1. Unique Situations for DAPMs How to Handle Them

2. Common Areas for Trouble Internally ◦ Operations ◦ City Hall ◦ HR ◦ Employees ◦ Management ◦ Consultants

3. Common Areas for Trouble Externally ◦ Collection Sites ◦ Mobile Collectors ◦ MRO ◦ TPA ◦ SAP

4. Common Areas for Trouble Externally ◦ Insurer ◦ Public ◦ Outside representation

5. Caught in the Middle DAPM & FTA Collectors Collection Site ManagementEmployees Vendors: MRO & TPA State or Grantee

6. Identifying Problem(s) Investigate for yourself Identify each deficiency Locate the specific rate-limiting step Rely on evidence

7. Analysis Mitigation likelihood ◦ Resources ◦ Support ◦ Level of effort ◦ Resistance ◦ Expertise

8. Mitigation

9. INTERNAL ISSUES

10. Areas for Issues Operations ◦ Supervisors ◦ Logistics for testing/service interruption ◦ Maintenance

11. Operations Identify, Analyze, Plan, Resolve Set VERY specific goals for Random Testing ◦ Actual dates and times for tests ◦ Don’t issue vague testing goals or theories ◦ Be hands-on if needed (go to the source)

12. Operations Identify, Analyze, Plan, Resolve Set VERY specific goals for Post-Accident Testing ◦ Go to the scene when possible ◦ Retrain in a brief gathering or formal meeting ◦ Full debrief after each accident ◦ Call the collection site

13. City Hall Billing Issues ◦ Vendor Invoices: Can you monitor them? Can you withhold payment? Can you be involved? Contracts/RFPs ◦ Do you have input into terms? Bid evaluations? Selection?

14. City Hall Billing Issues ◦ Vendor Invoices: Institute proactive memos of approval Contracts/RFPs ◦ Ask FTA for advice on language/pitfalls ◦ Push for involvement

15. Human Resources Understanding of the requirements ◦ Push/pull between Ops/HR/Exec ◦ Who is pushing for “efficiencies”? Closing the loop:  Accident information is critical to D&A program, but is often unavailable/difficult to receive  Random testing records  Pre-employment clearances

16. Human Resources Understanding of the requirements ◦ FTA can assist Closing the loop:  Proactively request records for debriefing and reviewing  Be a pest

17. Employees Notification vulnerabilities ◦ Are there internal vulnerabilities? ◦ How can you find out?

18. Employees At the collection site ◦ Waiting time before collection ◦ Waiting time during ◦ Total time of test

19. Employees Review the notification process for vulnerabilities Work with the collection site to reduce waiting times

20. Management Are you supported in your program? Are your supervisors supported? ◦ Post-accident testing thresholds ◦ Random spread requirements ◦ Return-to-duty ◦ Follow-up

21. Management Support for testing requirements: ◦ Post-accident: Present your side, but protect yourself in the documentation ◦ Random: Educate management, continue to work with Ops ◦ RTD & Follow-up: STAY ON TOP OF TESTING  NEVER fall behind & contact FTA immediately  Protect yourself

22. Consultants Authority Advice Changes Expertise/Grasp of Local Dynamics

23. Consultants Authority ◦ Are they clear about their authority/sponsor? Advice ◦ Is the advice correct? Is it personal preference or regulation? Which regulation? Fed/State/Local?

24. Consultants Changes ◦ Are the changes realistic? Overly burdensome? Do they have program health/regulatory compliance as a result? Expertise/Grasp of Local Dynamics ◦ FTA/FMCSA? Only one collection site?

25. Consultants Authority: Require articulation of authority before the visit. Contact FTA with concerns Advice: The changes required or suggested must be backed up by regulation. Require citations and read the citations yourself Changes: Require details about changes. Nothing is too specific Expertise/Grasp of Local Dynamics: Be firm with your local approach if there is more than one path to compliance

26. EXTERNAL ISSUES

27. Collection Site Limited hours/days Check-in times Collection process protocols ◦ Training ◦ The enclosure ◦ The CCF  Completeness & Accuracy

28. Collection Site Poor record transmittal Delays in reporting Inattention to small clients Complaints from employees/supervisors Repeated errors/affidavit requirements Mobile collector problems

29. Check Every CCF Completeness of the CCF ◦ Steps 1-5 Step 3 (unless the form is a Quest form) Accuracy of the CCF ◦ Time, date, test type, testing authority Timeliness of the collection process ◦ Start-to-finish times and wait times

30. Visit The Collection Site to Determine: The order in which the collection was performed The enclosure’s security The participation requirements/allowances of the donor ◦ Remove outer garments ◦ Pockets ◦ Wallet

31. Require Corrections Eliminating areas of concealment within the enclosure is the goal Ensuring the supervision of the donor is crucial Fatal flaws must be corrected by error correction training within 30 days

32. Tips Ask that responses from collection site personnel be sent to you by email ◦ Time/date included ◦ Correspondence trail included ◦ Easier to distribute as needed ◦ You can ask for photos, etc.

33. Tips After daylight savings time adjustments, monitor your collection site for a clock adjustment on the EBT If faxes are unclear, require digital photos of the CCF itself which can be emailed directly from a phone (8 megapixel or higher) while you await the paper copy

34. Tips If you like a particular collector, establish an on-call arrangement for late or early collections and pay them directly Delay payment if needed for collection site unresponsiveness

35. Tips Print bulletin cards for your collection site ◦ Multiple contact numbers ◦ Testing authority (you can pre-print these) ◦ Protocols

36. Tips Provide your collection site with SASEs in which to send your Employer Copies (Copy 4) from each CCF ◦ At the time of each collection ◦ Sent in batches at beginning of each testing period

37. Tips Check your ATF and CCF to determine which test occurred first Maintain a collaborative relationship (if possible) with your collectors Make appointments if possible (or needed) Monitor your employee’s wait time before the collection (after arrival)

38. The Required Order Step 1 The collection of the specimen Step 2 Step 3 Step 5 Step 4 The order is 1,2,3,5,4 and not 1,2,3,4,5

39. MRO/TPA/SAP Remember that THEY work for YOU You set the deadlines, dates, transmittal methods, and protocols in general If you get repeatedly poor service, drop them. If your employer is not assisting, contact the FTA

40. Insurer/Public/Representation Stay firm to the requirements ◦ Read them, ask the FTA, or ask internally for assistance Protect yourself with documentation Remain calm and articulate your stance Rely on evidence, not opinion or spin

41. Fixing Problems The FTA can assist with ◦ Policy ◦ New DAPM training ◦ Program evaluation ◦ Regulatory interpretation ◦ Regulatory application

42. Call the FTA Hotline (617) 494-6336 Or Email Fta.damis@dot.gov

43. Thank you for Attending Please fill out your evaluation forms