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

employers may expand and improve upon
the policy as appropriate to address these
audiences. This is acceptable as long as
FTA’s requirements are met and the
employer’s provisions are noted
accordingly. Thus, systems with detailed
policies may continue to use them, but
voluminous policies are not required by
FTA.
The required elements of a policy are
discussed in the following sections.
Identify Contact Persons
You must identify the person, office,
branch, and/or position to answer
employee questions about the drug and
alcohol program, with the telephone
number and office location clearly
indicated. In most cases, the contact
person will be the employer’s DAPM.
Employee Categories Subject to Testing
Employees who perform safetysensitive
functions must be tested under
the FTA regulation. Policies must identify
the safety-sensitive functions that are
covered and the employee’s positions that
are subject to testing. Most employers
attach a list of functions and position titles
to avoid policy revision every time they
make personnel changes (see Chapter 2, “
Regulatory Overview,” for safety-sensitive
definition).
Participation as a Requirement of
Employment
The policy should state that participation
in the agency’s prohibited substance testing
program is a requirement of each safetysensitive
employee and, therefore, it is a
condition of employment.
Prohibited Behavior
Employers must specify the employee
behaviors that the FTA rules prohibit. The
policy must also identify the times when
safety-sensitive employees must comply
with the drug and alcohol rule.
• Use of illegal drugs is prohibited at
all times.
• An employee must not consume
alcohol while performing a safetysensitive
function (§655.32).
Performing a safety-sensitive
function is defined as any time the
employee is actually performing,
ready to perform, or immediately
available to perform such functions.
• Employees are prohibited from
consuming alcohol 4 hours prior to
performing a safety-sensitive
function (§655.33).
• Employees must not consume
alcohol for 8 hours following an
accident unless the employee has
already undergone a post-accident
test (§655.34).
• Employees are also prohibited from
consuming alcohol during the hours
the employee is on-call (§655.33(b)).
• Employees are prohibited from
performing a safety-sensitive
function while having an alcohol
Chapter 4. Policy Development and Communication 4-2 August 2002