Testing controls
Drug & Alcohol Program Evidence for a New Entrant Audit
What a carrier should be able to prove about enrollment, testing decisions, Clearinghouse duties, record control, and driver eligibility.
Short answer
Direct answer
A consortium or third-party administrator may perform services, but the carrier must understand its responsibilities and prove that covered drivers were handled correctly before and during safety-sensitive work.
Enrollment is not the entire control
A consortium or third-party administrator may perform services, but the carrier must understand its responsibilities and prove that covered drivers were handled correctly before and during safety-sensitive work.
Build a decision trail
For each covered driver, the file should make eligibility decisions traceable without disclosing more sensitive information than necessary. Restrict access because testing records contain highly sensitive data.
- Program enrollment and service agreement
- Pre-employment decision evidence
- Random-program participation where applicable
- Clearinghouse query and consent evidence
- Supervisor training where required
- Removal and return-to-duty controls when applicable
Audit the vendor relationship
Confirm the vendor’s scope, reports, notification process, and record access. Outsourcing administration does not outsource the carrier’s accountability.
Primary sources
Verify the current rule
Questions carriers ask
Frequently asked questions
Does joining a consortium make the carrier compliant?
Not by itself. The carrier must perform its own required actions, make correct driver decisions, and retain evidence.
Should testing records be in the general driver file?
Sensitive records require controlled access and appropriate retention. Organize them so authorized reviewers can retrieve necessary evidence without broad disclosure.
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