6. Proposed Replacement DOT Drug & Alcohol Testing Policy 03022020DRAFT
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Drug and Alcohol Testing for Commercial Drivers Policy
Purpose and Objectives
The City of Scandia (“City”) has a vital interest in maintaining safe, healthful, and efficient
working conditions for employees, and recognizes that individuals who are impaired because of
drugs and/or alcohol jeopardize the safety and health of other workers as well as themselves. The
City is concerned about providing a safe workplace for its employees, and while the City does
not intend to intrude into the private lives of its employees, it is the goal to provide a work
environment conducive to maximum safety and optimum work standards. Alcohol and drug
abuse can cause unsatisfactory job performance, increased tardiness and absenteeism, increased
accidents and workers’ compensation claims, higher insurance rates, and an increase in theft of
city property. The use, possession, manufacture, sale, transportation, or other distribution of
controlled substance or controlled substance paraphernalia and the unauthorized use, possession
transportation, sale, or other distribution of alcohol is contrary to this policy and jeopardizes
public safety.
In response to regulations issued by United States Department of Transportation (“DOT”), the
City has adopted this Policy on Alcohol and Controlled Substances for employees who hold a
commercial driver’s license (CDL) to perform their duties. The City also has a separate Policy on
Controlled Substance and Alcohol Testing for employees not covered by DOT and Federal
Motor Carrier Safety Administration (FMCSA) regulations.
Given the significant dangers of alcohol and controlled substance use, each applicant and driver
must abide by this policy as a term and condition of hiring and continued employment.
Moreover, federal law requires the City to implement such a policy.
To ensure this policy is clearly communicated to all drivers and applicants, and in order to
comply with applicable federal law, drivers and applicants are required to review this policy and
sign the “Certificate of Receipt” portion.
Because changes in applicable law and the City’s practices and procedures may occur from time
to time, this policy may change in the future, and nothing in this policy is intended to be a
contract, promise, or guarantee the City will follow any particular course of action, disciplinary,
rehabilitative or otherwise, except as required by law. This policy does not in any way affect or
change the status of any at-will employee.
Any revisions to the Federal Omnibus Transportation Employee Testing Act and Federal Motor
Carrier Safety Administration (FMCSA) regulations will take precedent over this policy to the
extent the policy has not incorporated those revisions.
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Persons Subject to Testing & Types of Tests
All employees are subject to testing who job duties include performing “safety -sensitive duties”
on City vehicles that:
1. Have a gross combination weight rating or gross combination weight of 26,001 pounds or
more, whichever is greater, inclusive of a towed unit(s) with a gross vehicle weight rating
or gross vehicle weight of more than 10,000 pounds, whichever is greater; or
2. Have a gross vehicle weight rating or gross vehicle weight of 26,0001 or more pounds
whichever is greater; or
3. Are designed to transport 16 or more passengers, including the driver; or
4. Are of any size and are used in the transportation of materials found to be hazardous for
the purposes of the Hazardous Materials Transportation Act (49 U.S.C. 5103(b)) and
which require the motor vehicle to be placarded under the Hazardous Materials
Regulations (49 CFR part 172, subpart F).
The City does not require firefighters to possess a Commercial Driver’s License and not covered
under this DOT policy.
The following functions are considered safety-sensitive:
• all time waiting to be dispatched to drive a commercial motor vehicle
• all time inspecting, servicing, or conditioning a commercial motor vehicle
• all time driving at the controls of the commercial motor vehicle
• all other time in or upon a commercial motor vehicle
• all time loading or unloading a commercial motor vehicle, attending the same, giving or
receiving receipts for shipments being loaded or unloaded, or remaining in readiness to
operate the vehicle
• all time repairing, obtaining assistance, or attending to a disable commercial motor vehicle.
The City may test any applicant to whom a conditional offer of employment has been made and
any driver for controlled substance and alcohol under any of the following circumstances:
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Pre-Employment Testing.
All applicants, including current employees seeking a transfer, applying for a position where
duties include performing safety-sensitive duties described above, will be required to take a drug
test prior to the first time a driver performs a safety-sensitive function for the City. A driver may
not perform safety-sensitive functions unless the driver has received a controlled substance test
result from the Medical Review Officer (“MRO”) indicating a verified negative test result.
In addition to pre-employment controlled substance testing, applicants will be required to
authorize in writing former employers to release alcohol test results of .04 or greater Blood
Alcohol Content (“BAC”), positive controlled substance test results, refusals to test, other
violations of drug and alcohol testing regulations, and completion of return to duty requirements
within the preceding three years.
The City will contact the candidate’s DOT regulated previous and current employers within the
last three years for drug and alcohol test results as referenced above and review the testing
history if feasible before the employee first performs safety-sensitive functions for the city.
Beginning in 2020, an applicant must provide consent to the city, and successfully pass a full
query of the Federal Motor Carrier Safety Administration’s Clearinghouse. In addition, at least
once a year, the City will conduct a limited query of the Clearinghouse for each currently
employed CDL driver.
If the limited query reveals that the Clearinghouse has information about resolved or unresolved
drug and alcohol program violations by a candidate or current employee, he or she will be asked
to provide electronic consent to a full query of the Clearinghouse (unless he or she has
previously provided electronic consent).
