• Testing records must be kept in a secure location with controlled access.
• Employers have some flexibility on the location of records.

While records related to the Department of Transportation’s (DOT’s) drug and alcohol testing regulations must be maintained in a secure location with controlled access, motor carriers have some flexibility concerning the location. The Federal Motor Carrier Safety Administration (FMCSA) specifies that records may be maintained anywhere, e.g., regional office, work reporting location, or any other location of the company’s choosing.

However, the records must be made available for inspection at the employer’s principal place of business within 48 hours (two business days) after an FMCSA request. Requirements for the location of records are found in 390.29.

A company that uses a consortium to administer its testing program can arrange to have the consortium maintain some or all of its records. Under these circumstances, the employer does not have to keep a duplicate set of records. However, proper recordkeeping remains the employer’s obligation — the employer must ensure that records are accurate, current, and fully comply with FMCSA regulations. The consortium must still be able to get documents to the employer within two business days in the case of an FMCSA request.