice mails, pager systems, etc. are likewise not 

acceptable, as notification. 

Please fill in the information below and fax this page to 

_____________________________ (contact person at MRO’s office) at 

__________________ (fax number of contact person) as soon as contact 

with employee is made. 

REMEMBER, THE ’72-HOUR CLOCK” MAY NOT START 

UNTIL WE ARE PROPERLY NOTIFIED THAT THE DONOR 

HAS BEEN INFORMED TO CONTACT THE MRO. 

If you require additional information or have questions pertaining to this 

correspondence, please call ________________________ (contact person 

at MRO’s office) at _____________ telephone number of contact person). 

Please print:

I, _____________________, (employer/supervisor) hereby attest that 

__________________ (insert name of employee) has been notified to 

contact the MRO as soon as is possible. I attest that verbal contact was 

made directly with the donor on _______ (date of contact) and understand 

that the “72-hour clock” starts from this date. 

_________________________________________Date______________ 

(Signature of authorized supervisor or employer) 

 

5

 Prepared by University Services, Arsenal Business Center, Building 4, 5301 Tacony St., Philadelphia, PA, 19137, 

215 743 4200, for the Monroe County Transportation Authority, East Stroudsburg, PA. 

Appendix E. Example Medical Review Forms and Lists Page E-9 
Best Practices 

FTA Drug and Alcohol Testing Program 

Appendix E. Example Medical Review Forms and Lists Page E-10 

6

POSITIVE

RESULT

ADULTRANT

RESULT

CORRECTABLE

FLAW - REQUIRE 

CORRECTION

NON-NEGATIVE TEST,

STAND-DOWN POLICY,

CONTACT DER AND

EMPLOYEE

REMOVE

EMPLOYEE FROM

SAFETYSENSITIVE DUTIES

PENDING 

VERIFICATION

MRO

REVIEWS

CCF FOR

FLAWS

CONTACT

DER AND/OR

EMPLOYEE

TEST

CANCELLED,

NO OBSERVED

COLLECTION

TEST

CANCELLED,

NO OBSERVED

COLLECTION

TEST

CANCELLED,

NO OBSERVED

COLLECTION

TEST

CANCELLED,

IMMEDIATE

OBSERVED

COLLECTION

FLAW

CORRECTED

W/I FIVE

DAYS

CANCEL

TEST, NOTIFY

DER

CANCEL

TEST, NOTIFY

DER

CANCEL

TEST, NOTIFY

DER and

DOT

NEGATIVE

TEST

SUBSTITUTED

RESULT

MRO REVIEWS CCF

40.129A

MRO REVIEWS LAB REPORTS

INVALID

TEST

LAB REJECTS FOR

TESTING, FATAL OR

UNCORRECTED FLAW

FATAL FLAW -

REJECT TEST

NEGATIVE - VERIFY TEST, DER TAKES NO

FURTHER ACTION

CANCELLED, DER TAKES NO FURTHER ACTION

UNLESS A NEGATIVE RESULT IS REQUIRED

NEGATIVE DILUTE - EXPLAIN OPTIONS FOR

IMMEDIATE RETESTING TO DER

NON-NEGATIVE TEST, NO STAND-DOWN POLICY,

CONTACT EMPLOYEE DIRECTLY

USING PRIVATE CONTACT INFORMATION

CANNOT 

CONTACT

EMPLOYEE

MRO NOTIFIES DER TO

CONTACT EMPLOYEE

MRO MUST CONTACT EMPLOYEE DIRECTLY

40.131

A MINIMUM OF 3 ATTEMPTS OVER 24 HR PERIOD

EMPLOYEE DECLINES OPPORTUNITY TO

DISCUSS NON-NEGATIVE TEST RESULT

CONDUCT VERFICATION

40.135

POSITIVE TEST

OPIATES

NO

NO

YES

CLINICAL

YES

EVIDENCE

6-AM or

15000ng

mL

LEGITIMATE

MEDICAL

EXPLAINATION

MARIJUANA,

COCAINE, PCP,

AMPHETAMINE

EMPLOYEE HAS

BURDEN OF 

PROOF

EMPLOYEE HAS

