HomeMy Public PortalAbout009-2023 - Comprehensive Policy To The Substance Abuse Policy for Roseview Transit BOARD OF PUBLIC WORKS AND SAFETY
RESOLUTION NO. 9-2023
A RESOLUTION APPROVING THE COMPREHENSIVE POLICY TO THE SUBSTANCE
ABUSE POLICY FOR THE ROSE VIEW TRANSIT DIVISION
WHEREAS, On November 10, 2010, the City of Richmond, Indiana (City), by and through its Board of
Public Works and Safety (Board), passed the Rose View Transit Substance Abuse Policy for
the Richmond Rose View Transit rural transit system as required by the Federal Transit
Administration (FTA) and the Indiana Department of Transportation (INDOl ) and subsequent
updated policies were approved by the Board through prior Resolution No. 7-2016, prior
Resolution :II-2018, prior Resolution 3-2023, and prior Resolution 6-2023; and
WYIEREAS, An updated policy titled as the "Drug & Alcohol Testing Policy" ("Policy") for the Rose View.
Transit System has been provided by INDOT to be approved by all Rural Transportation
Assistance Program (RTAP) clients, to be effective as of December 7, 2023, which Policy is
attached hereto as Exhibit A, and is incorporated by reference; and
WHEREAS, It is in the best interest of the City of Richmond that the Policy be approved by the Bird of
Public Works and Safety of the City of Richmond, Indiana, for the Rose View 71`ransit System.
NOW THEREFORE, BE IT RESOLVED by the Board of Public Works and Safety of the City of Richmond,
Indiana, that said Board hereby approves the updated Policy attached as Exhibit A for the Rose View "Fransit
System, which policy is to be effective as of December 7, 2023, and which policy may be signed by the
Manger of Rose View Transit.
Passed and adopted this #44. clay of LI Crtiltr , 2023, by the Board of Public Works and Safety
of the City of Richmond, kidiana.
BOARD OF PUBLIC WORKS AND SAFE EY
Vicki Robinson, President
Member
lb 4 TA
Matt Evans, Member
Approved:
Snow,
DRUG AND ALCOHOL TESTING POLICY
Rose View Transit
Adopted as of Dee, ,)3_., 7 , 2023
A. PURPOSE
1) The Rose View Transit provides public transit and paratransit services for
the residents of the City of Richmond. Part of our mission is to ensure that
this service is delivered safely, efficiently, and effectively by establishing a
drug and alcohol-free work environment, and to ensure that the workplace
remains free from the effects of drugs and alcohol in order to promote the
health and safety of employees and the general public. In keeping with this
mission, Rose View Transit declares that the unlawful manufacture,
distribution, dispense, possession, or use of controlled substances or
misuse of alcohol is prohibited for all employees.
2) Additionally, the purpose of this policy is to establish guidelines to maintain
a drug and alcohol-free workplace in compliance with the Drug-Free
Workplace Act of 1988, and the Omnibus Transportation Employee Testing
Act of 1%1. Covered employees shall abide by the terms of this policy
stateme 11 as a condition of employment. This policy is intended to comply
with all applicable Federal regulations governing workplace anti-drug and
alcohol programs in the transit industry. Specifically, the Federal Transit
Administration (FTA) of the U,S. Department of Transportation has
published 49 CFR Part 655, as amended, that mandates drug and alcohol
testing far safety-sensitive positions, and prohibits performance of safety-
sensitive functions when there is a positive test result, or a refusal to test.
The U. S. Department of Transportation (USDOT) has also Published 49
CFR Part 40, as amended, that sets standards for the collection and testing
of specimens for drug and alcohol testing.
3) Any provisions set forth in this policy that are included under the sole
authority of Rose View Transit and are not provided under the authority of
the above named Federal regulations are underlined. Tests conducted
under the sole authority of Rose View Transit will be performed on non-
USDOT forms and will be separate from USDOT testing in all respects.
B. APPLICABILITY
This Drug and Alcohol Testing Policy applies to all safety-sensitive employees (full-
or part-time) when performing safety sensitive duties. See Attachment A for a list
of employees and the authority under which they are included.
A safety-sensitive function is operation of public transit service including the
operation of a revenue service vehicle (whether or not the vehicle is in revenue
service), maintenance of a revenue service vehicle or equipment used in revenue
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service, security personnel who carry firearms, persons controlling the dispatch or
movement of revenue service vehicles and any transit employee who operates a
non-revenue service vehicle that requires a Commercial Driver's License to
operate. Maintenance functions include the repair, overhaul, and rebuild of
engines, vehicles and/or equipment used in revenue service. A list of safety-
sensitive positions who perform one or more of the above mentioned duties is
provided in Attachment A. Supervisors are only safety sensitive if they perform
one of the above functions. Volunteers are considered safety sensitive and subject
to testing if they are required to hold a CDL, or receive remuneration for service in
excess of actual expense.
C. DEFINITIONS
Accident: An occurrence associated with the operation of a vehicle even when not
in revenue service, if as a result:
a. An individual dies;
b. An individual suffers a bodily injury and immediately receives
medical treatment away from the scene of the accident; or,
c. One or more vehicles incur disabling damage as the result of tne
occurrence and is transported away from the scene by a tow truck or
other vehicle. For purposes of this definition, disabling damage
means damage which precludes departure of any vehicle from the
scene of the occurrence in its usual manner in daylight after simple
repairs. Disabling damage includes damage to vehicles that could
have been operated but would have been further damaged if so
operated, but does not include damage which can be remedied
temporarily at the scene of the occurrence without special tools or
parts, tire disablement without other damage even if no spare tire is
available, or damage to headlights, taillights, turn signals, horn, or
windshield wipers that makes them inoperative.
Adulterated specimen: A specimen that has been altered, as evidence by test
results showing either a substance that is not a normal constituent for that type of
specimen or showing an abnormal concentration of an endogenous substance.
Alcohol: The intoxicating agent in beverage alcohol, ethyl alcohol, or other low
molecular weight alcohols contained in any beverage, mixture, mouthwash, candy,
food, preparation or medication.
Alcohol Concentration: Expressed in terms of grams of alcohol per 210 liters of
breath as indicated by a breath test under 49 CFR Part 40.
Aliquot: A fractional part of a specimen used for testing, It is taken as a sample
representing the whole specimen.
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PAGL:
Alternate specimen: An authorized specimen, other than the type of specimen
previously collected or attempted to be collected.
