Setting-Up a Random Pool of Employees
Who gets tested?
Regardless of job titles like supervisor, contractor, owner operators, etc., people are chosen for testing based on their job function (known as a safety-sensitive function) not their occupational title. Only DOT safety-sensitive employees may be part of the DOT random pool or pools.
Remember your DOT testing program must always be separate and distinct from your private company or non-DOT testing program. That goes for your random testing pools, too. DOT and non-DOT random testing pools must be completely separate
Testing Why are some people randomly tested more than once? The reality is that in a truly random selection process, a high probability exists that some employees will be selected several times while others may never be selected. Why? Because after each selection, the employee’s name is returned to the same pool, and he or she becomes just as likely as anyone else to be selected next time.
How are employees notified to report for a test? Every employee should be discreetly notified according to your company’s policy, but random testing must also be conducted in strict confidence with a limited number of people having knowledge of the selection list. Why? Because it helps maintain the element of surprise.
What happens if a selected employee is not available for testing? Employers need to have policies in place about what to do when employees are unavailable for testing.
Best Practices: · If an employee selected for testing is known to be unavailable during the selection cycle (legitimate extended absence, long-term illness, etc.), document the reason and make-up the rate shortfall by making another selection, or make an extra selection during the next selection cycle.
* No employee should be excused from testing because of operational difficulties.
Maintaining and Evaluating Your Random Program
It is the best practice for an employer to document everything on the entire random testing process. This includes the numbers, names drawn, dates and times of notification, dates and times of collections, why a selected employee was not tested during a selection cycle, etc. If you’re not sure, document it!
What must employees do when notified of a random test?
When an employee is notified, he or she must proceed immediately to the collection site. Contrary to the urban legends circulating among some employees, immediately does not mean two hours. Immediately means that after notification, all the employee’s actions must lead to an immediate specimen collection:
Best Practice: Many employers develop random testing procedures or policies that clearly state what activities are acceptable after notification: for instance, which safety-sensitive duties Agency regulations permit them to complete. If an employee is notified of a random test while working “off site” or “on the road,” the company’s policies should spell-out exactly what the employee must do before resuming safety-sensitive functions. That way there is no misunderstanding among employees about what is expected.