Drug & Alcohol Newsletter Issue 13
U.S. Department of Transportation Federal Transit Administration Office of Safety and Security
FTA Drug And Alcohol Regulation Updates
Fall 1999 Issue 13
Introduction.... The Federal Transit Administration (FTA) published its final rules on prohibited drug use (49 CFR Part 653) and the prevention of alcohol misuse (49 CFR Part 654) on February 15, 1994. Shortly thereafter, the FTA published the Implementation Guidelines for Drug and Alcohol Regulations in Mass Transit to provide a comprehensive overview of the regulations.
Since the Guidelines were published there have been numerous amendments, interpretations, and clarifications to the Drug and Alcohol testing procedures and program requirements.
This publication is being provided to update the Guidelines and inform your transit system of all of these changes. This Update is the thirteenth in a series.
Random Rates Remain The Same For 2000
The drug and alcohol random testing rates for the transit industry are established each year based on the positive random test results experienced by the transit industry as a whole during the previous two year period. The positive random test results are provided to FTA by individual employers on their annual MIS reports. The drug test rate is calculated by adding the positive tests to the number of refusals and dividing the total by the total number of random tests conducted and refused. The positive rate for drugs in 1997 was 1.21% and 1.07% in 1998. Since the rate for both years is greater than 1.0%, the drug random testing rate for employers subject to FTA drug testing rules (49 CFR Part 653) will remain at fifty percent for calendar year 2000. Similarly, the industry-wide violation rate for random alcohol tests is calculated by dividing the sum of the number of employees testing at 0.04 or greater and the number of test refusals by the sum of the total number of tests conducted and refused. In 1997, the violation rate was 0.19% and in 1998 the violation rate was 0.22%. Since both rates are below 0.5%, the alcohol random testing rate for employers subject to FTA alcohol testing rule (49 CFR Part 654) will remain at ten percent for calendar year 2000. An FTA notice officially announcing these rates was published in the Federal Register November 24, 1999 (Volume 64, Number 226).
Job Access Grantees Subject to Testing
The regulations (49 CFR 653.5 and 49 CFR 654.3) stipulate that FTA drug and alcohol regulations are applicable to all recipients under Section 5309, 5307, and 5311 of the Federal Transit Act. The regulations are also applicable to any recipient of a Job Access or Reverse Commute grant authorized under the Transportation Equity Act for the 21st Century (TEA-21), Pub. L. 105-178. Section 3037(j)(1) of TEA-21 states that all Job Access and Reverse Commute grants shall be subject to “all of the terms and conditions to which a grant is made under Section 5307.” Rural Job Access grantees (service area < 50,000) are subject to all of the terms and conditions to which a grant is made under Section 5311.
Part 40 Revisions Proposed
The Department of Transportation (DOT) is responsible for developing the procedural requirements for drug and alcohol testing in the transportation industry. These requirements are promulgated at 49 CFR Part 40. As technology advances, the testing industry evolves and practical experience warrants, these procedures must likewise evolve. Consequently, the DOT is proposing changes to Part 40 that will reflect this evolution, clarify past interpretations, and enhance the quality of the testing program. The new Part 40 was published in the form of a Notice of Proposed Rulemaking (NPRM) in the Federal Register on December 9, 1999, (Volume 64, Number 236, Pages 69075 - 69136). The NPRM can be found online at www.access.gpo.gov. All interested parties are encouraged to comment by the April 7, 2000 deadline. Comments should be provided in triplicate to: Docket Clerk, Attn: Docket No. OST-99-6578, Department of Transportation, 400 7th Street, SW, Room PL401, Washington, DC 20590. Once all the comments have been collected, the DOT will review each comment and revise the proposed rule. Once finalized, the final rule and effective date will be published in the Federal Register.
