Interpretation Response #PI-96-024 ([Alyeska Pipeline Service Company] [Angi L. Smith])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Alyeska Pipeline Service Company
Individual Name: Angi L. Smith
Location State: AK Country: US
View the Interpretation Document
Response text:
11/29/96
Ms. Angi L. Smith
Sr. Occupational Health Analyst
Alyeska Pipeline Service Company
1835 South Bragaw Street
Anchorage, Alaska 99512
Dear Ms. Smith:
This is in response to your correspondence dated November 11, 1996, requesting clarification on the lowering of the random testing rate from 50% to 25%, effective January 1, 1997, for pipeline operators.
QUESTION: As an operator, can Alyeska Pipeline Service Company request DOT/RSPA covered contractors to remain at the 50% random testing rate if the contractor has a history of positive DOT/RSPA drug tests (average 8-10 positives annually)? If so, can we impose this on a contractor using DOT authority instead of company policy? What is the maximum threshold (random test rate percentage) we can require using DOT authority? Or can we impose the two year positive test rate industry standard of 1.0% on covered contractors as a measure to keep them at a 50% random testing rate still utilizing DOT authority?
ANSWER: The regulations state that the minimum annual percentage rate for random drug testing is 25 percent for covered employees. Pipeline operators may exceed RSPA's minimum annual percentage rate requirement under DOT authority.
If you need additional information or have questions about the information provided please feel free to contact Ms. Catrina Pavlik on (202)366-6199.
Sincerely,
G. Tom Fortner
Director for Compliance
and State Programs
Office of Pipeline Safety