August 22, 2003
Docket Management System
U.S. Department of Transportation
Room Plaza 401
400 7th Street, SW
Washington, DC 20590
FRA 2001-11068 Notice No. 4
This is to submit comments in support of the July 28, 2003 proposed rule 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.
The Drug and Alcohol Testing Industry Association (DATIA) is an 1,100-member national trade association representing the full spectrum of drug and alcohol testing service agents including laboratories, collection sites, C/TPAs, BATs, MROs, SAPs, mandated employers, and testing device manufacturers. DATIA’s mission includes working closely with key policy makers in Federal Agencies and in Congress to ensure that the interests of the industry are heard and taken into account when changes in drug and alcohol testing rules are proposed. In response to the FRA’s proposed rule, DATIA offers the following comments on behalf of its members.
DATIA members understand the delicate situation that the FRA is dealing with to develop guidelines for employees domiciled in a foreign country. We believe, however, that the FRA has successfully balanced the need for safety on American railroads and the need to respect the policies of foreign countries. Specifically, the ability of foreign railroads to remove employees that test positive from service in the US, but not requiring them to follow the Department of Transportation (DOT) return to duty process addresses the concerns of all countries.
DATIA appreciates this opportunity to comment on the proposed rule changes being considered by the FRA. Should you seek further clarification or have any questions concerning DATIA’s comments, please feel free to contact me at 703-548-0901 or info@datia.org.
Sincerely,
Laura E. Shelton
Executive Director