Canceled Test: A drug or alcohol test that has a problem identified that cannot be
or has not been corrected, or which is cancelled. A canceled test is neither positive
nor negative.
Collection Site: A place selected by the employer where employees present
themselves for the purpose of providing a specimen for a drug test.
Confirmatory Drug Test: A second analytical procedure performed on a different
aliquot of the original specimen to identify and quantify a specific drug or drug
metabolite.
Confirmatory Validity Test: A second test performed on a different aliquot of the
original urine specimen to further support a validity test result.
Covered Employee Under FTA Authority: An employee who performs a safety-
sensitive function including an applicant or transferee who is being considered for
hire into a safety-sensitive function (See Attachment A for a list of covered
employees).
Cutoff: The analytical value (e.g., drug or drug metabolite concentration) used as
the decision point to determine a result (e.g., negative, positive, adulterated,
invalid, or substituted) or the need for further testing.
Designated Employer Representative (DER): An employee authorized by the
employer to take immediate action to remove employees from safety-sensitive
duties and to make required decisions in testing. The DER also receives test
results and other communications for the employer, consistent with the
requirements of 49 CFR Parts 40 and 655.
DOT, The Department, DOT Agency: These terms encompass all DOT agencies,
including, but not limited to, the Federal Aviation Administration (FAA), the Federal
Railroad Administration (FRA), the Federal Motor Carrier Safety Administration
(FMCSA), the Federal Transit Administration (FTA), the National Highway Traffic
Safety Administration (NHTSA), the Pipeline and Hazardous Materials Safety
Administration (PHMSA), and the Office of the Secretary (OST). For purposes of
49 CFR Part 40, the United States Coast Guard (USCG), in the Department of
Homeland Security, is considered to be a DOT agency for drug testing purposes.
These terms include any designee of a DOT agency.
Dilute specimen: A urine specimen with creatinine and specific gravity values that
are lower than expected for human urine.
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Disabling damage: Damage which precludes departure of any vehicle from the
scene of the occurrence in its usual manner in daylight after simple repairs.
Disabling damage includes damage to vehicles that could have been operated but
would have been further damaged if so operated, but does not include damage
which can be remedied temporarily at the scene of the occurrence without special
tools or parts, tire disablement without other damage even if no spare tire is
available, or damage to headlights, taillights, turn signals, horn, or windshield
wipers that makes them inoperative,
Employee: Any person who is designated in a DOT agency regulation as subject
to drug testing and/or alcohol testing. The term includes individuals currently
performing safety-sensitive functions designated in DOT agency regulations and
applicants for employment subject to pre-employment testing. For purposes of
drug testing under 49 CFR Part 40, the term employee has the same meaning as
the term "donor" as found on CCF and related guidance materials produced by the
Department of Health and Human Services.
Evidential Breath Testing Device (EBT): A device approved by the NHTSA for the
evidential testing of breath at the 0.02 and the 0,04 alcohol concentrations, and
appears on ODAPC's Web page for "Approved Evidential Breath Measurement
Devices" because it conforms with the model specifications available from NHTSA.
Initial Drug Test: The first test used to differentiate a negative specimen from one
that requires further testing for drugs or drug metabolites.
Initial Specimen Validity Test: The first test used to determine if a specimen is
adulterated, diluted, substituted, or invalid
Invalid Result.' The result reported by an HHS-certified laboratory in accordance
with the criteria established by the HHS when a positive, negative, adulterated, or
substituted result cannot be established for a specific drug or specimen validity
test.
Laboratory.' Any U.S. laboratory certified by HHS under the National Laboratory
Certification Program as meeting the minimum standards of HHS; or, in the case
of foreign laboratories, a laboratory approved for participation by DOT under 49
CFR Part 40,
Limit of Detection (LOD): The lowest concentration at which the analyte (e.g., drug
or drug metabolite) can be identified.
Limit of Quantification (LOQ): For quantitative assays, the lowest concentration at
which the identity and concentration of the analyte (e.g., drug or drug metabolite)
can be accurately established.
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Medical Review Officer (MRO): A licensed physician (medical doctor or doctor of
osteopathy) responsible for receiving laboratory results generated by the drug
testing program who has knowledge of substance abuse disorders, and has
appropriate medical training to interpret and evaluate an individual's confirmed
positive test result, together with his/her medical history, and any other relevant
bio-medical information.
Negative Dilute: A drug test result which is negative for the five drug/drug
metabolites but has creatinine and specific gravity values that are lower than
expected for human urine.
Negative result: The result reported by an HHS-certified laboratory to an MRO
when a specimen contains•no drug or the concentration of the drug is less than the
cutoff concentration for the drug or drug class and the specimen is a valid
specimen. An alcohol concentration of less than 0.02 BAC is a negative test result.
Non-negative specimen: A specimen that is reported as adulterated, substituted,
positive (for drug(s) or drug metabolite(s)), or invalid.
Oral Fluid Specimen: A specimen that is collected from an employee's oral cavity
and is a combination of physiological fluids produced primarily by the salivary
glands. An oral fluid specimen is considered to be a direct observation collection
for all purposes of 49 CFR Part 40, as amended.
Oxidizing Adulterant: A substance that acts alone or in combination with other
substances to oxidize drugs or drug metabolites to prevent the detection of the
drug or metabolites, or affects the reagents in either the initial or confirmatory drug
test.
Performing (a safety-sensitive function): A covered employee is considered to be
performing a safety-sensitive function and includes any period in which he or she
is actually performing, ready to perform, or immediately available to perform such
functions.
Positive result: The result reported by an HHS- Certified laboratory when a
specimen contains a drug or drug metabolite equal or greater to the cutoff
concentrations.
Primary specimen: In drug.testing, the specimen bottle that is opened and tested
by a first laboratory to determine whether the employee has a drug or drug
metabolite in his or her system; and for the purpose of specimen validity
testing. The primary specimen is the portion of the donor's subdivided specimen
designated as the primary ("A") specimen by the collector to distihguish it from the
split ("B") specimen, as defined in 49 CFR Part 40, as amended.
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Prohibited drug: Identified as marijuana, cocaine, opioids, amphetamines, or
phencyclidine as specified in 49 CFR Part 40, as amended.
Reconfirmed: The result reported for a split (Bottle B) specimen when the second
HHS-certified laboratory corroborates the original result reported for the primary
(Bottle A) specimen.
Rejected for Testing: The result reported by an HHS- Certified laboratory when no
tests are performed for specimen because of a fatal flaw or a correctable flaw that
has not been corrected.