FTA Drug and Alcohol Regulation Updates Issue 13, page 2
Clarifications and Corrections
Where To Find?..... 49 CFR Part 653 , Prevention of Prohibited Drug Use in Transit Operations February 15, 1994 Federal Register Vol. 59 Pages 7572-7611
Amended: August 2, 1995 Federal Register Vol. 60 Pages 39618-39620 Primary Topic: Exemption of Volunteers and Post-Accident Testing Provision
December 8, 1998 Federal Register Vol. 63 Pages 61612-67613 Primary Topic: Use of Law Enforcement Post-Accident Test Results
December 14, 1998 Federal Register Vol. 63 Pages 68818-68819 Primary Topic: Random Drug Testing Rate at 50%
January 5, 1999 Federal Register Vol. 64 Pages 425-427 Primary Topic: Safety-sensitive Maintenance Functions
Technical Corrections: March 6, 1995 Federal Register Vol. 60 Pages 12296-12300 Primary Topic: Corrections and Clarifications
The information presented on this page should be used to update Chapter 6 and 7 of the Implementation Guidelines. Minimum Thresholds For Drug Test Positive
The Department of Health and Human Services (DHHS) establishes the minimum threshold levels for each of the five drugs tested for under USDOT testing programs including the FTA. Minimum levels are established for both the initial screening test and for the confirmatory test. The current cutoff levels are as follows:
Initial Test Cut-off Level Confirmatory Test Cut-off Level Marijuana Metabolite (1) 50 ng/ml 15 ng/ml Cocaine Metabolite (2) 300 ng/nl 150 ng/ml Opiates 2000 ng/ml - Morphine - 2000 ng/ml Codeine - 2000 ng/ml Phencyclidine 25 ng/ml 25 ng/ml Amphetamines 1000 ng/ml - Amphetamine - 500 ng/ml Methamphetamine (3) - 500 ng/ml
(1) Delta 9-tetrahydrocannabinol-9 carboxylic acid; (2) Benzoylecgonine; (3) Specimen must also include amphetamine at a concentration greater than or equal to 200 ng/ml.
Custody and Control Form Proposed Change
On November 15, 1999, a Notice of Proposed Rulemaking (NPRM) was published in the Federal Register (Volume 64, Number 219, Pages 61916-61930) soliciting comments on proposed changes to the Federal Drug Testing Custody and Control Form (COC). The NPRM proposes changes that are intended to make the COC form easier to use and to reflect the collection process and how results are reported by the testing laboratories. Written comments on the proposed rule should be submitted by January 14, 2000, to Robert L. Stephenson II, M.P.H., Director (Acting), Division of Workplace Program, CSAP, 5600 Fishers Lane, Rockwall II, Suite 815, Rockville, MD 20857.
Best Practice: Drug Test Following Leave
The drug testing regulation (49 CFR Part 653.41) requires that an applicant must have a negative pre-employment drug test before they can be hired. Additionally, the regulation states that an employer may not transfer an employee from a non-safety-sensitive function to a safety-sensitive function until the employee takes a drug test with a verified negative result. In instances where an employee is on a lengthy leave of absence and will not be called on to perform a safety-sensitive job function, the individual should be taken out of the random pool. Transit systems that perform this post-leave testing commonly define a leave of absence as a change in status such as a seasonal layoff, extended worker’s compensation leave, maternity leave or other non-active leave status defined by the employer. Many transit systems also require pre-employment/pre-transfer tests following an extended leave, and have established a minimum leave duration (i.e., 30 days, 60 days, 90 days) that must be exceeded before a drug test is required. Even though the regulation does not require drug testing in this circumstance, FTA supports the common industry practice that any leave that extends beyond 90 days should trigger a test when the person returns to active status. These tests, however, are conducted under the employer’s own authority and must not be considered FTA tests. This interpretation is different from the article on page 7 of Issue 3 of the Updates and corrects that previous guidance.
