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Nuclear Regulatory Commission Publishes Revision of the NRC Enforcement Policy
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| On October, 31, 2002, the Nuclear Regulatory Commission (NRC) published a revision to its General Statement of Policy and Procedure for NRC Enforcement Actions (NUREG-1600) to include an interim enforcement policy regarding enforcement discretion for certain fitness-for-duty issues. These include suitable inquiry practices (including drug and alcohol testing information) and pre-access drug and alcohol testing. The revision is effective December 30, 2002, while comments are being received and comments must be submitted by December 2, 2002. Read an analysis of the revision. |
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Question & Answer: Excerpts from the DOT Forum
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Question: My MRO and I report negative results electronically. Our software generates a signed report that is DOT-approved (so we have been told). Results are sent via e-mail and fax. If results are sent by these methods so that an employer has a signed-hardcopy, is a signed hard-copy of the original COC necessary as well? If not, must the original COC be signed at all if kept alongside with the lab report? Can an original be signed long periods after results have been reported (e.g. I find out I need to have all original COCs signed, and sign all of them from the past two years... tomorrow-hypothetically speaking only)? Any help is greatly appreciated, as I would like to avoid having to sign thousands of COC's someday in the future.
Answer: According to the DOT regulations, the original MUST be signed, initialed, or stamped. Staff under the direct, personal supervision of the MRO can do this, however. The regulations in §40.1027 indicate that this must be completed prior to releasing the result to the employer.
§40.127 (e) states "On copy 2 of the CCF, place a check mark in the negative box (step 6), provide your name, and sign, initial, or stamp and date the verification statement."
§40.163 (e) states "You must retain a signed or stamped and dated copy of copy 2 of the CCF in your records. If you do not use copy 2 for reporting results, you must maintain a copy of the signed or stamped and dated letter in addition to the signed or stamped and dated copy 2. If you use the electronic date file to report negatives, you must maintain a retrievable copy of that report in a format suitable for inspection and auditing by a DOT representative."
Read other DATIA questions and answers.
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Mark Your Calendar
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January 31, 2003 is fast approaching! Make sure you receive your required specimen collector qualification training and perform your required proficiency demonstrations before the DOT’s deadline.
Register for a DATIA Certified Professional Collector Trainer™ (CPCT) course today. At the same time, you can register for the valuable Secrets to Successful Drug and Alcohol Testing Program Management course.
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