How do you conduct substance abuse testing for a non-regulated company?
… A company representative from the Human Resource approaches you as a drug testing C/TPA and would like you to conduct drug testing on their employees. They tell you that your were selected from the yellow pages on the phone book. You and company HR Representative quickly agree on a meeting date and time to discuss the areas of concern. C/TPA is a consortium and third party administrator for employer drug testing programs.
Several thoughts go through your mind but you need to ask the calling party about their regulatory status. One of the primary questions should be to see if they are regulated or not. At the meeting you can ask what their principle line of business is. With that answer, you make a determination that they are indeed not regulated. The company is large and with a variety of businesses that are owned or operated by this company.
You inquire further and find out this company would like to institute drug testing for their employees. You ask several more questions. You quickly determine why they want to do testing and that this company has several profitable business lines. They state that they have over 1,000 employees.
You talk to the HR person and it is indicated that they would like a 10 panel drug test with recognized cutoff levels. The panel includes marijuana, cocaine, amphetamines, opiates, Phencyclidine, Barbiturates, Benzodiazepines, propoxyphene, methadone and Quaaludes. The HR person gives approval for this testing panel which will utilize urine as the specimen source. You have talked to them about the potential benefits of and minuses of using oral fluid or hair as specimen sources. They elect to go with urine specimen testing.
The next step is to determine the cutoff levels that will be used for both screening and confirmation testing. You give the HR person the various options and explain what is meant by screening and confirmation testing as testing should be two-step process. The HR person accepts the levels as you have explained to her and plus how long the various drug can last in the human body after use.
The HR person inquires what happens if somebody should test positive and is taking a prescription drug. You explain that all tests results will go directly from the lab to the Medical Review Officer (MRO). The HR person looks you and asks “What is a Medical Review Officer?”
You take the time to patiently explain who and what a Medical Review Officer (MRO) is and their role in the drug test results verification. Some questions arise regarding confidentiality of the test results and you again answer those questions emphasis on the only designated personnel can handle drug test results and how they can be handled.
The HR representative inquires about how the specimens will be collected and where they will be collected. There is a look of relief as it is realized that the HR Department will not have to collect the specimens but that trained personnel would do the specimen collections.
You inquire as to when testing is to be done. The company would like to institute pre-employment testing on all new hires. They also would like to have testing for employees with suspected substance abuse problems and post-accident testing. Random testing has been discussed but nothing has been decided upon at this time. You go back and state that reasonable suspicion testing will required training of all the supervisors. The HR person recognizes that training will be needed and has already made some arrangements for that training. You mention that parameters need to be set for post-accident testing will be conducted. They are willing develop some of those parameters depending upon the many different employment tasks and potential accident scenarios.
This is good start to implementing a drug test program in a non-regulated company.
By: Robert C. Schoening
Robert Schoening is well renowned for his knowledge and influence in the drug-testing arena. As the Drug and Alcohol Program Manager for the US Coast Guard (December 2001-March 2013) he developed and managed a successful drug testing program for the marine industry nationwide and internationally. During this time he developed and implemented a new compliance audit checklist as well as the writing and publishing a new Marine Employers Guidebook for Drug Testing. He is also the author of the federal regulation commonly known as the two-hour alcohol testing for maritime incidents.
Robert’s drug testing career began in the Navy Medical Department, where he received the Navy Achievement Medal for his work on development of the Navy drug-testing program which was the first major workplace drug-testing program in the country. He retired in 1985 after serving 24 years.
Upon his retirement, Robert established his own drug testing consulting company assisting other companies to establish drug-free workplaces and drug testing programs, concentrating primarily on the marine industry. His knowledge of regulations and policy helped build his company to be one of the premier providers of drug testing services for the marine industry. During this time he was instrumental in establishing many of the current federal policies that are in place.
Robert has served on the Board of Directors of the Substance Abuse Program Administrators Association (SAPAA) as well as chairing the Governmental and Legislative Affairs committee. He was one of the first individuals to be recognized as an expert in the Drug and Alcohol testing industry and to receive designation as a Certified Substance Abuse Program Administrator (1996).
Robert is active participant in community service. He recently served on the Policy Board for the Alcohol Safety Action Program in Fairfax, VA (January 1989-December 2012). Since moving to Whidbey Island in Washington, he has been named to serve on the Substance Abuse Committee and recently been named to serve on the Ferry Advisory Committee both of these committees are located in Island County, WA.
Robert is currently a consultant for Workplace Drug Testing and Drug Abuse Prevention Programs.