Self-Assessment Checklist FTA Drug and Alcohol Regulation Updates Issue 13, page 3
Pre-Employment Drug Testing Checklist
The FTA drug testing regulation requires that all applicants for employment in safety-sensitive positions or individuals being transferred into safety-sensitive positions must take and pass a pre-employment drug test. The FTA does not allow any waivers of pre-employment drug tests. The employer may not utilize drug test results for the applicant which have been obtained from a previous employer in lieu of conducting their own pre-employment test. To assist in clarifying the requirement for pre-employment testing, the FTA has developed this checklist for use by employers in their program assessments. The checklist includes regulatory requirements, as well as “best practice” recommendations. The checklist should not be construed as the “last word” in regulatory compliance, but is merely provided for guidance.
Pre-Employment Testing Procedures
Does the transit agency have on file the negative drug test results for all new hires?
Does the transit agency hire an employee into a safety-sensitive function only if the employer has a negative drug test result for the applicant? The date the test results are reported must be before the date the applicant is hired and put on the payroll.
Does the transit agency require that employees transferring from a non-safety-sensitive position into a safety-sensitive position have a negative drug test result prior to performing any safety-sensitive function? If an individual has a positive pre-employment drug test, the individual cannot be hired. If that same individual applies for a safety-sensitive position in the future, a drug test must be administered again. At that time, if the drug test result is negative, the individual may be hired. Although not required by the FTA, the transit agency can require the applicant to provide evidence of well-being from a treatment specialist before administering the second test. The employer must allow the applicant to discuss the laboratory-confirmed positive test result with a medical review officer prior to the MRO making a final decision to verify a positive drug test result. Referral to an SAP is not required for a verified pre-employment positive drug test result. If pre-employment drug test is cancelled, the applicant is required to submit to and pass another test.
Is the time between the hire date and the test date reasonable (less than one month)?
Are MROs allowed to report a negative pre-employment test result for individuals that are unable to provide sufficient volume because of a permanent disability, but who have a medical evaluation that indicates no chemical evidence of illegal drug use?
Are all applicants notified in writing of the requirement to pass a drug test?
Even though not required, FTA supports employers who test employees who are returning to active status following a leave of absence of 90 days or more. Post-leave testing, however, must not be performed under FTA authority. See article on page 2 of this Update. (This information was excerpted from the Drug and Alcohol Program Self-Assessment Checklist developed for the Transportation Safety Institute by RLS & Associates, Inc.) Where To Find?..... 49 CFR Part 654, Prevention of Alcohol Misuse in Transit Operation February 15, 1994 Federal Register Vol. 59 Pages 7532-7571
Amended: May 10, 1995 Federal Register Vol. 60 Pages 24765-24766 Primary Topic: Suspension of Pre-employment Alcohol Testing
August 2, 1995 Federal Register Vol. 60 Pages 39618-39620 Primary Topic: Exemption of Volunteers and Post-Accident Testing Provision
December 8, 1998 Federal Register Vol. 63 Pages 67612-67613 Primary Topic: Use of Law Enforcement Post-Accident Test Results
December 14, 1998 Federal Register Vol. 63 Pages 68818-68819 Primary Topic: Random Alcohol Testing Rate at 10%
January 5, 1999 Federal Register Vol. 64 Pages 425-427 Primary Topic: Safety-Sensitive Maintenance Functions
Technical Corrections: March 6, 1995 Federal Register Vol. 60 Pages 12296-12300 Primary Topic: Corrections and Clarifications
The information presented on this page should be used to update Chapters 6 of the Implementation Guidelines.
FTA Drug and Alcohol Regulation Updates Issue 13, page 4
For Your Information
Where to Find? .....
49 CFR Part 40, Procedures for Transportation Workplace Drug Testing Programs
Amended: February 15, 1994 Federal Register Vol. 59 Pages 7340-7366 Primary Topic: DOT Alcohol Testing Procedures Procedures for Split Sample Procedures for Drug Testing
August 19, 1994 Federal Register Vol.59 Pages 42996-43018 Primary Topic: Clarified Urine Specimen and Collection Procedures and Clarified Alcohol Testing Procedures
April 19, 1995 Federal Register Vol.60 Pages 19535-19537 Primary Topic: Standardized Chain of Custody and Control Form
April 20, 1995 Federal Register Vol.60 Pages 19675-19681 Primary Topic: Established Procedures for Use of Non-evidential Alcohol Screening Devices
The information presented on this page should be used to update Chapter 2 of the Implementation Guidelines. Drug Testing: Is It Working?
