Implementation Guidelines - Federal Transit Administration - U.S. ...

as long as the testing rate is addressed in
their policy statement.
Calculation of the Number of Random
Tests
The method used to figure the actual
number of random tests needed has confused
many in the industry, often resulting in
under-testing by many and some
unnecessary over-testing by others. Transit
system employee bases often fluctuate over
the course of a year due to terminations, new
hires, or seasonal variations due to weather,
school/university sessions, or tourist
seasons. Consequently, the size of the
random testing pool also fluctuates.
Some transit systems have established
the size of their pool by estimating the
number of safety-sensitive employees
employed as of January 1 (or any other
arbitrary date) of each year. This method is
incorrect. To clarify this issue, a step-bystep
method of calculation is provided in
Figure 6-1.
Only completed tests can be used to
meet the random test rate. Thus, if any of
the individuals selected during the current
test period were not tested or the test was
cancelled, an adjustment must be made
when calculating the number of tests to be
performed during the next testing period to
ensure that the required rates are achieved
within the year. Progress toward rate
achievement should be monitored
throughout the year to avoid the need to
make one major adjustment at the end of the
year.
Also, consortia use the same method of
calculation. The employer and consortium
must have procedures in place to ensure that
the pool is up-to-date before each draw, and
to inform the random selector of cancelled
or incomplete tests that will require an
adjustment in the number of draws made for
the next testing period.
A reporting requirement in the MIS
Drug and Alcohol Data Collection forms has
also caused confusion in determining the
number of random tests needed. These
forms require each employer to report the
number of covered employees that were
employed in each safety-sensitive function.
The MIS form requires that the number of
covered employees reported be a cumulative
total of all employees performing safetysensitive
functions over the course of the
reporting year. Given employee turnover,
cumulative totals usually exceed the number
of safety-sensitive positions since they count
all individuals that fell under the FTA
regulatory authority sometime during the
year. Many people have assumed that the
random test rate should be based on this
cumulative total. This is not the case, and
would result in too many tests for systems
with larger staff turnover. Rather, you
should use the method described in Figure
6-1, which reflects the fluctuation in staffing
levels.
Random Testing Pool Management
All safety-sensitive employees in the
random pool must have an equal chance of
being selected for testing and shall 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.
Depending on the size of the safety-sensitive
employee pool, numbers may be selected on
a periodic basis, usually daily, weekly,
monthly, or quarterly. Selections should be
made as frequently as possible, but not less
often than quarterly (see chart on page 6­
16).
Chapter 6. Types of Testing 6-14 August 2002