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

problems associated with the collection
process will be minimized when an
employee will be taking both an alcohol and
a drug test. Remember, in instances where a
drug and alcohol test will both be conducted,
the alcohol test is to be performed first and
without undue delay.
In unusual circumstances (e.g., accident,
reasonable suspicion) when an alcohol
testing site meeting these requirements is not
available, the alcohol test can be conducted
in a manner that provides the employee with
privacy to the greatest extent practicable
(i.e., back of a supervisor’s car at an
accident scene).
Testing sites must have the necessary
personnel, materials, equipment, and
facilities to conduct the test. The testing site
must prevent unauthorized individuals from
entering the testing area. The only people
who should be authorized to enter the testing
site are the employees being tested, BATs,
STTs, and other alcohol testing site workers,
DERs, and DOT agency representatives.
Employee representatives should be allowed
to enter only if authorized by the employer’s
policy or labor management agreement.
Anyone entering the site must be supervised
by the BAT/STT, and he/she may be
removed from the site anytime the
BAT/STT believes the individual is
obstructing, interfering with, or causing
unnecessary delays in the testing process.
No one other than the BAT/STT, employee,
and/or DOT agency representative may
actually witness the testing process.
The EBT and ASDs must be stored in a
secure place when not in use. The site must
be secured with no unauthorized access at
any time the EBT is unsecured or when
testing is occurring. The BAT must conduct
only one test at a time and must not leave
the testing site while the preparations for
testing or the test itself are in progress.
Recommendation
Locating Rural Alcohol Testing Sites
The number, location, and availability of
alcohol breath testing services may be limited,
especially in very rural areas. Employers
who are experiencing difficulty finding
alcohol testing sites may wish to join forces
with other transportation employers in your
region to purchase EBT and BAT services as
a group (see Chapter 11,“Joining a
Consortium).” Transportation employers
may include transit systems, trucking firms,
school bus operations, or other agencies that
have drivers holding CDLs.
In very rural areas, some transit agencies
conduct their own initial screens using
inexpensive saliva ASDs, and then using local
law enforcement agencies to conduct
confirmatory tests using their EBTs. This
arrangement is less expensive for the transit
system because they need not purchase or
maintain an EBT. Yet, it is not a burden on
the local law enforcement agency since they
will be called upon on only in the rare event
that the initial screen indicates a breath
alcohol concentration of 0.02 or greater. This
approach will only work if the local law
enforcement agency agrees and the
confirmatory test can be performed within 30
minutes of the screen test.
This method should be implemented with
caution to avoid any perception of testing as a
“police” action. However, where there are
no alternatives, use of local law enforcement
agencies may be the only workable option.
Any employer, new or existing, that
needs to establish alcohol testing services
within its service area should consider the
following procedures for identifying
potential vendors:
1. Develop specifications for EBT/ASD
and BAT/STT services consistent
with 49 CFR Part 40. Estimate the
number and types of tests to be
performed throughout the year.
Specify the hours of required
Chapter 8. Alcohol Testing Procedures 8-5 August 2002