The primary intent of the Omnibus Transportation Employee Testing Act of 1991 was to achieve a drug- and alcohol-free transportation work force in the interest of the health and safety of employees and the public. The resulting regulations (49 CFR Parts 653 and 654) promulgated by the Federal Transit Administration and subsequent guidance have been designed to deter and detect the illegal use of drugs and misuse of alcohol by transit safety-sensitive employees. Even though the transit industry is not yet free of illegal drugs, the anecdotal evidence indicates that drug testing is working, transit systems across the country are safer and more productive, and employee morale has improved. More specifically, data reported by the transit industry through the annual Management Information System (MIS) submissions have provided quantitative documentation of the impact of the program. The data for the 1995-1998 calendar years have been summarized and published in annual reports for each of the respective years. The 1998 annual report will be available from FTA in January, 2000.
A comparison of the test results combined for all FTA test categories since 1995 indicates that the positive test rate for drugs has declined at a steady rate. As can be seen in the accompanying chart, the positive rate for all FTA drug tests has decreased from a high of 2.14% in 1995 to 1.67% in 1998. This change represents a decrease of 22%. The chart also shows the decline in positive test results that have occurred for all workplace drug tests over the past decade as represented by the Drug Testing Index (DTI), maintained by Quest Diagnostics Incorporated, a leading provider of drug testing services in the United States. The DTI is derived from 2.8 million drug tests of federally mandated, safety-sensitive workers and the general workforce. According to the DTI, in 1988 the positive drug test rate was 13.6%, . Ten years later in 1998, this rate dropped to 4.8%. The long-term downward trend indicates that testing programs are deterring use, while the positive rates indicate that testing programs are successfully detecting workers who still choose to use. Is it working? Most would answer, Yes!
“Test Cheater” Numbers Growing
According to the Drug Testing Index (DTI) released by Quest Diagnostics Incorporated on October 19, 1999, individuals who are trying to beat their drug test made up a significant percentage of positive test results during the first half of 1999. The DTI defines cheaters as those whose urine specimens contain adulterants and those who substitute specimens. Nearly 2% of the positive test results included in the DTI were attributed to cheaters. Among the most common adulterants are oxidizing agents including nitrites used as masking agents intended to defeat the process of detecting drug use. Also common are substituted specimens that do not contain certain chemical components characteristic of normal human urine. These adulterants can be identified by labs by performing basic validity tests on specimens.
For Your Information FTA Drug and Alcohol Regulation Updates Issue 13, page 5
1998 Data Are Available
FTA now has four years of quality data to document drug and alcohol testing results within the industry. Patterns and trends have evolved that validate the program and confirm what many already believed while at the same time contradicting many commonly held misconceptions. The highlights of the 1998 annual report are summarized here. The full report for 1998 and previous years can be obtained after January by contacting the FTA Office of Safety and Security at (202) 366-2896. In 1998, 151,237 specimens were collected for drug testing; in total, 1.67% were positive. The vast majority of tests (111,490) performed were random tests with a positive rate of 1.07 percent. The industry’s safety-sensitive contractors, when viewed as a whole, experienced a positive random rate (1.69%) for drugs that was nearly double the transit systems’ rate (0.94) highlighting the difference between systems that directly perform safety-sensitive functions and contract service providers. Small urban systems (50,000 to 200,000 service area population) had the highest average positive rate of 1.19 percent for drugs followed by rural systems (<50,000 population) with a rate of 1.12 percent and large urban systems (>200,000 population) with a rate of 1.06 percent. These statistics are in direct contrast to the commonly held perception that drug use is only a large urban problem.
