“Randomly” schedule drug testing

Sometimes, the best laid plans are random.

Usually, the sign of a well run program is evident by how well the manager is organized and how consistent they are in meeting their minimum requirements and goals. This type of a structured program takes the guess work out of the equation and allows the employees to act in a predictable manner that produces the desired results. However, this should not be the blueprint for a random drug testing program.

The whole concept of “random” is an activity without an identifiable pattern, plan, system, or connection. Ironically, a random drug testing program should be a well thought out plan and system which tests at least 50 percent of the average number of drivers operating a commercial motor vehicle for controlled substances and 10 percent of the average number of drivers for alcohol.

Who gets tested among this 50 and 10 percent of CDL drivers must be a random method and often times is generated by a computer program that matches a number associated to a driver. This number can be the driver’s social security number, driver’s license number, employee ID number, or any other numbering system that identifies the driver. Each driver must have an equal chance to be tested each time the testing cycle occurs, even if the same driver is selected in previous cycles.

The Federal Motor Carrier Safety Administration (FMCSA) does not address the number of testing cycles a motor carrier must perform. It is up to the carrier’s discretion to determine if this should be a monthly, bi-monthly, or quarterly event, so long as the year is evenly broken up among the proper number of drivers required to be tested.

Where the term “random” should definitely not be an identifiable pattern is in the scheduling of these tests. If a carrier is testing on a monthly basis, and the selected drivers are sent for testing during the first week of every month, the element of surprise is partially eliminated. Once a pattern is established, drivers will be able to time a series of events and adjust their activities around them. For random drug testing purposes, this predictability could skew the results and allow the non-tested driver an opportunity to engage in prohibited activity thinking they were safe until the same time next month.

If monthly random testing is the cycle used to satisfy FMCSA requirements, the motor carrier must make sure the testing days are varied throughout each individual month so that no deliberate and identifiable pattern can be determined.

Therefore, a random system of unscheduled events can prove to be a well managed program!

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