To Sign or Not to Sign: Non-DOT Alcohol Testing
Whenever we get questions about the Non-DOT Alcohol Testing Form we frequently find it useful to remember that many companies were doing what we now call “non-DOT” alcohol testing before the DOT alcohol testing regulations were implemented in 1994. Prior to 1994 employers documented their alcohol test results in any number of ways. Lacking a national standard, each employer invented their own method to document alcohol test results – which may, or may not, have included a specific form on which the results were recorded.
The important thing to remember today is that every company that conducts non-regulated alcohol testing can make their own policy. One of the most important choices companies make when writing an alcohol mis-use policy is to establish a cut-off level that defines a positive test. Anecdotal evidence from our customers tells us that non-regulated companies choose a wide range of cut-off levels, from any non-zero result to 0.080. (See our January 2012 newsletter for a discussion on AlcoPro’s recommendations for appropriate cut-off levels.)
The generic Non-DOT Alcohol Test Form was designed to accommodate any cut-off level because it does not refer to a specific level. Step 4 of the form reads “… I understand that I must not drive …. because the results are positive.” While that allows the form to fit any policy, it puts the burden on the BAT to know the definition of a positive test for that employer in order to know whether to ask the employee to sign Step 4. That’s not a problem for a BAT who works for only one company, but it becomes a challenge for collection sites that might have hundreds of customers.
This question is typical of the discussions we have in our BAT and Collector training classes.