Turning over a motorcoach carriers federally required random drug and alcohol testing to a third party doesnt relieve the coach operator of the responsibility of seeing that the program is run properly.

Instead, it should make them even more vigilant.

The rules set by government regulators for testing drivers and other workers assigned to safety-sensitive jobs can be complicated, creating a need for someone in the company to become extremely familiar with them and to carefully monitor the program.

The random testing mandated by the Federal Motor Carrier Safety Administration is aimed at deterring individuals in safety-sensitive positions from using illegal drugs and misusing alcohol. If they dont know when they might be tested, regulators say, then drivers and mechanics will be less likely to use drugs or misuse alcohol.

Under the rules, each person in the random testing pool must have an equal chance of being selected, testing must be spread evenly through out the year and test times should not be predictable.

Here are tips that could help you make sure your program meets federal government requirements:

Do not select the pool a year ahead of time or even on a quarterly basis because people hired after the selection would not be subject to immediate testing.

Place all new employees who required testing in the testing pool immediately after they are hired, and remove those workers who are no longer in safety-sensitive jobs or who have left the company.

If someone is not tested during the selection cycle, they cannot be tested during the next selection period. However, if the person was not tested, then their name must be returned to the pool for the next selection time frame.

An individual can be tested at any time during the selection time frame and it is up to the employer to know the workers work and vacation schedules and to make sure they are available when called in to be tested. Selecting a substitute who might be more readily available is not permitted.

Employees who are placed on extended sick leave and will be gone for the entire test period can be removed from the pool and be replaced by an alternate.

An individual cannot be required to report for a test in the middle of vacation time, while sick, or on other types of excused leave. The individual, however, may be called in for work and then be tested.

Operators should keep in mind, too, that the random testing is a "short notice" test and the individual should not be given excessive notification time to be tested.

For example, an employee should not be told at the beginning of his or her work shift that they are to report to a clinic for a drug test at the end of the shift. Such notification would give them time to drink large amounts of water to dilute the specimen, obtain products to adulterate the specimen or obtain substituted urine specimens.

FMCSA directs employers to ensure that once a selected individual is notified, they proceed immediately to the collection site. If an operator knows that an employee will be unable to leave the work site promptly, they should not be notified until such time as they are able to leave.

Also, the definition of "immediately" should be clearly spelled out in the employers drug and alcohol testing policy. For example, if the collection site is within five minutes of the work site, the policy should say that when an individual leaves to go to the collection site, they must arrive within 10 or 15 minutes or it will be considered a refusal.

The rules differ a little between drug and alcohol testing.

An employee is subject to random alcohol testing only while performing safety-sensitive functions or just before or just after they perform such functions. Performing a safety-sensitive function includes being immediately available to work in such a position. This means that a worker who is doing clerical work, but is available to drive, is subject to random alcohol testing.

Additionally, testing for alcohol should not be confined only to just before an employee begins work. Instead, some tests should be scheduled during the shift or immediately after the shift.

And, finally, individuals covered by FMCSA rules and those who are not cannot be mixed in the same testing pool. You may have one random testing pool for both drugs and alcohol provided you have documentation of how the process works and that the method is scientifically valid and impartial regarding who gets selected. Or, you may have two separate pools, one for drugs and one for alcohol testing.

The bottom line is that operators need to be sure they have documentation for all of their testing procedures and the actual testing.