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

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alternative medical explanations for<br />

laboratory confirmed drug test results. The<br />

MRO must also be knowledgeable about<br />

issues relating to adulterated and substituted<br />

specimens, as well as the possible medical<br />

causes of specimens having an invalid<br />

result. MROs must have detailed<br />

knowledge of Part 40, the DOT MRO<br />

<strong>Guidelines</strong>, and the DOT agency regulations<br />

applicable to the employers they serve (i.e.,<br />

FTA—Part 655). The DOT MRO<br />

<strong>Guidelines</strong> can be obtained from the<br />

ODAPC at the previously cited Web site.<br />

The MRO must also remain current with any<br />

changes to the regulations or DOT MRO<br />

<strong>Guidelines</strong>.<br />

Qualification Training. The MRO<br />

qualifications training must include<br />

collection procedures for urine specimens,<br />

chain of custody, reporting and record<br />

keeping procedures, and the interpretation of<br />

drug and validity test results. The training<br />

must also define the role and responsibilities<br />

of the MRO in the DOT drug testing<br />

program and the interaction with other<br />

participants in the program such as the DER<br />

and the SAP. The training must also address<br />

the DOT agency rules (i.e., FTA) that apply<br />

to employers for whom the MRO provides<br />

services.<br />

Following the completion of the<br />

qualification training, the MRO must<br />

satisfactorily complete an examination<br />

which must be administered by a nationally<br />

recognized MRO certification board or<br />

subspecialty board of medical practitioners<br />

who perform MRO functions.<br />

Continuing Education. MROs are<br />

required to complete 12 professional<br />

development hours during each 3-year<br />

period, counting from the date of the<br />

successful completion of the initial<br />

examination. The professional development<br />

education hours must be relevant to<br />

performing MRO functions and must<br />

address new technologies, DOT and modal<br />

interpretations, new guidance, rule changes,<br />

and other information relevant to MRO<br />

practice. The continuing education activities<br />

must also include a method of assessing the<br />

MRO’s understanding of the materials<br />

covered.<br />

Substance Abuse Professionals<br />

The Substance Abuse Professional<br />

(SAP) is the person responsible for the<br />

return-to-duty process. To be considered a<br />

SAP, an individual must have the following<br />

credentials and training:<br />

Credentials. A SAP is a licensed<br />

physician, a licensed or certified social<br />

worker, a licensed or certified psychologist,<br />

a licensed or certified employee assistance<br />

professional, or a drug and alcohol<br />

counselor certified by the National<br />

Association of Alcoholism and Drug Abuse<br />

Counselors Certification Commission<br />

(NAADAC), or the International<br />

Certification Reciprocity<br />

Consortium/Alcohol and Other Drug Abuse<br />

(ICRC).<br />

Basic Knowledge. A SAP must be<br />

knowledgeable about and have clinical<br />

experience in the diagnosis and treatment of<br />

alcohol and controlled substance-related<br />

disorders. A SAP must be knowledgeable<br />

about the Part 40 requirements and the DOT<br />

agency (i.e., FTA) regulations applicable to<br />

the employers they serve, and the DOT SAP<br />

<strong>Guidelines</strong>. The SAP <strong>Guidelines</strong> can be<br />

obtained from the ODAPC. More<br />

important, however, the SAP must be<br />

knowledgeable about their function and how<br />

it relates to the employer’s interests in<br />

safety-sensitive duties. The SAP must also<br />

Chapter 5. Training 5-11 August 2002

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