In the event a full query of the Clearinghouse reveals unresolved violation information for a
candidate or current employee, the driver will not be permitted to perform safety-sensitive
functions, including the operation of a Commercial Motor Vehicle and, in the case of a
candidate, may have their conditional offer of employment rescinded or, in the case of a current
employee, may be subject to discipline.
Post-Accident Testing.
As soon as practicable following an accident involving a commercial motor vehicle operating on
a public road, the City will test each surviving driver for controlled substances and alcohol when
the following occurs:
• The accident involves a fatality or
• The driver receives a citation for a moving traffic violation from the accident and an injury is
treated away from the accident scene or
• The driver receives a citation for a moving traffics violation from the accident and a vehicle
is required to be towed from the accident scene.
The following chart summarizes when DOT post-accident testing needs to be conducted:
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Type of accident involved
Citation issued to
the DOT covered
CDL driver?
Test must be
performed
by the City
Human Fatality Yes Yes
Human Fatality No Yes
Bodily Injury with Immediate
Medical Treatment Away from the
Scene
Yes Yes
Bodily Injury with Immediate
Medical Treatment Away from the
Scene
No No
Disabling Damage to Any Motor
Vehicle Requiring Tow Away
Yes Yes
Disabling Damage to Any Motor
Vehicle Requiring Tow Away
No No
A driver subject to post-accident testing must remain readily available or the driver will be
deemed to have refused to submit to testing. This requirement to remain ready for testing does
not preclude a driver from leaving the scene of an accident for the period necessary to obtain
assistance in responding to the accident or to obtain necessary medical care.
Post – Accident Controlled Substance Testing
Drivers are required to submit a urine sample for post-accident controlled substance testing as
soon as possible. If the driver is not tested within thirty-two (32) hours after the accident, the
City will cease its attempts to test the driver and prepare and maintain on file a record stating
why the test was not promptly administered.
Post- Accident Alcohol Testing
Drivers are required to submit to post-accident alcohol testing as soon as possible. After an
accident, consuming alcohol is prohibited until the driver is tested. If the driver is not tested
within two (2) hours after the accident, the City will prepare and maintain on file a record stating
why the test was not administered within that time. If eight hours have elapsed since the accident
and the driver has not submitted to an alcohol test, the City will cease its attempts to test the
driver and prepare and maintain on file a record stating why the test was not administered.
The City may accept the results of a blood or breath test in place of an alcohol test and urine test
for the use of controlled substances if:
• The tests are conducted by federal, state, or local officials having independent authority for
the test, and
• The tests conform to applicable federal, state, or local testing requirements, and
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• The test results can be obtained by the City.
Whenever such a test is conducted by a law enforcement officer, the driver must contact the City
and immediately report the existence of the test, providing the name, badge number, and
telephone number of the law enforcement officer who conducted the test.
Random Testing.
Every driver will be subject to unannounced alcohol and controlled substance testing on a
random selection basis. Drivers will be selected for testing by use of a scientifically valid method
under which each driver has an equal chance of being selected each time selections are made.
These random tests will be conducted throughout the calendar year. Each driver who is notified
of selection for random testing must cease performing safety-sensitive functions and report to the
designated test site immediately. It is mathematically possible drivers may be selected be picked
and tested more than once, and others not at all.
If a driver is selected for a random test while he or she is absent, on leave or away from work,
that driver may be required to undergo the test when he or she returns to work.
For 2020, federal law requires the City to test at a rate of at least fifty percent (50%) of its
average number of drivers for controlled substance each year, and to test at a rate o f at least ten
percent (10%) of its average number of drivers for alcohol each year. These minimum testing
rates are subject to change by the DOT.
Reasonable Suspicion Testing.
When a supervisor has reasonable suspicion to believe a driver has engaged in conduct
prohibited by federal law or this policy, the City will require the driver to submit to an alcohol
and/or controlled substance test.
The City’s determination that reasonable suspicion exists to require the driver to undergo an
alcohol test will be based on “specific, contemporaneous, articulable observations concerning the
appearance, behavior, speech, or body odors of the driver.” In the case of controlled substance,
the observations may include indications of the chronic and withdrawal effects of a controlled
substance.
The required observations for reasonable suspicion testing will be made by a supervisor or other
person designated by the City who has received appropriate training in identification of actions,
appearance and conduct of a driver which are indicative of the use of alcohol or controlled
substance. These observations leading to an alcohol or controlled substance test, will be reflected
in writing and signed by the supervisor who made the observations. The record will be retained
by the City. The person who makes the determination that reasonable suspicion exists to conduct
testing, will not be the person conducting the testing, which shall instead be conducted by
another qualified person.
Alcohol testing is authorized only if the observations are made during, just before, or just after
the driver has ceased performing such functions. If a reasonable suspicion alcohol test is not
administered within two (2) hours following the determination of reasonable suspicion, the City
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will prepare and maintain on file a record stating the reasons the alcohol test was not promptly
administered. If a reasonable suspicion alcohol test is not administered within eight (8) hours
following the determination of reasonable suspicion, the City will prepar e and maintain on file a
record stating the reasons the alcohol test was not administered and will cease attempts to
conduct the alcohol test.
