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At the core of any successful drug-testing program is a written policy. And despite what you may have heard there is no such thing as a "model," one-size-fits-all drug testing policy. Just as all companies are different, all policies will be different, at least somewhat. Much depends on your company's experience with worker substance abuse, as well as the safety-sensitive nature of the business and your company’s overall drug testing objectives.
Although no two policies will be exactly alike, every policy should cover certain key issues. For example, a good policy will clearly state your drug testing objectives, the behavior prohibited by the policy, and the consequences for policy violations.
Why You Are Implementing a Policy
In order to know what kind of drug testing to do, you must first understand why you are drug testing. One such objective common to most companies is concern for safety—the safety of workers, customers and clients, and the general public. This is particularly true if the work being performed is of a safety-sensitive nature.
Other common reasons include improving productivity; controlling the costs of doing business, such as health care insurance, workers' compensation, and accident insurance premiums; increasing the overall health and well-being of employees and their families and helping them with their problems; and minimizing employee theft and other wasteful and costly behaviors. Compliance with federal or state government regulations should also be stated when applicable.
What the Policy Prohibits
While it may be obvious that all illegal drug use on company time should be prohibited, what will the policy say concerning off-duty use, criminal drug convictions, and being at work under the influence of illegal drugs even though the use took place elsewhere? What about the misuse of prescription and over-the-counter medications?
What will be the company’s position on alcohol use? Alcohol is legal and, in many circles, socially accepted. It is not uncommon for a company to serve alcohol at company functions or to reimburse employees' travel or sales expenses that include alcohol consumption. However, alcohol is the most commonly abused substance in America. When measuring the impact of substance abuse on your company, ignoring the role of alcohol is almost like ignoring the problem altogether.
It is appropriate for a company to require its employees to report to work fit for duty and to prohibit any employee from purchasing, manufacturing, transferring, using, or possessing illicit drugs while on company business. This includes work performed off company premises.
Consequences for Violations
Simply put, any violations of the company policy should result in disciplinary action, which may include termination. The purpose of this section of the policy is to make it clear that employees will be held accountable for their substance abuse-related behavior.
Drug and Alcohol Testing
The policy should describe who will be subject to drug testing and who will have the authority to require a drug test. Also, how and under what circumstances testing will occur should be stated in the policy. Pre-employment and reasonable suspicion testing are the most common types of testing, followed by post-accident and random testing.
If the company tests with a point-of-care testing (POCT) device, it should state so in the policy. Also, the specimen used for testing should be explained... oral fluid, urine, or hair. The lab being used for confirmation and the medical review officer who will verify positive results should be listed in the policy. The consequences for a positive drug or alcohol test should also be explained.
Your company’s drug testing policy is your opportunity to clearly express your position on employee substance abuse.
For some workers, the knowledge that the company is active on the issue and that they will be held accountable for their behavior is enough to deter future substance abuse. For others, knowing that their company is aware of the problem and is trying to respond to it will strengthen their commitment to being loyal and productive workers. Still others who may be struggling with a loved one's substance abuse problems will appreciate the opportunity to obtain support and assistance at work.
Much good can be accomplished by establishing a substance abuse program, and it all starts with a written policy.
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