Revenue Service Vehicles: All transit vehicles that are used for passenger
transportation service.
Safety-sensitive functions: Employee duties identified as:
(1) The operation of a transit revenue service vehicle even when the vehicle
is not in revenue service.
(2) The operation of a non-revenue service vehicle by an employee when
the operation of such a vehicle requires the driver to hold a Commercial
Drivers License (CDL).
(3) Maintaining a revenue service vehicle or equipment used in revenue
service.
(4) Controlling dispatch or movement of a revenue service vehicle and
(5) Carrying a firearm for security purposes.
Specimen: Fluid, breath, or other material collected from an employee at the
collection site for the purpose of a drug or alcohol test.
Specimen Bottle: The bottle that, after being sealed and labeled according to the
procedures in 49 CFR Part 40, is used to hold a primary ("A") or split ("B") specimen
during the transportation to the laboratory. In the context of oral fluid testing, it may
be referred to as a "vial," "tube," or "bottle."
Split Specimen: In drug testing, the specimen that is sent to a first laboratory
and stored with its original seal intact, and which is transported to a second
laboratory for retesting at the employee's request following MRO verification of the
primary specimen as positive, adulterated or substituted.
Split specimen collection: A collection in which the single specimen collected is
divided into two separate specimen bottles, the primary specimen (Bottle A) and
the split specimen (Bottle B).
Substance Abuse Professional (SAP): A licensed physician (tedical doctor or
doctor of osteopathy) or licensed or certified psychologist, social worker, employee
assistance professional, state-licensed or certified marriage and family therapist,
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'AC3E:
or drug and alcohol counselor (certified by an organization listed at
https://www.transportation.goviodapc/sap) with knowledge of and clinical
experience in the diagnosis and treatment of drug and alcohol related disorders,
Substituted specimen; An employee's specimen not consistent with a normal
human specimen, as determined by HHS (e.g,, a urine specimen, with creatinine
and specific gravity values that are so diminished, or so divergent that they are not
consistent with normal human urine).
Test Refusal: The following are considered a refusal to test if the employee:
(1) Fail to appear for any test (except a pre-employment test) within a
reasonable time, as determined by the employer.
(2) Fail to remain at the collection site until the testing process is complete. An
employee who leaves the testing site before the testing process
commences for a pre-employment test has not refused to test.
(3) Fail to attempt to provide a specimen. An employee who does not provide
a specimen because he or she has left the testing site before the testing
process commenced for a pre-employment test has not refused to test,
(4) In the case of a directly-observed or monitored urine collection in a drug
test, fail to permit monitoring or observation of your provision of a specimen.
(5) Fail to provide a sufficient quantity of specimen without a valid medical
explanation.
(6) Fail or decline to take an additional test as directed by the collector or the
employer for drug testing.
(7) Fail to undergo a medical evaluation as required by the MRO or the
employer's Designated Employer Representative (DER).
(8) Fail to cooperate with any part of the testing process.
(9) Fail to folliow an observer's instructions to raise and lower clothing and turn
around during a directly-observed urine collection
(10) Possess or wear a prosthetic or other device used to tamper with the
collection process.
(11) Admit to the adulteration or substitution of a specimen to the collector or
MRO.
(12) Refuse to sign the certification at Step 2 of the Alcohol Testing Form
(ATF).
(13) Fail to remain readily available following an accident.
(14) As a covered employee, if the MRO reports that you have a verified
adulterated or substituted test result, you have refused to take a drug test.
Undiluted (neat) oral fluid: An oral fluid specimen to which no other solid or liquid
has been added. For example: A collection device that uses a diluent (or other
component, process, or method that modifies the volume of the testable specimen)
must collect at least 1 mL of undiluted (neat) oral fluid.
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Urine specimen: Urine collected from an employee at the collection site for the
purpose of a drug test.
Vehicle: A bus, electric bus, van, automobile, rail car, trolley car, trolley bus, or
vessel. A public transit vehicle is a vehicle used for public transportation or for
ancillary services.
Verified negative test: A drug test result reviewed by a medical review officer and
determined to have no evidence of prohibited drug use at or above the minimum
cutoff levels established by the Department of Health and Human Services (HHS).
Verified positive test: A drug test result reviewed by a medical review officer and
determined to have evidence of prohibited drug use at or above the minimum cutoff
levels specified in 49 CFR Part 40 as revised.
Validity testing: The evaluation of the specimen to determine if it is consistent with
normal human ine. Specimen validity testing will be conducted on all specimens
provided for testing under DOT authority. The purpose of validity testing is to
determine whether certain adulterants or foreign substances were added to the
specimen, if the specimen was diluted, or if the specimen was altered.
D. EDUCATION AND TRAINING
1) Every covered employee will receive a copy of this policy and will have
ready access to the corresponding federal regulations including 49 CFR
Parts 655 and 40, as amended. In addition, all covered employees will
undergo a minimum of 60 minutes of training on the signs and symptoms of
drug use including the effects and consequences of drug use on personal
health, safety, and the work environment. The training also includes
manifestations and behavioral cues that may indicate prohibited drug use.
2) All supervisory personnel or company officials who are in a position to
determine employee fitness for duty will receive 60 minutes of reasonable
suspicion training on the physical, behavioral, and performance indicators
of probable drug use and 60 minutes of additional reasonable suspicion
training on the physical, behavioral, speech, and performance indicators of
probable alcohol misuse.
E. PROHIBITED SUBSTANCES
1) Prohibited substances addressed by this policy include the following.
a. Illegalty Used Controlled Substance or Drugs Uncle)* the Drug-Free
Workplace Act of 1988 any drug or any substance identified in Schedule
I through V of Section 202 of the Controlled Substance Act (21 U.S.C.
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812), and as further defined by 21 CFR 1308.11 through 1308.15 is
prohibited at all, times in the workplace unless a legal prescription has
been written for the substance. This includes, but is not limited to:
marijuana, amphetamines, opioids, phencyclidine (PCP), and cocaine,
as well as any drug not approved for medical use by the U.S. Drug
Enforcement Administration or the U.S. Food and Drug Administration.
Illegal use includes use of any illegal drug, misuse of legally prescribed
drugs, and use of illegally obtained prescription drugs. It is important to
note that the use of marijuana in any circumstances remains completely
prohibited for any safety-sensitive employee subject to drug testing
under USDOT regulations. The use of marijuana in any circumstance
(including under state recreational and/or medical marijuana laws) by a
safety-sensitive employee is a violation of this policy and a violation of
the USDOT regulation 49 CFR Part 40, as amended.
