{"id":50868,"date":"2014-07-18T08:40:43","date_gmt":"2014-07-18T08:40:43","guid":{"rendered":"https:\/\/www.nationaldrugscreening.com\/?p=50868"},"modified":"2022-12-02T12:05:07","modified_gmt":"2022-12-02T17:05:07","slug":"compliance-for-employer-drug-alcohol-testing","status":"publish","type":"post","link":"https:\/\/www.nationaldrugscreening.com\/blogs\/compliance-for-employer-drug-alcohol-testing\/","title":{"rendered":"Compliance for Employer Drug & Alcohol Testing"},"content":{"rendered":"\n
… In 1986 President Reagan signed an executive order requiring drug testing for federal employees. In 1989 the federal Department of Transportation<\/strong><\/a> requires private employers to test interstate drivers; the U.S. Supreme Court upheld drug testing and twelve state laws existed for private workplace testing. Since then more private and public, non-regulated employers have recognized the benefits of testing being enjoyed by their regulated colleagues.<\/p>\n\n\n\n Any discussion of compliance for employer drug & alcohol testing programs must start with an understanding of the Mandatory Guidelines for Federal Workplace Drug Testing Programs (Mandatory Guidelines). These guidelines were first published by the Substance Abuse and Mental Health Services Administration (SAMHSA), United States U.S. Department of Health and Human Services (HHS), on April 11, 1988. These guidelines establish scientific and technical guidelines for Federal drug testing programs, as well as standards for certification of laboratories engaged in urine drug testing for Federal agencies.<\/p>\n\n\n\n The Mandatory Guidelines also establish the National Laboratory Certification Program (NLCP), with comprehensive standards for the testing of specimens, quality assurance and quality control, chain of custody, personnel, and confidentiality in the reporting of results. Quality assurance is addressed for the entire testing process from specimen collection through reporting of the results to the employer. Specifically, the Mandatory Guidelines requires the Department to: inspect each certified laboratory at least twice a year to document its overall performance; conduct quarterly proficiency challenges for all certified laboratories; and support an external blind control specimen program, with quality control specimens submitted by employers as though they were actual donor specimens.<\/p>\n\n\n\n Confusion often exists because the Mandatory Guidelines apply to Federal Workplace Drug Testing programs which means agencies employees of the Federal Government. This does not include Department of Transportation (DOT) regulated employers<\/strong><\/a>, DOT-regulated employees or private employers. It must be noted that the Mandatory Guidelines have set the foundation and the model for a comprehensive legally defensible drug testing program for all employers who conduct drug testing. DOT\u2019s drug & alcohol testing program, State law programs and private employers use these Mandatory Guidelines for the structure and model of the programs to be administered. The DOT program mirrors the Mandatory Guidelines program with a few exceptions.<\/p>\n\n\n\n For a complete review of the Mandatory Guidelines with background information and information on revisions go to: http:\/\/edocket.access.gpo.gov\/2008\/pdf\/E8-26726.pdf<\/a><\/p>\n\n\n\n A part of SAMHSA, the Division of Workplace Programs (DWP) is mandated by Executive Order and Public Law to provide oversight for:<\/p>\n\n\n\n DWP provides comprehensive information at https:\/\/www.samhsa.gov\/workplace<\/a> and a complete Drug-Free Workplace Kit at: https:\/\/www.samhsa.gov\/workplace\/toolkit<\/a>. A complete review of these websites is necessary for one to be an expert on Drug Free Workplace programs.<\/p>\n\n\n\n The Federal Government does not require most private companies or individuals to have a drug-free workplace policy of any kind. The exceptions to this are Federal contractors and grantees, as well as \u201csafety-sensitive industries\u201d (DOT regulated employers).<\/p>\n\n\n\n Requirements for Federal Contractors\/Grantees<\/strong><\/p>\n\n\n\n The most important piece of legislation regulating Federal contractors\/grantees is the Drug-Free Workplace Act of 1988.<\/strong> This Act requires any organization that receives a Federal contract worth $100,000 or more, to establish a drug-free workplace policy. It also requires all organizations receiving a Federal grant of any size to maintain such a policy.<\/p>\n\n\n\n At a minimum, the organization must:<\/p>\n\n\n\n Health Insurance Portability and Accountability Act of 1996 <\/strong>(HIPAA) and Drug Testing<\/strong><\/p>\n\n\n\n HIPAA protects the confidentiality of “medical records” of a “patient”. None of those terms apply in drug testing. First, there is no patient. Many state drug test laws state so. There is only a donor. Second, there is no record of a “medical” examination. A drug test is not conducted to “diagnose” or “treat” a “patient”. It is a forensic safety exam to determine if an “employee” or “prospective employee” meets the “employer’s” work qualifications. In fact it’s not even a “fitness for duty” exam.<\/p>\n\n\n\n Americans with Disabilities Act states as follows: (1) In general.–For purposes of this title, a test to determine the illegal use of drugs shall not be considered a medical examination.”<\/p>\n\n\n\n DOT has also published its position on this subject stating that HIPAA does not require employers and service agents in the DOT drug and alcohol testing program<\/strong><\/a> to obtain written employee authorization to disclose drug and alcohol testing information required by 49 CFR Part 40 and other DOT agency drug and alcohol testing rules.\u00a0 Review this at: https:\/\/www.transportation.gov\/odapc\/hipaa-statement<\/a><\/p>\n\n\n\n A test for the illegal use of drugs is not considered a medical examination under the ADA; therefore, employers may conduct such testing of applicants or employees and make employment decisions based on the results. The ADA does not encourage, prohibit, or authorize drug tests. At the same time, the ADA provides limited protection from discrimination for recovering drug addicts and for alcoholics. An employer may discharge or deny employment to current illegal users of drugs, on the basis of such drug use, without fear of being held liable for disability discrimination. Current illegal users of drugs are not “individuals with disabilities” under the ADA. If the results of a drug test reveal the presence of a lawfully prescribed drug or other medical information, such information must be treated as a confidential medical record.<\/p>\n\n\n\n State Laws \u2013 Private Employers<\/strong><\/p>\n\n\n\n Since there is no comprehensive federal drug testing law effecting non-regulated private employers, this leaves the field open to state regulation, and many states over the past 20 years have enacted provisions imposing drug testing restrictions of various kinds. Some limit testing to “reasonable suspicion” or “probable cause” situations. Some explicitly authorize random testing under certain circumstances. Some impose restrictions on public sector employers but not on private companies. Many prescribe specific methods for handling of specimens and the use of test results.<\/p>\n\n\n\n As a general rule, testing is presumed to be lawful unless there is a specific restriction in state or federal law. Employers are encouraged to involve unions when creating drug-free workplace policies<\/strong><\/a>. The National Labor Relations Act requires that the terms and conditions regarding any workplace drug testing program be included in collective bargaining agreements. Unions are generally not against drug testing, they work hard to protect the privacy and rights of their members while understanding the importance of employee safety.<\/p>\n\n\n\n Today, more than 550 state laws that affect workplace drug testing exist.<\/p>\n\n\n\n\n
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Americans with Disabilities Act (ADA) and Drug Testing<\/h2>\n\n\n\n