Mr. Lawrence G. Reuter
General Manager
Washington Metropolitan Area Transit Authority
600 Fifth Street, NW
Washington, DC 20001-2693

Dear Mr. Reuter:

Thank you for your letter asking whether the Federal Transit Administration's (FTA) drug and alcohol testing regulations (59 FR 7531 (1994) (to be codified at 49 CFR Parts 653 and 654) apply to escalator and elevator mechanics.

The rules apply to persons who perform safety-sensitive functions, including the maintenance of revenue service equipment. 49 CFR 653.7 and 654.7. As we noted in the regulatory preamble, "Each employer must decide for itself whether a particular employee performs any of the functions listed in this definition." 59 FR 7544 and 7584. Consistent with this rule, then, I understand that the Washington Metropolitan Area Transit Authority has determined that, under the circumstances of its operations, escalator and elevator mechanics are safety-sensitive workers subject to drug and alcohol tests.

If you have any questions about this matter, please contact Daniel Duff or Nancy Zaczek at (202) 366-4011.

Very truly yours,
(Signed)
Berle M. Schiller
Chief Counsel