How is random drug testing affected by COVID-19?
DOT has not released any guidance in regards to the coronavirus and random testing. The expectation is still to meet the minimum % rates per DOT agency. Per the CDC you want to ensure the safety of all your employees. We understand right now may be a difficult time to get employees tested. Here are some reminders on best practices for random testing in general. We will keep you informed if we learn of any changes.
Please make sure to contact the collection sites prior to sending anyone for testing. Some of the collection sites may not be performing collections currently. They may have limited hours, may require appointments to reduce wait times, or they may not be collecting at all. We want to stop the spread of the virus and follow all local, state, and federal requirements and suggestions.
Random Testing
- A scientifically sound method must be used for random selections
- Each employee must have an equal chance of being selected for drugs and/or alcohol
- The random pool must be updated before each selection is done
- Old names removed/new employees added as necessary
Random selections should be done as frequently as possible but no less than quarterly. Choose alternates ONLY if the employee initially selected will be unavailable the ENTIRE selection period
Only DOT safety-sensitive employees can be included in the random testing pool. Tests should be distributed:
· Throughout all period of operation
· Spread throughout the week/month/year
· Include weekends/holidays/if your safety-sensitive employees work during those times
You can combine different MODES but you must test at the HIGHEST random testing rate applicable.
Best Practice #1
When your testing period expires it is best to close down that list and start on the new list. If you have an employee that was not tested during that period, document why they were not tested. At mid-point in the year confirm you are meeting your regulatory requirements and adjust your section % as necessary to stay on track for the year.
- Drug Testing can be performed anytime the employee is on duty
- Alcohol Testing can only be conducted just before/during and or directly after the performance of safety-sensitive duty
Best Practice #2
Service agents and C/TPAs providing random selection and testing services to employers should monitor on an ongoing basis (daily or weekly) the random tests that have been completed and compare them to those that were selected. If a random test has not been completed in an acceptable timeframe (within a day or week) of the expected test date, the service agent or C/TPA should contact the employer to determine the status of the test and take the necessary steps to ensure the test is completed within the selection period. Employers, service agents, and C/TPA should not wait until the end of the selection period to reconcile the random testing numbers. This is a weak business practice that we want to discourage.
Best practice #3
Closeout your 1st quarter testing when you receive your 2nd quarter selections. However, you can also roll them into the 2nd quarter and continue to test. You would just need to ensure that any employee available for testing during the 2020 year is tested by 12.31.2020. You could not roll the 1st quarter into the 2nd quarter and then excuse someone in the 3rd quarter for being absent if they were available in the 4th quarter to test. All testing must be completed by 12.31.2020 it would not roll over into the next year. This would also apply to monthly testing as well.