BURDEN OF 

PROOF

MRO DISCUSSES

W/CERTIFYING

SCIENTIST

MEDICATION OR

OTHER VALID

EXPLANATION

ADULTERANT FOUND BY

LAB HAS PHYSIOLOGICAL

EXPLANATION

PHYSIOLOGICAL REASON

FOR VERY LOW SPEC

GRAV AND CREATININE

NO VALID MEDICAL

EXPLANATION EXISTS

ADULTERATED

TEST

EMPLOYEE HAS

MEDICAL REASON

EMPLOYEE HAS

MEDICAL REASON

EMPLOYEE HAS

MEDICAL REASON

EMPLOYEE DOES

NOT HAVE

MEDICAL REASON

EMPLOYEE DOES

NOT HAVE

MEDICAL REASON

EMPLOYEE DOES

NOT HAVE

MEDICAL REASON

SUBSTITUTED

TEST INVALID TEST

TO SPLIT-SAMPLE PROCEDURE

DER CONTACTS

EMPLOYEE,

EMPLOYEE DOES

NOT CONTACT

MRO

DER INFORMS

MRO UNABLE TO

CONTACT 

EMPLOYEE

DER CONTACTS

EMPLOYEE,

EMPLOYEE 

 CONTACTS

MRO

DER CANNOT

CONTACT

EMPLOYEE

MRO ALLOWS

72 HOURS

NO CONTACT IN

72 HOURS

NO CONTACT IN

10 DAYS

MRO ALLOWS

10 DAYS

MRO CONTACTS EMPLOYEE, OFFERS EMPLOYEE

OPPORTUNITY TO EXPLAIN TEST RESULT

REQUIRE

CORRECTIVE

ACTION AND/OR

RETRAINING

60 DAYS TO REQUEST 

VERIFICATION BE

REOPENED FOR 

LACK OF NOTICE

YES

NO

 

6

 Prepared by the Ketron Division of the Bionetics Corporation 

Fi

gure E-6. MRO Verification Flow Chart6 (Sheet 1)
Best Practices 

FTA Drug and Alcohol Testing Program 

Fi

gure E-6. MRO Verification Flo

w Chart (Sheet 2)

SPLIT-SAMPLE PROCEDURE

INFORM EMPLOYEE HAS 72 HRS T

O

REQUEST TEST OF SPLIT SPECIMEN

MRO PROVIDES WRITTEN REQUEST T

O

LAB T

O SEND SPECIMEN T

O SECOND

LAB FOR TESTING

 EMPLOYEE REQUESTS 

SPLIT SPECIMEN

 SECOND LAB SENDS RESULTS T

O MRO

MRO VERIFYS RESULTS

CANCEL TEST,

REPORT T

O DER

AND D

OT

REPORT TO DER RECONFIRMED

POSITIVE, ADULTERATED OR

SUBSTITUTED

FROM MRO REVIEWS LAB REPORT

Appendix E. Example Medical Review Forms and Lists Page E-11

Best Practices 

FTA Drug and Alcohol Testing Program 

Appendix F. Example Referral, Evaluation, and Treatment Forms 

 

This appendix contains best practice examples of forms that have been used 

successfully to assist with management of the referral, evaluation, and 

treatment process for safety-sensitive employees who test positive for drugs or 

alcohol or otherwise violate provisions of Parts 40 or 655. Each of these 

examples is referenced and described in Chapter 5. The examples appear in 

the following figures: 

F-1. Referral to Substance Abuse Professional 

F-2. Substance Abuse Program Treatment Referral Form 

F-3. Agreement for Continuation of Employment 

F-4. Return-to-Work Agreement 

F-5. Return-to-Duty and Post Rehabilitation Worksheet 

F-6. SAP Client Evaluation 

F-7. Mandated Individual Treatment Plan 

F-8. SAP Return to Work Evaluation 

F-9. Follow-Up Assessment 

F-10. Return to Duty Testing Flow Chart 

F-11. Follow-Up Testing Flow Chart

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-1 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure F-1. Referral to Substance Abuse Professional1

SUBSTANCE ABUSE PROFESSIONAL REFERRAL 

I acknowledge that I have received a referral to a Substance Abuse Professional as required by 

FTA regulations. 