Notwithstanding the absence of a reasonable suspicion test, no driver may report for duty or
remain on duty requiring the performance of safety-sensitive functions while the driver is under
the influence of or impaired by alcohol, as shown by the behavioral, speech, and performance
indicators of alcohol use, nor will the City permit the driver to perform or continue to perform
safety-sensitive functions until (1) an alcohol test is administered and the driver’s alcohol
concentration is less than .02; or (2) twenty-four (24) hours have elapsed following the
determination of reasonable suspicion.
Return-to-Duty Testing.
The City reserves the right to impose discipline against drivers who violate applicable FMCSA
or DOT rules or this policy, subject to applicable personnel policy and collective bargaining
agreements. Except as otherwise required by law, the City is not obligated to reinstate or
requalify such drivers for a first positive test result.
Should the City consider reinstatement of a DOT covered driver, the driver must undergo a
Substance Abuse Professional (“SAP”) evaluation and participate in any prescribed
education/treatment, and successfully complete return-to-duty alcohol test with a result
indicating an alcohol concentration of less than 0.02 and/or or a controlled substance test with a
verified negative result, before the driver returns to duty requiring the performance of a safety-
sensitive function. The SAP determines if the driver has completed the education/treatment as
prescribed.
Employees are responsible for selecting their SAP from the City’s List of Approved SAPs. The
employee is responsible for notifying the City’s Designated Representative or City Administrator
of their SAP selection and that an appointment is arranged.
The employee is responsible for paying for all costs associated with the return -to-duty test. The
controlled substance test will be conducted under direct observation.
Follow-Up Testing.
The City reserves the right to impose discipline against drivers who violate applicable FMCSA
or DOT rules or this policy, subject to applicable personnel policies and collective bargaining
agreements. Except as otherwise required by law, the City is not obligated to reinstate or
requalify such drivers.
Should the City reinstate a driver following a determination by a Substance Abuse Professional
(SAP) that the driver is in need of assistance in resolving problems associated with alcohol use
and/or use of controlled substance, the City will ensure that the driver is subject to unannounced
follow-up alcohol and/or controlled substance testing. The number and frequency of such follow-
up testing will be directed by the SAP and will consist of at least six (6) tests in the first twelve
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(12) months following the driver’s return to duty. Follow-up testing will not exceed sixty (60)
months from the date of the driver’s return to duty. The SAP may terminate the requirement for
follow-up testing at any time after the first six tests have been administered, if the SAP
determines such test is no longer necessary. The employee is responsible for paying for all costs
associated with follow-up tests.
Follow-up alcohol testing will be conducted only when the driver is performing safety-sensitive
functions, or immediately prior to or after performing safety-sensitive functions.
Cost of Required Testing.
The City will pay for the cost of pre-employment, post-accident, random, and reasonable
substance and alcohol testing requested or required of all job applicants and employees. The
driver must pay for the cost of all requested confirmatory re-tests, return-to-duty, and follow-up
testing.
Prohibited Conduct
The following conduct is explicitly prohibited by applicable DOT and FMCSA regulations and
therefore constitutes violation of City policy.
Under the influence of alcohol when reporting for duty or while on duty.
No driver may report for duty or remain on duty requiring the performance of safety-sensitive
functions while having an alcohol concentration of 0.04 or greater. Drivers reporting for duty or
remaining on duty to perform safety-sensitive functions while having an alcohol concentration of
0.02, but less than 0.04, will be removed from duty for 24 hours, escorted home and placed on
Paid Time Off (PTO) or another appropriate leave of absence for hours missed from work.
On-Duty Use of Alcohol.
No driver may use alcohol while performing safety-sensitive functions.
Pre-Duty Use of Alcohol.
No driver may perform safety-sensitive functions within four (4) hours after using alcohol. If an
employee has had alcohol within four hours they are to notify their supervisor before performing
any safety-sensitive functions.
Alcohol Use Following an Accident.
No driver required to take a post-accident alcohol test may use alcohol for eight (8) hours
following the accident, or until the driver undergoes a post-accident alcohol test, whichever
occurs first.
Refusal to Submit to a Required Alcohol or Controlled Substance Test.
No applicant or driver may refuse to submit to pre-employment, post-accident, random,
reasonable suspicion or follow-up alcohol or controlled substance testing.
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In the event an applicant or driver does in fact refuse to submit to required alcohol or controlled
substance testing, no test will be conducted. Refusal by a driver to submit to controlled substance
or alcohol testing will be considered a positive test result, will cause disqualification from
performing safety-sensitive functions, and may appear on the driver’s permanent record. Drivers
who refuse to submit to testing will be subject to discipline, up to an including termination.
In accordance with the Federal Motor Carrier Safety Administration’s (FMCSA) Commercial
Driver’s License (CDL) Drug and Alcohol Clearinghouse reporting requirements, beginning
January 6, 2020, the City will report a driver’s refusal to submit to a DOT test for drug or alcohol
use to the Clearinghouse within three business days. If an applicant refuses to submit to pre-
employment controlled substance testing, any applicable conditional offer will be withdrawn.
For purposes of this section, a driver is considered to have refused to submit to an alcohol or
controlled substance test when the driver:
• Fails to provide adequate breath for alcohol testing without a valid medical explanation after
he or she has received notice of the requirement for breath testing.
• Fails to provide adequate urine for controlled substance testing without a genuine inability to
provide a specimen (as determined by a medical evaluation), after he or she has received
notice of the requirement for urine testing.
• Fails to report for testing within a reasonable period of time, as determined by the City.
• Fails to remain at a testing site until testing is complete.
• In the case of directly observed or monitored collection, fails to permit observation or
monitoring.
• Fails or declines to take a second test as required by the City and/or collector.
• Fails to undergo a medical examination as directed by the City pursuant to federal law.
• Refuses to complete and sign the alcohol testing form, to provide a breath or saliva sample,
to provide an adequate amount of breath, or otherwise cooperate in any way that prevents the
completion of the testing process.
• Engages in conduct that clearly obstructs the test process.
Altering or attempting to alter a urine sample or breath test.
A driver altering or attempting to alter a urine sample or controlled substance test, or substituting
or attempting to substitute a urine sample, will be subject to providing a specimen under direct
observation. Both specimens will be subject to laboratory testing. In such case, the employee
may be subject to immediate termination of employment and any job offer made to an applicant
will be immediately withdrawn.
Controlled Substance Use.
No driver may report for duty or remain on duty requiring the performance of safety-sensitive
functions when the driver uses any controlled substance, except when the use is pursuant to the
instructions of a licensed medical practitioner who has advised the driver in writing the substance
does not adversely affect the driver’s ability to safely operate a commercial motor vehicle.
Drivers must forward this information regarding therapeutic controlled substance use to the City
immediately after receiving any such advice.
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Having a medical marijuana card and/or a cannabis prescription from a physician does not allow
anyone to use or possess that drug in the city’s workplace. The federal government still classifies
cannabis as an illegal drug. There is no acceptable concentration of marijuana metabolites in the
urine or blood of an employee who performs safety -sensitive duties for the City. Employees are
still subject to being tested under our policies, as well as for being disciplined, suspended or
terminated after testing positive for cannabis while at work.
Controlled Substance Testing.
No driver may report for duty, remain on-duty or perform a safety-sensitive function if the driver
tests positive for controlled substance. In addition to the conduct prohibited by applicable DOT
and FMCSA regulations, the City also maintains other applicable policies regarding drug and
alcohol that are applicable to all employees. For specifics regarding those requirements, refer to
the City’s policy for non-DOT related drug and alcohol policy.
Collection and Testing Procedures
Drivers are required to report immediately upon notification to the collection site. For random
tests conducted off site, employees may use a City vehicle to drive to the collection site. Drivers
will be expected to provide a photo ID card for identification to the collection staff. All drivers
will be expected to cooperate with collection site personnel request to remove any unnecessary
outer garments such as coats, sweaters or jackets and will be required to empty their pockets.
Collection personnel will complete a Federal Custody and Control Form (“CCF”) which drivers
providing a sample will sign as well. For follow-up and return to duty testing, an employee may
receive only a testing order slip to take to the collection sheet. In such instances, collection
personnel will provide the employee with chain of custody and control form.
Alcohol Testing.
Employees will be tested for alcohol just before, during, or immediately following performance
of a safety-sensitive function. If a driver is also taking a DOT controlled substance test, generally
speaking, the alcohol test is completed before the urine collection process begins. Screening tests
for alcohol concentration will be performed utilizing a non-evidential screening device included
by the National Highway Traffic Safety Administration on its conforming products list (e.g., a
saliva screening device) or an evidential breath testing device (“EBT”) operated by a trained
breath alcohol technician (“BAT”) at a collection site.
An alcohol test usually takes approximately 15 minutes if the result is negative. If a driver’s first
attempt is positive (with an alcohol concentration of .02 or greater), the driver will be asked to
wait at least 15 minutes and then be tested again. The driver may not eat, drink or place anything
in his/her mouth (e.g., cigarette, chewing gum) during this time. All confirmation tests will be
conducted in a location that affords privacy to the driver being tested, unless unusual
circumstances (e.g., when it is essential to conduct a test outdoors at the scene of an accident)
make it impracticable to provide such privacy. Any results less than 0.02 alcohol concentration is
considered a “negative” test result.
If the driver attempts and fails to provide an adequate amount of breath, he/she will be referred to
a physician to determine if the driver’s inability to provide a specimen is genuine or constitutes a
refusal to test. Alcohol test results are reported directly to the City by the collection site staff.
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Controlled Substance Testing.
The City will use a “split urine specimen” collection procedure for controlled substance testing.
Collection of urine specimens for controlled substance testing will be conducted by an approved
collector and will be conducted in a setting and manner to ensure the driver’s privacy.
Controlled substance testing generally takes about 15 minutes. At the collection site, the driver
will be given a sealed container and must provide at least 45 ml of urine for testi ng. Once the
sample is provided the collection personnel will check the temperature and color and look for
signs of contamination. The urine is then split into two separate specimen containers (A, or
“primary,” and B, or “split”) with identifying labels and security seals affixed to both. The
collection facility will be responsible for maintaining a proper chain of custody for delivery of
the sample to a DHHS-certified laboratory for analysis. The laboratory will retain a sufficient
portion of any positive sample for testing and store that portion in a scientifically acceptable
manner for a minimum 365-day period.
If an employee fails to provide a sufficient amount of urine to permit a controlled substance test
(45 milliliters of urine), the collector will discard the insufficient specimen, unless there is
evidence of tampering with that specimen. The collector will urge the driver to drink up to 40
ounces of fluid, distributed reasonably over a period of up to three hours, or until the driver has
provided a sufficient urine specimen, whichever occurs first. If the driver has not provided a
sufficient specimen within three hours of the first unsuccessful attempt, the collector will cease
efforts to attempt to obtain a specimen. The driver must then obtain, within five calendar days,
an evaluation from a licensed physician, acceptable to the MRO, who has expertise in the
medical issues raised by the employee’s failure to provide a sufficient specimen. If the licensed
physician concludes the driver has a medical condition, or with a high degree of probability
could have, precluded the driver from providing a sufficient amount of urine, the City will
consider the test to have been canceled. If a licensed physician cannot make such a
determination, the City will consider the driver to have engaged in a refusal to test and will take
appropriate disciplinary action under this policy.
The primary specimen is used for the first test. If the test is negative, it is reported to the MRO
who then reports the result, following a review of the CCF Form for compliance, to the City. If
the initial result is positive or non-negative, a “confirmatory retest” will be conducted on the
primary specimen. If the confirmatory re-test is also positive, the result will be sent to the MRO.
The MRO will contact the driver to verify the positive result. If the MRO is unable to reach the
driver directly, the MRO must contact the City who will direct the driver to contact the MRO.
Review of Test Results
The MRO is a licensed physician with knowledge and clinical experience in substance abuse
disorders and is responsible for receiving and reviewing laboratory results of the controlled
substances test as well as evaluating medical explanations for certain drug test results. Prior to
making a final decision to verify a positive test result, the MRO will give the driver or the job
applicant an opportunity to discuss the test result, typically through a phone call. The MRO, or a
staff person under the MRO’s supervision, will contact the individual directly, on a confidential
basis, to determine whether the individual wishes to discuss the test result. If the employee or job
applicant wishes to discuss the test result:
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• The individual may be required to speak and/or meet with the MRO, who will review t he
individual’s medical history, including any medical records provided.
• The individual will be afforded the opportunity to discuss the test results and to offer any
additional or clarifying information which may explain the positive test result. If the
employee or job applicant, believes a mistake was made at the collection site, at the labor, on
a chain-of-custody form, or that the drug test results are caused by lawful substance use, the
employee should tell the MRO.
• If there is some new information which may affect the original finding, the MRO may
request the laboratory to perform additional testing on the original specimen in order to
further clarify the results; and
• A final determination will be made by the MRO that the test is either positive or negative,
and the individual will be so advised.
If the MRO upholds the positive, adulterated or substituted drug determination, that test result
will be provided to the City. There is no opportunity to explain a positive alcohol test provided in
the DOT regulations.
The driver can request the MRO to have the split specimen (the second “B” container) tested at
the driver’s expense. This includes all costs that may be associated with the re-test. There is no
split specimen testing for an invalid result. The driver has 72 hours after they have been notified
of the positive result to make this request. If the employee requests an analysis of the split
specimen, the MRO will direct the laboratory to send the split specimen to another certified
laboratory for analysis.
If an employee has not contacted the MRO within 72 hours, the employee may present
information documenting that serious injury, illness, lack of actual notice of the verified test
result, inability to contact the MRO, or other circumstances unavoidably prevented the employee
from making timely contact. If the MRO concludes there is legitimate explanation for the
employee’s failure to contact within 72 hours, the MRO will direct the analysis of the split
specimen.
If the results of the split specimen are negative, the City may pay for all costs associated with the
rest and there will be no adverse action taken against the employee or job applicant.
Notification of Test Results
Employees.
The City will notify a driver of the results of random, reasonable suspicion, and post -accident
tests for controlled substance if the test results are verified positive and will inform the driver
which controlled substance or substances were verified as positive. Results of alcohol tests will
be immediately available from the collection agent.
Right to Confirmatory Retest.
Within seventy-two (72) hours after receiving notice of a positive controlled substance test
result, an applicant or driver may request through the MRO a re-analysis (confirmatory retest) of
the driver’s split specimen. Action required by federal regulation as a result of a positive
controlled substance test (e.g., removal from safety-sensitive functions) will not be stayed during
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retesting of the split specimen. If the result of the confirmatory retest fails to reconfirm the
presence of the controlled substance(s) or controlled substance metabolite(s) found in the
primary specimen, or if the split specimen is unavailable, inadequate for t esting or untestable, the
MRO will cancel the test.
Dilute Specimens
Dilute Negatives Creatinine concentration of specimen is equal to or greater than 2 mg/dL, but
less than or equal to 5 mg/dL. If the City receives information that a driver has provided a dilute
negative specimen, the City will direct a recollection, pursuant to the MRO’s direction, under
direct observation. Creatinine concentration of specimen is greater than 5 mg/dL. If the MRO
advises the City that the employee’s dilute negative specimen contains a creatinine concentration
greater than five mg/dL the City will direct the driver to take a second screening test, not under
direct observation. The second screening test will be performed as soon as possible after the City
receives word of the dilute negative specimen.
The City can choose only to require retesting for dilute negatives where the Creatinine
concentration of specimen is greater than 5 mg/dL for pre-employment testing, reasonable
suspicion testing, post-accident testing, or random testing.
Consequences for Drivers Engaging in Prohibited Conduct
Job Applicants.
Any applicable conditional offer of employment will be withdrawn from a job applicant or
employee seeking a transfer who refuses to be tested or tests positive for controlled substance
pursuant to this policy.
Employees.
Drivers who are known to have engaged in prohibited behavior with regard to alcohol misuse or
use of controlled substance, as defined earlier in this policy, are subject to the following
consequences:
• Removal from Safety-Sensitive Functions
No driver may perform safety-sensitive functions, including driving a commercial motor
vehicle, if the driver has engaged in conduct prohibited by federal law.
No driver who is found to have an alcohol concentration of 0.02 or greater but less than 0.04 may
perform or continue to perform safety-sensitive functions for the City, including driving a
commercial motor vehicle, until the start of the driver’s next regularly scheduled duty, but not
less than twenty-four (24) hours following administration of the test.
If a driver tests positive under this policy or is found to have an alcohol concentration of .02 or
greater but less than .04, the driver will be removed from safety sensitive dut ies and escorted
home; the driver should not drive home but be escorted to his or her home. The driver will then
be placed on Compensatory, PTO or another appropriate leave of absence for hours missed from
work.
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Notification of Resources Available
The City will advise each driver who has engaged in conduct prohibited by federal law or who
has a positive alcohol or controlled substance test of the resources available to the driver, in
evaluating and resolving problems associated with the misuse of alcohol and use of a controlled
substance, including the names, addresses, and telephone numbers of Substance Abuse
Professionals and counseling and treatment programs. The City will provide this SAP listing in
writing at no cost to the driver.
• Discipline
The City reserves the right to impose whatever discipline the City deems appropriate in
its sole discretion, up to and including termination for a first occurrence, against drivers
who violate applicable FMCSA or DOT rules or this policy, subject to applicable
personnel policies and collective bargaining agreements. Except as otherwise required by
law, the City is not obligated to reinstate or requalify such drivers following a first
positive confirmed controlled substance or alcohol test result.
• Evaluation, and Return to Duty Testing
Should the City wish to consider reinstatement of a driver who engaged in conduct
prohibited by federal law and/or who had a positive alcohol or controlled substance test,
the driver must undergo a SAP evaluation, participate in any prescribed
education/treatment, and successfully complete return-to-duty alcohol test with a result
indicating an alcohol concentration of less than 0.02 and/or or a controlled substance test
with a verified negative result, before the driver returns to duty requiring the performance
of a safety-sensitive function. The SAP will determine what assistance, if any, the driver
needs in resolving problems associated with alcohol misuse and controlled substance use
and will ensure the driver properly follows any rehabilitation program and submits to
unannounced follow-up alcohol and controlled substance testing.
• Follow-Up Testing
If the driver passes the return-to-duty test, he/she will be subject to unannounced
follow-up alcohol and/or controlled substance testing. The number and frequency for
such follow-up testing will be as directed by the SAP and will consist of at least six tests
in the first twelve months. These tests will be conducted under direct observation.
• Refusal to test
All drivers and applicants have the right to refuse to take a required alcohol and/or
controlled substance test. If an employee refuses to undergo testing, the employee will be
considered to have tested positive and may be subject to disciplinary action, up to and
including termination. Refer to Refusing to Test provided earlier in this policy.
• Responsibility for Cost of Evaluation and Rehabilitation
Drivers will be responsible for paying the cost of evaluation and rehabilitation (including
services provided by a Substance Abuse Professional) recommended or required by the
City or FMCSA or DOT rules, except to the extent that such expense is covered by an
applicable employee benefit plan or imposed on the City pursuant to a collective
bargaining agreement.
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• Reporting to the FMCSA’s CDL Drug and Alcohol Clearinghouse
In accordance with the Federal Motor Carrier Safety Administration’s (FMCSA)
Commercial Driver’s License (CDL) Drug and Alcohol Clearinghouse reporting
requirements beginning January 6, 2020, the City will report the following information to
the Clearinghouse within three business days:
✓ A DOT alcohol confirmation test result with an alcohol concentration of 0.04 or
greater;
✓ A negative DOT return-to-duty test result;
✓ The driver’s refusal to submit to a DOT test for drug or alcohol use;
✓ Actual knowledge a driver has used alcohol or controlled substances, based on the
employer’s direct observation, information provided by the driver’s previous
employer(s), a traffic citation for driving a CMV while under the influence of
alcohol or controlled substances, or an employee’s admission of alcohol or
controlled substance abuse except as provided in § 382.121) of:
o On duty alcohol use pursuant to § 382.205;
o Pre-duty alcohol use pursuant to § 382.207;
o Alcohol use following an accident pursuant to § 382.209;
o Controlled substance use pursuant to § 382.213;
✓ Employers will also report negative return-to-duty (RTD) test results and the
successful completion of a driver’s follow-up testing plan as ordered by a SAP.
