to provide you with a paper trail so you can show compliance (or atempts at compliance) in the event of an au- dit, however, if they cannot, make sure that you always have documentation explaining the causation of any irregu- larities in your programs data, or the cause of any inaccessible documents.
DOT Audits Under the U.S. Department of Transportation (DOT), companies with employees in safety-sensitive positions mandated by the DOT must abide by a specific DOT drug and alcohol testing policy and requirements. Companies must have a Designated Employee Representative (DER) who manages the policy. Typically, the DER is someone in human resources, risk management, safety, or security. Some employers may have both a non-regulated policy, as well as a DOT policy to cover employees who may or may not hold a safety- sensitive position. Ultimately, DOT auditors are looking
to determine if your company is in compliance with the federal regulations of DOT drug and alcohol testing.
DOT auditors check: Does your company: • Have a writen DOT-compliant substance abuse policy?
• Ensure that supervisors are trained via DOT-compliant reasonable suspicion training?
• Request drug test records from employees’ previous employers?
Are your employees: • Given educational materials about substance abuse?
• Enrolled in a random drug testing program?
• Recipients of a negative pre-employment test result? Many other questions may and will be asked. If you are prepared, it should be
www.datia.org
a breeze. For more information on the DOT’s current drug and alcohol testing requirements, click here.
Non-DOT (or Client Required) Audits
For companies that are not specifically reporting safety-sensitive employee drug- testing data to the DOT it is important to note that the questions asked by a non-DOT auditor will be largely similar, but they can always ask for more. Make sure that you clearly understand what is required by the Third-Party Auditing Agency and prepare by using the tips above. The costs of non-compliance can be
significant, and audits may be scary, but a level-head goes a long way. Preparation is key and as long as you remain aware of what is required and ensure the accessibility and accuracy of your records, your next audit shouldn’t be a painful experience. ❚
Colinda Howard is the Director of Compliance for DISA Global Solutions, an industry-leading drug testing company since 1982. Colinda is a licensed
attorney with twenty years of experience managing legal, investigations, compliance and ethics issues focused on consumer bankruptcy, real estate, human resources, retail compliance and risk management with a specific emphasis on alcohol, tobacco, and firearms. Her employment has spanned both the public and private sectors and most recently a Fortune 5 corporation where she leads innovative compliance programs for more than 5,000 retail stores. Colinda manages the team that is responsible for ensuring DISA and our customer’s compliance with state and federal laws focused on drug/alcohol test- ing and background screening. Outside of her professional role, Colinda is a portrait photographer and avid reader.
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When it comes to any type of compliance audit, the old saying, “an ounce of prevention is worth a pound of cure” rings true.
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