The cost of this service will be borne by:  the City  the employee 

Substance Abuse Professional referral: 

 

Name 

Address 

City/State 

Phone 

Alternate Substance Abuse Professional referral: 

Name 

Address 

City/State 

Phone 

I have received a copy of this referral: 

 

Employee Signature Date 

 

Agency Representative Signature Date

 

1

 City of Albuquerque 

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-2 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure F-2. Substance Abuse Program Treatment Referral Form 

SAN FRANCISCO BAY AREA RAPID TRANSIT DISTRICT 

1330 Broadway, Suite 907, Oakland, 94612 

(510) 464-6205, (510) 464-6198 

Fax # (510) 464-6255

SUBSTANCE ABUSE PROGRAM 

TREATMENT REFERRAL FORM

Date_______________________ Referred To: ______________________________ Phone:__________ 

Employee Name _____________________________ M/F Birthday __________________ Age _____ 

Address __________________________________________ City _______________________________ 

Zip Code ________________ Home Phone _______________________ Work Phone ______________ 

Job Title: _________________________________________Shift _________________Days Off ______ 

Self-Pay: _________________ Insurance Carrier: _______________________ Plan # ______________ 

Group: ______________ Phone # _____________ Address: ___________________________________ 

BART Pay: _______ 

(If BART Pay, Submit Claims to Barbara George, BART EAP, 1330 Broadway, Suite 907, 

Oakland, 94612.) 

Circumstances under which employee is being referred: _______________________________________

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

SAP Findings and Recommendations: _____________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

Please call _________________________________ Phone____________________________________

with findings, recommendations, and name and phone number of the assigned case manager.

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-3 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure F-3. Agreement for Continuation of Employment2

POST DRUG and/or ALCOHOL TESTING AGREEMENT 

FOR CONTINUATION OF EMPLOYMENT ____________________________________________________________________________________________________________________________________________________________________________________________________________________________________

THIS AGREEMENT is entered into by and between ________________________(transit system)

And _________________(employee). __________________________(transit system) is committed to providing 

channels of assistance for employees seeking rehabilitation. However, the employee seeking rehabilitation must be

committed in his/her efforts to remain free of drug use and alcohol misuse. Therefore, as part of the commitment, it 

is understood that the employee’s continuation of employment at _______________________ (transit system), for

matters relating to the Drug Abuse and Alcohol Misuse Prevention Program, is based upon and constrained by the 

following terms: 

1. ____________________ (employee) and ________________________ (transit system) mutually agree that 

your continuation of employment for the next five years is contingent upon your satisfactorily meeting the terms 

outlined in this agreement and that failure to do so may subject you to disciplinary action up to and including

termination of employment with ___________________ (transit system).

2. You must submit to evaluation of potential drug and/or alcohol problems by a substance abuse professional

(SAP). This evaluation must be completed within _________ days from the date of this document. 

3. You must participate in and attend rehabilitation, treatment, or community resource programs recommended by

the SAP. The SAP or a program counselor shall provide _________ (transit system) with periodic progress 

reports regarding your participation and attendance at all required sessions. Failure to follow the terms of the 

program recommended by the SAP shall be cause for discipline up to and including discharge.

4. Following satisfactory completion of the program recommended by the SAP, you must at a minimum, report to

____________ (transit system) within 24 hours following release by your counselor or the SAP and be tested

for drug use and/or alcohol misuse before you are allowed to return to duty. Such return to duty test must be

negative for drugs and/or show an alcohol concentration of less than .02. There may also be additional

stipulations outlined by _______________________ (transit system) and/or the SAP at this time. 

5. During the five (5) year period following your return to duty, you will be subject to unannounced follow-up

testing. There will be a minimum of six (6) tests in the twelve (12) months following your return to duty date. 

