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DATIA Submits Comments to Federal Railroad Administration
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Earlier today, DATIA submitted comments in reference to the December 10, 2002 Notice Inviting Comment concerning application of the Federal Railroad Administration (FRA) drug and alcohol testing regulations to employees of foreign railroads who are based outside of the United States and perform train or dispatch services in the United States. These comments were based on input from DATIA’s Legislative and Regulatory Committee and DATIA’s Board of Directors. Read the full comments.
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Question & Answer: Excerpts from the DATIA Forum
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Question: Is it necessary to keep a manual handwritten log of every test number used on the EBT in addition to a copy of the Alcohol Testing Form? If not, is it necessary to record only the test numbers that may be invalid, insufficient breath, etc.? During an audit will the DOT want an account of every test number? We have several satellite offices from our clinic that all have EBTs. Is it necessary to keep all the collector copies of the ATF in the same physical location as the EBT? We enter all the information on our database and it would easier to keep the copies at our main location.
Answer: It is not necessary to keep a log of alcohol tests performed. The logbook requirement was eliminated by DOT in May of 1995. Many collection sites continue to maintain test logs for their own records, but it is not required by Part 40 or by any operating agency regulation, to my knowledge. Check out 49 CFR Part 40.349 (e) for the answer to your record-keeping question. "You must ensure that you can make available to the employer within two business days any information the employer is asked to produce by a DOT agency representative." I take this to mean that you can keep the records wherever you wish as long as they are confidential and can be provided to a DOT auditor within 2 business days. I hope this information is helpful.
Read other DATIA questions and answers.
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Mark Your Calendar
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The deadline for many DOT training requirements expired on January 31,2003. Have you met the DOT required specimen collector qualification training and proficiency demonstrations?”
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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