Interpretation Response #PI-92-001 ([Compliance Services] [John I. Reed])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Compliance Services
Individual Name: John I. Reed
Location State: LA Country: US
View the Interpretation Document
Response text:
Mr. John I. Reed
Compliance Services
P.O. Box 944
Eunice, LA 70535
Dear Mr. Reed:
This is in response to your letter of October 15, 1992 requesting guidance concerning the random selection of "pipeline crews" rather than individual employees.
You indicated that your comply provides drug testing services to various pipeline operators and one of your clients has raised the question about conducting random testing of "pipeline crews" in lieu of a random selection process that would select from all the covered employees. You also indicated that the client assigns different employees to each work crew on a daily basis and that they may never consist of the same employees.
We have indicated in past agency training sessions/seminars conducted by the Office of Pipeline Safety and by members of the Transportation Safety Institute that a random selection pool may be comprised of all employees, subject to Part 199, with random selection being conducted on the entire pool. We have also indicated that "geographical selection" by various work sites would be acceptable under our regulations. We have cautioned many operators that the employee size and location of different sites may present a problem when trying to satisfy the 50 percent random test requirements. If several sites with a limited number of personnel are selected each time it may require the operator to conduct more random selection testing during the year in order to meet the 50 percent test ratio.
You should also be aware that when random test selection is conducted, each and every employee subject to the regulations should have an equal chance of being selected. The procedure you have outlined may not represent an equal chance of being selected each time the random draw is conducted if the selection is based on selecting pipeline sites, especially if the work force changes daily, as opposed to selecting from the entire random pool.