The other testing categories had higher positive results than random. The pre-employment positive rate was 2.74% for drugs. The post-accident positive rate was 1.45% for drugs and the reasonable suspicion positive rate for drugs was 8.04%. The midwest (FTA Region V) and mountain (FTA Region VIII) states had the highest positive random drug test results, whereas, New York (Region II), northwest (Region X), and the remainder of the east coast (Regions I and III) had the lowest rates. The alcohol test results indicate much lower positive rates. Of the 41,206 total alcohol screening tests, 0.29% were confirmed positive at the 0.04 or greater BAC level. The random positive rate was 0.13%, while post-accident and reasonable suspicion rates were 0.12% and 9.52%, respectively. The rates were nearly equal between directly operated (0.13%) and contracted (0.14%) services. However, there was a significant difference associated with service area size. The large urban systems had a 0.15 % positive random alcohol test rate whereas, the small urban and rural systems experienced positive random rates of 0.03% and 0.02%, respectively. Geographically, the northeast (Regions II and III) had the highest positive random alcohol rates (0.20% and 0.23%) while the west coast (Regions IX and X) and central states (Regions VI and VII) had the lowest (<0.05%). Where To Find?..... Part 40 Amendments, Cont.
July 16, 1996 Federal Register Vol.61 Pages 37015-37017 Primary Topic: Use of Labs Outside the U.S.
July 17, 1996 Federal Register Vol.61 Pages 37222-37224 Primary Topic: Expansion of SAP Definition
July 19, 1996 Federal Register Vol.61 Pages 37693-37700 Primary Topic: Insufficient Specimen
November 25, 1998 Federal Register Vol. 63 Pages 65128-65129 Primary Topic: Opiate Threshold
The information presented on this page should be used to update Chapter 2 of the Implementation Guidelines.
FTA Drug and Alcohol Regulation Updates Issue 13, page 6
Q & A
Q: Are examples of forms and procedures that have proven to be effective available? How can I find them?
A: FTA is compiling an assortment of best practices used within the industry and will share them through the FTA home page. Best practices that will appear include procedures, forms, sample language, and oversight techniques to name a few. Currently, information on Substance Abuse Professionals and Places to Look for Information is available. The FTA home page is http://transit-safety.volpe.dot.gov
The information presented on this page should be used to update Chapter 6 of the Implementation Guidelines. Understanding Terms Eases MIS Reporting
Employers subject to the FTA drug and alcohol testing regulations will soon be undertaking the task of completing their annual MIS reports. The 1999 report will constitute the fifth year of reporting. Improvements have been made to the process each year and employers have become familiar with the data requests. Employers are keeping better records and the reporting process has become much smoother for most. However, there still remains confusion over some terminology used in the data request that results in reporting errors. The Volpe National Transportation Systems Center recommends that employers follow the reporting directions precisely and review the data request terminology to avoid possible reporting mistakes and subsequent follow-up calls by data analysts at the Volpe Center. The Volpe Center has identified common reporting mistakes and provides the following guidance to help you avoid these mistakes:
Send the reports/diskettes to the correct address. All reports should be sent to: USDOT/Volpe Center, Drug and Alcohol MIS Program Office DTS-781 55 Broadway, Kendall Square Cambridge, MA 02142-1093
Use the correct data collection forms. The EZ form for drug tests is to be used to report results only if there have been no positive drug tests. Similarly, the EZ form for alcohol tests is to be used to report results only if there have been no alcohol tests with a result of 0.02 or greater. If there is one or more positive test results to report for the year, the long form must be used. Make sure you include an original signature on the front cover of both the drug and alcohol MIS forms; copies are not acceptable. If you are reporting electronically, you must send in the signed front cover page (paper version) for both the drug and alcohol forms along with the diskette. Answer all questions. There should be no blank entries on the form. If there is no information to enter in a space, a zero (“0”) must be entered. If the space is left blank, the data analyst will assume you neglected to answer the question and will initiate a follow-up call. If your system is a member of a drug and alcohol testing Consortium, be sure to provide complete and correct information about the Consortium in your report. For reporting purposes, a Consortium is an entity (including a group or association of employers) that provides testing