When records are stored and transferred electronically, how should they be made available to DOT representatives?

Question – When records are stored and transferred electronically, how should they be made available to DOT representatives?

Answer – The obligations of employers and service agents to make records available expeditiously to DOT representatives apply regardless of how the records are maintained.

  • All records must be easily and quickly accessible, legible, and formatted and stored in a well-organized and orderly way.
  • If electronic records do not meet these criteria, then the employer or service agent must convert them to printed documentation in a rapid and readily auditable way by the MRO’s receipt of a confirmed laboratory test result, would not require a §40.21 waiver.
  • It would not be appropriate for an employer to remove employees from performance of safety-sensitive functions pending the result of a random or follow-up test, since there is no triggering event to which the action could rationally be tied.
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