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

Chapter 4. POLICY
DEVELOPMENT AND
COMMUNICATION
The FTA regulation requires that every
covered employer including direct
recipients, sub-recipients, and safetysensitive
contractors that have safetysensitive
employees develop a compliant
policy on prohibited drug use and alcohol
misuse in the workplace. The rule also
requires that the policy statement be
written and made available to every
safety-sensitive employee. You should
use this chapter as a checklist of the items
that should be included in your policy.
Only an employer can establish a
policy for its employees. Therefore,
contractor employees should not be placed
under an agency’s policy. The agency,
however, can dictate through its contract,
the minimum requirements of the
contractor’s policy and can require
approval authority. Agencies that contract
out their safety-sensitive functions and
have no safety-sensitive employees are not
required to have a policy statement.
Section 1. REQUIRED POLICY
STATEMENT
The employer’s Drug and Alcohol
Program Manager (DAPM) should guide the
development of the initial draft and any
subsequent revisions. Depending on the
structure of the agency, the DAPM may
wish to solicit input from employees, labor
organizations, other management personnel,
and service agents as described on page 2-1
of the Best Practices manual.
FTA suggests that an employer’s policy
statement incorporate its position and
information on all major aspects of its drug
and alcohol program. Part 655 specifies the
minimum requirements that must be
included to be considered compliant.
FTA acknowledges that policy
statements are written for many various
target audiences, including employees,
unions, the legal system, etc. Therefore,
Chapter 4. Policy Development and Communication 4-1 August 2002