Federal Transit Administration drug testing regulations (49 CFR Part
655) require that all employees covered under FTA authority be tested
for marijuana, cocaine, amphetamines, opioids, and phencyclidine as
described in this policy. Illegal use of these five drugs is prohibited at all
times and thus, covered employees may be tested for these drugs
anytime that they are on duty.
b. Legal Drugs: The appropriate use of legally prescribed drugs and non-
prescription medications is not prohibited. However, the use of any
substance which carries a warning label that indicates that mental
functioning, motor skills, or judgment may be adversely affected must
be reported to a Rose View Transit supervisor and the employee is
required to provide a written release from his/her doctor or pharmacist
indicating that the employee can perform his/her safety-sensitive
functions.
c. Alcohol: The use of beverages containing alcohol (including mouthwash,
medication, food, candy) or any other substances containing alcohol in
a manner which violates the conduct listed in this policy is prohibited.
F. PROHIBITED CONDUCT
1) Illegal use of the drugs listed in this policy and as defined in 49 CFR Part
40, as amended is prohibited at all times. All covered employees are
prohibited from reporting for duty or remaining on duty if they have used a
prohibited drug as defined in 49 CFR Part 40, as amended.
2) Each covered employee is prohibited from consuming alcohol while
performing safety-sensitive job functions or while on-call to perform safety-
sensitive)ob functions. If an on-call employee has consumed alcohol, they
Drug and Alcohol Testing Policy(Zero Tolerance- v.0623) Page 9
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must acknowledge the use of alcohol at the time that they are called to
report for duty. The covered employee will subsequently be relieved of
his/her on-call responsibilities and subject to discipline for not fulfilling
his/her on-call responsibilities.
3) The Transit DepartMent shall not permit any covered employee to perform
or continue to perform safety-sensitive functions if it has actual knowledge
that the employee is using alcohol
4) Each covered employee is prohibited from reporting to work or remaining
on duty requiring the performance of safety-sensitive functions while having
an alcohol concentration of 0.04 or greater regardless of when the alcohol
was consumed.
a. An employee with a breath alcohol concentration which measures
0.02-0.039 is not considered to have violated the USDOT-FTA drug
and alcohol regulations, provided the employee hasn't consumed the
alcohol within four (4) hours of performing a safety-sensitive duty.
However, if a safety-sensitive employee has a breath alcohol
concentration of 0,02-0.039, USDOT-FTA regulations require the
employee to be removed from the performance of safety-sensitive
duties until:
i. The employee's alcohol concentration measures less than
0.02; or
ii. The start of the employee's next regularly scheduled duty
period, but not less than eight hours following administration
of the test.
5) No covered employee shall consume alcohol for eight (8) hours following
involvement in an accident or until he/she submits to the post-accident
drug/alcohol test, whichever occurs first.
6) No covered employee shall consume alcohol within four (4) hours prior to
the performance of safety-sensitive job functions.
7) Rose View Transit, under its own authority, also prohibits the consumption
of alcohol at all times the employee is on duty, or anytime the employee is
in uniform.
8) Consistent with the Drug-free Workplace Act of 1988, all Rose View Transit
employees are prohibited from engaging in the unlawful manufacture,
distribution, dispensing, possession, or use of prohibited substances in the
work place including transit system premises and transit vehicles.
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G. DRUG STATUTE CONVICTION
Consistent with the Drug Free Workplace Act of 1998, all employees are required
to notify Rose View Transit management of any criminal drug statute conviction for
a violation occurring in the workplace within five days after such conviction. Failure
to comply with this provision shall resu t in disciplinary action as defined in this
policy.
H. TESTING REQUIREMENTS
1) Drug testing and alcohol testing will be conducted as required by 49 CFR
Part 40 as amended. All employees covered under FTA authority shall be
subject to testing prior to performing safety-sensitive duty, for reasonable
suspicion, following an accident, and random as defined in this policy, and
return to duty/follow-up.
2) A drug test can be performed any time a covered employee is on duty. A
reasonable suspicion, random, or follow-up alcohol test can only be
performed just before, during, or after the performance of a safety-sensitive
job function. Under Rose View Transit authority, a non-DOT alcohol test
can be performed any time a covered employee is on duty.
All covered employees will be subject to drug testing and alcohol testing as a
condition of ongoing employment with Rose View Transit. Any safety-sensitive
employee who refuses to comply with a request for testing shall be removed from
duty and subject to discipline as defined in this policy.
I. DRUG TESTING PROCEDURES
1) Testing shall be conducted in a manner to assure a high degree of accuracy
and reliability and using techniques, equipment, and laboratory facilities
which have been approved by the U.S. Department of Health and Human
Service (1-IHS). All testing will be conducted consistent with the procedures
set forth in 49 CFR Part 40, as amended. The procedures will be performed
in a private, confidential manner and every effort will be made to protect the
employee, the integrity of the drug testing procedure, and the validity of the
test result.
2) The drugs that will be tested for include marijuana, cocaine, opioids,
ampheta-nines, and phencyclidine. After the identity of the donor is
checked using picture identification, a urine and/or oral fluid specimen will
be collected as described in 49 CFR Part 40, as amended. Each specimen
will be accompanied by a DOT Custody and Control Form and identified
using a unique identification number that attributes the specimen to the
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correct individual. The specimen analysis will be conducted at a HHS
certified laboratory. An initial drug screen and validity test will be conducted
on the • imary specimen. For those specimens that are not negative, a
confirmatory test will be performed. The test will be considered positive if
the amounts of the drug(s) and/or its metabolites identified by the
confirmatory test are at or above the minimum thresholds established in 49
CFR Part 40, as amended.
3) The test results from the HHS certified laboratory will be reported to a
Medical Review Officer. A Medical Review Officer (MRO) is a licensed
physician with detailed knowledge of substance abuse disorders and drug
testing. The MRO will review the test results to ensure the scientific validity
of the test and to determine whether there is a legitimate medical
explanation for a confirmed positive, substitute, or adulterated test result.
The MRO will attempt to contact the employee to notify the employee of the
non-negative laboratory result, and provide the employee with an
opporturity to explain the confirmed laboratory test result. The MRO will
subsequently review the employee's medical history/medical records as
appropriate to determine whether there is a legitimate medical explanation
for a non-negative laboratory result. If no legitimate medical explanation is
found, the test will be verified positive or refusal to test and reported to Rose
View Transit. If a legitimate explanation is found, the MRO will report the
test result as negative.
