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

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employees who have problems with<br />

prohibited drugs. Of course, you must make<br />

clear which parts of your policy and testing<br />

program apply to employees who are<br />

covered under the FTA drug and alcohol<br />

testing regulation and which parts apply to<br />

those who are not.<br />

Given the DFWA requirement for the<br />

establishment of an “ongoing” substance<br />

abuse awareness program, you may also<br />

wish to retrain employees and supervisors<br />

on a regular basis. In addition, if your<br />

system has regular safety meetings, you may<br />

wish to include discussions of substance<br />

abuse to keep the issue in your employees’<br />

minds.<br />

Section 6. SERVICE AGENT<br />

TRAINING REQUIREMENTS<br />

You must ensure that the service agents<br />

who provide the testing services for your<br />

agency are appropriately educated and<br />

trained. This includes urine specimen<br />

collectors, breath alcohol technicians (BAT),<br />

screen test technicians (STT), Medical<br />

Review Officers (MRO), and Substance<br />

Abuse Professionals (SAP). These<br />

individuals must possess certain credentials,<br />

have a basic knowledge of the program,<br />

attend qualifications training, undergo<br />

periodic refresher training, and demonstrate<br />

knowledge either through an examination in<br />

the case of MROs and SAPs, or the<br />

demonstration of proficiency in the case of<br />

collectors, BATs, and STTs. Even though<br />

this training will be conducted by<br />

professional organizations, professionals<br />

within the area of expertise, or by equipment<br />

manufacturers, it is your responsibility as<br />

the regulated employer to assure that the<br />

training has occurred. You need not be<br />

concerned about the training of DHHScertified<br />

laboratory personnel as DHHS is<br />

responsible for laboratory oversight.<br />

Urine Collection Personnel<br />

Individuals who conduct urine specimen<br />

collections under the DOT drug testing<br />

program must meet the following<br />

requirements:<br />

Basic Knowledge. Urine collection<br />

personnel must be knowledgeable about Part<br />

40 and its requirements, DOT agency<br />

regulations applicable to the employers for<br />

whom they perform collections (i.e., FTA,<br />

Part 655), and the current “DOT Urine<br />

Specimen Collection Procedures<br />

<strong>Guidelines</strong>.” This publication is available<br />

from the DOT Office of Drug and Alcohol<br />

Policy Compliance (ODAPC) at<br />

http://www.dot.gov/ost/dapc. Collectors<br />

must also take action to remain current with<br />

regulatory changes.<br />

Qualifications Training. Collectors<br />

must receive qualification training that<br />

addresses all of the steps necessary to<br />

complete a urine specimen collection<br />

correctly, including problem collections<br />

(e.g., shy bladder, attempts to adulterate,<br />

temperature out of range), fatal flaws,<br />

correctable flaws, and corrective actions.<br />

The training must cover the proper<br />

completion and transmission of the Custody<br />

Chapter 5. Training 5-8 August 2002

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