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With many municipalities furloughing some or all of their public works or highway department employees during this pandemic, a question has arisen as to whether it is still necessary perform federally mandated drug and alcohol testing for employees operating commercial motor vehicles (CMVs). Some PACIF members have questioned whether testing is still required, while others have struggled to coordinate the testing of their employees.

The U.S. Department of Transportation (DOT) has provided guidance on drug and alcohol testing for commercial motor vehicle operators, during the pandemic. In essence, it requires the employer of CMV operators to continue to complete the random testing, whenever possible as outlined in this federal guidance. The requirement to complete the testing still applies to employees who are furloughed but on call in the event of an emergency. DOT does allow employers to notify these “off-duty” operators of a scheduled test, with the caveat that the notified employee immediately proceed to the testing location. You can find that guidance in this part of the regulations under question 17.

Based on federal DOT guidance, members should advise their furloughed employees that they are subject to FMCSA random drug and alcohol testing during the period of furlough, unless there is no expectation that they will be called in to respond to an emergency event. After such notification, members are encouraged to work with DISA to coordinate random drug testing when requested to do so.

DISA mobile collectors are up and running with enhanced cleaning and safety protocols in place – which follow CDC COVID-19 guidelines to prevent COVID transmission and ensure the safety of the tester and tested individual. Responding promptly to scheduling requests will prevent a testing backlog in June which could overwhelm our testing partner - and potentially adversely affect program compliance. Members can reach out to DISA’s Vermont Collection Manager, Wesley “Jamie” Davis by calling (802) 839-0171 or by emailing him at Wesley.davis@disa.com to schedule testing.

If you have any questions or concerns regarding the need to test, you are always welcome to reach out to PACIF Loss Control staff at losscontrol@vlct.org.