4) If the test is invalid without a medical explanation, a retest will be conducted
under direct observation. Employees do not have access to a test of their
split specimen following an invalid result.
5) Any covered employee who questions the results of a required drug test
may request that the split sample be tested. The split sample test must be
conducted at a second HHS-certified laboratory. The test must be
conducted on the split sample that was provided by the employee at the
same time as the primary sample. The method of collecting, storing, and
testing the split sample will be consistent with the procedures set forth in 49
CFR Part 40, as amended. The employee's request for a split sample test
must be made to the Medical Review Officer within 72 hours of notice of the
original sample verified test result. Requests after 72 hours will only be
accepted at the discretion of the MRO if the delay was due to documentable
facts that were beyond the control of the employee. Rose View Transit will
ensure that the cost for the split specimen analysis is covered in order for a
timely analysis of the sample, however Rose View Transit will seek
reimbursement for the split sample test from the employee.
6) If the analysis of the split specimen fails to eonfirm the presence of the
drug(s) detected in the primary specimen, if the split specimen is not able
Drug and Alcohol Testing Policy (Zero Tolerance - v.0623) Page 12
to be analyzed, or if the results of the split specimen are not scientifically
adequate, the MRO will declare the original test to be canceled,
7) Observed collections
a. Consistent with 49 CFR Part 40, as amended, collection under direct
observation with no advance notice will occur if:
i. The laboratory reports to the MRO that a specimen is invalid,
and the MRO reports to Rose View Transit that there was not
an adequate medical explanation for the result;
The MRO reports to Rose View Transit that the original
positive, adulterated, or substituted test result had to be
cancelled because the test of the split specimen could not be
performed;
iii, The laboratory reported to the MRO that the urine specimen
was negative-dilute with a creatinine concentration greater
than or equal to 2 mg/dL but less than or equal to 5 mg/dL,
and the MRO reported the urine specimen as negative-dilute
and that a second collection must take place under direct
observation (see §40,197(b)(1)).
iv. The collector observes materials brought to the collection site
or the employee's conduct clearly indicates an attempt to
tamper with a specimen;
v. The temperature on the original urine specimen was out of
range (See §40.65(b)(5));
vi. Anytime the employee is directed to provide another
specimen because the original specimen appeared to have
been tampered with (See §40.65(c)(1)).
vii. All follow-up-tests; or
viii. All return-to-duty tests
Urine collections that are required to be directly observed will be conducted
by a person of the same gender as the donor as required, by 49 CFR Part
40.67.
Drug and Alcohol Testing Policy(Zero Tolerance - v.0623) Page 13
A3
J. ALCOHOL TESTING PROCEDURES
1) Tests for breath alcohol concentration will be conducted utilizing a National
Highway Traffic Safety Administration (NHTSA)-approved Evidential Breath
Testing device (EBT) operated by a trained Breath Alcohol Technician
(BAT). A list of approved EBTs can be found on ODAPC's Web page for
"Approved Evidential Breath Measurement Devices". Alcohol screening
tests may be performed using a non-evidential testing device (alcohol
screening device (ASD)) which is also approved by NHTSA. A list of
approved ASDs can be found on ODAPC's Web page for "Approved
Screening Devices to Measure Alcohol in Bodily Fluids". If the initial test
indicates an alcohol concentration of 0.02 or greater, a second test will be
performed to confirm the results of the initial test. The confirmatory test
must occur on an EBT. The confirmatory test will be conducted no sooner
than fifteen minutes after the completion of the initial test. The confirmatory
test will be performed using a NHTSA-approved EBT operated by a trained
BAT. The EBT will identify each test by a unique sequential identification
number. This number, time, and unit identifier will be provided on each EBT
printout. The EBT printout, along with an approved alcohol testing form, will
be used to document the test, the subsequent results, and to attribute the
test to the correct employee. The test will be performed in a private,
confidential manner as required by 49 CFR Part 40, as amended. The
procedure will be followed as prescribed to protect the employee and to
maintain the integrity of the alcohol testing procedures and validity of the
test result.
2) A confimied alcohol concentration of 0.04 or greater will be considered a
positive alcohol test and in violation of this policy. The consequences of a
positive alcohol test are described in this policy. Even though an employee
who has a confirmed alcohol concentration of 0.02 to 0.039 is not
considered positive, the employee shall still be removed from duty for at
least eight hours or for the duration of the work day whichever is longer and
will be subject to the consequences described in this policy. An alcohol
concentration of less than 0.02 will be considered a negative test.
3) Rose View Transit affirms the need to protect individual dignity, privacy, and
confidentiality throughout the testing process. If at any time the integrity of
the testing procedures or the validity of the test results is compromised, the
test will be canceled. Minor inconsistencies or procedural flaws that do not
impact the test result will not result in a cancelled test.
4) The alcohol testing form (ATF) required by 49 CFR Part 40 as amended,
shall be used for all FTA required testing. Failure of an employee to sign
step 2 of the ATF will be considered a refusal to submit to testing.
Drug and Alcohol Testing Policy (Zero Tolerance - v.0623) Page 14
pi.,)01011
K. PRE-EMPLOYMENT TESTING
1) All applicants for covered transit positions shall undergo drug testing prior
to performance of a safety-sensitive function.
a. All offers of employment for covered positions shall be extended
conditional upon the applicant passing a drug test. An applicant will
not be allowed to perform safety-sensitive functions unless the
applicant takes a drug test with verified negative results.
b. An employee shall not be placed, transferred or promoted into a
position covered under FTA authority or company authority until the
employee takes a drug test with verified negative results,
c. If an applicant fails a pre-employment drug test, the conditional offer
of employment shall be rescinded and the applicant will be provided
with a list of at least two (2) USDOT qualified Substance Abuse
Professionals, Failure of a pre-employment drug test will disqualify
an applicant for employment for a period of at least one year. Before
being considered for future employment the applicant must provide
the employer proof of having successfully completed a referral,
evaluation and treatment plan as described in section 655.62 of
subpart G. The cost for the assessment and any subsequent
treatment will be the sole responsibility of the applicant.
d. When an employee being placed, transferred, or promoted from a
non-covered position to a position covered under FTA authority or
company authority submits a drug test with a verified positive result,
the employee shall be subject to disciplinary action in accordance
with this policy.
e. If a pre-employment test is canceled, Rose View Transit will require
the applicant to take and pass another pre-employment drug test.
