Drug and alcohol program audits can be conducted by a number of different entities. Employers that are performing Department of Transportation (DOT) covered work will generally be audited by the federal agency in which they are performing covered functions. Although DOT audits are often viewed as the most stringent, employers may also be subject to audits at the state, municipal, or contractual level. Regardless of who the auditing party is, the overall goal for the auditor is to evaluate an employer’s safety performance and to ensure recordkeeping practices are complete and compliant with all applicable requirements.
The DOT agencies that conduct audits include the Federal Motor Carriers Safety Administration (FMCSA), Pipeline and Hazardous Materials Safety Administration (PHMSA), Federal Aviation Administration (FAA), Federal Transit Authority (FTA), Federal Railroad Authority (FRA), and the United States Coast Guard (USCG). It is important for employers to understand that each DOT agency has their own set of regulations that must be followed. If any employer is performing work under multiple DOT agencies, they may be subject to drug and alcohol program audits by more than one federal agency. Therefore, employers must know which agencies they fall under and which employees may be considered “covered employees” under each agency.
Program audits are usually not regularly scheduled events and under general circumstances an audit will occur when the auditing party is available for the audit. For Alaska, DOT auditors will typically try to audit as many companies as possible during their on-site visit. Audits may also occur if a violation is reported. For example, an accident may prompt a post-incident investigation to include an audit of the company’s drug and alcohol policies and records.
Depending on who the auditing entity is, different items may be reviewed throughout the audit. When it comes to a company’s drug and alcohol testing program, the auditor’s number one priority is to ensure that the employer is maintaining compliance with applicable regulations. Items such a company’s drug and alcohol plan will be reviewed to ensure it is being followed. Auditors will also review any type of non-negative test result. They will look to ensure that proper documentation accompanies all post-accident tests, reasonable cause tests, positive tests, and refusals to test. Some employers may also have employees participate in a return-to-work or follow-up testing program. Auditors will need to see all documents pertaining to these programs, including communication received from a substance abuse professional (SAP). Most companies are required to have supervisor training. Auditors will confirm that these requirements are being met.
Preparing for an audit can seem like a daunting task to many employers. In reality, preparing for an audit can be a smooth process as long as the employer fully understands the requirements and expectations. These requirements can be found on the DOT website and should also be included in a company’s drug and alcohol plan. Companies that are being audited for contractual compliance should have access to these requirements from the entity that oversees the drug and alcohol program. Additionally, mock audits can help an employer prepare for a true audit. Mock audits can be performed by other contractors or even internally.
Employers may often wonder why they are being audited. The number one priority with a drug and alcohol program audit is to ensure safety and compliance. An auditor will notify the employer prior to the actual audit. The employer will also be given a period of time to correct any violations that may have been discovered throughout the audit. While a drug and alcohol program audit may seem like concern, the benefit of a successful audit is an employer being fully compliant and having an effective drug and alcohol testing program.