Random Drug/Alcohol Testing
SIMPLY PERFORMING RANDOM DRUG AND ALCOHOL TESTING
DOES NOT REMOVE SUBSTANCE ABUSE AND ENSURE A
DRUG-FREE WORKPLACE. ALTHOUGH AN EFFECTIVE TOOL,
THE EMPLOYER NEEDS TO DO MUCH MORE IN THE WAY OF
EDUCATION AND MORE FREQUENT TESTING.
The following are excerpts from: Best Practices for DOT Random Drug and Alcohol Testing
http://www.dot.gov/ost/dapc/testingpubs/final_random_brochure.pdf
What’s the best tool employers have for deterring drug and alcohol use in the workplace?
Random Testing. And, here are just a few of the reasons why:
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Saves lives and prevents injuries.
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Helps employers identify workers with substance abuse issues and facilitate their treatment.
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Allows employees to easily say no to illegal drug use. "No, thanks. They drug test at work."
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Reduces employer liability.
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It is a fair way of testing.
How are employees selected for testing?
Everyone in the pool must have an equal chance of being selected and tested in each selection period. Selections can be by employee name, identifying title, or with FRA regulated testing, a group that is clearly delineated in company policy or random plan.
Be sure to use a scientifically valid method to select employees for testing, which may include: use of a random-number table, a computer-based random number generator that’s traceable to a specific employee (or with FRA, a group).
Note:
In the railroad industry, it is a common practice to select employees by the train number rather than specific employee. This would mean that any covered employee working on that train on a specific day (whether it was their regularly assigned position or not) would be tested. Only the FRA permits this practice.
Warning:
Unacceptable random selection practices include selecting numbers from a hat, rolling dice, throwing darts, picking cards, or selecting ping pong balls.
How often should selections and tests take place?
What makes random testing so effective is the element of surprise. While employees know they will be tested, they are never quite sure of when, so random selections and testing should be performed at least quarterly. Some employers are selecting and testing more frequently. We think that is a good idea. (Emphasis added)
Note:
If you think you might not meet your annual testing rate requirement, increase your testing. But, in an effective random program, testing must be spread equally throughout the year.
Best practice:
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Spread testing dates reasonably throughout the year in a non-predictable pattern.
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Conduct random drug tests anytime employees are on duty or while performing safety-sensitive duties. See your Agency regulations for your specific industry requirements of when to conduct testing. FRA has "hours of service" testing considerations.
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Conduct random alcohol tests just before, during, or just after the employee performs a safety-sensitive job, as described in your industry specific regulations.
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Each workday or weekend, you can enhance the non-predictability of your program by conducting tests at the start, middle, or end of each shift. The worse thing that could happen is for employees to say, "Yup, the last Friday of every month the second shift gets tested."
How are employees notified to report for a test?
Every employee should be discretely notified according to your company’s policy, but random testing must also be conducted in strict confidence with a limited number of people having knowledge of the selection list.
Why? Because it helps maintain the element of surprise.
Best Practice:
Every employer should have procedures in place to ensure that each employee receives no advanced notice of selection. But, be sure to allow sufficient time for supervisors to schedule for the administration of the test and to ensure that collection sites are available for testing.
Remember:
Employers must provide appropriate privacy for each employee the fact that he or she is being tested.
What must employees do when notified of a random test?
When an employee is notified, he or she must proceed immediately to the collection site. Contrary to the urban legends circulating among some employees, immediately does not mean two hours. Immediately means that after notification, all the employee’s actions must lead to an immediate specimen collection.
Why? For the integrity of the testing process.
Best Practice:
Many employers develop random testing procedures or policies that clearly state what activities are acceptable after notification: for instance, which safety-sensitive duties Agency regulations permit them to complete. If an employee is notified of a random test while working "off site" or "on the road," the company’s policies should spell-out exactly what the employee must do before resuming safety-sensitive functions. That way there is no misunderstanding among employees about what is expected.
Maintaining and Evaluating Your Random Program
It is the best practice for an employer to document everything on the entire random testing process. This includes the numbers, names drawn, dates and times of notification, dates and times of collections, why a selected employee was not tested during a selection cycle, etc. If you’re not sure, document it!
Best Practice:
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Service agents and C/TPAs providing random selection and testing services to employers should monitor on an ongoing basis (daily or weekly) the random tests that have been completed and compare them to those that were selected. If a random test has not been completed in an acceptable timeframe (within a day or week) of the expected test date, the service agent or C/TPA should contact the employer to determine the status of the test and take the necessary steps to ensure the test is completed within the selection period
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Employers, service agents, and C/TPA should not wait until the end of the selection period to reconcile the random testing numbers. This is a weak business practice that we want to discourage.
Remember:
You must maintain all your testing records in accordance with industry specific regulations. For more information, see the document, "Employer Record Keeping Requirements for Drug and Alcohol Testing Information." You can find this document at: http://www.dot.gov/ost/dapc/documents.html.
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