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-Email, 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 GoalTotal 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-AccidentMaking 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 IssuesCollection 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 email
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) 494-6336
Sample Policy & Policy Checklist Notification Form Tracking Form
Available at:http://transit-safety.volpe.dot.gov/DrugAndAlcohol/Training/NatConf/2014/Sessions.aspx
Or
http://tinyurl.com/kzrgkcr
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: http://tinyurl.com/kj43xka