Many TSS clients are seasonal clients. This means they only operate during certain parts of the year, usually mid-March through October. It is crucial for Designated Employer Representatives working for seasonal employers regulated by the U.S. Department of Transportation to pay especially careful attention to their employee lists for random drug testing, especially at the start and end of the season, when many employees are coming and going.
We have a unique situation in Alaska, where the cruise season is the primary driver for many businesses, including tour operators and those serving the cruise and tourism industries. Over the last few years, the length of cruise season has shifted, from starting in mid-May and ending in early September, to starting in early April and running through October. This change has a significant impact on the random drug testing timeline and how the DER approaches the random pool.
Employees are selected for random testing on the first day of every quarter (January 1, April 1, July 1 and October 1). So, cruise season and random testing for DOT-regulated businesses operating for cruise season are extending into the fourth quarter for the first time. Simultaneously, many cruise season employees are leaving their jobs in October and moving on to other pursuits, thereby dropping out of the random testing pools.
Because of the extended season, the DER needs to pay extra attention and be strategic about sending selected employees for random testing. If an employee is scheduled to leave the job on October 8, and they were chosen for a fourth-quarter random test, the DER must make sure they are sent for their test before they leave for the season. In an audit situation, if that employee was still working for the employer on October 1, was selected for random testing, but was not tested before they left on October 8, the company could incur fines. So keep your lists updated and send your people in!
The DER is also responsible for informing the Consortium managers when their seasonal company is ready to come out of the pool. The Consortium cannot assume that the company is finished for the season. We must have a phone call, email or letter of notification from the DER before we can remove the employees and inactivate the company.
As mentioned before, too much communication between the DER and the Consortium manager is never a bad thing! Call, email or stop by and keep us updated. We all want a clean pool with eligible employees at the start of the quarter.