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

policy with the requirement to formally
train certain employees and supervisors in
selected aspects of your drug and alcohol
program. See Chapter 5, “Training,” for
an explanation of your training
obligations.
You can include other items in your
policy orientation sessions. One
suggestion is to provide an open forum
where top management, union officials,
laboratory representatives, and/or a
substance abuse professional may answer
questions regarding the policy, its
implications, testing procedures, or
available employee assistance. Be sure
that persons answering questions about the
policy and regulations are completely
knowledgeable concerning the program.
Avoid generalities, vague answers,
opinions, and guesses. If a specific issue
is not resolved or addressed by the policy,
say so. If you do not know the answer to a
question, assure the audience that you will
get an answer as soon as possible, and be
sure to follow-up.
Management Commitment
FTA suggests that top management
should demonstrate its personal
commitment and support of the program
by communicating the policy to
employees, which will set an example, and
ensure fair and impartial implementation.
Management assurances of strict
confidentiality are key elements in
promoting the program. Senior transit
officials should understand the program
thoroughly and should know about the
effects of substance abuse, the
requirements of the regulation, and the
prescribed disciplinary actions. A positive
attitude toward a drug- and alcohol-free
work site should be communicated at
every opportunity and will help to achieve
a successful program.
Labor Involvement
Implementation of the FTA-mandated
drug and alcohol program is not subject to
bargaining, unless the transit agency chooses
not to accept FTA operating or capital
funding. Even then, the employer may fall
under the regulatory authority of the Federal
Motor Carrier Safety Administration
(FMCSA). Only those policy provisions
included under the employer’s own
authority are subject to collective
bargaining.
Union or employee leadership must be
notified of the employer’s anti-drug and
alcohol misuse policies and procedures and
any subsequent changes made in the
program. It can be advantageous to involve
the union or employee leadership in the
policy formulation/revision process. Your
employee representatives may actively
support the drug and alcohol program and
may offer to assist in the administration of
employee support programs (i.e., Alcoholics
Anonymous, Employee Assistance
Programs). For a more detailed discussion
of labor involvement practices, see Section
3.1 of the Best Practices manual.
Applicants for Employment
You must make sure that all safetysensitive
applicants are fully aware of the
transit system’s commitment to a drug- and
alcohol-free workplace. Add a statement
similar to the one below to all notices of
safety-sensitive positions:
The (Transit Agency) has established the
goal of a 100 percent drug- and alcoholfree
workplace. Applicants will be
required to undergo drug testing prior to
employment and will be subject to
further drug and alcohol testing
throughout their employment.
Chapter 4. Policy Development and Communication 4-9 August 2002