Loss of CDL License for Traffic Violations in Commercial and Personal
Vehicles
Effective August 1, 2005, the FMCSA established strict rules impacting when CDL license
holders can lose their CDL for certain traffic offenses in a commercial or personal vehicle.
Employees are required to notify their supervisor immediately if the status of their CDL license
changes in anyway.
Maintenance and Disclosure of Records
Except as required or authorized by law, the City will not release driver’s information that is
contained in records required to be maintained by this policy or FMCSA and DOT regulation s.
Beginning in 2020, the city will be required to query and report to the agency’s Commercial
Driver’s License (CDL) Drug and Alcohol Clearinghouse prior to hiring new drivers, will
conduct annual checks of existing CDL-drivers, and will report certain violations of the DOT
drug and alcohol testing program for holders of CDLs. In addition, a driver is entitled, upon
written request, to obtain copies of any records pertaining to the driver’s use of alcohol or a
controlled substance, including any records pertaining to his or her alcohol or controlled
substance tests.
Policy Contact for Additional Information
If you have any questions about this policy or the City’s controlled substance and alcohol testing
procedures, you may contact the City Administrator to obtain additional information.
Definitions
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Accident:
Means an occurrence involving a commercial motor vehicle operating on a public road which
results in a fatality; bodily injury to any person who, as a result of the injury, immediately
receives medical treatment away from the scene of the accident; or one or more motor vehicles
incurring disabling damage as a result of the accident, requiring the vehicle to be transported
away from the scene by a tow truck or other vehicle. The term “accident” does not include an
occurrence involving only boarding and alighting from a stationary motor vehicle; an occurrence
involving only the loading or unloading of cargo; or an occurrence in the course of the operation
of a passenger car or a multipurpose passenger vehicle unless the vehicle is transporting
passengers for hire or hazardous materials of a type and quantity that require the motor vehicl e to
be marked or placarded in accordance with 49 C.F.R. § 177.823; 49 C.F.R. § 382.303(a); 49
C.F.R. § 382.303(f).
Alcohol Concentration (or Content):
Means the alcohol on a volume of breath expressed in terms of grams of alcohol per 210 liters of
breath as indicated by an evidential breath test. 49 C.F.R. § 382.107.
Alcohol Use:
Means the consumption of any beverage, mixture, or preparation, including any medication,
containing alcohol. 49 C.F.R. § 382.107.
Applicant:
Means a person applying to drive a commercial motor vehicle. 49 C.F.R. § 382.107.
Breath Alcohol Technician or BAT:
Means an individual who instructs and assists individuals in the alcohol testing process and
operates an evidential breath testing device (EBT). 49 C.F.R. § 40.3.
City:
Means City of Scandia.
City Premises:
Means all job sites, facilities, offices, buildings, structures, equipment, vehicles and parking
areas, whether owned, leased, used or under the control of the City.
Collection Site:
Means a place designated by the City where drivers present themselves for the purpose of
providing a specimen of their urine or breath to be analyzed for the presence of alcohol or
controlled substances. 49 C.F.R. § 40.3.
Commercial Motor Vehicle:
Means a motor vehicle or combination of motor vehicles used in commerce to transport
passengers or property if the motor vehicle (1) has a gross combination weight rating or gross
combination weight of 26,001 or more pounds, whoever is greater, inclusive of a towed unit(s)
with a gross vehicle weight rating or gross vehicle weight of more than 10,000 pounds,
whichever is greater; or (2) has a gross vehicle weight rating or gross vehicle weight of 26,001 or
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more pounds, whichever is greater; or (3) is designed to transport sixteen (16) or more
passengers, including the driver; or (4) is of any size and is used in the transportation of materials
found to be in the transportation of materials found to be hazardous for the purposes of the
Hazardous Materials Transportation Act (49 U.S.C. 5103(b)) and which require the motor
vehicle to be placarded under the Hazardous Materials Regulation. (49 C.F.R. part 172, subpart
F) § 382.107. Firetrucks and other emergency fire equipment are not considered to be
commercial vehicles under this policy.
Confirmation (or Confirmatory) Test:
For alcohol testing means a second test, following a positive non-evidential test, following a
positive non-evidential (e.g., saliva) screening test or a breath alcohol screening test with the
result of 0.02 or greater, that provides quantitative data of alcohol concentration. For controlled
substance testing, “Confirmation (or Confirmatory) Test” means a second analytical procedure to
identify the presence of a specific controlled substance or metabolite which is independent of the
screen test and which uses a different technique and chemical principal from that of the screen
test in order to ensure reliability and accuracy. 49 C.F.R. § 382.107.
Controlled Substance:
Means those substances identified in 49 C.F.R. § 40.85. Marijuana, amphetamines, opioids,
(including heroin), phencyclidine (PCP), cocaine, and any of their metabolites are included
within this definition. 49 (C.F.R. § 382.107; 49 C.F.R. § 40.85.
Department of Transportation or DOT:
Means the United States Department of Transportation.
Designated Representative: This is a role of the City Administrator or her/his designee. The
Designated Representative is able to receive communications and test results from service agents
and is authorized to take immediate actions to remove employees from safety-sensitive duties
and to make required decisions in the testing and evaluation processes.
