As you know, the D.O.T. Research and Special Programs Administration requires Pipeline Operators and their contractors that perform certain safety sensitive functions to maintain an Anti-Drug and Alcohol testing program that complies with all the guidelines set forth in 49 CFR Parts 40 and 199. These guidelines require that Operator and the Contractor to:

• Write and maintain both corporate and federal drug and alcohol policies

• Adhere to all federal recordkeeping and reporting protocols

• Train supervisory personnel

• Offer an Employee Assistance Program (EAP)

• Ensure that employees are randomly screened for 5 specific drugs at precise concentration levels by a properly certified government approved laboratory

• Ensure that drug and alcohol testing is conducted appropriately and as required by federal regulations

• Have all test results reviewed by a Medical Review Officer (MRO)

• Conduct alcohol a testing utilizing DOT approved instruments

• Provide referral to a qualified Substance Abuse Professional (SAP) for evaluation

Failure to comply with any of the above requirements can result in fines and penalties as well as the obvious civil liability exposure (for the Pipeline Operator) and the failure and/or loss of contracts on the part of the Pipeline contractors.

• Provide your written Anti-Drug and Alcohol Misuse Prevention policies.  We have developed written policies, which have been approved by the FMCSA and FTA, Pipeline Operators (and their auditing agencies) across the country, and the U.S. Coast Guard.  As the regulations are modified (which they are continually) we provide updates at no additional fee*, so you remain in compliance.
• Maintain your DOT covered employees in our database.  Each employee is assigned to each DOT operating agency under which the employee is regulated.  This ensures that each employee is tested properly according to the administration regulating him/her.
• Provide computer generated random selections.  Random lists are provided quarterly.  The random testing is monitored to ensure that the proper percentage of randoms is conducted.
• Process urine specimens in a SAMHSA certified laboratory.
• Provide MRO services for DOT tests. (MRO services are also available for positive Non-DOT tests for an extra fee.)
• Provide a confirmation of testing letter for each employee DOT tested.
• Provide and submit blind specimen testing on your behalf.
• Maintain all drug / alcohol statistics and records in password protected computer database.  Actual “hard copies” of all records are kept in locked secure storage on-site at our facility.
• Provide Return-to-Duty / Follow-up testing and monitoring.  CMI will track and schedule required Return-to-Duty and Follow-up testing of employees who have engaged in prohibited conduct and been placed into a follow-up program.
• Provide Substance Abuse Professional (SAP) referral services.  DOT requires that an employee who violates the substance abuse program prohibitions be referred to a SAP for a face to face evaluation.  The employee must comply with SAP recommendations prior to returning to duty in a covered function.
• Ensure alcohol testing is conducted by a certified technician and that only approved devices are used for alcohol testing.
• Provide all required record keeping and reporting.  This will include preparing and submitting MIS reports each year.
• Prepare and submit audit responses and compliance certification.  If you are a contractor who performs covered functions for pipeline operators, you will frequently be required to submit documentation of compliance to the operator or auditing agency monitoring contractor compliance on behalf of the operator.