f. In instances where a FTA covered employee does not perform a
safety-sensitive function for a period of 90 consecutive days or more
regardless of reason, and during that period is not in the random
testing pool the employee will be required to take a pre-employment
drug test under 49 CFR Part 655 and have negative test results prior
to the conduct of safety-sensitive job functions.
g. Following a negative dilute the employee will be required to undergo
another test. Should this second test result in a negative dilute result,
Drug and Alcohol Testing Policy(Zero Tolerance- v.0623) Page 15
:.A,W11 PAGL:
the test will be considered a negative and no additional testing will
be required unless directed to do so by the MRO.
h. Applicants are required (even if ultimately not hired) to provide with
signed written releases requesting USDOT drug and alcohol records
from all previous, USDOT-covered, employers that the applicant has
worked for within the last two years. Failure to do so will result in the
employment offer being rescinded. Rose View Transit is required to
ask all applicants (even if ultimately not hired) if they have tested
positive or refused to test on a pre-employment test for a USDOT
covered employer within the last two years. If the applicant has
tested positive or refused to test on a pre-employment test for a
USDOT covered employer, the applicant must provide Rose View
Transit proof of having successfully completed a referral, evaluation
and treatment plan as described in section 655.62 of subpart G.
L. REASONABLE SUSPICION TESTING
1) All Rose View Transit FTA covered employees will be subject to a
reasonable suspicion drug and/or alcohol test when the employer has
reasonable suspicion to believe that the covered employee has used a
prohibited drug and/or engaged in alcohol misuse. Reasonable suspicion
shall mean that there is objective evidence, based upon specific,
contemporaneous, articulable observations of the employee's appearance,
behavior, speech or body odor that are consistent with possible drug use
and/or al co hol misuse. Reasonable suspicion referrals must be made by
one or more supervisors who are trained to detect the signs and symptoms
of drug and alcohol use, and who reasonably concludes that an employee
may be adversely affected or impaired in his/her work performance due to
possible prohibited substance abuse or alcohol misuse. A reasonable
suspicion alcohol test can only be conducted just before, during, or just after
the performance of a safety-sensitive job function. However, under FTA
authority, a non-DOT reasonable suspicion alcohol test may be performed
any time the covered employee is on duty. A reasonable suspicion drug
test can be performed any time the covered employee is on duty.
2) Rose View Transit shall be responsible for transporting the employee to the
testing site. Supervisors should avoid placing themselves and/or others into
a situation which might endanger the physical safety of those present. The
employee shall be placed on administrative leave pending disciplinary
action described in,this policy. An employee who refuses an instruction to
submit to a drug/alcohol test shall not be permitted to finish his or her shift
and shall immediately be placed on administrative leave , pending
disciplinary action as specified in this policy.
Drug and Alcohol Testing Policy (Zero Tolerance- v.0623) Page 16
3) A written record of the observations which led to a drug/alcohol test based
on reasonable suspicion shall be prepared and signed by the supervisor
making the observation. This written record shall be submitted to Rose
View Transit.
4) When there are no pecific, contemporaneous, articulable objective facts
that indicate current drug or alcohol use, but the employee (who is not
already a participant in a treatment program) admits the abuse of alcohol or
other substances to a supervisor in his/her chain of command, the
employee shall be referred for assessment and treatment consistent with
this policy, Rose View Transit shall place the employee on administrative
leave in accordance with the provisions set forth under this policy. Testing
in this circumstance would be performed under the direct authority of the
Rose View Transit. Since the employee self-referred to management,
testing under this circumstance would not be considered a violation
of this policy or a positive test result under Federal authority.
However, self-referral does not exempt the covered employee from testing
under Federal authority as specified in this policy or the associated
consequences.
M. POST-ACCIDENT TESTING
1) FATAL ACCIDENTS—A covered employee will be required to undergo drug
and alcohol testing if they are involved in an accident with a transit vehicle,
whether or not the vehicle is in revenue service at the time of the accident,
that results in a fatality. This includes all surviving covered employees that
are operating the vehicle at the time of the accident and any other whose
performance could have contributed to the accident, as determined by the
employer using the best information available at the time of the decision.
2) NON-FATAL ACCIDENTS—A post-accident test of the employee operating
the public transportation vehicle will be conducted if an accident occurs and
at least one of the following conditions is met:
a. The accident results in injuries requiring immediate medical
treatment away from the scene, unless the covered employee can
be completely discounted as a contributing factor to the accident.
b. One or more vehicles incurs disabling damage as a result of the
occurrence and must be transported away from the scene, unless
the covered employee can be completely discounted as a
contributing factor to the accident
Drug and Alcohol Testing Policy(Zero Tolerance - v.0623) Page 17
•
In addition, any other covered employee whose performance could have
contributed to the accident, as determined by the employer using the best
information available at the time of the decision, will be tested.
As soon as practicable following an accident, as defined in this policy, the transit
supervisor investigating the accident will notify the transit employee operating
the transit vehicle and all other covered employees whose performance could
have contributed to the accident of the need for the test. The supervisor will
make the determination using the best information available at the time of the
decision.
The appropriate transit supervisor shall ensure that an employee, required to be
tested under this section, is tested as soon as practicable, but no longer than
eight (8) hours of the accident for alcohol, and no longer than 32 hours for drugs.
If an alcohol test is not performed within two hours of the accident, the Supervisor
will docum the reason(s) for the delay. If the alcohol test is not conducted
within (8) eight hours, or the drug test within 32 hours, attempts to conduct the
test must cease and the reasons for the failure to test documented.
Any covered employee involved in an accident must refrain from alcohol use for
eight (8) hours following the accident, or until he/she undergoes a post-accident
alcohol test.
An employee who is subject to post-accident testing who fails to remain readily
available for such testing, including notifying a supervisor of his or her location if
he or she leaves the scene of the accident prior to submission to such test, may
be deemed to have refused to submit to testing.
Nothing in this section shall be construed to require the delay of necessary
medical attention for the injured following an accident, or to prohibit an employee
from leaving the scene of an accident for the period necessary to obtain
assistance in responding to the accident, or to obtain necessary emergency
medical care.
In the rare event that Rose View Transit is unable to perform an FTA drug and
alcohol test (i.e., employee is unconscious, employee is detained by law
enforcement agency), Rose View Transit may use drug and alcohol post-
accident test results administered by local law enforcement officials in lieu of the
FTA test. The local law enforcement officials must have independent authority
for the test and the employer must obtain the results in conformance with local
law.
