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March 2020: ODAPC’s Clarification – Face-to-Face is Still Required

This morning ODAPC posted a notice about DOT's testing regulations and the current health crisis. 
View ODAPC Notice
The last bullet-point is about service agents: 

As a collector, BAT, laboratory, MRO, or SAP, you should continue to provide services to DOT-regulated employers if it is possible to do so in accordance with State or local mandates related to COVID-19.  Should you have concerns about COVID-19 when testing or interacting with employees, please follow your company policy, directions from State and local officials, and guidance from the Centers for Disease Control and Prevention (CDC).
Assessments and follow-up evaluations must still be face-to-face.  There is no accommodation.
In the third bullet, it says “the underlying modal regulations continue to apply”.  The example given:  if it is not possible to conduct a pre-employment test (due to lockdown, etc.), a new employee cannot be permitted to perform safety-sensitive functions. 
Similarly, this would also mean that a SAP not being able to conduct a face-to-face evaluation or a face-to-face follow-up evaluation cannot be the basis for that SAP to make a treatment recommendation or report successful compliance.
If you are in a location that is under lock-down (because of State or local mandates), SAP evaluations will have to be put on hold until the lock-down is lifted.

SAPlist UREMINDER: SAPlist U For Your Continuing Ed Requirement

SAPlist U provides 12 hours of continuing education related to DOT's testing rules.  It is endorsed by EACC, NASW, and NBCC.  It’s online, convenient, and you can complete it at your own pace.

Go to SAPlist U Continuing Ed
Until next time,

Lee Mauk signature

Lee Mauk  | and SAPlist U
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