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

Transit employers may go beyond these
requirements to incorporate additional
features (such as Employee Assistance
Programs and additional testing
circumstances) that are not mandated by
FTA regulations. Additional provisions that
go beyond the regulatory requirements must
be clearly represented as features included
under the authority of the transit agency and
not the FTA-mandated program. For
example, if you test for drugs other than the
specific five that FTA requires, you must
make the employees aware that they are
being tested for those additional drugs under
the authority of the transit agency, not FTA.
A separate specimen must also be collected
to analyze the additional drugs.
Policies and procedures beyond the
regulatory scope are not addressed in this
manual to avoid confusion and
misinterpretation over which provisions are
requirements of the regulation and which are
additional features. Discussion of best
practices and examples of additional policies
and procedures are included in the Best
Practices manual that serves as a sister
document to this publication.
Best Practices
The Best Practices manual was published
to supplement the Implementation
Guidelines by providing examples of “real
world” policies, procedures, sample forms,
and narrative descriptions of approaches that
have been successfully used by transit
employers to effectively manage their drug
and alcohol testing programs. Though the
regulations are very comprehensive and
address each of the major components of a
legally defensible program, the regulations
represent only the minimum requirements.
Transit employers are encouraged to
develop a program that goes beyond these
minimum requirements to reflect the unique
nature of the employer, operating
environment, labor/management
relationship, and existing policies and
procedures.
The examples provided in the Best
Practices manual represent materials that
transit employers have found effective to
help them efficiently manage their
programs, and to comply with the
regulations. In some cases, multiple
examples are given to address the same
issue or requirement. These best practices
are not required methods of implementation,
but are examples of how some systems have
dealt with particularly difficult issues.
Updates Newsletter
The Implementation Guidelines is a
comprehensive summary of the regulations
and supercedes previous guidance provided
by FTA. Given the dynamic nature of the
drug and alcohol testing industry and the
practical insights obtained following
implementation of the regulations, it is
expected that additional clarifications,
corrections, explanations, and procedural
guidance will be necessary overtime to
supplement these guidelines. Consequently,
FTA publishes a quarterly newsletter
entitled, FTA Drug and Alcohol Regulation
Updates, which keeps covered employers
informed of the regulatory clarifications,
Chapter 1. Introduction 1-3 August 2002