Waynes World - September 2010
THE ADVANTAGES & IMPORTANCE OF
JOINING AN ACCREDITED CONSORTIUM...
CSA 2010 AND DRUG &
ALCOHOL TESTING
by Wayne Schooling
When it comes down to the brass tacks of CSA 2010, there is simply no reason to take a chance on using a non-accredited drug testing program – your company’s safety record (and score) is at stake. Implementing your company’s drug and alcohol program is a significant undertaking and should not be based on price alone. It will involve lots of time and planning, which even some of the larger employers may find among the most complex and demanding elements of their safety programs. Small employers may be more seriously challenged.
One common method of reducing these challenges and their associated costs is to join a consortium. The term “consortium” is defined by the FMCSA as including, but not limited to, a group of employers who join together to administer DOT drug and alcohol testing programs. The FMCSA encourages all employers to consider the advantages of joining a consortium. Moreover, the FMCSA requires individual owner/drivers to be in a random pool of two or more persons.
The FMCSA regulations allow you to join a consortium comprised of employers of any transportation mode subject to DOT alcohol and drug testing regulations. If you’re smart, you will pick a consortium that is accredited. If the consortium is nationally accredited that is even better (it practically assures you that you will have no problems if you follow the rules). Employers who join a consortium will enjoy lower costs, greater expertise and a reduced administrative burden.
Like all businesses, drug and alcohol testing laboratories incur overhead costs as part of doing business. The same is true of collection sites, BATs, MROs and SAPs. When only a few tests are conducted or only a few drivers are evaluated, these costs can be substantial. When a larger number of tests are conducted or drivers evaluated, the overhead costs can be significantly reduced. Consortiums allow several small purchasers to combine their service needs and buy in bulk, thereby lowering their costs.
The DOT regulations are not simple. The main reason for joining an accredited consortium is for the greater expertise. By being accredited, the consortium’s facilities, operations and personnel meet the highest standards of ethics and competency. The regulations establish minimum standards, so many decisions are left to your management. That is why choosing the right consortium is so important. Many of the issues left to local option can have significant effects on your program’s cost and overall effectiveness, so joining a consortium that has a professional manager can be very helpful in determining which of the permissible approaches are best for you and your company.
Most of the managers at non-accredited consortiums have other job responsibilities. In cases of smaller employers and owner operators, those other responsibilities may already be overwhelming them, making them much more likely to make a mistake when trying to administer their drug and alcohol program. Joining an accredited consortium allows employers to pool resources and hire a professional manager to run the program. Depending upon the size of the consortium, the manager should be full time, and his or her salary, as well as consortium expenses, should be recovered through the money saved on expenditures for testing services.
The professional consortium manager should be able to devote their full attention to the testing regulations and to your testing program. Many non-accredited consortiums, such as local medical clinics, do not provide you with everything that is necessary for DOT compliance because they are often more interested to treating your sore back or some other physical condition you may have.
The administrative burden of operating a program in compliance with the many DOT regulations can be substantial. Procuring services, training employees and program personnel, maintaining proper chains of custody, collection equipment and facilities, maintaining the random pool, completing random selection and notification, quality assurance, record keeping and reporting can each be very time-consuming activities – and taken together, they can be daunting to any employer that wants to operate a first class safety program. An accredited consortium will assume responsibility for any or all of these activities, and because the services are provided for all employers as a whole, the cost to each individual employer will be substantially reduced.
Beyond cost savings and expertise is practicality – particularly for small employers. Maintaining of a random pool and selecting drivers for random testing can be difficult. The accredited consortium approach to managing random selection also has one other advantage. Some drivers fear that if an employer wished to target one driver, the employer could manipulate the random process to ensure that the driver was selected repeatedly or at specific times. Delegation of the random selection process to a consortium can minimize the employer’s control and ease driver concerns.
An employer that employs only him or herself as a driver MUST join a random pool. Therefore, it is to their advantage to join an accredited consortium with a random pool. The FMCSA believes these individuals, by definition, cannot select themselves for a random test. The test therefore cannot be unannounced and the intent of the random testing provisions of the regulations cannot be met by individuals who are not members of a random pool consisting of two or more drivers. Using an accredited consortium may distance employers from the actual operation of the testing program, but employers still remain responsible for program actions. When choosing a consortium, you should consult the Drug & Alcohol Testing Industry Association (DATIA) to find the accredited consortium that best fits your needs.
The FMCSA just announced they will publish on August 16, 2010 the revised CSA 2010 Methodology, and one of the revisions deals with the Controlled Substances/Alcohol BASIC Category. Don’t miss next month’s 10-4 Magazine for these latest updates on the ever-changing CSA 2010 rules!
~ NTA is a name and organization you can trust. Not only is our website (www.ntassoc.com) an official US DOT Internet Training Site, but we are also the administrators of a Nationally Accredited Drug and Alcohol Program. If you have any questions, call me at (562) 279-0557 or send me an e-mail at wayne@ntassoc.com. Until next month, “Drive Safe – Drive Smart!”