Independents/small carriers, before you enter a relationship with a drug/alcohol testing consortium, says Richard Wilson, regulatory manager for the Trans Products Trans Services firm, specializing in fitting various administrative/ consulting needs for smaller carriers, make certain the consortium is doing the job it’s supposed to be doing.
Namely, that’s random-testing pools of drivers for alcohol at the rate of 10 percent in any given year and for drugs at 50 percent. If you don’t ensure they can and will do what they’re supposed to, and they then drop the ball on it due to a scenario like the one Wilson describes in the video below, you could find yourself in trouble with the feds.
The vid is a brief selection from a wide-ranging talk I had with Wilson on the occasion of the MCSAC CSA Subcommittee meetings early in the month. He described to me how, in his work with small carriers, he’s seen FMCSA’s focused on-site interventions creep into full compliance reviews or non-ratable reviews when carriers were seen to have problems in areas outside the intervention’s purpose.
“If you have an intervention,” Wilson says, whether it comes in the form of a warning letter about a rising CSA BASIC (Behavioral Analysis and Safety Improvement Category) score or an on-site investigation, “take it seriously. … An experienced auditor can very quickly assess a carrier’s safety operation” to know whether or not he will be able to find violations.
And, he adds, “they look at it this way – if you’re lacking in one area with a corrective action policy – you’re going to be lacking in another. They say, ‘While we’re here why don’t you pull me a couple of qualification files on these particular drivers here.’ They review them and look for the basics. Are medical cards up to date? Did you do an annual review of the driver’s MVR and an annual summary to see they’re still qualified? If they discover violations during that quick pass-through – for instance, say qualification files aren’t maintained correctly, etc. — and the carrier shows a lack of organization, that will open a door to another area, which usually leads into maintenance. Now, that’s not 100 percent, but I have seen it happen” frequently.
Likewise drug and alcohol. Here’s what he had to say about procedures for pre-auditing your testing consortium and/or monitoring their performance along the way:
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The National Association of Small Trucking Companies has model language for an effective drug/alcohol policy for small carriers that is a benefit of membership — having such a written policy will keep you in compliance with those requirements of employers, if you have a driver working with or for you. Find more about their program here.