Such tests are in addition to any tests necessitated by _____________________ (transit system) Program or

required by the SAP as part of his/her program to monitor your compliance with his/her recommendations. 

6. If you are absent from work during the five (5) year period and it is determined that the absence is a result of, or 

related to, the use of drugs or misuse of alcohol, then _________________ (transit system) may take

disciplinary measures up to and including discharge. 

7. If you violate the conditions of __________________ (transit system) Program, the SAP’s program, refuse to

be tested, or have a positive drug test or an alcohol test with a concentration of .04 or greater under any testing

circumstance within the five year period, you will be discharged. 

This Agreement is voluntarily entered into by all parties, and in consideration for continuation of 

employment, the above conditions are hereby agreed to. 

Dated this _____________ day of ____________, 20__. 

SIGNATURES: 

_______________________________ ________________________________________ 

Employee Date Representative Date

 

2

 Ohio Department of Transportation 

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-4 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure F-4. Return-to-Work Agreement3

POST DRUG and/or ALCOHOL TESTING 

RETURN-TO-WORK AGREEMENT 

THIS AGREEMENT is entered into by and between ___________________________________ 

AND _________________. ________________________ is committed to providing channels of 

assistance for employees seeking rehabilitation. However, the employee seeking rehabilitation must be 

committed in his/her efforts to remain free of drug use and alcohol misuse. Therefore, as part of the 

commitment, it is understood that the employee’s continuation of employment at __________________, 

for matters relating to the Drug Abuse and Alcohol Misuse Prevention Program, is based upon and 

constrained by the following terms: 

1. ____________________ and ________________________ mutually agree that your continuation of 

employment for the next five years is contingent upon your satisfactorily meeting the terms outlined 

in this agreement and that failure to do so may subject you to disciplinary action up to and including 

termination of employment with ___________________. 

2. During this period, you will be subject to unannounced follow-up testing with a minimum of six (6) 

tests the first year. Such tests are in addition to any tests that may be necessitated by

_______________ Drug Abuse and Alcohol Misuse Prevention Program or any tests required by a 

substance abuse professional (SAP) as part of their program to monitor the employee’s compliance 

with his/her recommendations. You will be subject to disciplinary action up to and including 

discharge if you refuse to submit to testing or if you test positive for drugs and/or alcohol during this 

time period. 

3. If you are absent from work during this period and it is determined that the absence is a result of, or 

related to, the use of drugs or misuse of alcohol, then _________________ may take disciplinary

measures up to and including discharge.

4. If you violate the conditions of __________________ Program, the SAP’s program, refuse to be 

tested, or have a positive drug test or an alcohol test with a concentration of .04 or greater under any 

testing circumstance within the five year period, you will be discharged. 

This Agreement is voluntarily entered into by all parties, and in consideration for continuation of 

employment, the above conditions are hereby agreed to. 

Dated this _____________ day of ____________, 20__. 

SIGNATURES: 

_______________________________ __________________________________ 

Employee Date Representative Date 

 

3

 Ohio Department of Transportation 

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-5 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure F-5. Return to Duty and Post Rehabilitation Worksheet4

SAP RETURN TO DUTY AND POST REHABILITATION WORKSHEET 

Employee: 

Employee SSN or ID#: 

Address: 

Phone (H): Phone (W): 

Employer Name & Address: 

 

Contact Person: 

Date of SAP Contact: Date of Assessment: 

Date Test Verified: 

Type of Test: Random Reasonable Suspicion 

Post-Accident Return-To-Duty Follow-Up

Substances:

Treatment Plan Signed:  Yes  No Date: 

Signed Release of Information:  Yes  No Date: 

Rehabilitation Program Date Began: Completed 

Name & Address of Rehab Facility:  Outpatient  Inpatient

Contact Name: Phone:

Progress Assessment: 

 Rehab Testing 

Date Results Date Results

Date Results Date Results

Date Results Date Results

Date Results Date Results

Date Results Date Results

Discharge Diagnosis: 

After Care Plan and Follow-Up: 

