Checklist: Substance Abuse Programs

Employers who decide to implement substance abuse programs should consider the following:

¨ Establish a clear, written policy that spells out the employer's position on substance abuse, what is expected of the employee, and the consequences of violating the policy.

¨ Train supervisory personnel on how to do their jobs properly. Supervisors must understand the policy, be able to explain it to employees, and know when to take action.

¨ Educate employees. This includes reinforcement training for current employees as well as making new employees aware of the company's substance abuse policy.

¨ Provide employee assistance programs to rehabilitate those employees who have substance abuse problems and to get help for employees who may be experiencing difficulties that could lead to substance abuse problems.

¨ Consider implementing a drug testing practice but only if the company already has a substance abuse policy, training and education programs for its supervisors and employees, and an employee assistance policy in effect.

Checklist for Developing a Corporate Substance Abuse Program

For developing a policy that will adequately meet the needs of the individual company, experts recommend answering the following checklist of questions. Although the checklist is extensive, it covers the kinds of issues that must be addressed in order to implement an effective policy.

1. Research

¨ Why institute a substance testing program?

¨ How does your company's accident rate compare with that of others in the industry?

¨ Have accidents occurred that may have been drug-related?

¨ Have there been any measurable changes in productivity over the last few years?

¨ Is absenteeism higher than normal?

¨ Is the company paying more medical and hospitalization benefits than before, particularly for psychiatric rehabilitative disorders?

¨ Are other companies similar to your instituting testing programs?

¨ Are they screening job applicants?

¨ What kinds of substance abuse problems exist?

¨ What information can your employee assistance program (EAP) provide?

¨ Are regional or national studies available with data specific to your industry?

¨ Can local substance abuse agencies, or health and police departments, provide workplace statistics?

¨ Can you obtain information from trade or industry associations or local treatment centers?

¨ Can outside consultants, working with your EAP or human resources staff, provide original data?

2. Policy Statement

¨ What happens if an employee uses, sells or possesses drugs in the workplace? Will he or she be disciplined? Fired? Referred to the authorities?

¨ What is the company's position on job performance as it relates to drug usage?

¨ What is your position on substance abuse testing?

¨ What are the consequences of testing positive?

¨ What treatment and rehabilitation services can be made available?

¨ Does the plan have the support of top management?

¨ Have all element of the workforce been involved?

¨ Have union representatives been consulted?

¨ Is a system for monitoring and evaluating its success built into the plan?

¨ Has legal counsel been involved in every step?

3. Communication

¨ Do employees know the policy is backed by the highest level of management?

¨ Is every employee aware of the policy and is it available to them?

¨ If substance abuse testing is to apply to current employees, do they understand the reasons for it -- that it ensures their safety, improves the quality of the company's product, or increases sagging production levels, for example?

¨ Is it necessary to extend the policy to contractor employees?

4. Education

¨ Are the dangers that substance abuse creates for all employees being stressed?

¨ What information can be made available to employees about the overall health hazards of drug abuse?

¨ Do educational materials explain how substance abuse may affect the company's products and services? Do they stress the effects of abuse on themselves, their families and the community?

5. Training Supervisors

¨ Do supervisors understand:

• the warning signs, both psychological and physiological, of addiction and abuse?
• the specifics of corporate policy so they can answer an employee s questions?
• how to observe and document poor performance?
• how to confront a drug-impaired employee?
• how to go about making a referral to the EAP or to the appropriate rehabilitation outlets?

6. Testing

¨ Who will be tested? Job applicants? All employees? Selected employees?

¨ Will testing be done on-the-job as part of a routine annual physical?

¨ Will testing be done on a random basis, unannounced?

¨ Will you test only for cause?

¨ Will testing be done company-wide, without prejudice, including executives and hourly workers? And if not, why not?

¨ Are there state or federal laws that limit or prohibit the testing program you ve chosen?

¨ How frequently will you test?

If you are not testing all employees:

¨ What will be the criteria for those subject to testing?

¨ Will you test only those in sensitive positions?

¨ How will you define sensitive?

If you test for cause:

¨ What will be your criteria?

¨ Who will make the judgment? A physician? The supervisor?

¨ Will the test be mandatory?

