Mr. David J. Lofgren
Transportation Director
Greater Roanoke Transit Company
Roanoke, Virginia 24032

Dear Mr. Lofgren:

This is in response to your July 16, 1997, letter to Ms. Judy Meade, Director of the Federal Transit Administration's Office of Safety and Security. You ask whether, once the dates for drug and alcohol testing have been randomly selected, a second computer-generated random selection process must occur to pick the time of day when testing occurs, or if management has discretion to chose the actual time the test takes place.

Once the testing day has been determined by a scientifically valid number selection method, the transit system management has discretion to chose the actual time of day testing is performed, keeping in mind that such time should be varied, unannounced, unpredictable, and unlikely to become a pattern (e.g., all testing done at the end of the work shift).

If you have further questions regarding this issue, please contact Michael Connelly of my staff at (202) 366-4011.

Sincerely yours,
(Signed)
Patrick W. Reilly
Chief Counsel