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

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Chapter 3.<br />

PROGRAM FORMULATION<br />

AND REVISION<br />

Following the initial publication of the<br />

regulation in 1994, most transit employers<br />

worked aggressively to develop<br />

comprehensive drug and alcohol testing<br />

programs to address the regulatory<br />

requirements. Originally, implementation of<br />

the program was phased in with the large<br />

systems required to implement first (1995),<br />

and the small operators required to follow a<br />

year later (1996). The implementation<br />

deadlines for all covered employers have<br />

long passed; all covered employers are now<br />

required to be in compliance.<br />

New transit operations, contractors, or<br />

employers that are new to public transit are<br />

required to be in compliance with the<br />

regulations before they assume any safetysensitive<br />

responsibilities. These employers<br />

must either formulate a program if none<br />

exists, or revamp an existing drug and<br />

alcohol testing program to meet FTA<br />

requirements.<br />

Covered employers with existing FTA<br />

programs may also find that their programs<br />

require periodic fine-tuning, revision, or<br />

overhaul depending on the extent of changes<br />

in regulations, organizational structure,<br />

policy, collective bargaining agreements,<br />

and/or internal procedures.<br />

For those employers who are<br />

establishing new FTA-compliant drug and<br />

alcohol testing programs or those who are<br />

revamping an existing program, the<br />

recommended first step is to identify and<br />

assemble key personnel who are responsible<br />

for developing and implementing the<br />

program.<br />

The early involvement of transit<br />

management, employees, and labor<br />

organizations and their continued<br />

involvement throughout the implementation<br />

Chapter 3. Program Formulation 3-1 August 2002

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