HHS/DOT DRUG & ALCOHOL TESTING PROGRAM
COMPARISON GUIDE (8/96)
| ITEM | HHS | DOT |
| 1. WHO
testing applies to a. positions b. area located |
1.a. Testing Designated
Position (TDP) - public health, safety, national security - includes pilots, firefighters, top secret, law enforcement, divers, motor vehicle operators, presidential appointees, etc. 1.b. US & Territories, Guam, PR, VI |
1.a. Commercial
Driver's License (CDL) and Railroad
Operations (RO) - CDL (FHWA): if vehicle is 26,001 lbs or more; is designed to carry 16 or more passengers including the driver; or is required to be placarded for hazardous materials 1.b. - RO (FRA): NPS Steamtown only - includes conductors, engineers, dispatchers, passenger services, signal maintenance, etc. 1.b. US only |
| 2. WHAT a. tested for b. procedures apply |
2.a. Drugs
only (Single specimen; 30ml) - marijuana, cocaine, amphetamines, opiates, phencyclidine (PCP) - measures use not impairment 2.b. HHS Mandatory Guidelines |
2.a. Drugs
(Split specimen: bottle A 30ml; bottle B 15ml; same void)
- marijuana, cocaine, amphetamines, opiates, phencyclidine (PCP) Alcohol - both measure use not impairment 2.b. 49 CFR Part 40 |
| 3. WHEN tested (test types) |
3.a. applicant - must
test negative before
hire - applies to TDP's only - 100% of permanent - 20-25% seasonal (applies only to firefighters; allowed to test 100%) 3.b. random - applies to TDP's only - test approx. 15% per year 3.c. reasonable suspicion - TDP: on or off duty use/impairment - non-TDP: on duty use/impairment - requires prior approval from 1st & 2nd level super., BDPC, DPM, SOL 3.d. accident/unsafe practice - applies to all DOI positions: required if involves death, or serious injury requiring immediate hospitalization; or $10,000+ damage to govt/pvt property 3.e. follow-up - after successfully complete EAP - minimum 4 tests for 1 year 3.f. voluntary - name added to TDP random testing pool |
Note: DOT testing applies only to
CDL/RO positions, while on duty. 3.a. pre-employment (100%) - must test negative before perform CDL/RO safety sensitive function (recommend not hiring until test negative) Note: no alcohol test pending DOT final decision 3.b. random - required 50% drug and 25% alcohol per year 3.c. reasonable suspicion - 1hr drug & 1hr alcohol training required prior to initiating test (CDL); 3hrs for RO 3.d. post accident - required if: involves a death; receive citation for moving violation (CDL only); $150k+ damage (RO only) 3.e. return-to-duty - after completes SAP recommended program; - before perform CDL/RO safety sensitive function 3.f. follow-up - after completes SAP recommended program - minimum 6 tests for 1 year (up to 60 mths); SAP may require drug and alcohol tests |
| 4. WHERE tested | 4. Clinic, hospital, doctor office, suitable work location | 4. Clinic, hospital, doctor office, suitable work location |
| 5. WHY test | 5. EO 12564, Drug-Free
Workplace - focus to provide education/training; EAP; testing |
5. Omnibus
Transportation Employee Testing Act of 1991 - primarily a safety program |
| 6. HOW to request tests | 6. Input as HHS test in
FAST. Note: EPS schedules all random and reasonable suspicion tests |
6. Input as DOT test in
FAST: - FHWA for CDL; FRA for RO Note: EPS schedules all random; reasonable suspicion requires EPS advance approval |
| 7. EDUCATION & TRAINING | 7.a.
supervisors/managers: required on drug-free workplace
program 7.b. employees: required to provide educational material |
7.a. any person who
initiates a request for reasonable suspicion test:
required 1 hr drug & 1 hr alcohol (CDL); 3 hrs for RO
7.b. CDL/RO employees: required info package on DOT program; signed certification of receipt |
| 8. IDENTIFICATION -test
positions a. SF-52 coding b. vacancy announcement; position description (PD) c. signed employee receipt |
8.a. identify as HHS
(TDP) 8.b. state position is TDP under HHS drug testing program; also put in PD 8.c. initially required of all TDP's; now handled via vacancy announ., PD |
8.a. identify as DOT;
then as CDL or RO (and type) 8.b. state CDL/RO under DOT drug & alcohol testing program; put in PD 8.c. CDL/RO employees, current and new, must sign receipt for information package |
| 9. FINDING OF DRUG & ALCOHOL
USE a. administrative actions b. disciplinary actions |
9.a. administrative -
remove from TDP (or TDP duties) until pass EAP - undergo 1 year FU testing 9.b. disciplinary 1st finding: required minimum letter of reprimand, up to removal 2nd finding: required to initiate removal action |
9.a. administrative Drug |
Key/Legend
AMP = Amphetamines PA = Post-Accident Test
BAC = Breath Alcohol Concentration PCP = Phencyclidine
BAT = Breath Alcohol Technician PD = Position Description
BDPC = Bureau Drug Program Coordinator R = Random Test
CDL = Commercial Drivers License RO = Railroad Operations
CFR = Code of Federal Regulations RTD = Return-To-Duty Test
CMV = Commercial Motor Vehicle RS = Reasonable Suspicion Test
COC Form = Federal Drug Testing and Control Form SAP = Substance
Abuse Professional
COK = Cocaine EPS = Employee and Public Services
DOI = Department of the Interior SOL = Solicitor
DOT = Department of Transportation TDP = Testing Designated
Position
DPM = Drug Program Manager
V = Voluntary Test
EAP = Employee Assistance Program
EBT = Evidential Breath Measurement Device
E.O. = Executive Order
FHWA = Federal Highway Administration
FRA = Federal Railroad Administration
FU = Follow-up Testing
HHS = Department of Health and Human Services
LE = Law Enforcement
OP = Opiates
OTETA = Omnibus Transportation Employee Testing Act of 1991