Program Complete or Assessment: 

 Extension of Treatment

 MRO Input 

 Return-to-Duty Test Date Result

 Return to Safety-Sensitive Duty Date 

 Return to Duty Contract Date 

 Follow-Up Testing Schedule (Complete on Back)________________________________________________

Supervisor Phone

Comments

 

4

 City of Albuquerque 

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-6 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure F-6. SAP Client Evaluation5 (Sheet 1) 

Substance Abuse Professional Client Evaluation 

Client: 

Date: 

Evaluator: 

Directions: If one of the following statements says something that is true about you, put a 

check mark in the space for YES. If a statement says something that is not true 

about you, put a check mark in the space for NO. Please answer all the questions. 

 

YES NO 

1. Do you feel you are a normal drinker or drug user? _____ _____ 

2. Have you ever awakened in the morning after some drinking or drug 

use the night before and found you could not remember a part of the 

evening before? _____ _____ 

3. Does your spouse, parents, family (or friends) ever express worry

or complain about your drug or alcohol use? _____ _____ 

4. Can you stop drinking or using drugs without a struggle? _____ _____ 

5. Do you ever feel bad about your alcohol or drug use? _____ _____ 

6. Do friends or relatives think you are a normal drinker or drug user? _____ _____ 

7. Do you ever try to limit your drinking or drug use to certain times of 

the day or to certain places? _____ _____ 

8. Are you always able to stop drinking or using drugs when you want to? _____ _____ 

9. Have you ever attended a self-help meeting of Alcoholics Anonymous 

(AA) or Narcotics Anonymous (NA)? _____ _____ 

 

10. Have you ever gotten into fights when drinking and/or using drugs? _____ _____ 

 

11. Has drinking or using drugs ever created problems with you and your 

spouse/partner? _____ _____ 

12. Has your spouse (or other family members) ever sought professional 

help about your alcohol or drug use? _____ _____ 

 

5

 Massachusetts Bay Transportation Authority (MBTA) 

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-7 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure F-6. SAP Client Evaluation (Sheet 2) 

Substance Abuse Professional Evaluation 

Page Two 

Employee # 

 YES NO 

13. Have you ever lost friends or partners because of your drug or alcohol _____ _____ 

 use?

14. Have you ever gotten into trouble at work because of your drug or 

alcohol use? _____ _____

15. Have you ever lost a job because of your alcohol or drug use? _____ _____ 

16. Have you ever neglected your obligations, your family, or your work for 

two or more days in a row because you were using alcohol or drugs? _____ _____ 

17. Do you ever use alcohol or drugs before noon time? _____ _____ 

18. Have you ever been told you have medical problems with your liver? _____ _____ 

19. Have you ever had withdrawal symptoms, severe shaking, hearing voices, 

and/or seen things that were not there, after using alcohol or drugs? _____ _____ 

20. Have you ever gone to anyone for help about your drug or alcohol use? _____ _____ 

21. Have you ever been in a hospital because of your drug or alcohol use? _____ _____ 

22. Have you ever been in a psychiatric hospital or on a psychiatric ward in a 

general hospital where your drug or alcohol use was part of the problem? _____ _____ 

23. Have you ever seen a mental health care professional, doctor, social 

worker or member of the clergy for help in addressing a mental health 

issue that was or could have been related to your alcohol and/or drug use? _____ _____ 

24. Have you ever been arrested due to your alcohol or drug use? _____ _____

25. Have you ever been arrested for drunk driving? _____ _____ 

26. Have you ever experienced financial difficulties because of your 

alcohol and/or drug use? _____ _____ 

27. Do you ever spend more money on drinking or drug use activities 

than you planned to? _____ _____ 

28. Have you ever lied about your drinking or drug use? _____ _____

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-8 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure F-6. SAP Client Evaluation (Sheet 3) 

Scoring Key: Substance Abuse Professional Evaluation 

Directions for scoring: Add the point values for all items on which points are earned. 

