Tips, Innovations & Best Practices For DAPM’s

The Greatest Test Laboratory  Innovations and best practices are rarely invented from thin air  The industry produces thousands of tests per day; each has potential to indicate areas of improvement locally  This presentation will share the best examples of innovation and best-practices that the FTA has found

Change  Some fundamental approaches should change very little  Most practices should be regularly evaluated for efficacy and efficiency  Learn from others

Policy The Blueprint, The Rulebook

Policy  Accept that it is a changing document  Don’t fear revision  Prepare your governing body early  Read through carefully after changes  Consult peers or FTA

Pre-Employment The Gatekeeper

Pre-Employment  Review the process for holes  Genuine start-to-finish analysis

Pre-Employment  Ensure that all stakeholders involved understand the requirements  Adds a safety-net  May illuminate other problems

Pre-Employment  Build in a safety measure  Clearance form or card  Signature sheet  Identify a single employee and assign final responsibility

Pre-Employment  Save the result  Start the 1-year clock after the employee leaves the company

Pre-Employment  Add/Remove/Return the employee to/from the random testing pool promptly  Keep a note or calendar reminder of date

Pre-Employment  Remember: Out of safety-sensitive duties for 90+ days and  Removed from the random testing pool for 90+ days FTA Pre-employment test is required (FTA test not allowed if both conditions not met)

Random The Foundation

Random  Make sure your random program is random  Re-evaluate the selection process  If TPA used, ask to specifically describe/walk you through the process  Check the updates of the pool

Random  Decide on a selection period that makes sense for you  Quarterly is the minimum frequency; no maximum  Consider advantages/disadvantages of consortium  Consider customizing your selection intervals

Random  Receipt of the Selection List  Decide when you want it transmitted/received  Decide the transmission method - , fax, letter, etc.

Random  Understand your selection pool  Are there procedural or structural limitations?  What are the vulnerabilities? -Often, the problems arise simply from employees “falling through the cracks”

Random  Understand your selection pool  Can it be improved by using other databases? -Payroll -Scheduling -Benefits Or, can it improved by separating from those databases?

Random  Understand the requirements of your TPA  Update timing (your internal capabilities)  Selection list timing  Pre-selection roster deadlines (their capabilities)  Do you control the database they use? (auto- upload from company?)

Randoms, Part 2: Random Spread Detection & Deterrence

Establish your Distribution Goal Total safety-sensitive employees -multiplied by- Desired testing rate (must meet minimum) -divided by- Number of selections per year -equals- Number of tests to spread throughout each period

1.Total safety-sensitive employees…………………….____________ -multiplied by- 2. Desired testing rate (25%, 30%, 50%, etc.)……….. ____________ 3. Equals…(Desired number of randoms per year).…. ___________ 4. Desired number of randoms per year…………___________ -divided by- 5. Number of selections per year……………….…___________ 6. Equals: Randoms to be spread throughout each selection period……..………. __________

Now that you have the number: How will it look operationally?

Anticipate Problem Areas

Connecticut Consortium Solution Q1 Q2 Q3 Q4 “Holiday Selection”

Random Spread  What times of the day have you never tested?  What days of the week have you never tested?  Scenario: If you were trying to predict/avoid a random test, how would you do it?

Post-Accident Making the Decision

Post Accident Decision Making  Have a post-accident decision-making form that contains:  Date and time of the accident  Whether or not any of the criteria were met  A YES or NO answer as to whether employees can be completely discounted as contributing factors to the accident

Post Accident Decision Making  The form should also contain areas for noting:  Time employee was sent to the collection site  Released from the scene  The reason for delays in testing (2+ hours between accident time and alcohol test)  The reason an employee was not tested after it was deemed necessary (medical attention, police custody, etc.)

Post Accident Decision Making  Call the collection site as soon as possible to notify that a post-accident test is needed / employee is en route

Vendor Issues Collection Site, MRO & TPA

 Long wait-times at collection site?  Shift to appointments  Offer incentive for immediacy  Ask for preferential treatment based on jurisdiction  Request on-site testing (shifts the waiting onto the collector)

 Errors in the process: Visiting the site  Review training: ignore the certificates and actually talk about the training  (politely) Point out instructions on front and back of CCF  Explain that the steps are federally enforced, and are not your preference only  Nor FTA’s preference – all modes are identical with regard to collection process

 Errors in the process: Visiting the site  Begin from a collaborative approach  Control your hired consultants / inspectors -You may have worked hard to establish a good working relationship. -Don’t let an inspector sour the relationship; it could cost you the use of your preferred collection site

 Delays in results  Occasional delays are normal, but 48 hours for a negative is typical nationally  Make sure the collection site uses a fax machine or scanner that actually works and produces legible and clear copies  Ask them about busy signals from the MRO

 Delays in results (continued)  Are the specimens going out promptly?  Are chronic payment issues slowing down the process (you might not be told about these!)?  Expect interference or scapegoating when you investigate the chronic delays (extremely common)  Don’t give up! Keep asking and verifying!

 Delays in results (continued)  Is the MRO copy being sent promptly?  Is it going through?  How soon does the MRO report the result to you after receiving lab results? This may be visible on the MRO results form under “results received”. Occasional delays are expected (verification of metabolites)

 Delays in results (continued)  Is the TPA holding the results or immediately transmitting them?  Does the collection site have the correct information and contact numbers?

 Delays in corrections / receipt of forms  If employees are escorted, have supervisor receive and deliver Copy 4 of CCF  Provide collection site with envelopes  Provide them or request that they use a digital photo (secure smartphone is allowed*) to transmit images of documents: -Copy 2 to MRO -Copy 4 to you *Ensure confidentiality and security of images

 Delays in corrections / receipt of forms  Delay payment until all forms are received -Is this possible? Can you establish involvement with billing?  Conduct correspondence by

 Identify specific problems and solve small first -Tell others involved what the issues are -Don’t throw away the entire structure without identifying the problems -Pick and choose your components when possible: MRO, Collection Site, TPA, Consortium

 CCF Quality Control  Pre-check Step 1, Part D (DOT/FTA)  If necessary, control your testing forms  Use a notification form  Track waiting time  Look over each step for completeness

 CCF Quality Control  Check MRO result for spelling, designation, or time errors  Errors on the MRO result form may be due to  Illegible Copy 2 sent to MRO  Poor handwriting by collector  Sloppy MRO verification process

Final Discussion Immediate Action

Sample Forms & Resources Hotline: (617)  Sample Policy & Policy Checklist  Notification Form  Tracking Form Available at: safety.volpe.dot.gov/DrugAndAlcohol/Training/NatConf/2014/Sessions.aspx Or

Don’t Leave The Conference Empty-Handed  Meet the FTA experts  Meet your peers  Collect Sample Forms  Ask Questions during Lectures  Ask MRO’s, Collectors, TPA’s about innovations  Subscribe to the FTA Regulatory Update Newsletter here: