FTA Drug and Alcohol Testing Compliance Audit

Inspection template for auditing a transit agency’s drug and alcohol testing program against 49 CFR Part 655, including policy controls, covered employee pools, random testing readiness, and MIS reporting for annual certification.

Audit Scope and Program Setup

• Audit period and agency scope documented
  Record the audit period, transit service types covered, and the departments or subsidiaries included in scope.
• Current drug and alcohol program owner identified
  Identify the responsible program manager, designated employer representative, or compliance owner.
• Reference documents available for review
  Select the documents reviewed during the audit.

Written Policy and Employee Notice

• Written policy references FTA 49 CFR Part 655
  Policy explicitly cites the applicable FTA drug and alcohol testing requirements.
• Policy includes prohibited conduct, testing triggers, and consequences
  Policy addresses prohibited drug and alcohol use, required testing circumstances, and disciplinary or removal consequences.
• Employee notice and acknowledgment process documented
  Agency can show how covered employees receive the policy and acknowledge receipt.
• Policy revision date is current and controlled
  Record the most recent policy revision or effective date and verify version control.

Covered Employee Roster and Testing Pools

• Covered employee roster is current and complete
  Roster includes all safety-sensitive employees subject to FTA testing and excludes non-covered staff.
• Random testing pools are maintained separately for drug and alcohol testing
  Pools are organized so random selections can be administered according to the applicable testing categories.
• Pool updates reflect hires, transfers, leaves, and terminations
  Evidence shows timely updates when employees enter or leave safety-sensitive status.
• Random selection records retained for the audit period
  Agency can produce selection reports, notification records, and completion evidence for the review period.

Testing Operations and Chain of Custody

• Collection process uses approved procedures and qualified collectors
  Collection records show use of proper procedures and trained personnel for drug and alcohol testing events.
• Chain-of-custody documentation is complete and traceable
  Forms and records support specimen integrity from collection through laboratory or testing vendor receipt.
• Positive, refusal, and other non-negative results are documented and acted upon
  Agency can show timely removal-from-duty, referral, or other required response steps.
• Testing vendor and medical review processes are defined
  Third-party roles, result review, and notification responsibilities are documented and understood.

Training, Supervisor Readiness, and Records

• Supervisors receive reasonable suspicion training as required
  Training records show supervisors who make reasonable suspicion determinations are current.
• Employee education and awareness materials are available
  The agency provides training or awareness materials covering policy expectations and reporting obligations.
• Records retention process supports audit retrieval
  Testing, training, and policy records can be retrieved promptly for the audit period.
• Record storage protects confidentiality and access control
  Sensitive records are stored with appropriate access restrictions and confidentiality safeguards.

MIS Reporting and Annual Certification Readiness

• Most recent MIS report is complete and submitted on time
  The latest annual MIS submission is available and shows timely filing.
• MIS data matches source records
  Reported counts for covered employees, tests, positives, refusals, and other required metrics reconcile to source documentation.
• Annual certification readiness issues identified
  Select any issues that could affect annual certification readiness.
• Corrective action plan assigned for findings
  Any deficiencies identified during the audit have an owner, due date, and follow-up plan.

Findings, Corrective Actions, and Inspector Sign-Off

• Summary of deficiencies and non-conformances
  Summarize all findings, including critical items, root causes, and affected program areas.
• Corrective action owner and due date
  List the responsible owner and target completion date for each corrective action.
• Inspector signature
  Inspector confirms the audit results are accurate and complete.