Creating a solid workplace safety and health program that includes a drug and alcohol policy with testing for drugs and alcohol requires integrating best practices from other successful organizations. Merriam-Webster Dictionary defines best practice as “a procedure that has been shown by research and experience to produce optimal results and that is established or proposed as a standard suitable for widespread adoption.”
Benefits of Utilizing Best Practices
There are definite benefits to using best practices for a company’s drug and alcohol program:
- Credibility from the outset with evidence-based standards.
- Cost reductions related to reduced absenteeism and Workers’ Compensation claims.
- Maintain and improve quality of products and services.
- Use of most current and accurate testing methods.
- Decreased risk of liability and litigation.
- Consistency of application of the program’s policies.
Planning a Drug and Alcohol Program
Two areas of best practice are important for a drug and alcohol program. The first is to do proper planning and due diligence before the program launch. The second is to manage the program fairly and appropriately.
Best practices for proper planning:
- A clear “top-down” message of support: Unless there is commitment from all levels of management, any program will fail. Resistance or obstruction by even one supervisor can lead to inequality when the policies are implemented. Absolute buy-in is necessary from the outset.
- Comprehensive policies and procedures: The program should strive to anticipate and cover all possible scenarios around testing. For example, prescription drug abuse has become a common workplace problem and testing policies should reflect this. (Learn more in "A Look At Prescription Drug Abuse Statistics".) Also, all policies and procedures should be reviewed by attorneys familiar with employment and disability law.
- Follow all local, state, and federal laws: Depending on the company, its location, and federal contracts, different laws and regulations apply. (Learn more in "State Drug Testing Laws: What Should Employers Know?") Organizations with offices in more than one state must be knowledgeable about each state’s requirements. As medical and recreational marijuana becomes legal or decriminalized, (Learn more in "Medical Marijuana Law Differences and Contradictions".) specific language may be needed to address the situation if a test result is positive. (Learn more in "Why Employers Need a Workplace Marijuana Policy".)
- Contracting with an accredited drug testing provider: Timely and accurate drug and alcohol testing results are crucial. The entire testing process must follow strict adherence to “chain of custody” and confirmatory testing procedures. A certified Medical Review Officer should oversee and interpret test results. The provider can offer guidance regarding the logistics of the program for both DOT and non-DOT companies. (Learn more in "DOT vs. Non DOT Testing: What's the Difference?")
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- Training for front-line managers and supervisors: Anyone who will observing, supervising, and counseling employees should have adequate training prior to launching the program. These people are the “eyes and ears” of the company, and should learn how to recognize signs of drug or alcohol abuse, what actually counts as reasonable suspicion, and what to do if they have reasonable suspicion of any employee who may be under the influence. (Learn more in "What is Considered Reasonable Suspicion? A Look at the Criteria for With Cause Drug Testing in the WorkplaceWhat is Considered Reasonable Suspicion?".)
- Structure employee notification and testing to be completed within a limited amount of time: When setting up the testing program, coordinate times with the provider. The ideal situation is to inform the employee and send him or her to get tested. Long windows of time can lead to cheating or tampering with samples (such as adulteration). If the employee does not comply, action can be taken for refusal to test.
Managing a Drug and Alcohol Program
Best practices for managing the program:
- Inform and educate all employees: Everyone should understand the drug and alcohol program, including testing and actions following a positive result. Employees subject to random testing should be given any additional necessary instructions. Documentation on policies and procedures (including the types of drug testing to be used) can be handed out, as well as posted, or easily accessed in the workplace. (Learn more in "Three Types of Drug Testing: What Employers Should Know About Lab Testing, POCT, and Express to Lab Testing".)
- The drug and alcohol program should not be punitive: The purpose of the program should not be draconian compliance with regulations, but an emphasis on workplace safety and well-being. Open communication about the importance of helping employees who require intervention and treatment, and the reasons for everyone to maintain productivity and the company’s reputation can create shared responsibility.
- All testing must be consistent with the policies: For example, if the policy includes pre-employment testing for all candidates, then it must be applied, even if the candidate is at low risk for a positive result. Also, each employee within a job class or category must be treated the same.
- Random testing must be truly random: Using a statistically valid random generator will ensure that all employees who require random testing have the same probability of being selected each time. Random testing must be compliant with all regulations.
- Documentation must be thorough: There is a saying in medicine: “If it’s not documented, it didn’t happen.” Begin with documenting all training, then continue with each testing encounter. Results are confidential (and subject to federal regulations such as HIPAA) and must be kept in a separate file from employee records. However, an auditor or attorney should get a clear record of how the company manages its drug and alcohol program, including testing.
- Know testing locations and hours: Some companies have onsite testing capability, while others send employees to a clinic or laboratory. A supervisor cannot request that a worker submit to a random sample a few minutes before the testing site closes. Allowing sufficient time can prevent a test from being inaccurate because it couldn’t be performed in a timely manner, allowing for cheating. (Learn more in "Top 3 Ways Employees Try to Cheat Drug Testing".)
Whether the organization is required to perform drug and alcohol testing as part of a federal contract, or it seeks to have a drug-free workplace, best practices can help make the program successful and effective from the outset. (Learn more in "The Importance of a Good Drug and Alcohol Policy in the Workplace".)