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

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What, if anything, caused them to believe it was substance-abuse-related behavior? On what<br />

basis did they reach their conclusions?<br />

The supervisor should observe the employee. What can the supervisor observe and<br />

objectively document as it relates to physical signs and symptoms, emotional state, physical<br />

evidence, and related facts? The reasonable suspicion determination must be made based on the<br />

trained supervisor’s observations.<br />

Transport the Employee. Although the FTA regulations do not specify that the employee<br />

must be transported, it is unwise to allow an employee suspected of being under the influence of<br />

alcohol or drugs to proceed alone to the collection site or to drive home. He or she could be a<br />

danger to self or others. In addition, the employer’s exposure to liability is great if damage or<br />

injury occurs. Accompanying the employee to the collection site also assures that there is no<br />

opportunity en route for the employee to ingest or acquire anything that could affect the test<br />

result.<br />

The direct or immediate supervisor of the employee must not serve as the collection site<br />

person for drug or alcohol tests (§655.53).<br />

Document Events. Record the behavioral signs and symptoms that support the<br />

determination to conduct a reasonable suspicion test, and maintain those records for a minimum<br />

of 2 years. The signs and symptoms to look for are more fully described in Appendix F.<br />

Chapter 5. Training 5-22 August 2002

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