¨ What happens if the employee refuses to be tested? Will the employee be disciplined, suspended or even terminated?

Pre-employment testing:

¨ If you test all new hires, when will you test? After the job offer but before hiring?

¨ Do you require pre-employment physicals? Is substance abuse testing a routine part of them?

¨ Will you tell applicants that hiring is subject to test results? If so, when? Just prior to their physical? Earlier?

¨ If an applicant tests positive, what will your policy be? Will you bar employment?  Will you reconsider the application in three months? Six months? A year? Under what conditions? Will it depend on the job for which the person applies -- that is, will it differ for a heavy equipment operator and a file clerk?

¨ If you eventually hire an applicant that failed the test, will you:

• require periodic, random testing?
• inform the supervisor?
• set any job restrictions?

¨ What kind of test will you administer?

¨ What substances will you test for?

¨ What type of drug test will you request?

¨ What options do various laboratories and testing consultants offer you?

¨ What cutoff levels will you use?

¨ Will you instruct your laboratory to conduct a confirmation test on all positives, or will you accept and act on a single positive test?

¨ What kind of laboratory will you choose?

¨ What criteria will you use in choosing a laboratory?

¨ If you have a number of facilities, will you use a different laboratory for each of your various locations or will you select a national laboratory with geographically-disbursed testing sites?

¨ What type of laboratory security system, or chain of custody, will you look for?

• Do you need to document specimen accountability? Is there a chance the outcome will be challenged?
• How much assurance is necessary that the sample has not been adulterated by the person providing the specimen? What precautions will you take?
• How is the specimen sealed to prevent tampering?
• What assurance do you have that the specimen will not be tampered with in transit?
• What happens to the specimen before and after testing?
• How are the results reported? Is there a hard copy? Are the terms clear and easy to understand? Are quantitative values provided on confirmed positives?
• Are positive specimens kept frozen following testing? For how long?

¨ Does the laboratory participate in proficiency testing programs sponsored by outside agencies? What are its ratings?

¨ Are laboratory personnel certified technicians?

¨ Who will read and interpret the results?

¨ How will you ensure confidentiality?

¨ Who will tell the applicant or employee and how?

¨ Who needs to know? The company physician? The individual's physician? The supervisor? Human resources professionals? Law enforcement officials? What do you expect them to do with this information?

¨ What will you do with the results?

¨ What if current employees test positive? Will they be disciplined? Terminated? Reassigned? Rehabilitated? How will you decide?

¨ Will terminated employees be eligible for rehire? When? Under what circumstances?

¨ What if an employee tests positive from use of drugs at home but shows no sign of impairment on the job?

7. Assistance

¨ Are trained professional guiding your employee assistance program?

¨ Have local treatment centers been evaluated and deemed capable of handling substance abuse rehabilitation? Is this list monitored and updated?

¨ If rehabilitation is supported, who pays? Has insurance coverage been reviewed and added to, if necessary?

¨ Will the EAP be available for counseling and support following rehabilitation?

¨ Will you have a voluntary self-referral program for treatment?

¨ How will employees be treated if they volunteer? Will costs be paid? Will employees be given time off with pay? If they volunteer, are they protected against discipline or termination for any and all reasons?

A drug testing program must be fair, accurate and legally defensible. It should be undertaken only as part of a comprehensive drug-free workplace program.

Checklist for Detecting Employee Substance Abuse

Whether or not an employer has a drug testing program, supervisors need to be alert to patterns of employee job performance deterioration, physical signs, and behavioral characteristics that may signal a worker with a substance abuse problem. The following checklist, developed by the Louisiana Workers' Compensation Corporation as part of a drug-free workplace program, may assist in detecting employee substance abuse (.05).

Job Performance Deterioration

Absenteeism. Unauthorized leave, excessive sick leave, Monday and Friday absences, repeated absence of two to four days or one to two weeks, excessive tardiness, especially on Monday or after lunch, leaving work early, peculiar and increasingly improbable excuses for absence, and frequent unscheduled short-term absence with or without medical excuse.

On-the-job absenteeism. Unnecessary absence from the work station, frequent trips to the water fountain or rest rooms, long breaks, physical illness on the job, and returning to work in an obviously abnormal condition.

