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actual knowledge before implementation

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If a driver violated the drug and alcohol program prior to January 6, 2020, but the employer did not obtain actual knowledge (as defined in § 382.107) of the violation until January 6, 2020 or later, is the employer required to report the violation to the

Guidance on reporting actual knowledge violations to the Clearinghouse before January 6, 2020

Question

If a driver violated the drug and alcohol program prior to January 6, 2020, but the employer did not obtain actual knowledge (as defined in § 382.107) of the violation until...