Defending Your Drug and Alcohol Testing Program

Currently, the Drug Demand Reduction Program Manager (DDRPM) for Creech Air Force Base, responsible for testing 3170 military members or more each fiscal year (October 1st–September 30th), and 52 DOD civilians in a Designated Testing Position (DTP). Served as a Drug and Alcohol Compliance and Enforcement Inspector for the Federal Aviation Administration (FAA) for 9 years, responsible for regulating and enforcing 49 CFR Part 40 Procedures for Transportation Workplace Drug and Alcohol Testing Programs and 14 CFR Part 120 Drug and Alcohol Testing Program FAA regulations out of the Western Pacific office in Los Angeles, covering territory from Colorado to Alaska, Hawaii, and Guam. Coordinated and performed investigations, inspections, enforcement, and advisory work to ensure complete understanding and compliance with DOT and FAA regulations regarding all aspects of drug and alcohol testing program compliance. Provided technical expertise for the development of educational material and training to meet all regulatory requirements and inspected and educated all regulated companies' Designated Employee Representatives (DER) and Human Resources Representatives' (HR) employment hiring records for compliance. Inspected Third-Party Administrators, Consortiums, Collection Sites, and Service Agents for compliance. Interviewed Substance Abuse Professionals (SAP), reviewed evaluations for face-to-face initial and follow-up interviews, reviewed SAP testing plans, and interviewed Medical Review Officers (MRO) to ensure all training and certification were current. Prepared final technical reports on findings of non-compliance violations, identified appropriate corrective actions required to resolve non-compliance violations, and conducted a risk analysis to determine the appropriate actions to address all non-compliance violations detected, which may result in administrative action, a civil penalty, or certificate action.  

Defend Your Drug and Alcohol Program can assist with your DOT Drug and Alcohol Program before an up-and-coming inspection or during a normal compliance office review.  As a former Drug and Alcohol Compliance Enforcement Inspector in that capacity, conducted numerous fact-finding inspections, successfully finding and recommending hundreds of violations, including egregious fact-finding violations that resulted in legal enforcement action costing companies hundreds of thousands of dollars in fines. During my tenure, successfully inspected over a thousand companies. I'm not an attorney and do not provide legal advice, but this site will provide drug and alcohol advice concerning your drug and alcohol program. The Drug/Alcohol Compliance  will guide you with valuable corrective action for your out-of-compliance violations that are not in compliance with the agency regulations. 

THE DOT ADVOCATE expertise offers guidance on how to make your company's drug and alcohol program compliant and defend it against actions that may be taken against your business by Federal Drug and Alcohol Compliance Regulators. These Regulators/Inspectors are responsible for monitoring and enforcing the Agency rules  and 49 CFR Part 40, which may result in a civil penalty or the cancellation of your certificate or contractor registration or program period. This website will provide you with a "road map" that will protect your drug and alcohol program. The DOT Advocate will also outline the steps that the agency Regulators/Inspectors will take from the alleged violation(s) through the inspection process or the investigation process to the administrative remedial corrective action or legal enforcement action.