A sunny day in Ketchikan. OK – so I did wear my winter coat to work. Yesterday it was snowing, today is sunny and beautiful, but cold. Hard to believe that our Ketchikan and Juneau locations will soon have cruise ship visitors. Cruise visitors bring a renewed energy to our island communities. As seasonal employees start to arrive, our offices see an influx of traffic for pre-employment drug screening. Our Keokuk, Iowa office also has an influx, but of a construction driven industry, instead of tourism. Random drug screening will be a large part of keeping these employees safe during the summer season. As the consortium manager, our job is to make sure your selections and collections are done in an appropriate manner, in line with federal and state regulations. The assistance of the Designated Employer Representative in very important in the compliance side of random testing. Updating your employee roster frequently allows the TSS staff to be sure that the numbers are accurate in our pool selection. Communication is a critical piece of your drug free workplace program. The DER also receives results and follows through on the recommendations from the Medical Review Officer and/or the Substance Abuse Professional, if necessary. The DER job is no small feat. TSS offers DER training several times per year. Not only will this help you do your job, but it will help us do a better job for your company, if you understand how the process works. Question for the day: Suppose the Substance Abuse Professional fails to make the required recommendation for education and/or treatment of an employee who has violated a DOT agency drug or alcohol testing rule, and sends the employee back to the employer for a Return to Duty test. What should the employer do? ANSWER: Do not administer a Return to Duty test under these circumstances. Refer the employee back to the Substance Abuse Professional (SAP) with direction to prescribe direction for education and/or treatment and conduct a re-evaluation of the employee to determine whether the employee has successfully complied with the SAP’s instructions. This means the employee should be removed from performing safety sensitive duties until the regulations have been followed. SEE 49 CFR Part 40 (40.291 & 40.293)

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