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

during the introduction. You are also
encouraged to be active in the process by
accompanying the auditors to the contractor
and service agent facilities.
Following the introductions, the audit
team will break into smaller teams as
indicated in the schedule. The auditors
follow a set line of questions. A copy of the
questions is contained in Appendix K.
The auditors will review your policy
before the on-site visit. Some common
problems found in substance abuse policies
include the following:
• Failure to obtain policy adoption by
local governing board or other
authorized official
• Confuse FTA/FMCSA requirements
• Not current with regulatory changes
• Consequences for policy violation
not clearly defined
• Use of boilerplate policy without
modifying for local circumstances
• Failure to adequately identify safetysensitive
employees
For the records review portion of the
audit, the auditors will generally chart their
findings on a computer. Figures 14-1
through 14-8 are examples of the types of
charts the auditors will include in the Final
Audit report. Figure 14-1 shows an
acceptable example of random testing
reasonably spread across the year. Figure
14-2 is an unacceptable example of random
tests lumped together at the beginning of
each testing period. Figures 14-3 and 14-4
present acceptable and unacceptable
examples of random tests reasonably spread
across the week, and Figures 14-5 and 14-6
present acceptable and unacceptable
examples of the random tests reasonably
spread across the workday. Figures 14-7
and 14-8 are examples of what the auditors
may include in the Final Audit report to
show the compliance of post-accident
testing. The auditors will show if the
alcohol test was delayed more than 2 hours
from the time of the accident.
The team will generally complete all onsite
questioning of the grantee, contractor(s),
and service agents in 3 days. On the fourth
day, the team will compile the report.
Section 4. FINAL REPORT
After the audit is complete, the team
conducts an exit interview presenting the
findings, if any, to the transit system
management. A letter and final report
documenting the deficiencies and necessary
corrective actions will be generated and
given to the DAPM at the exit interview.
In the early years of the audit program,
the audit report only identified areas of
deficiency. More recently, the audit process
and the software have been enhanced to
enable the audit reporter to identify the
compliant areas of the program. The report
represents a compilation of the facts as
presented by the grantee/subrecipient staff,
service agents, safety-sensitive contractors,
and their respective records.
Chapter 14. Administrative Requirements 14-10 August 2002