The Federal Transit Administration (FTA) regularly sends drug and alcohol audit teams out to visit covered employers to check their drug and alcohol testing programs. (Learn more in Drug and Alcohol Program Best Practices). While you may dread getting a notification letter, the FTA audit team sees these audits as having two main purposes:
To ensure compliance with 49 CFR Part 655 and Part 40, and
To offer an opportunity for providing technical assistance to stakeholders
When your business receives a notice letter informing you of a pending audit, prepare for it with this dual purpose in mind.
By considering how your drug and alcohol compliance program can be made better, and not just how you can be dinged because some part of it doesn’t meet the standard, you can work through the audit with a focus on improvement.
Here are a few steps to take to prepare for an FTA drug and alcohol compliance audit.
Read your audit notification carefully
Make sure you understand what the notification letter says and what will be expected of you and your team during the audit and site visit. Note the scheduled date for the site visit. It should be about six weeks out from the date on the notification letter.
Contact the FTA audit team leader with any questions or concerns
If you have questions about your audit or concerns about what’s expected it’s best to get them dealt with up front. Reach out at any point while you are preparing for the site visit. Don’t wait until the site audit is underway. That will most likely be too late. Remember, part of the FTA audit team’s purpose is to provide technical assistance.
Notify all relevant contractors and vendors
The audit will most likely involve some or all of the service agents you are working with. Be sure to let them know that an audit is coming up as soon as possible. Tell them the focus of the audit and the scheduled date for the site visit. Then work with them to make sure that you both are prepared to successfully complete the audit.
Send requested information to the FTA audit team by the due date
Your notification letter will list all the documents and information the FTA needs to receive in advance of the site visit. Work with your in-house compliance team and your service agents to gather the required information.
Submit all the requested information the FTA audit team by the deadline listed in your notification letter.
Gather the documents that need to be available for review in advance of the on-site visit
About a week before the scheduled site visit you will receive a notification of the specific records that need to be available for review during the site visit.
Work with your in-house compliance team and service agents to collect these documents in advance of the scheduled visit.
Again, if you are uncertain about what’s required or have any questions be sure to contact the FTA audit team leader to resolve them before the scheduled on-site visit.
Organize all the requested documents
You want to have all the required records organized and ready for review before the FTA audit team arrives on site. This will save time and help the audit process go smoothly.
Think about any questions that you still have
Remember, the FTA audit team is there to provide technical assistance as well as check for compliance. At some point during the on-site visit you will have an opportunity to discuss best practices and address questions. Use this opportunity to learn how you can strengthen your drug and alcohol testing and compliance program. (Learn more in The Importance of a Good Drug and Alcohol Policy In The Workplace).
Stay current with tools and resources from the FTA
After completing a FTA drug and alcohol compliance audit you will want to stay current on the regulations and best practices. This will make it easier for you to keep your testing program in compliance and ensure safety in the workplace, on the roads, and on the rails.
One way to stay up-to-date is to take a look at the materials available on the FTA’s website which includes a comprehensive collection of tools and resources to help employers understand and comply with its drug and alcohol testing requirements.
Familiarize yourself with the information available. You will find everything from general guidance on what employers and employees need to know to a detailed checklist for assessing your company’s level of compliance with the FTA and DOT regulations.
Also, keep current with the FTA drug and alcohol testing program and the department’s practices by reading its quarterly newsletter. Recent issues addressed the risks of using mobile collection sites and announced the latest published amendments to 49 CFR Part 40.
Ultimately the value of successfully completing an FTA drug and alcohol compliance audit is that it helps maintain safety in the transportation industry for both employees and the public. While the audit process requires a fair amount of work, the benefits that come from a successful outcome far outweigh the effort required.