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DEVELOPING A WORKPLACE DRUG POLICY
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ALSO, HERE'S A WORK IN PROGRESS BY THE AUTHOR --
THE FEATURES OF A GOOD POLICY:
- Must be in writing! .... thorough but easy to understand.
- Must be confidential
- Absolutely no court or law-enforcement involvement!
- No public punishment! The thrust should be to
deter people, not to shame them!
- A copy must be given to each person in the system....
and it's good to get a signed statement of understanding
from each person in the testing pool.
KEY ITEMS TO BE INCLUDED: (discussion of each item
follows)
- Define what (if any) agencies and regulations your
program is governed by
- Locate and master the regulations of whomever
governs you
- Know who may "inspect" your program and what
they might be looking for.
- Even if not regulated by federal or state rules,
it is a good idea to refer to them because:
- Much thought and expertise has gone into developing
them.
- They have stood the test of time.
- Define who is included in the testing pool
- Define philosophy of the program: Deterrence or
Enforcement
- Decide upon the frequency of testing
THE FOLLOWING CHART PROVIDES GUIDANCE FOR ITEMS
3, 4, AND 5.
What is the basic approach and philosophy of your
drug program?
DETERRENCE? or DETECTION?
- MOST PROGRAMS ARE A "COMBINATION."
Here's how the two approaches differ:
|
DETERRENT PROGRAM
| DETECTION PROGRAM |
| WHOM TO INCLUDE: |
Whomever you wish to deter
(Everyone) |
Persons at high risk or those requiring scrutiny |
| MEASURE OF SUCCESS |
Negative Tests |
Positive Tests |
| NUMBER OF SUBSTANCES: |
Select few |
Maximum affordable |
| (Unannounced & Randomized) |
| FREQUENCY OF SUBSTANCES: |
May randomize
(different "panel" each time) |
Maximal!
(every test every time) |
| FREQUENCY OF TESTING: |
Can be infrequent / unannounced |
As often as possible |
| WHAT DRUGS TO TEST FOR: |
Select randomized few |
As many as suspected |
| Here's how the two approaches
are the same: |
| RANDOM TESTING |
Necessary |
Necessary |
| SCHEDULED OR ANNOUNCED TESTS |
Useless |
Useless
(Abusers can "clean up" for a scheduled test) |
| ENFORCEMENT OF CONSEQUENCES: |
Prompt and Consistent! |
Prompt and Consistent |
OTHER KEY ITEMS ARE:
- Define who will manage the random testing... and
how -- Both donors and test panels may be randomized.
- Define who will (and who may) do the specimen collections.
-- In house collections are the most cost effective
and give the most confidence.
- Define the parameters of any "for cause" testing.
- Define who will do the reviews. ("outside" MRO is
optimal but more expensive)
- Monitor for false negatives.
- Monitor and interview for false positives.
- Know the "tricks of the trade" used by savvy
abusers.
- An adulteration protocol should be defined.
- Define the consequences of a positive test!
- One person should be in charge and only that
person should receive positive results.
- Define list (or criteria) of approved counselors
and/or treatment options required for those persons
who test positive.
- Also define clearly who is responsible for cost
of counseling.
- Schools may consider a course (for credit) covering
Substance Abuse and explaining how the school's program
works.
- Selection of a laboratory: [All the following may
affect the choice of a lab.]
- Define your documentation and chain of custody
system.
- Best to use a recognized system rather than
inventing your own.
- D.O.T. 7-part form is the "gold standard."
- Define whether collections will be single or
"split" specimens
- Split specimens give added confidence and
protection against litigation.
- Define which substances will be tested for.
[See the discussion at the end of the page.]
DEFINITIONS AND DISCUSSION OF THE KEY ITEMS:
Items 3 -5 are covered in the chart above... The
rest of the items follow:
- RANDOM MEANS:
- EVERY PERSON IN THE SYSTEM HAS AN EQUAL CHANCE
OF BEING SELECTED EVERY TIME A DRAWING OCCURS!
- Cannot be "a certain group" (unless randomized
in groups)
- Randomization may be by location, class, alphabet,
or any set of parameters as long as the categories
include everyone (and no one is duplicated.)
- Policy must define exactly which person or persons
are in charge of random program.
- SPECIMEN COLLECTIONS:
IN HOUSE COLLECTION IS HIGHLY RECOMMENDED -- even
though collection services abound!
- No certification or degree is required for collectors.
- Informal training (& practice) is available
many places.
- Training materials available FREE from government
and labs!
- Most important ingredient is a CONSCIENTIOUS
person doing the collections.
- Requirements for a "legal" collection site are
VERY SIMPLE!
- Just a few collections each month will maintain
skills and competence.
- "OUTSIDE" collection sites are also very easy
to find, but are VERY EXPENSIVE!
- Almost every clinic is willing to do collections
-- Typical price for collection = $10-30.
- WEB SITE listing collection sites is at: http://www.wpa.org/nacs/members.htm
- SAAPA will soon publish a complete list of all
collection sites nationwide
- FOR CAUSE TESTING:
- "For cause" testing is fine but conditions must
be spelled out in your policy and well documented
BEFORE such testing is done.