DHHS:
Means the Department of Health & Human Services or any designee of the Secretary,
Department of Health & Human Services. 49 C.F.R. § 40.3.
Disabling Damage:
Means damage which precludes departure of a motor vehicle from the scene of the accident in its
usual manner in daylight after simple repairs, including damage to motor vehicles that could
have been driven, but would have been further damaged if so driven. Disabling damage does not
include damage which can be remedied temporarily at the scene of the accident without special
tools or parts, tire disablement without other damage even if no spare tire is available, headlight
or tail light damage or damage to turn signals, horn or windshield wipers which make them
inoperative. 49 C.F.R. § 382.107.
Driver:
Means any person who operates a commercial motor vehicle. This includes, but is not limited to
full-time, regularly employed drivers; casual, intermittent or occasional drivers; leased drivers
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and independent owner-operator contractors who are either directly employed by or under lease
to the City or who operate a commercial motor vehicle at the direction of or with the consent of
the City. For purposes of pre-employment testing, the term driver includes a person applying to
drive a commercial motor vehicle. 49 C.F.R. § 382.107.
Drug:
Has the same meaning as “controlled substance.”
Employee seeking a transfer:
Refers to an employee who is not subject to DOT regulations seeking a transfer to a position that
will subject them to DOT regulations in the sought after position.
Evidential Breath Testing Device or EBT:
Means a device approved by the National Highway Traffic Safety Administration (“NHTSA”)
for the evidential testing of breath and placed on NHTSA’s “Conforming Products List of
Evidential Breath Measurement Devices.” 49 C.F.R. § 40.3.
Federal Motor Carrier Safety Administration or FMCSA:
Means the Federal Motor Carrier Safety Administration of the United States Department of
Transportation.
Medical Review Officer or MRO:
Means a licensed physician (medical doctor or doctor of osteopathy) responsible for receiving
laboratory results generated by a controlled substance testing program who has knowledge of
substance abuse disorders and has appropriate medical training to interpret and evaluate an
individual’s confirmed positive test result together with his or her medical history and any other
relevant biomedical information. 49 C.F.R. § 40.3
Performing (a Safety-Sensitive Function):
Means any period in which a driver is actually performing, ready to perform, or immediately
available to perform any safety-sensitive functions. 49 C.F.R. § 382.107.
Positive Test Result:
Means a finding of the presence of alcohol or controlled substance, or their metabolites, in the
sample tested in levels at or above the threshold detection levels established by applicable law.
Reasonable Suspicion:
Means a belief a driver has engaged in conduct prohibited by the FMCSA controlled substance
and alcohol testing regulations, except when related solely to the possession of alcohol, based on
specific contemporaneous, articulable observations made by a supervisor or City Administrator
who has received appropriate training concerning the appearance, behavior, speech or body
odors of the driver. The determination of reasonable suspicion will be made in writing on a
Reasonable Suspicion Record Form during, just preceding, or just after the period of the work
day that the driver is required to be in compliance with this policy. In the case of a controlled
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substance, the observations may include indications of the chronic and withdrawal effects of a
controlled substance.
Safety-Sensitive Function:
Means all time from the time a driver begins to work or is required to be in readiness to work
until the time he or she is relieved from work and all responsibility for performing work. Safety -
sensitive functions include:
• All time at a city plant, terminal, facility, or other property, or on any public property,
• waiting to be dispatched, unless the driver has been relieved from duty by the employer;
• All time inspecting equipment as required by 49 C.F.R. § 392.7 and 392.8 or otherwise
inspecting, servicing, or conditioning any commercial motor vehicle at any time;
• All time spent at the driving controls of a commercial motor vehicle in operation;
• All time, other than driving time, in or upon any commercial motor vehicle except time spent
resting in a sleeper berth (a berth conforming to the requirements of 49 C.F.R. § 393.76);
• All time loading or unloading a vehicle, supervising, or assisting in the loading or unloading,
attending a vehicle being loaded or unloaded, remaining in readiness to operate the vehicle,
or in giving or receiving receipts for shipments loaded or unloaded; and
• All time repairing, obtaining assistance, or remaining in attendance upon a disabled vehicle.
49 C.F.R. § 382.107.
Screening Test (also known as Initial Test):
In alcohol testing, mean an analytical procedure to determine whether a driver may have a
prohibited concentration of alcohol in her or her system. Screening tests may be conducted by
utilizing a non-evidential screening device included by the National Highway Traffic
Administration on its conforming products list (e.g., a saliva screening device) or an evidential
breath testing device (“EBT”) operated by a trained breath alcohol technician (“BAT”). In
controlled substance testing, “Screening Test” means an immunoassay screen to eliminate
“negative” urine specimens form further consideration. 49 C.F.R. § 382.107.
Substance Abuse Professional” or “SAP”:
Means a licensed physician (medical doctor or doctor of osteopathy), licensed or certified
psychologist, licensed or certified social worker, licensed or certified employee assistance
professional, or licensed or certified addiction counselor (certified by the National Association of
Alcoholism and Controlled Substance Abuse Counselors Certification Commission) with
knowledge of and clinical experience in the diagnosis and treatment of alcohol and controlled
substance-related disorders. 49 C.F.R. § 40.281.