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Post-Accident Testing: Thresholds, Procedures, and Regulatory Requirements

Learn about the criteria, decision-making procedures, and regulatory requirements for post-accident drug and alcohol testing in the FTA program. Understand when testing is required and how to properly document and handle different scenarios. Ask questions to the experts, Ed VanderPloeg and Jack Mastrangelo.

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Post-Accident Testing: Thresholds, Procedures, and Regulatory Requirements

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Presentation Transcript

  1. FTA Post-Accident TestingTesting Thresholds, Decision-Making Procedures, and Regulatory RequirementsEd VanderPloeg and Jack MastrangeloFTA Drug and Alcohol Program Auditors

  2. What is an Accident? • Accident: an event associated with the operation of a revenue service vehicle, whether or not the vehicle is in revenue service (includes in the yard)

  3. Order of Investigation • Criteria • Contributors/Clearances

  4. Criteria • Fatality • Disabling Damage to any vehicle • Injuries requiring immediate medical treatment away from the scene

  5. Disabling Damage • A vehicle can not proceed under its own power without further damaging itself • Usually requires towing • Cannot be easily repaired at the scene: wipers, head/signal lights, tires, etc.

  6. Injuries • An individual receives immediate medical attention away from the scene • Transported to medical facility by any means

  7. Actions On the Scene • What steps do you take?

  8. What Happened? • How is this determined?

  9. Drug & Alcohol Testing Priority • All medical and treatment considerations must be addressed • All safety considerations should be addressed • The site or scene must be secured • No further requirements from Law Enforcement • No further information immediately required from the operator

  10. Slip & Fall?

  11. Slip & Fall? • Was there a collision? • Was the fall related to a maneuver? • Was the maneuver consistent with the expected movements associated with the safe operation of the vehicle? • Example: swerving to avoid a pedestrian who runs out into the road

  12. Factors that do not trigger Post-Accident testing • Dollar amount of damage • Driver citation • Insurance or Company requirement • “Just to be safe” • Reasonable Suspicion indications • At-fault/preventable

  13. Steps In Ordering a Test • Establish that at least one of the three criteria have been reached • Establish possible contributors (operator, mechanic, etc.) • Use event-specific facts to rule out all possible contributors • If the performance of one or more SSE can not be discounted, order the test

  14. Review (to this point) • Criteria? Fatality, Disabling Damage, Injuries? • Contributors? Safety-sensitive employee involvement? • Clearances? Who can be reasonably ruled out? • Clock? How long has it been since the accident?

  15. Time Limitations on Post Accident Testing • Alcohol • Clock starts at time of accident • Document after 2 hours • Cannot test after 8 hours • Alcohol test first

  16. Time Limitations on Post-Accident Testing (Cont.) • Drugs • Test should be performed as soon as possible, but no more than 32 hours following the accident • After 32 hours, a USDOT test will no longer be valid

  17. Documentation (See Post-Accident Form)

  18. Scenarios & Discussion/Analysis

  19. Analysis:

  20. Analysis:

  21. Making the Call • Use the best information available at the scene • Order an FTA test, a transit authority test, or no test • Examine and debrief with others afterwards • As a supervisor, YOU are responsible for making the determination to test

  22. Acceptance of Other Test Results • In the rare event the employee cannot participate in the FTA collection process, following an accident, the employer may accept the results of a test performed by Federal, State, or local officials if results are released • Employer must document why DOT test was not performed within time period

  23. Employee MUST give consent • Dead or unconscious employees may NOT be tested • Every test must include the employee signing the ATF/CCF*. • Refusals must be recognized by the regulations (as listed) *Though an employee may refuse to sign the drug CCF, they must consent to testing by providing a urine sample to the collector. An employee may not refuse to sign the alcohol testing form (ATF).

  24. Common Problems: Post-Accident Testing • FTA thresholds not met, but test still done • Delayed, or even no test • Ill-defined policies • No documented procedure for decision-making • Poorly trained company official • Lack of company official empowerment • Testing “Just to be safe”

  25. Final Discussion

  26. The EndEd and Jack will be available for questions immediately following this session.

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