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

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

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Chapter 3. PROGRAM FORMULATION AND REVISION Following the initial publication of the regulation in 1994, most transit employers worked aggressively to develop comprehensive drug and alcohol testing programs to address the regulatory requirements. Originally, implementation of the program was phased in with the large systems required to implement first (1995), and the small operators required to follow a year later (1996). The implementation deadlines for all covered employers have long passed; all covered employers are now required to be in compliance. New transit operations, contractors, or employers that are new to public transit are required to be in compliance with the regulations before they assume any safetysensitive responsibilities. These employers must either formulate a program if none exists, or revamp an existing drug and alcohol testing program to meet FTA requirements. Covered employers with existing FTA programs may also find that their programs require periodic fine-tuning, revision, or overhaul depending on the extent of changes in regulations, organizational structure, policy, collective bargaining agreements, and/or internal procedures. For those employers who are establishing new FTA-compliant drug and alcohol testing programs or those who are revamping an existing program, the recommended first step is to identify and assemble key personnel who are responsible for developing and implementing the program. The early involvement of transit management, employees, and labor organizations and their continued involvement throughout the implementation Chapter 3. Program Formulation 3-1 August 2002

process ensures that all critical concerns are addressed and improves the chances for acceptance and support of the new/revised program. The program should be presented in a positive, proactive manner as the product of a visible, agency-wide effort. Section 1. TASK TEAM Experience has shown that implementation of a new program or revision to an existing one is best achieved when a task team is formed and given responsibility for formulating or revising the policy and implementing the drug and alcohol program, with management guidance and approval. The composition of the team will depend on the size of the organization. In medium- to large-sized systems, representatives from each of the following disciplines should be included if possible: management, legal, medical personnel, operations, maintenance, and labor relations. The team in unionized systems should include one representative from each bargaining unit, and at least one employee representative from the general work population. You may also wish to include representatives from your consortium/third party administrator or service agents (e.g., MRO, SAP) if you have already obtained their services. In small systems with limited staff, the team should include at least a driver and/or a maintenance employee. Small systems that are part of a city or county department may also wish to include legal counsel and someone from the personnel department. Program Manager. The transit system’s drug and alcohol program manager (DAPM) should lead the team. The DAPM should be knowledgeable about the transit system’s operations, human resources, drug and alcohol program and regulatory requirements. The DAPM will be ultimately responsible for the formation, implementation, and day-to-day management of the program. The DAPM needs sufficient authority to direct the program and must have easy access to senior management, union representatives, and first-line workers. Task Team Responsibilities. The primary responsibility of the task team is to develop an action plan for accomplishing the program’s goals and objectives, thereby ensuring the successful implementation or revision of the program. The action plan should include: a list of necessary tasks, the assignment of individuals responsible for tasks, and a time schedule for completion. Other duties of the task team may include: • Helping resolve local policy issues; • Providing input into the development or revision of the employer’s drug and alcohol testing program policy; • Establishing roles and responsibilities of individuals responsible for developing procedures for the transit system’s drug and alcohol testing program; • Identifying and evaluating potential service agents, testing pools, consortia, or other programs that may be beneficial to the employer; • Providing input into procurement of equipment and contract services for specimen collection, laboratory testing, MRO services, BATs, and SAP and/or consortia; • Assisting in employee awareness and supervisor training; and Chapter 3. Program Formulation 3-2 August 2002

process ensures that all critical concerns are<br />

addressed and improves the chances for<br />

acceptance and support of the new/revised<br />

program. The program should be presented<br />

in a positive, proactive manner as the<br />

product of a visible, agency-wide effort.<br />

Section 1. TASK TEAM<br />

Experience has shown that<br />

implementation of a new program or<br />

revision to an existing one is best achieved<br />

when a task team is formed and given<br />

responsibility for formulating or revising the<br />

policy and implementing the drug and<br />

alcohol program, with management<br />

guidance and approval. The composition of<br />

the team will depend on the size of the<br />

organization. In medium- to large-sized<br />

systems, representatives from each of the<br />

following disciplines should be included if<br />

possible: management, legal, medical<br />

personnel, operations, maintenance, and<br />

labor relations. The team in unionized<br />

systems should include one representative<br />

from each bargaining unit, and at least one<br />

employee representative from the general<br />

work population. You may also wish to<br />

include representatives from your<br />

consortium/third party administrator or<br />

service agents (e.g., MRO, SAP) if you have<br />

already obtained their services.<br />

In small systems with limited staff, the<br />

team should include at least a driver and/or a<br />

maintenance employee. Small systems that<br />

are part of a city or county department may<br />

also wish to include legal counsel and<br />

someone from the personnel department.<br />

Program Manager. The transit<br />

system’s drug and alcohol program manager<br />

(DAPM) should lead the team. The DAPM<br />

should be knowledgeable about the transit<br />

system’s operations, human resources, drug<br />

and alcohol program and regulatory<br />

requirements. The DAPM will be ultimately<br />

responsible for the formation,<br />

implementation, and day-to-day<br />

management of the program. The DAPM<br />

needs sufficient authority to direct the<br />

program and must have easy access to senior<br />

management, union representatives, and<br />

first-line workers.<br />

Task Team Responsibilities. The<br />

primary responsibility of the task team is to<br />

develop an action plan for accomplishing the<br />

program’s goals and objectives, thereby<br />

ensuring the successful implementation or<br />

revision of the program. The action plan<br />

should include: a list of necessary tasks, the<br />

assignment of individuals responsible for<br />

tasks, and a time schedule for completion.<br />

Other duties of the task team may include:<br />

• Helping resolve local policy issues;<br />

• Providing input into the<br />

development or revision of the<br />

employer’s drug and alcohol testing<br />

program policy;<br />

• Establishing roles and<br />

responsibilities of individuals<br />

responsible for developing<br />

procedures for the transit system’s<br />

drug and alcohol testing program;<br />

• Identifying and evaluating potential<br />

service agents, testing pools,<br />

consortia, or other programs that<br />

may be beneficial to the employer;<br />

• Providing input into procurement of<br />

equipment and contract services for<br />

specimen collection, laboratory<br />

testing, MRO services, BATs, and<br />

SAP and/or consortia;<br />

• Assisting in employee awareness<br />

and supervisor training; and<br />

Chapter 3. Program Formulation 3-2 August 2002

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