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

Greater Expertise. The FTA and
DOT regulations are not simple.
Although the regulations were carefully
crafted, experience indicates that you
may encounter situations where it is not
clear what your responsibilities are
under the regulations. The regulations
purposely leave many decisions to local
management, which should be included
in policy statements and operating
procedures. Beyond this, no one can
anticipate every situation that will arise.
Few transit systems can afford to
hire a full-time DAPM to administer its
program. In most cases, the
administration of the agency’s drug and
alcohol program is delegated to someone
in the organization who has many other
responsibilities. This is especially true
in small rural transit systems.
Joining a consortium allows
employers to pool resources to hire a
professional manager with specialized
knowledge and experience. The
consortium manager can devote his/her
full attention to the testing requirements,
and can provide oversight to the drug
and alcohol programs of member
organizations. Depending upon the size
of the consortium, the manager may be
full or part-time, and his/her salary, as
well as consortium expenses may be
recovered with testing cost savings.
Reduced Administrative Burden.
The administrative burden of operating a
program that complies with the
regulations can be substantial. Procuring
services, training employees and
program personnel, maintaining
collection equipment and facilities,
maintaining the random pool,
completing random selection and
notification, assuring quality, and record
keeping and reporting can each be time
consuming activities. Together, these
activities can be daunting to a system
that wants to operate a first-class safety
program.
Pooling Resources – An Example
A consortium of seven transit agencies
was established to pool talents to meet
the FTA regulations.
Due to the geographic closeness and
density of populations served by the
transit agencies, the consortium
members found it helpful to collectively
develop as much of the drug and alcohol
testing program as they could. Each
member contributed its own special
areas of expertise.
The consortium members worked
collectively to develop common RFPs,
contract specifications, and common
language for policy statements. Each
transit agency developed its own policy
and program using parts of the
consortium-developed material.
It was especially valuable to pool
employees and obtain better prices for
services like collections and laboratory
analysis. Another advantage was that it
gave the organizations a chance to hear
other’s opinions on how to implement
the regulations, as well as different
“readings” or understandings of the
regulations.
This consortium approach for
developing a drug and alcohol program
is a model of how multiple transit
agencies, pooling limited resources, can
build stronger programs than they could
by themselves.
A consortium can manage many of
these program-related activities. By
pooling administrative functions, a
consortium may save its members time
Chapter 11. Joining a Consortium 11-3 August 2002