By: Tommy Eden, Attorney
a. Filling out Step 1-D on Copy 1 of the new CCF, which now includes the Federal testing authorities – HHS; DOT; and Nuclear Regulatory Commission (NRC), with further specificity for the DOT Agencies – FMCSA; FAA; FRA; FTA; PHMSA; and the USCG;
• In harmonizing with HHS, Part 40 will require mandatory reporting of confirmed positive drug / drug metabolite quantitations by laboratories to MROs.
Common Sense Counsel: All DOT-regulated employers should update their drug and alcohol testing procedures to incorporate these changes by the October 1st implementation date. Those employers who fail to do so risk DOT fines of up to $10,000.
Tommy Eden is a Lee County native, an attorney with the local office of Constangy, Brooks & Smith, LLP and a member of the ABA Section of Labor and Employment Law and serves on the Board of Directors for the East Alabama SHRM Chapter. He can be contacted at firstname.lastname@example.org or 334-246-2901. Blog at www.alabamaatwork.com