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

PolicyThe 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-EmploymentThe 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)

RandomThe 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 DiscussionImmediate 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