Classification of client: 0-2 (total score), client uses alcohol/drugs in social situations not 

presenting serious problem, but needs education. 3-5 (total score), client is demonstrating border 

line use, and should have an educational and treatment intervention referral. 6 and above (total 

score), client is demonstrating addictive behavior (past or present), and should be assessed for 

current use and treatment referral. 

 

 YES NO 

 1. _____ __2__ 

 2. __2__ _____ 

 3. __1__ _____ 

 4. ____ __2__ 

 5. __1__ _____ 

 6. _____ __2__ 

 7. __2__ _____ 

 8. _____ __2__ 

 9. __5*∗

_ _____ 

10. __1__ _____ 

11. __2__ _____ 

12. __2__ _____ 

13. __2__ _____

14. __2__ _____

15. __2__ _____ 

16. __2__ _____ 

17. __1__ _____ 

18. __2__ _____ 

19. __5__ _____ 

20. __5__ _____ 

21. __5__ _____ 

22. __2__ _____ 

23. __2__ _____ 

24. __2__ _____

25. __2__ _____ 

26. __2__ _____ 

27. __2__ _____ 

28. __2__ _____ 

 

∗

Discretion may be indicated in scoring this item to account for those who accompanied a family member to the 

meeting. 

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-9 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure F-7. Mandated Individual Treatment Plan6 (Sheet 1) 

 Date: _________________ 

MANDATED INDIVIDUAL TREATMENT PLAN

He/She has indicated by their Signature below, his/her need to participate in the MBTA 

Rehabilitation Program. Be advised that participation at ECS does not exempt the employee

from performing his/her job responsibilities, nor does adherence to this treatment plan

guarantee the employee a Return To Work Agreement or reinstatement to the Authority. 

Self Help Group Meetings: 

Educational Group Meetings: 

Individual Counseling: 

Aftercare Program: 

Other: 

I will participate in the MBTA Rehabilitation Program and agree to Comply with all conditions 

of my treatment plan. 

I understand that an approved Leave of Absence (LOA) for Family Medical Leave Act (FMLA), 

extended illness, or Worker’s Compensation does not preclude my participation in ECS. It is

my responsibility to discuss any absences from group or individual treatment due to illness 

of FMLA with my counselor and the Manager of ECS. 

I UNDERSTAND THAT I WILL BE SUBJECT TO PERIODIC DRUG AND ALCOHOL 

TESTING AT THE AUTHORITY’S DISCRETION. 

______________________________________ ___________________________________ 

Employee Signature Date 

______________________________________ ___________________________________ 

Counselor Signature Date 

 

6

 Massachusetts Bay Transportation Authority (MBTA) 

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-10 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure F-7. Mandated Individual Treatment Plan (Sheet 2) 

RETURN TO WORK SERVICE PLAN 

 __________________ 

 Date 

_____________________________________________________ _______________ 

Name Employee #

Education Group Meetings 

List required meetings ________________________ 

 ________________________ 

 ________________________ 

EAP Group Meetings

List Required Meetings ________________________ 

 ________________________ 

 ________________________ 

Individual Counseling

List Counselor Name or _____________________

Referral source. Also list _____________________

Frequency of counseling required ________________________ 

After Program (for clients being released from an input. treatment program) 

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

Comments: 

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

Client Initials _____________ Counselor Initials _____________ 

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-11 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure F-7. Mandated Individual Treatment Plan (Sheet 3) 

INITIAL SERVICE PLAN 

 ___________________ 

 Date 

_____________________________________________________ ___________________ 

Name Employee #

Education Group Meetings 

List Required Meetings _____________________________ 

 _____________________________ 

 _____________________________

EAP Group Meetings

List Required Meetings _____________________________ 

 _____________________________

 _____________________________ 

Individual Counseling

List Counselor Name or _____________________________

Referral source. Also list _____________________________ 

Frequency of counseling required _________________________________ 

_______________________________________ _______________________________________ 

EAP REPRESENTATIVE Client Signature 

Completed Intake __________________ □

Completed Assessment Group __________________ □

Completed Disease Concept Group __________________ □

Completed Denial Group __________________ □

Completed Self Help Information __________________ □

Completed SAP Evaluation (if needed) __________________ □

Completed MBTA Drug and Alcohol Training __________________ □

Second Review Scheduled ______________________________________ □

Reviewed by _________________________________________ Date: ___________________

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-12 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure F-7. Mandated Individual Treatment Plan (Sheet 4) 