services required by the regulations and that acts on behalf of the employers. Many employers incorrectly list their collection site as a Consortium. Only include information about FTA safety-sensitive employees in your report. Do not include information on employees that fall under FHWA regulations or other City, County, or agency employees who do not perform FTA safety-sensitive functions on this report. Only those employees who are actually covered by the United States Coast Guard (i.e., commuter ferry or water shuttle personnel) should be reported as employees covered by the USCG. This occurrence is very rare and therefore, the vast majority of employers would place a “0” in the answer box for this question. For those employers that do have employees covered by the USCG, this column should be a subset of the total number of FTA covered employees. Only employees that have received their “first-time” substance abuse awareness training in 1999 should be reported as Initial Training. Annual or refresher training should not be reported. This number should reflect the number of new hires and transfers into safety-sensitive positions during 1999. Only Post-Accident test results that pertain to accidents which meet FTA accident criteria should be reported. Return-to-Duty testing refers only to employees who are returning to duty after testing positive on a drug and/or alcohol test or after refusing to submit to a test. Tests conducted on employees who return to work following a leave of absence (see article on Page 2 of this newsletter) should not be reported as a return-to-duty test. For additional guidance on how to complete the MIS Forms, please refer to the most recent FTA Drug and Alcohol MIS guidance that accompanies the reporting forms and compact discs, or call the Drug and Alcohol MIS Program Office at (617) 494-6336.
MIS Reporting FTA Drug and Alcohol Regulation Updates Issue 13, page 7
Annual MIS Reporting
The Volpe National Transportation Systems Center, under contract to FTA, is responsible for collecting and analyzing annual MIS reports from all employers subject to FTA’s drug and alcohol testing regulations. Michael Redington, the Volpe Center project manager, indicates that grantees and state DOTs who submitted reports last year will be mailed a package of information and forms by the end of 1998. Rural systems will receive their reporting packages directly from their state DOT. The package will include report guidance, a paper version of the forms, and a compact disc version of the forms with associated reporting software. The employer has the option of which version to use. The forms and report guidance can also be downloaded from the Volpe Center website. The address is http://transit-safety.volpe.dot.gov/damis. The MIS data collection forms or their diskette equivalent must be submitted to the FTA Drug and Alcohol MIS Program Office by March 15, 2000. The Volpe Center has made significant improvements to the MIS reporting software and directions for producing the reports electronically. Specifically, the electronic version has incorporated range checks and validation procedures that will bring questionable responses to the attention of the reporter for verification. In addition, the ability of the reporter to edit entries has been greatly improved and state DOTs will now be able to make multiple entries in a streamlined fashion. FTA encourages employers to submit electronically if possible to facilitate report submission, validation, and analysis. Electronic submissions can also be processed more quickly and can minimize data entry and manipulation errors. If you do not receive a 1999 DAMIS reporting package by January 15, 2000, please contact the Volpe Center at (617) 494-6336 to request a copy.
Four regional seminars are planned on FTA’s drug and alcohol rules for the Year 2000. These seminars will provide an overview of the regulations including all updates, relevant FTA interpretations, audit process, and NPRMs as appropriate. The seminars will be designed to accommodate 300 attendees or more and will be presented in a lecture hall format. The dates and locations of the seminars are yet to be determined, but will be published in the newsletter as soon as they become known. Enrollment will be open to all and the seminars will be provided free of charge. The content of the seminars will be similar to the 3-day Substance Abuse Management courses presented by the Transportation Safety Institute (TSI) . However, the TSI course is offered in an intimate workshop format with less than 45 attendees that generates a high level of interaction and includes hands-on use of a program self-assessment checklist. The TSI courses are provided on a cost-recovery basis with enrollment controlled by the host. At the time of publication, five dates remained open for TSI courses in 2000. For more information regarding hosting a TSI course, contact Mr. Steve Dallman at (405) 954-7224.
