
Question: If I have more than one driver and a driver has been selected for a random test, and he/she is out on vacation, medical leave, etc., can or should I pick another driver as an alternate in his/her place?
Answer: YES, in fact the DOT clearly directs motor carrier employers to select another driver from the company rather than not testing, plus make sure that the company explains this substitution procedure within their drug testing company policy!
Here is how DOT explained it in their Interpretation for 382.305, Question #19. The C/TPA (and company) may randomly order and select a driver's name from the motor carrier that employs the driver who is unavailable rather than (a C/TPA) selecting the next name on (their) random selection list. This procedure is a scientifically valid method for selecting driver names. This method is similar to methods used by organizations, including the Department of Labor's Bureau of Labor Statistics, to randomly order, select, and substitute names for sampling with replacement of groups of individual and companies. This procedure has a small degree of theoretical bias for a simple random sampling selection procedure. The theoretical bias, though, is so minimal the FMCSA does not believe the agency should prohibit its use. This method is useful for operational settings, such as FMCSA's motor carrier random testing program. The method is less impartial toward drivers than other theoretical methods, but maintains a deterrent effect for both motor carriers and drivers. This method should deter motor carriers from claiming drivers are unavailable each time the C/TPA selects one of its drivers, there by never having its drivers subject to actual random tests. The operational procedures should also outline the measures for selecting alternate drivers, including documenting the reasons for using an alternate. This interpretation clearly suggests that the motor carrier (employer) should add clear language to the company drug testing policy concerning selecting alternative or substitute drivers versus not testing.
Question: I noticed the renewal dates have changed. Is it mandatory that I have this new renewal date or can I use June 30 or continue to use December 31 of every year?
Answer: You can change it to any month you prefer or just leave the renewal date of December 31, it is your choice. This change was made because we have received many requests over the years to change the annual renewal window from the end of the year, when business and revenue is typically tight and holidays are fast approaching, to months that are less hectic. You can choose any month you like!
This year has been fast and furious, with many important changes to our operations. And there will be more to come next year as many internal and external improvements are slated for completion!
Many of these changes allow us to provide a higher level of customer service while keeping our prices as competitive as possible. Our new upgraded technology provides us the best tools available to serve our clients and has enabled us to add numerous online user-friendly features at no additional costs.
Our client online access tools allows you to securely access your account and process changes, view driver lists, find a collection site for testing, see who's selected for random testing, pay invoices, and renew online. There's even a broker online access feature available. One day there will be no need for certificates and ID cards, as the enforcement and broker community will just log in and access selected data fields to check enrollment status of your company and drivers under your direction.
Our paperless office project, in addition to being "green," is more than one-third completed. Digital document storage and retrieval allows the staff to see your account information and signed forms right at the click of their mouse, cutting down the time to respond to your calls and questions concerning all aspects of your account.
We have also implemented our staggered enrollment based on each client's original enrollment month, thus changing from the standard calendar year of enrollment to a staggered client-designated renewal month. Many clients have chosen to change their renewal period from the year end when cash flow is tight to the summer time, when at least for construction-oriented businesses; revenue is near its peak.
With this year's renewals we have also added our updated automatic renewing service agreement contract; your 2012 service agreement will stay in effect during the duration of your consecutive enrollment as long as there's no break in enrollment as determined by you or us. This is by far the most asked-for change to our documentation requirements. We do listen and act upon client suggestions.
We have also implemented a variety of internal operational changes from printing most documents and booklets on demand to storing and sharing all incoming faxes electronically. All of this allows us to remain extremely lean and very competitive for years to come. While inflation (food and fuel) seems to be going through the roof, our pricing has not!
Finally, we want to thank you all for your business and continued support. We also would like to wish you all a Merry Christmas, Happy Holidays, and Happy New Year.
Cheers, Sandy, Lisa, Martha, and Dianna
Pre-employment Testing
The actual text that addresses pre-employment testing in DOT Regulations is Part 382, Section 382.301. This can be found in Section 5 of the AADT manual or on our website, AADrugTesting.com.
Before an applicant can perform a safety-sensitive job or position for an employer, the applicant must undergo DOT testing for drug abuse and receive a written verified negative test result from a medical review officer (MRO).
An employer who uses a driver more than once a year, but does not employ the driver, must assure once every six months that the driver participates in an alcohol and controlled substances testing program(s) that meets DOT requirements.
If you have determined that pre-employment testing is required, follow the steps below:
STEP 1. Show the applicant your Company Controlled Substance and Alcohol Misuse Policy, and notify the
individual that a drug test (alcohol only if specifically required per your company's policy) will be required for employment.
STEP 2. Have the applicant read and complete the Consent Form for Urinalysis and/or Alcohol Testing Form 113, located in Section 4.
STEP 3. Ask the applicant if he/she has ever tested positive or refused to test on a previous pre-employment DOT drug or alcohol test. You may use Form 104, located in Section 6, for this purpose.
STEP 4. Fill out a Collection Site Passport Form 111, located in Section 6. You will need the last 4 digits of the applicant's social security number (SSN) or an employer issued identification number. Please refer to
"How to Fill Out Form 111" form "O" in this section for instructions.
STEP 5. Select a collection site (see list of sites in Section 7), and contact the site to inform them that you are sending in the applicant for pre-employment testing. At that time, verify with the collection site that they have the AADT/lab's CCF forms on hand. If they do not, contact AADT immediately at (800) 820-9314.
STEP 6. Send the individual to the collection site with:
a. The completed Collection Site Passport Form 111
b. The Donor's CDL or photo ID
STEP 7. The collection site should have the required DOT Federal Custody and Control Form (CCF) on hand. They will use Form 111 to fill out the CCF.
STEP 8. After the collection has been performed, you should receive the employer's Copy 4 of the CCF directly from the collection site but you may also want to review Copy 5, the donor's copy, for confirmation that the testing was completed.
STEP 9. For drug test results, you will be notified directly by the Medical Review Officer (MRO) via the method of reporting you had selected during your enrollment. For alcohol results, the collection site will notify you by phone, fax or by the employer copy of the testing form. Please note that if an employee's alcohol test is confirmed positive, the collection site will contact you, and the employee will not be allowed to leave the site without an escort. You should receive a test result usually between 24 to 48 hours, if you have not received a result within that time please call us at 1-800-820-9314 and we can assist with tracking the result process.
STEP 10. Notify the donor of the test results by giving him/her a copy of the Confirmation Report you receive from the MRO or AADT. You retain the original in the employee's confidential personnel file, along with Copy 4 of the CCF and any other documentation pertaining to the testing process.
STEP 11. Have the applicant complete the Driver Request and Authorization for Release of Information Form 114, located in Section 6, and forward a copy to each of the applicant's previous employers for the past 2 years for intrastate, or 3 years for interstate.
STEP 12. Complete and return to AADT the Add/Delete Form 110, located in Section 6. Once your request is complete, an ID card, driver handbook, and updated company profile will be forwarded to you automatically, verifying that the applicant has been enrolled.
Notes:
Note that throughout this article, when I refer to the applicable federal regulations, I’m referring to CFR 49, Parts 40 & 382; these regulations can be found in Section 5 of the AADT Company Compliance Manual or in the AADT website at www.aadrugtesing.com under links at DOT Office of Drug and Alcohol Policy and Compliance at www.dot.gov/ost/dapc or Federal Motor Carrier Safety Administration at www.fmcsa.dot.gov.