The 6 DOT agencies can and do issue updated guidelines for random drug testing rates on an annual basis. These are the updated 2019 Specifications for each federal agency.
- FMCSA – Federal Motor Carrier Safety Administration – 25% drug and 10% alcohol
- FAA – Federal Aviation Administration – 25% drug and 10% alcohol
- FRA (Covered Service) – Federal Railroad Administration – 25% drug and 10% alcohol
- FRA (Maintenance of Way) – 50% drug and 25% alcohol
- FTA – Federal Transit Administration – 50% drug and 10% alcohol
- PHMSA – Pipeline and Hazardous Materials – 50% drug
- USCG – United States Coast Guard – 50% drug
It’s important to be sure that your DOT random consortium is successfully completing tests at least as often as required by your modality. When DOT auditors come on-site to audit company drug testing records, they typically ask for something called an annual MIS report to prove that your consortium is testing at a rate that meets their minimum requirements. Health Street’s Random Pool members often call us when an auditor is checking their records to be sure they have the updated MIS report. The auditors look at this report carefully to make sure the percentages of random drug tests and random alcohol tests are at or above the thresholds set for the relevant audit period.
Let me give you an example. Let’s say your company has 10 safety-sensitive employees (“covered employees”), and you join a random DOT drug testing pool (also known as a consortium). Let’s say that there were an average of 1000 covered employees per month in your consortium across all of the companies that enrolled for the last calendar year. You wouldn’t normally need to know how may total covered employees that there are in the pool, as long as when you are notified to get your random tests done, you send your people in and get tested. However, the DOT auditor will absolutely want to know this number. He or she will then reference the percentage required to test for the relevant calendar year. Let’s say your company is covered by FMCSA (trucking), which had a rate of 25% drug and 10% alcohol in 2018. The auditor would then look to see that at least 250 random drug tests and 100 random alcohol tests were completed in 2018 and shown on the MIS report. If your company was covered by PHMSA (pipelines and hazardous materials), those numbers would be 500 random drug tests, but zero random alcohol tests.
As you can see, while it’s not that difficult to calculate how to stay in compliance, it’s extremely important that the consortium that you belong to is on top of it. If you have any questions regarding your company’s ability to comply with these regulations, including DOT audits, Health Street is happy to help.