CONTINUING SERVICE PLAN II

 ___________________ 

 Date 

_____________________________________________________ ___________________ 

Name Employee #

Education Group Meetings 

List Required Meetings _____________________________ 

 _____________________________ 

 _____________________________

EAP Group Meetings

List Required Meetings _____________________________ 

 _____________________________

 _____________________________ 

Individual Counseling

List Counselor Name or _____________________________

Referral source. Also list _____________________________ 

Frequency of counseling required _________________________________ 

_______________________________________ _______________________________________ 

EAP REPRESENTATIVE Client Signature

Completed 1ST Review __________________ □

Completed Job Safety Group __________________ □

Completed Stress and Coping Tech. Group __________________ □

Completed Family Group __________________ □

Completed Road to Recovery __________________ □

Third Review Scheduled __________________ □

Reviewed by ___________________________________________ Date: ______________________

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-13 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure F-7. Mandated Individual Treatment Plan (Sheet 5) 

CONTINUING SERVICE PLAN III 

 ___________________ 

 Date 

_____________________________________________________ ___________________ 

Name Employee #

Education Group Meetings 

List Required Meetings _____________________________ 

 _____________________________ 

 _____________________________

EAP Group Meetings

List Required Meetings _____________________________ 

 _____________________________

 _____________________________ 

Individual Counseling

List Counselor Name or _____________________________

Referral source. Also list _____________________________ 

Frequency of counseling required _________________________________ 

_______________________________________ _______________________________________ 

EAP REPRESENTATIVE Client Signature

Completed 2nd Review __________________ □

Completed Relapse Prevention Group __________________ □

Completed Aftercare Planning Group __________________ □

Transition Meeting Scheduled __________________ □

Reviewed by ___________________________________________ Date: ______________________

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-14 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure F-8. SAP Return to Work Evaluation7

Substance Abuse Professional Return to Work Evaluation 

Case # _______________ Employee Identification # _____________ 

Date of Evaluation: ____________________________ 

Substance Abuse Professional:__________________________________________ 

 Print Name

Describe client’s progress with treatment/education plan since being referred for services. What 

goals were achieved? What areas of concern were addressed? Number of groups attended? 

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________ 

Describe client’s attitude and compliance with treatment/educational referral including self-help 

groups, treatment referrals, and aftercare. 

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________ 

Recommendations for Return to Work aftercare treatment/education and follow-up Drug and/or 

Alcohol Testing. 

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________ 

# of Drug Tests 1st year ___ 2nd year___ 3rd year___ 4th year ___ 5th year ____ 

# of Alcohol Tests 1st year ___ 2nd year___ 3rd year___ 4th year ___ 5th year ___

_____________________________________________ __________________ 

Signature and License # Date 

____________________________________________________________________________ 

Mailing Address 

________________________ 

Telephone #

 

7

 Massachusetts Bay Transportation Administration (MBTA) 

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-15 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure F-9. Follow-Up Assessment8

FOLLOW-UP ASSESSMENT 

EMPLOYEE NAME: _____________________________________________ DATE: _______________________

WORK LOCATION: _________________________ SUPERVISOR: ____________________________________

REASON FOR INITIAL ASSESSMENT: __________________________________________________________

DATE OF SPECIFIC VIOLATION: _______________________________________________________________

DATE OF INITIAL ASSESSMENT: ______________________________________________________________

TREATMENT PROVIDER: _____________________________________________________________________

PRIMARY COUNSELOR ___________________________________ PHONE: ____________________________

LEVEL OF CARE:_____________________________________________________________________________

DESCRIPTION OF INITIAL TREATMENT PLAN: __________________________________________________

____________________________________________________________________________________________

INCLUSIVE DATES OF THE TREATMENT PROGRAM: ____________________________________________

DESCRIBE EMPLOYEE’S LEVEL OF PARTICIPATION IN THE TREATMENT PROGRAM: ______________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