N. RANDOM TESTING
Drug and Alcohol Testing Policy(Zero Tolerance - v.0623) Page 18
1)::kifi3rf çy (Th2-1'
1) All covered employees will be subjected to random, unannounced testing.
The selection of employees shall be made by a scientifically valid method
of rando y generating an employee identifier from the appropriate pool of
safety-sensitive employees. Individuals who may be covered under
company authority will be selected from a pool of non-DOT-covered
individuals.
2) The dates for administering unannounced testing of randomly selected
employees shall be spread reasonably throughout the calendar year, day
of the week and hours of the day.
3) The number of employees randomly selected for drug/alcohol testing during
the calendar year shall be not less than the percentage rates set each year
by the FTA administrator. The current year testing rates can be viewed
online at Ittps://www.transportation.gov/odapc/random-testing-rates.
4) Each covered employee shall be in a pool from which the random selection
is made. Each covered employee in the pool shall have an equal chance
of selection each time the selections are made. Employees will remain in
the pool and subject to selection, whether or not the employee has been
previously tested. There is no discretion on the part of management in the
selection.
5) Covered transit employees that fall under the Federal Transit Administration
regulations will be included in one random pool maintained separately from
the testing pool of non-safety-sensitive employees that are included solely
under Rose View Transit authority.
6) Random tests can be conducted at any time during an employee's shift for
drug testing. Alcohol random tests can only be performed just before,
during, or just after the performance of a safety sensitive duty. However,
under Rose View Transit authority, a non-DOT random alcohol test may be
performed any time the covered employee is on duty. Testing can occur
during the beginning, middle, or end of an employee's shift.
7) Employees are required to proceed immediately to the collection site upon
notification of their random selection.
O. RETURN-TO-DUTY TESTING
Rose View Transit will terminate the employment of any employee that tests
positive or refuses a test as specified in this policy. However, in the rare event an
employee is reinstated with court order or other action beyond the control of the
transit system, the employee must complete the return-to-duty process prior to the
Drug and Alcohol Testing Policy(Zero Tolerance - v.0623) Page 19
OF31.
"
performance of safety-sensitive functions. All covered employees who previously
tested positive on a drug or alcohol test or refused a test, must test negative for
drugs, alcohol (below 0.02 for alcohol), or both and be evaluated and released by
the Substance Abuse Professional before returning to work. Following the initial
assessment, the SAP will recommend a course of rehabilitation unique to the
individual. The SAP will recommend the return-to-duty test only when the
employee has successfully completed the treatment requirement and is known to
be drug and alcohol-free and there are no undue concerns for public safety. The
SAP will determine whether the employee returning to duty will require a return-to-
duty drug test, alcohol test, or both.
P. FOLLOW-UP TESTING
Covered employees that have returned to duty following a positive or refused test
will be required to undergo frequent, unannounced drug and/or alcohol testing
following their return-to-duty test. The follow-up testing will be performed for a
period of one to five years with a minimum of six tests to be performed the first
year. The frequency and duration of the follow-up tests (beyond the minimums)
will be determined by the SAP reflecting the SAP's assessment of the employee's
unique situation and recovery progress. Follow-up testing should be frequent
enough to deter and/or detect a relapse. Follow-up testing is separate and in
addition to the random, post-accident, reasonable suspicion and return-to-duty
testing.
In the instance of a self-referral or a management referral, the employee will be
subject to non-USDOT follow-up tests and follow-up testing plans modeled using
the process described in 49 CFR Part 40. However, all non-USDOT follow-up tests
and all paperwork associated with an employee's return-to-work agreement that
was not precipitated by a positive test result (or refusal to test) does not constitute
a violation of the Federal regulations will be conducted under company authority
and will be performed using non-DOT testing forms.
Q. RESULT OF DRUG/ALCOHOL TEST
1) Any covered employee that has a verified positive drug or alcohol test, or
test refusal, will be immediately removed from his/her safety-sensitive
position, informed of educational and rehabilitation programs available, and
will be provided with a list of at least two (2) USDOT qualified Substance
Abuse Professionals (SAP) for assessment, and will be terminated.
2) Following a negative dilute the employee will be reqUired to undergo
another test. Should this second test result in a negative dilute result, the
Drug and Alcohol Testing Policy(Zero Tolerance- v.0623) Page 20
•,
"La t
test will be considered a negative and no additional testing will be required
unless directed to do so by the MRO.
3) Refusal to submit to a drug/alcohol test shall be considered equivalent to a
positive test result and a direct act of insubordination and shall result in,
termination and referral to a list of USDOT qualified SAPs. A test refusal is
defined as any of the following circumstances:
a. Fail to appear for any test (except a pre-employment test) within a
reasonable time, as determined by the employer.
b. Fail to remain at the collection site until the testing process is
complete. An employee who leaves the testing site before the testing
process commences for a pre-employment test has not refused to
test.
c. F.41 to attempt to provide a specimen. An employee who does not
provide a specimen because he or she has left the testing site before
the testing process commenced for a pre-employment test has not
refused to test.
d. In the case of a directly-observed or monitored urine collection in a
drug test, fail to permit monitoring or observation of your provision of
a specimen.
e. Fail to provide a sufficient quantity of specimen without a valid
medical explanation.
f. Fail or decline to take an additional test as directed by the collector
or the employer for drug testing.
g. Fail to undergo a medical evaluation as required by the MRO or the
employer's Designated Employer Representative (DER).
h. Fail to cooperate with any part of the testing process.
I. F.:I to follow an observer's instructions to raise and lower clothing
and turn around during a directly-observed urine collection.
j. Possess or wear a prosthetic or other device used to tamper with the
collection process.
k. Admit to the adulteration or substitution of a specimen to the collector
or MRO.
I. Refuse to sign the certification at Step 2 of the Alcohol Testing Form
(ATF).
m. Fail to remain readily available following an accident.
n. As a covered employee, if the MRO reports that you have a verified
adulterated or substituted test result, you have refused to take a drug
test
4) An alcohol test result of .0.02 to 5_ 0.039 BAC shall result in the removal of
the employee from duty for eight hours or the remainder or the work day
whichever is longer. The employee will not be allowed to return to safety-
sensitive duty for his/her next shift until he/she submits to a NONDOT
alcohol test with a result of less than 0.02 BAC.