- Examples could be: thrice tardy, definable drop
in academic performance, fighting or other definable
forms of violence or loss of impulse control.
sleeping during work-time or class,
- Most successful programs require TWO WITNESSES
to sign written documentation of observed "offense"
before lab results return. A "check sheet" can
be developed to simplify this...... but signatures
of witnesses are critical!
- Provision should be made for a student (employee)
to announce a problem and "volunteer" for assistance
-- without consequences (or with defined consequences.)
- COMPETENT REVIEW IS CRITICAL (Certified Physician
MRO is recommended)
Advantages of "outside MRO" are:
- Eliminates "politics" and the potential for
having to pronounce someone positive who is a
neighbor, a patient, or a family member.
- They are most knowledgeable about the drugs
and the testing, .... and most competent to eliminate
false negatives, false positives, and invalid
tests.
- Lessens the danger of retaliation or "mischief"
by an angry abuser.
- Increases impartiality and confidence in the
system if professional MRO is used.
- Abusers will always know that the person who
pronounced them positive is NOT the same person
who enforced the consequences.
- DEFINE THE CONSEQUENCES OF A POSITIVE TEST!
- One person should be in charge and only that
person should receive positive results.
- A "committee" can be considered to monitor compliance
and manage "appeals."
- Only consequences may be appealed.... not drug
test results...........unless....
- If you choose "split specimen" collections,
appeal for a re-test (in a different lab) is available
(at donor's expense.) [Costs about $85.00]
- Define the controversial issue of ASSIGNING
AND ENFORCING CONSEQUENCES. SEE APPENDIX A
- DEFINE TREATMENT OPTIONS
- There should be a pre-defined list (or set of
criteria) for approved counselors and/or treatment
options required for those who test positive!
- Federal standards in 49-CFR-49 are considered
the best guidelines!
- Ministers, Shamans, astrologers, crystal ball
therapists, witch doctors etc. must all be approved
ahead of time unless meeting federal guidelines.
- Therapists must be accountable to program administrator
for WRITTEN summaries of treatment including goals
and predicted outcomes.
- Also define clearly who is responsible for cost
of counseling.
- EDUCATION IS CRITICAL!
- Schools and businesses may consider a course
(for credit/with pay) covering Substance Abuse
and explaining how their particular program works.
- Federally mandated programs MANDATE training
for both employees and supervisors!
- SELECTION OF A LABORATORY [All the following may
affect the choice of a lab]
- Define your documentation and chain of custody
system.
- Best to use a recognized system rather than
inventing your own.
- D.O.T. 7-part form is the "gold standard."
- Define whether collections will be single or
"split" specimens
- Split specimens give added confidence and
protection against litigation.
- Define which substances will be tested for.
[This is discussed at the end of the paper.]
- COST! [Cost is inevitably the "final compromiser"]
WHAT DRUGS SHOULD BE TESTED FOR:
The ones in bold are in prominent use today!
- DANGEROUS SUBSTANCES THAT ARE ALWAYS ILLEGAL:
Marijuana, Cocaine, LSD, Heroin, Psilocybin (Mushrooms),
anabolic steroids, PCP,
- DANGEROUS SUBSTANCES THAT ARE ILLEGAL without a
prescription:
Amphetamines, Opiates, Benzodiazepines, Propoxyphene,
Methadone, Barbiturates
- SUBSTANCES THAT ARE NOT ILLEGAL (even in minors
if dispensed by parents)
Tobacco, Alcohol, Over-the-counter medications
- THREE TESTS ARE ALSO NEEDED TO ASSURE SPECIMENS
ARE VALID:
pH, Specific Gravity, and Creatinine
- TESTS FOR ADULTERATION MAY OCCASIONALLY BE NECESSARY.
An "adulteration protocol" should be defined in your
policy
- MAKE "TEST PANEL" FLEXIBLE
Give program administrator(s) authority to change
testing panel or randomization without written notice
if circumstances warrant
TO AVOID LEGAL PROBLEMS AND LITIGATION:
- THE CARDINAL RULE:
-
- DO NO TEST unless there is specific requirement
for THAT test on THAT person on THAT occasion IN WRITING
in your policy! NO "DISCRETIONARY TESTING!"
TO SEE OUR FAVORITE POSTERS FOR POLICY MAKERS
CLICK: A, B,
or C
APPENDIX A
ADMINISTERING THE "CONSEQUENCES" OF POSITIVE
TESTS
The most controversial issue in all discussions
about Drug Screening is the issue of whether a positive
result should result in the same consequences for
every person and every drug in the system.
APPENDIX B
AGREEMENT TO AVOID USE OF ILLEGAL SUBSTANCES
[to be read and signed by employee/student]
UNDER CONSTRUCTION SAMPLE POLICIES AND/OR AGREEMENTS
ARE HEREBY SOLICITED....
drewb@nmrllc.com
QuestDiagnostics has a
wonderful PowerPoint Presentation regarding "Zero
Tolerance" DFW policy. Please
email us if you would like to receive a copy.
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