PROVIDE CLINICAL CHARACTERIZATION OF EMPLOYEE’S INVOLVEMENT WHILE IN TREATMENT:

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

HAS EMPLOYEE DEVELOPED AN UNDERSTANDING OF THE CONSEQUENCES OF HIS/HER DRUG

AND/OR ALCOHOL USE: YES _______ NO _______

HAS THE EMPLOYEE FULLY DEMONSTRATED SUCCESSFUL COMPLIANCE WITH THE INITIAL 

TREATMENT RECOMMENDATIONS: YES _______ NO _______ IF NO, DESCRIBE:___________________

____________________________________________________________________________________________

____________________________________________________________________________________________

RECOMMENDATIONS FOR FOLLOW-UP TESTING: ______________________________________________

____________________________________________________________________________________________

RECOMMENDATIONS FOR FOLLOW-UP CARE: _________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

RETURN TO WORK UA/BAT TEST DATE: _______________________________________________________

RETURN TO WORK AGREEMENT SIGNED:______________________________________________________

RETURN TO WORK DATE: ____________________________________________________________________

SUPERVISOR NOTIFIED OF RTW ____________________________________ DATE: ___________________

SAP _________________________________________________________ PHONE: ________________________

 

8

 San Francisco Bay Area Rapid Transit (BART) District 

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-16 
Best Practices 

FTA Drug and Alcohol Testing Program 

Figure F-10. Return to Duty Testing Flow Chart9

FTA DRUG & ALCOHOL TESTING PROGRAM

Return to Duty Testing

imen = 

testing 

ional (SAP)

(SAP) 

 

Determination made by Executive Director on advice of Substance Abuse Professional to 

test under FTA Drug and Alcohol Testing Program 

Employee instructed to report for testing 

Employee reports to Lab Employee not

readily available for 

Employee provides specimen Employee fails to 

provide specimen 

Employee Informed

that failure to 

provide spec

REFUSAL =

POSITIVE

Test POSITIVE = 

MAY NOT 

RETURN TO 

WORK 

Test NEGATIVE 

= OK to return to 

work

Employee informed

that failure to provide 

specimen = REFUSAL

= POSITIVE

Employee removed 

from safety-sensitive 

position 

Employee 

removed from

safety-sensitive 

position 

Employee removed 

from safety-sensitive 

position 

Employee instructed 

to contact 

Substance Abuse 

Profess

Employee 

instructed to

contact Substance 

Abuse 

Professional 

Employee instructed to 

contact Substance 

Abuse Professional 

(SAP) 

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-17 

9 West Virginia Department of Transportation, Division of Public Transit
Best Practices 

FTA Drug and Alcohol Testing Program 

Appendix F. Example Referral, Evaluation, and Treatment Forms Page F-18 

Figure F-11. Follow-Up Testing Flow Chart10

FTA DRUG & ALCOHOL TESTING PROGRAM 

Follow-up Testing

Employee reports to Lab 

Employee provides specimen Employee fails to 

provide specimen 

Employee Informed

that failure to 

provide spec

REFUSAL =

imen = 

POSITIVE

Employee not

readily available for 

testing 

Test POSITIVE = 

MAY NOT 

RETURN TO 

WORK 

Employee informed

that failure to provide 

specimen = REFUSAL

= POSITIVE

Employee 

removed from

safety-sensitive 

position 

Employee removed 

from safety-sensitive 

position 

Employee instructed 

to contact 

Substance Abuse 

Professional (SAP) 

Employee instructed to 

contact Substance 

Abuse Professional 

(SAP) 

Employee 

instructed to

contact 

Substance Abuse 

Professional 

(SAP) 

Employee removed 

from safety-sensitive 

position 

Test NEGATIVE 

= OK to return to 

work

Employee instructed to report for testing 

 

10 West Virginia Department of Transportation, Division of Public Transit