» policy development
The first step in any drug and alcohol-testing program should be the development of a drug and alcohol policy. It is well worth the time and effort spent on developing or reviewing your policy and ensuring that it meets all of your requirements fairly.
d:tec are experienced in advising many different companies in the development of their Drug and Alcohol policies. We can provide specific expert advice, or help to lead you down the right track. Consider that a "generic" drug and alcohol policy will not likely be suited to the specific needs of your business. No-one knows your requirements, facilities, operation and circumstances better than you, so don't be afraid to use your own expertise. We can help you put the pieces together.
Some "generic" issues that you may wish to cover in your policy include:
Purpose
Responsibilities
Scope of testing
The Australian/New Zealand Standard 4308:2001
How are you testing?
What substances are you testing for?
Consult, train and provide information to staff
Consider Privacy and Confidentiality Issues
Action taken on positive results
Purpose
What are your objectives for testing? Eg. Is it a duty of care under the OH&S Act, to protect staff, to provide a safe working environment, to protect the safety of the general public, as part of the corporate fitness for work program etc.
Responsibilities
Who is responsible for carrying out the testing? Who is responsible for carrying out the repercussions for a positive test? What responsibilities do the employees have?
Scope of testing
When will testing be conducted? Pre-employment, random, for cause/behavioural, incident, self testing?
Pre-employment is the most common form of testing, as it is the easiest form to introduce.
Random testing allows on-going protection for your staff and the public. It provides a good deterrent to drug and alcohol abuse, but you need to ensure that a random testing process is just that, random. This can be achieved either by testing ALL of your employees on a random date, or by randomly choosing a specified number of employees for each round of testing. When we randomly choose a list of employees for companies we use a computer software program to select employees for testing from a file of staff names. The computer algorithm of the software selection program ensures a truly random selection system. The fact that the staff who are selected for testing are chosen by an external contractor adds further to the independent nature of the selection and eliminates concerns of bias or unfair targeting of individuals. If you are participating in a drug testing program where our nurses come on-site we will randomly select the day or testing.
Many companies also perform testing after an accident or near miss, or if there are reasonable grounds for suspicion of drug or alcohol use.
Self testing is a good way to ease your workforce in to a random testing regime. It allows them to test themselves at home before random testing begins so as to determine if there is any reason that they may test positive when the "live" tests start. Having some self test kits or a breathalyser on-site also allows employees who may feel a bit "scratchy" after a night out or big weekend to test themselves upon returning to work to determine if they are fit to be there. We recommend that if employees do not pass this test that they catch a taxi home and access annual leave until they are fit to return to work.
The Australian/New Zealand Standard 4308:2001
This standard outlines the procedures for the collection, detection and quantitation of drugs of abuse in urine. Any company that is considering implementing a urine drug testing regime should be familiar with this standard. It can be purchased at www.standards.com.au.
How are you testing?
On-site screening vs. lab screening
You can choose to screen samples on-site using a device such as the SiteScreen on-site test. This will give you a result detailing the presence/absence of 5 drug groups (as per the Australian Standard) in the urine sample being tested within 5 minutes. All on-site testing provides a presumptive positive result and should be confirmed by Gas Chromatography Mass Spectrometer (GCMS) in an accredited laboratory.
Alternately, you may choose to collect samples on-site and send them to the laboratory for screening and confirmation if required.
Both of these methods are valid and provide a deterrent for drug abuse. The format of testing you choose for the initial screening test will depend on your circumstances and the advantages that each form of testing offers you.
Drug screening has been set up as a "two-tier" testing procedure. This means that there are two completely independent tests (each with independent set cut-off levels). For a sample to be reported as positive it MUST test above the cut-off level on BOTH tests. The first test is a screening test (immunoassay) and it is used to rapidly eliminate the clearly negative samples, and to flag other samples for further laboratory investigation. This screening test is providing information on the presence or absence of drug groups in the sample being tested. It can be performed on-site or specimens dispatched to the laboratory. If no drug groups are found, the sample is negative. If a drug group is detected above the set cut-off level of the Standard the sample is considered a presumptive positive result and is investigated further by GCMS. The GCMS testing determines the exact drug present and therefore easily distinguishes between prescription and illicit drugs. Again, the level must be above the set cut-off levels to be reported as a positive result.
The two tier testing system is in place to ensure that the accuracy of results and to provide a cost-effective means of eliminating many samples rapidly and concentrating further investigation on a small percentage.
What substances are you testing for?
State clearly which drugs are being tested for, and at what levels. The Australian Standard (AS/NZS4308:2001) details types of drugs to be tested and the cut-off levels for these drugs in urine. All drug-screening results should be confirmed by GCMS to determine the exact drug and not just the drug group to enable prescription drugs to be differentiated from illicit drugs. State how you are going to deal with the person during the period before the screening result is confirmed.
Alcohol levels are usually set in line with legislation covering a specific industry and therefore typical levels in policy may be zero (eg. Dangerous goods transport, rail industry), 0.02%, or 0.05% in line with roadside levels. For positive alcohol screens a second breath test should be conducted after 20 minutes, and blood testing can also be offered for laboratory confirmation if required. Detail how any screening test results will be confirmed.
Consult, train and provide information to staff
Your employees deserve some education upon implementation of a drug and alcohol workplace policy. Discuss the introduction of a drug and alcohol policy and testing program with staff and provide them with education on the purpose of the program, and the manner in which it will be conducted. Include information on the affects of drugs and alcohol.
d:tec staff can assist with training of staff, from senior managers to all ground staff. This allows an external and fully trained person to handle questions from all levels of employees.
This may also be an appropriate time to link this as a part of a "fitness for work" program and discussions on other general health issues. Clearly there are other issues that impact on fitness for work beyond drug and alcohol abuse, such as fatigue for example.
Consider privacy and Confidentiality Issues
There are several key privacy issued involved in this testing that you must consider before you commence.
- Do your collection facilities provide privacy for the donor?
- How are the results of the test being reported eg. A confidential fax line, posted to a nominated person, by phone to a nominated person?
- Who are the results being reported to?
- How are the results being stored, for how long, where, and by whom?
- How are positive samples being shipped to the laboratory for confirmation?
Action taken on positive results
If you get a positive result what are you going to do? You cannot leave this decision until you get your first positive result. The action you are going to take must be clearly stated in your policy. This may cover the disciplinary procedures, Employee Assistance Program (EAP), counselling etc. and action to take on subsequent breaches of the policy. Consider what will happen if an employee refuses to be tested, tampers with a sample or is unable to produce a sample. It is also wise and fair to advise employees of the ramifications of a positive drug or alcohol test before the testing regime begins.