High accident rate. Accidents on the job, frequent need for first aid, and off-the-job accidents that affect job performance.

Difficulty in concentration. The employee's work requires greater effort, the job takes more time, and hand tremors are apparent when concentrating.

Confusion. Difficulty with instructions, details, handling complex assignments, or recalling mistakes.

Spasmodic work patterns. Alternate periods of very high and very low productivity.

Tenacity to job. The worker does not change jobs easily because control of the present job facilitates covering up poor job performance.

Lowered job efficiency. Missed deadlines, mistakes due to inattention and poor judgment, wasted materials, bad decisions, complaints from customers and coworkers and improbable excuses for poor performance.

Poor employee relations.Friction in relationships with co-workers resulting in decreased performance and efficiency, overreaction to real or imagined criticism, wide swings in morale, borrowing money from co-workers, complaints from co-workers, and unreasonable resentments.

Physical Signs Associated with Substance Abuse

Appearance. Deterioration of physical appearance and grooming, wearing sunglasses at work, wearing long-sleeve clothes in hot weather, and reluctance to wear short-sleeve attire when appropriate.

Eyes. Difficulty focusing, glazed appearance of the eyes, red eyes, and dilated or constricted pupils.

Nose and mouth. Dry mouth, frequent lip licking, dry nose, runny nose, chronic nasal problems, and nose bleeds or red nostrils.

Skin. Flushed skin, scars and tracks, and excessive perspiration or body odor.

Drowsiness. Sleepy or stuporous condition, slurred speech, and lethargy or drowsiness.

Behavioral Characteristics Associated with Substance Abuse

Aggressive behavior. Unusual flare-ups and outbreaks of temper, irritability, loud or aggressive behavior, competitive or argumentative behavior, more talkative than usual, conversations lacking continuity, agitation, fear, paranoia, and nervousness.

Passive behavior.Uncharacteristically passive behavior, withdrawal from responsibility, memory loss, deadened sensory perception, disorientation, and lack of interest in food or sleep.

Relationships. Association with known substance abusers, stealing from the employer, and interpersonal relationship problems with co-workers and family.

For more information

For more information on workplace substance abuse programs:

The National Clearinghouse for Alcohol and Drug Information (NCADI) is a toll-free service funded by the federal government. NCADI s information specialists will help an employer find information on all aspects of substance abuse from videos and prevention materials, to specific program descriptions, resources in the employer s state, and the latest research results. Many publications and educational materials are available free.

The Drug-Free Workplace Hotline is a toll-free service funded by the federal government to assist businesses, industry and unions on the development and implementation of comprehensive drug-free workplace programs.

Coordinators from the Drug Enforcement Administration, the Federal Bureau of Investigation, and the Law Enforcement Coordinating Committee offer a variety of technical assistance services to employers on workplace substance abuse. Contact your local DEA, FBI or U.S. Attorney s office to locate the nearest coordinator and ask what type of assistance they offer.

Drug-Free Workplace Act. For more information on the requirements of this federal law:

The contract and/or grant administration office of the federal department or agency awarding a contract or grant can also answer questions about the provisions and requirements of the Drug-Free Workplace Act.

Department of Transportation Regulations. For more information on DOT substance abuse regulations:

For specific information about compliance with the DOT drug abuse regulations, contact the Department of Transportation, Office of the Secretary, Drug Enforcement and Program Compliance.

State and local resources. For more information on programs on the local level:

The National Association of State Alcohol and Drug Abuse Directors (NASADAD) coordinates and encourages cooperative efforts between the federal government and state agencies on substance abuse. Through its Drug-Free Workplace Project, NASADAD is working through state substance abuse agencies to provide technical assistance to small businesses developing substance abuse programs and policies. NASADAD serves as a resource on state drug programs and can provide contacts in each state.

State Drug an Alcohol Programs offices exist across the country. To find an individual state office, consult the state government, consult the local phone directory, or contact NCADI and NASADAD, listed above.

Community organizations are available to help with drug or alcohol problems. Check the local phone directory under headings such as Alcohol/Drug Abuse Information, Treatment or Counseling. Be sure to look in the blue pages (government listings and public service section), the yellow pages, and the community service section.

Reprinted with permission. © CCH