Petition to the Federal Motor Carrier Safety Administration (FMCSA) Request for Revision

If I'm reading this correctly, this is about correcting the way warnings count against our PSP as much as, or worse than, a ticket.

So of course I signed it.

 

I feel some unfair policies with SAP regulations need addressing. I listed here a few facts I believe deserve attention.

1 the level at which a drug is found in someones system determines probabilities of if or not a persons motor function, cognitive ability, perception, behavior etc....are being affected by substance at time of detection. That should taken into account before concluding a rate at which substance use has contributed to accidents

2 detected levels should also be deemed important to determine levels of usage and to what extent it can be concluded a persons habitual usage has affected them long term.

3 if the point is to keep drug impaired employees from putting saftey at risk, restrictions should only be imposed where it can be evidenced a person has been on duty while actualy impaired. Certain drug use may be illegal, but the mere fact it was found in ones system does not mean they would come on duty impaired It also doesnt mean a substance wasnt ingested unintentional.

4 if it has been found by investigation that treatment expenses and other restrictions are recurringly being imposed with ulterior motive, a person shouldnt be prevented from knowing certain treatment plan details. For example: While not disclosing test frequency can be considered a measure to prevent users knowing when to pause using, a person not being allowed to know how long he is being required to undergo testing or restrictive/costly circumstances is not. This only enables ethical rules to be avoided. A person should have right to know if or not any restrictive obligations have been imposed fairly and in accord with actual treatment needs and ethical guidelines

5 its contrary to procedural fairness to declare that conclusions made by fmcsa affiliated laboratories or SAP counselors cant be challenged for legitamcy or accuracy by other outside scientific institutions.

I dont if these matters are being addressed but I believe they deserve attention as well as anything else