Drug and Alcohol Testing Policy(Zero Tolerance - v.0623) Page 21
Hi
R
5) In the instance of a self-referral or a management referral, disciplinary
action against the employee shall include:
a. Mandatory referral for an assessment by an employer approved
counseling Professional for assessment, formulation of a treatment
plan, and execution of a return-to-work agreement
b. Failure to execute, or remain compliant with the return-to-work
agreement shall result in termination from Rose View Transit
employment.
i. Compliance with the return-to-work agreement means that the
employee has submitted to a drug/alcohol test immediately
prior to returning to work; the result of that test is negative; the
employee is cooperating with his/her recommended treatment
program; and, the employee has agreed to periodic
unannounced follow-up testing as described in this policy;
however, all follow-up testing performed as part of a return-to-
work agreement required under this policy is under the sole
authority of Rose View Transit and will be performed using
non-DOT testing forms.
c. Refusal to submit to a periodic unannounced follow-up drug/alcohol
test shall be considered a direct act of insubordination and shall
result in termination. All tests conducted as part of the return-to-
work agreement will be conducted under company authority
and will be performed using non-DOT testing forms.
d. A self-referral or management referral to the employer's
counseling professional that was not precipitated by a positive
test result does not constitute a violation of the Federal
regulations and will not be considered as a positive test result
in relation to the progressive discipline defined in this policy.
e. Periodic unannounced follow-up drug/alcohol testing conducted as a
result of a self-referral or management referral which results in a
verified positive shall be considered a positive test result in relation
to the progressive discipline defined in this policy.
f. A Voluntary Referral does not shield an employee from disciplinary
action or guarantee employment with Rose View Transit.
g. A Voluntary Referral does not shield an employee from the
requirement to comply with drug and alcohol testing,
6) Failure of an employee to report within five days a criminal drug statute
conviction for a violation occurring in the workplace shall result in
termination.
R. GRIEVANCE AND APPEAL
Drug and Alcohol Testing Policy(Zero Tolerance- v.0623) Page 22
The consequences specified by 49 CFR Part 40.149 (c) for a positive test or test
refusal is not subject to arbitration.
S. PROPER APPLICATION OF THE POLICY
Rose View Transit is dedicated to assuring fair and equitable application of this
substance abuse policy. Therefore, supervisors/managers are required to use and
apply all aspects of this policy in an unbiased and impartial manner. Any
supervisor/martager who knowingly disregards the requirements of this policy, or
who is found to deliberately misuse the policy in regard to subordinates, shall be
subject to disciplinary action, up to and including termination.
T. INFORMATION DISCLOSURE
1) Drug/alcohol testing records shall be maintained by the Rose View Transit
Drug and Alcohol Program Manager and, except as provided below or by
law, the results of any drug/alcohol test shall not be disclosed without
express written consent of the tested employee.
2) The employee, upon written request, is entitled to obtain copies of any
records pertaining to their use of prohibited drugs or misuse of alcohol
includin any drug or alcohol testing records. Covered employees have the
right to gain access to any pertinent records such as equipment calibration
records, and records of laboratory certifications. Employees may not have
access to SAP follow-up testing plans.
3) Records of a verified positive drug/alcohol test result shall be released to
the Drug and Alcohol Program Manager, and other transit system
management personnel on a need-to-know basis,
4) Records will be released to a subsequent employer only upon receipt of a
written request from the employee.
5) Records of an erriployee's drug/alcohol tests shall be released to the
adjudicator in a grievance, lawsuit, or other proceeding initiated by or on
behalf of the tested individual arising from the results of the drug/alcohol
test. The records will be released to the decision maker in the proceeding.
6) Records will be released to the National Transportation Safety Board during
an accident investigation.
7) Information will be released in a criminal or civil action resulting from an
employee's performance of safety-sensitive duties, in which a court of
Drug and Alcohol Testing Policy(Zero Tolerance- v.0623) Page 23
;:'',''c3L1
competent jurisdiction determines that the drug or alcohol test information
is relevant to the case and issues an order to the employer to release the
information. The employer will release the information to the decision
maker in the proceeding with a binding stipulation that it will only be
released to parties of the proceeding.
8) Records will be released to the DOT or any DOT agency with regulatory
authority over the employer or any of its employees.
9) Records will be released if requested by a Federal, state or local safety
agency with regulatory authority over Rose View Transit or the employee.
10)1f a party seeks a court order to release a specimen or part of a specimen
contrary to any provision of Part 40 as amended, necessary legal steps to
contest t e issuance of the order will be taken
11)In cases of a contractor or sub-recipient of a state department of
transportation, records will be released when requested by such agencies
that must certify compliance with the regulation to the FTA.
Drug and Alcohol Testing Policy(Zero Tolerance- v.0623) Page 24
)rr
1 IP
This Policy was adopted by the Board of Public Works & Safety on
2023.
[APPLICABLE SIGNATURES]
Drug and Alcohol Testing Policy (Zero Tolerance- v.0623) Page 25
.
Attachment A
Job Title Job Quties Testing Authority
Fixed Route Bus Driver Drives on a time-schedule FTA
Paratransit Driver Drives Demand-Response Safety Sensitive
Dispatcher Dispatches Demand Response Safety Sensitive
Fleet Maintenance Fuels/Details Fleet Safety Sensitive
Drug and Alcohol Testing Policy(Zero Tolerance- v.0421) Page 26
S .
Attachment B Contacts
Any questions regarding this policy or any other aspect of the substance abuse
policy should be directed to the following individual(s).
Druq and Alcohol Program Manager
Name:Terri Quinter
Title: Manager
Address: 401 South "Q" St. Richmond, IN 47374
Telephone Number: 765-983-7227
Medical Review Officer
Name:Richard Weinstein .
Title: Medical Review Officer
Address 2800 Black LK PI.Ste A Philadelphia, PA 19154
Telephone Number: 800-624-3784
Substance Abuse Professional #1
Name:Mary Brown
Title: Substance Abuse Professional
Address: 4130 Linden Ave. Suite 390 Dayton, OH45432
Telephone Number: 937-258-1638
Substance Abuse Professional #2
Name:Kathleen Bowers
Title: Substance Abuse Professional
Address: 275 Medical Dr. Suite 1, Anderson, IN 46082
Telephone Number:
HHS Certified Laboratory Primary Specimen
Name: Baptist Medical Center
Address: 11401-1-30, Little Rock, AR 72209-7056
Telephone Number: 501-202-7590
Drug and Alcohol Testing Policy(Zero Tolerance- v.0421) Page 27
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