Part 655 Awaited
The Federal Transit Administration is in the process of revising and combining the drug testing regulation (49 CFR Part 653) and the alcohol testing regulation (49 CFR Part 654) into one new regulation (49 CFR Part 655). The new regulation promises to eliminate inconsistencies between the two existing regulations and clarify points of confusion. In addition, the new combined rule will incorporate the content of the FTA letters of interpretation and will address other issues of concern. Part 655 will first be published as a Notice of Proposed Rulemaking in the Spring of 2000. All stakeholders, including large and small transit systems, contractors, service vendors, consortia, state DOTs and trade associations are encouraged to comment. The industry now has several years of experience upon which to base its opinions and comments. Consequently, it is important that all viewpoints be reflected. Comments should address specific issues and provide documentation to support the points being made. All comments will be taken into consideration. This will be your chance to make your concerns be known and to champion your cause. All comments will be viewed with respect and addressed on their merit. FTA is committed to making this rulemaking process a success. Q & A
Q: If an individual cannot provide sufficient urine for a drug test and therefore has three hours to make another successful attempt, when does the three hours start? Does the employee get another three hours if a second attempt also results in insufficient volume?
A: The three hour window begins at the time the first specimen is provided to the collector and the insufficient volume is determined. Insufficient volume on a second attempt does not result in an additional three hour period. If the first attempt was submitted to the collector at 6:00 am, the donor has until 9:00 am to submit a specimen with the required 45 ml no matter how many attempts are made during the time period. Each specimen that results in insufficient volume must be discarded and a new attempt made. Specimens cannot be combined.
The information presented on this page should be used to update Chapters 2 and 9 of the Implementation Guidelines.
FTA Drug and Alcohol Regulation Updates Issue 13, page 8
Who Should Be Receiving This Update? In an attempt to keep each transit system well informed, we need to reach the correct person within each organization. If you are not responsible for your system’s Drug and Alcohol program, please forward this update to the person(s) who is and notify us of the correct listing. If you know of others who would benefit from this publication, please contact us at the following address to include them on the mailing list. This publication is free.
RLS & Associates, Inc. 3131 South Dixie Hwy., Ste. 545 Dayton, Ohio 45439 Phone: (937) 299-5007 FAX: (937) 299-1055
email@example.com FTA home page: www.fta.dot.gov FTA Office of Chief Counsel: www.fta.dot.gov/office/counsel FTA Office of Safety & Security: http://transit-safety.volpe.dot.gov FTA Letters of Interpretation: www.fta.dot.gov/library/legal DHHS-Certified Laboratories: Center for Substance Abuse Prevention: www.health.org/labs/index.htm FTA, Office of Safety and Security: (202) 366-2896 Drug and Alcohol Consortia Manual Drug and Alcohol Testing Results: 1995, 1996, and 1997 Annual Reports Random Drug Testing Manual Implementation Guidelines for Drug and Alcohol Regulations in Mass Transit Identification of Drug Abuse and/or Alcohol Misuse in the Workplace: An Interactive Training Program
USDOT Drug and Alcohol Documents FAX on Demand: 1 (800) 225-3784 USDOT, Office of Drug Enforcement and Program Compliance: (202) 366-3784 Urine Specimen Collection Procedures Guideline SAP Procedures Guidelines for Transportation Workplace Drug and Alcohol Testing Programs
FTA - Office of Safety and Security 400 7th Street SW Washington, DC 20590 Published by:
USDOT-John A. Volpe National Transportation Systems Center Kendall Square Cambridge, MA 02142 Edited by:
RLS & Associates, Inc. 3131 South Dixie Highway Suite 545 Dayton, OH 45439 Illustrated by: