HomeMy WebLinkAbout01-96 - Res. Adopting Mason County Drug and Alcohol Testing Policy and Procedure RESOLUTION NO. () I— q
ADOPTING THE MASON COUNTY
DRUG AND ALCOHOL TESTING
POLICY AND PROCEDURE
WHEREAS, the rules of the Federal Highway Administration found in 49 CFR Parts 382,
391, 392, and 395 require drug and alcohol testing of employees who operate commercial
vehicles;
WHEREAS;RCW 41.56.100 requires that public employers engage in collective
bargaining with employees representatives;
NOW THEREFORE BE IT RESOLVED, by the Board of County Commissioners that
the attached Mason County Drug and Alcohol Testing Policy and Procedure be adopted on an
interim basis, subject to completion of bargaining with Mason County employee representatives
and final adoption by the Board of County commissioners.
ADOPTED this -- day of January, 1996.
BOARD OF MASON COUNTY COMMISSIONERS
Mary Jo C airp er
lam,
M. L. Faughender, C ssion
O /d
William O. Hunter, Commissioner
ATTEST:
aoll"oeel' ' c�M4
Rebecca S. Rogers, Clerk oft,he Board
APFVEDAS TO FORM:
Michael Clift, Chief Deputy Prosecutor
DRUG AND ALCOHOL TESTING PROCEDURES MANUAL
TABLE OF CONTENTS
I. INTRODUCTION
A. Requirement to Participate . . . . . . . . . . . . . . . . . . . . . . . . . . 1
B. Covered Employees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
C. Designated Contact . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
D. Employee Assistance Program . . . . . . . . . . . . . . . . . . . . . . . 2
E. Testing, Evaluation and Referral Services . . . . . . . . . . . . . . . . 2
11. TESTING PROCEDURES
A. Pre-Employment Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
B. Random Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . 4
C. Reasonable Suspicion Testing . . . . . . . . . . . . . . . . . . . . . . . . 5
D. Post-Accident Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
E. Return to Duty and Follow Up Testing . . . . . . . . . . . . . . . . . . 7
F. After Hours Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Ill. TESTING COSTS AND COMPENSATION
A. Testing Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
B. Pay Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
IV. TESTING METHODS
A. Drug Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
B. Alcohol Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
V. TRAINING AND EDUCATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
ATTACHMENT A - Drug Testing Policy
ATTACHMENT B - Testing Methodology
ATTACHMENT C - MRO/SAP Functions
ATTACHMENT D - Sample Forms
ATTACHMENT E - Effects of Drug Use and Alcohol Abuse
INTRODUCTION
A. Requirement to Participate in Drug and Alcohol Testing Program
Mason County is required by Federal regulation to administer a testing,
program for drug and alcohol use for employees who are required to have
and maintain a Commercial Driver's License to perform their job duties.
B. Covered Employees
The following groups of employees are required by law to participate in the
drug and alcohol testing program:
1. Regular employees who are required to operate a commercial
vehicle as part of their routine job duties;
2. Temporary employees who are required to operate a commercial
vehicle as part of their routine job duties;
3. Any employee who possesses a Commercial Driver's License who
may at any time operate a commercial vehicle on an emergency or
unscheduled basis (including supervisory employees who may be
called upon at any time to operate a commercial motor vehicle);
4. Current employees who transfer or promote to a position requiring
operation of a commercial vehicle and possession of a Commercial
Driver's License;
5. A pre-employment drug test is required of all persons given a
conditional job offer for a position that meets the description outlined
above.
C. Designated Contact
The following individual(s) have been designated by the County to answer
questions about the program and program materials and may provide
employees with resource materials or referral assistance:
Skip Wright John Flynn
Human Resources Director Maintenance Engineer
427-9670, ext. 424 427-9670, ext. 385
D. Employee Assistance Program
The County offers an Employee Assistance Program (EAP) designed to
assist employees and their families who are experiencing personal or job-
related problems. The EAP is available toemployees who need assistance
in dealing with a substance abuse problem. Employees are encouraged to
contact the EAP for assistance in early detection of substance abuse
problems and referral for treatment programs. All EAP services are
confidential and at no cost to the employee. Employees who would like
information on benefits of the Employee Assistance Program should contact
Skip Wright, in Human Resources.
To contact the EAP call:
1-800-523-5668; TDD# 1-800-882-7610
E. Testing, Evaluation and Referral Services
The County has joined the Association of Washington Cities (A WC) Drug
and Alcohol Testing Consortium for much of the administration of this
program. The AWC consortium has contracted with Virginia Mason to
conduct the random testing services, provide the testing laboratory facilities,
arrange the testing collection sites, and provide the Medical Review Officer
(MRO) functions. The services of a Substance Abuse Professional (SAP)
are also available for employees with positive test results.
Drug and Alcohol Testing Collection Site:
Mason General Hospital
Front Registration Desk
901 Mountain View Dr.
Shelton, WA 98584
(360) 426-1611
Testing Laboratory:
Drug Proof
Nordstrom Medical Tower
P.O. Box 14950
Seattle WA 98114
(206) 386-2454
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Medical Review Officers
Robert D. Petrie, M.D.
or
Samuel Strauss, DO, MPH, FACPM
Virginia Mason Occupational Medicine
6720 Southcenter Blvd.
Suite 110
Tukwila WA 98188
(206) 242-3651
Substance Abuse Professional
Olympic Resources
18720 33rd Ave West, Suite 200
Lynnwood WA 98037
1-800-624-5357
Olympic Resources will refer caller to a Substance Abuse
Professional in the local area.
II. TESTING PROCEDURES
A. Pre-Employment Testing
Following a conditional offer of employment, prospective employees will be
tested for the presence of drugs.
Current employees who are transferring from a position that does not
require a Commercial Driver's License to a position that does require one,
will be tested for the presence of drugs prior to performing duties that
require driving or operating a commercial vehicle.
A positive drug test result for an employment candidate will result in
rescinding the conditional offer of employment by Mason County. The
individual will only be eligible to re-apply for a position covered by these
procedures after six months. Employees seeking to transfer to. a position
requiring the driving of a commercial vehicle will be denied the transfer.
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B. Random Testing
The names and social security numbers for employees covered by these
procedures at the County have been included in the AWC Drug and Alcohol
Testing Consortium pool. This pool contains all eligible individuals from all
of the consortium members. The pool database is managed by Virginia
Mason and is updated monthly as changes in personnel occur.
The annual random testing rate required under federal regulations is 50%
of the pool for drug testing and 25% of the pool for alcohol testing. This
means that if the pool contains 1,000 members, there will be at least 500
random drug tests and at least 250 random alcohol tests conducted
throughout the year.
Virginia Mason uses a software program called HEIDI to randomly select
individuals for random testing on a monthly basis. Some individuals will be
selected for drug testing and others will be selected for both drug and
alcohol testing.
Each month, Virginia Mason will send the names of individuals selected for
random testing to the appropriate consortium member contacts. If Mason
County has any employees selected for testing, the names will be sent to
the designated County contact.
Employees selected for random testing will be scheduled for a test by the
designated County contact at some time during the month that the name
was selected. Employees selected for alcohol testing may only be tested
just before, during or after driving a commercial vehicle. Employees will not
be notified until just prior to the testing.
Upon notification of selection for random testing, the employee will receive
an Employee Notification of Scheduled Drug and/or Alcohol Test letter from
the designated County contact. The employee will be asked to sign this
letter and a Testing Consent form. The employee must present the
Employee Notification of Scheduled Drug and/or Alcohol Test letter at the
collection site along with picture identification at the time of testing. A copy
of all of the forms will be retained by the County.
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After notification, the employee must proceed directly to the collection site
for testing accompanied by a supervisor or other non-bargaining unit
designee.
The collection and testing procedures are outlined in Attachment B .
If an employee scheduled for an alcohol test receives a confirmed test result
with a blood alcohol level of 0.02 or above and is unaccompanied at the
collection site, a supervisor will be called to the site to transport the
employee.
C. Reasonable Suspicion Testing
According to the federal regulations, reasonable suspicion testing is to be
based on "specific, contemporaneous, articulable observations concerning
the appearance, behavior, speech or body odors of the employee." Only
supervisors who have been trained in detecting the symptoms of alcohol
misuse or drug use and who have directly observed behaviors, appearance
or physical symptoms can subject an employee to reasonable suspicion
testing. Supervisors should complete a Reasonable Suspicion Observation
Form and if possible have the form signed by a witness.
If a supervisor has reasonable suspicion to believe that an employee who
is on duty, about to go on duty or just completed duty is under any
influence of drugs or alcohol, the supervisor will remove the employee from
duty immediately. The employee will be advised of the reasons for
reasonable suspicion and will be transported to the collection site by the
supervisor for testing.
Reasonable suspicion alcohol testing may only occur just before, during or
after an employee drives a commercial vehicle. If a reasonable suspicion
alcohol test is not conducted within two hours of determination that it is
necessary, the supervisor will prepare and maintain documentation of the
reasons why it did not occur.
D. Post-Accident Testing
All employees covered by these procedures will be subject to post-accident
testing if they are involved in an accident with a commercial vehicle on a
public road which results in:
1. A fatality OR
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2. The driver receives a citation under state or local law fora moving
violation AND
a. there is bodily injury to a person who, as a result of the injury,
immediately receives medical treatment away from the scene
OR
b. one or more motor vehicles incurs disabling damage requiring
the vehicle to be transported away from the scene by a tow
truck or other vehicle.
After an accident, employees are responsible for contacting the immediate
supervisor or other management personnel. If the above conditions are
met, the employee must make themselves available for post-accident testing
as soon as possible. Post-accident testing for alcohol should occur within
two hours if possible, but may not exceed eight hours. Testing for drugs
should occur within 32 hours.
Employees subject to post-accident testing are prohibited from consuming
alcohol for eight hours following the accident, or until the employee has
completed the alcohol test, whichever comes first. An employee who does
not comply with the post-accident testing will be considered to have refused
testing and will be subject to disciplinary action. An employee in a post-
accident situation should cooperate with law enforcement personnel
investigating the scene.
Supervisors are responsible for determining if the accident qualifies the
driver for post-accident testing and they or a non-bargaining unit designee
shall escort the employee to the collection site if possible. If an employee
is unable to provide consent to testing due to their medical condition, the
supervisor will document the reasons why the employee was not tested.
If testing is not completed within the required time following an accident, the
supervisor will document in writing why the tests were not administered.
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E. Return to Duty and Follow-Up Testing
All employees who have engaged in prohibited conduct as defined.in
in the
Drug and Alcohol Testing Policy for Employees who Operate Commercial
Vehicles, including those who have tested positive for drugs or alcohol, are
subject to return to duty and may be subject to follow-up testing.
1. Return to Duty Testing
After engaging in prohibited conduct regarding alcohol or drug use,
an employee is required to undergo a return to duty alcohol and/or
drug test prior to returning to a duty which requires driving a
commercial vehicle. A return to duty alcohol test must result in a
breath alcohol concentration of less than 0.02. A return to duty drug
test must result in a verified negative result.
2. Follow Up Testing
An employee who returns to work after evaluation by a Substance
Abuse Professional (SAP) determining that the employee is in need
of assistance in resolving problems associated with alcohol misuse
or drug abuse is subject to unannounced follow up alcohol and/or
drug testing as directed by the SAP, but no less frequent than six
times in the first year following the return to work.
F. After Hours Testing
If the need for testing occurs outside of the normal hours of operation of the
designated collection site, a supervisor or manager will be responsible for
following the procedures established by Virginia Mason for such
occurrences.
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TESTING COSTS AND COMPENSATION
A. Testing Costs
1. The County will pay for the following alcohol and or initial drug tests:
a. Random testing
b. Reasonable suspicion testing
C. Post-accident testing
d. Pre-employment
e. Follow-up testing
f. Return to duty testing
2. Employees are responsible for the costs associated with the
following tests:
a. Split sample re-tests made at the employee's request
If a split sample re-test returns a negative result, the County will
reimburse the employee for the cost of the test.
3. Substance Abuse Professional and rehabilitation costs will be the
responsibility of the employee.
B. Pay Status
1. For Time Spent Testing
Employees will be compensated for time spent to report to the
testing facility, being tested and returning to the shop for the
following alcohol and/or initial drug tests:
a. Random testing
b. Reasonable suspicion testing
C. Post-accident testing
d. Return to duty testing
e. Follow-up testing
2. Waiting for Results
Employees who have been asked to submit to a reasonable
suspicion drug test will be placed on unpaid leave pending the
outcome of the test results. Such employees are eligible to use
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accrued vacation or sick leave during this time. If the test result is
negative, the time will be paid and any sick or vacation leave used
will be credited.
3. Alcohol Concentration of 0.02 but less than 0.04
If an employee receives an alcohol test result of at least 0.02 but less
than 0.04, the employee must be removed from duty which requires
driving a commercial motor vehicle for 24 hours following the
administration of the test. The employee may use accrued vacation
or sick leave during this absence.
4. Positive Drug Test or Alcohol Test Result of 0.04 or Higher
An employee who receives a positive drug test or who tests 0.04 or
greater on an alcohol test is not allowed to return to work until all of
the applicable requirements are met as outlined in the Policy (see
Consequences of Engaging in Prohibited Conduct and Positive Drug
or Alcohol Test). Such employees may use accrued vacation or sick
leave during this absence.
IV. TESTING METHODS
A. Drug Testing
The drug testing requires candidates to provide a urine specimen of at least
45 ml to be tested for the presence of amphetamines, cocaine, marijuana
(THC), opiates, and phencyclidine (PCP). The specimen will be sent to
Drug Proof, a laboratory certified by the Substance Abuse and Mental
Health Services Administration (SAMSHA) to conduct screening and
confirmation tests according to the protocols identified in the Department
of Transportation Rules. All test results will be reviewed by the Medical
Review Officer (MRO). Specific collection procedures and analytical
procedures are covered in Attachment B.
B. Alcohol Testing
Alcohol testing will be conducted using an approved evidential breath
testing (EBT) device operated by a trained breath alcohol technician (BAT)
at the collection site. The first test performed will be a screening test. If the
screening test results in an alcohol concentration of less than 0.02, it will be
considered a negative test. If the screening test results in an alcohol
concentration of 0.02 or greater, a second, or confirmation test is performed
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within 15 to 20 minutes. Specific alcohol testing procedures are covered in
Attachment B.
V. TRAINING AND EDUCATION
The County will provide all affected employees with copies of these procedures
and the Drug and Alcohol Testing Policy for Employees who Operate Commercial
Vehicles and other information as may be required by the federal regulations.
Each driver must sign a receipt upon having been provided the above referenced
information.
Managers and supervisors designated to determine whether reasonable suspicion
exists to require a driver to undergo,alcohol or drug testing will receive at least 60
minutes of training on alcohol and 60 additional minutes of training on drug abuse.
The training will cover the physical, behavioral, speech and performance indicators
of probable alcohol misuse and use of controlled substances.
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ATrACHMENT A
MASON COUNTY
Drug and Alcohol Testing Policy
Commercialfor Employees who Operate
1. PURPOSE
The purpose of this policy is to establish compliance with the Federal Highway
Administration regulations requiring drug and alcohol testing for Commercial
Driver's License holders. Regulations issued by the United States Department of
Transportation mandate urine drug and evidential breath alcohol testing for
employees in safety-sensitive positions, including those who are required to hold
a Commercial Driver's License. This policy sets forth the Mason County alcohol
and drug testing program and the testing and reporting requirements as required
by those regulations.
If. APPLICATION
This policy applies to all employees of Mason County who are required to have
and maintain a Commercial Driver's License in order to perform the duties of the
job. Contractors performing functions for the County involving the use of a vehicle
requiring a Commercial Driver's License, will be subject to specific alcohol and
drug testing as required by federal regulations.
111111. POLICY
The County has a significant interest in the health and safety of its employees and
the citizens of Mason County. In furtherance of that interest, it is the policy of the
County to take those steps necessary to ensure that its employees perform their
duties and responsibilities free of the influence of drugs and alcohol. Employees
are encouraged to seek confidential counseling on problems associated with
alcohol and drug abuse through the Employee Assistance Program. There will be
mandatory drug and alcohol testing for employees and job applicants under the
circumstances outlined in this policy.
IV. DEFINITIONS
ACCIDENT - Accident means an occurrence involving a commercial vehicle on a
public road which results in (1) a fatality; or (2) the driver receives a citation under
state or local law for a moving violation and (a) there is bodily injury to a person
who, as a result of the injury, immediately receives medical treatment away from
the scene; or (b) one or more motor vehicles incur disability damage requiring the
vehicle to be transported away from the scene by a tow truck or other vehicle.
DRIVER - This term includes all employees whose positions may involve driving a
commercial vehicle and that require the possession of a Commercial Driver's
License.
COMMERQIAL VEHICLE - A commercial vehicle is one that either: 1) has a gross
vehicle weight of over 26,000 pounds (including combined weight if towed unit
weighs over 10,000 pounds); 2) is designed to transport 16 or more persons,
including the driver; or 3) is used to transport hazardous materials.
DRUG$ - For the purposes of this policy, in accordance with the applicable federal
regulations, "drugs" refers to the following five substances: marijuana (THC),
cocaine, opiates, phencyclidine (PCP), and amphetamines.
MEDICAL REVIEW OFFICER (MRO - The Medical Review Officer is the licensed
physician responsible for receiving and interpreting laboratory results from the
urine drug tests.
SAFETY SENSITIVE POSITION - For purposes of this policy, these are positions
associated with the driving of commercial vehicle that require a Commercial
Driver's License.
SUBSTANCE ABUSE PROFESSIONAL (SAP) - A Substance Abuse Professional
is a licensed physician, or a licensed or certified psychologist, social worker,
employee assistance professional, or addiction counselor (certified by the National
Association of Alcoholism and Drug Abuse Counselors Certification Commission)
with knowledge of and clinical experience in the diagnosis and treatment of alcohol
and drug-related disorders. The SAP is responsible for evaluating employees with
positive test results.
V. PROHIBITED CONDUCT
The following conduct regarding alcohol and drug use or abuse is prohibited and
employees engaging in such conduct may be subject to disciplinary action up to
and including discharge:
A. ALCOHOL CONCENTRATION
An employee may not report for or remain on duty requiring the
performance of duties covered under this policy while having an alcohol
concentration of 0.04 or greater.
B. ALCOHOL POSSESSION AND ON DUTY USE OF ALCOHOL
An employee may not possess or use alcohol while on duty or while
operating a commercial vehicle.
C. PRE-DUTY USE OF ALCOHOL
An employee may not operate a commercial vehicle within four hours after
using alcohol. An employee who consumes alcohol within four hours of
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being called in must acknowledge the use of alcohol and may not report for
duty.
D. ALCOHOL USE FOLLOWING AN ACCIDENT
An employee required to take a post-accident alcohol test may not use
alcohol for eight hours following the accident, or until a post-accident
alcohol test is given, whichever comes first.
E. USE OF DRUGS
An employee may not report for duty or remain on duty which requires
driving a commercial vehicle when the employee has used a drug or drugs,
except when the use is pursuant to instructions of a physician who has
advised the employee that the substance does not adversely affect the
employee's ability to safely operate a commercial vehicle. While use of
medically prescribed medications and drugs is not per se a violation of this
policy, employees shall report the use of any medication that may impair
their job performance. In the event there is a question regarding an
employee's ability to safely and effectively perform assigned duties while
using such medications or drugs, written clearance from a physician or
pharmacist may be required.
F. REFUSAL TO SUBMIT TO A REQUIRED TEST
An employee may not refuse to submit to a post-accident, random,
reasonable suspicion, or follow-up alcohol or drug test as directed by this
policy.
G. POSITIVE DRUG TEST
An employee may not report for duty or remain on duty requiring the
performance of duties covered under this policy if the employee tests
positive for drugs or alcohol.
H. TAMPERING WITH A REQUIRED TEST
An employee may not tamper with, adulterate, alter, substitute or otherwise
obstruct any testing process required under this policy. An employee may
consume a reasonable amount of fluid, after notification of the need to test,
during transportation to the test site.
I. POSSESSION, TRANSFER OR SALE
No employee may possess, transfer or sell drugs or alcohol while on duty.
V1. TESTING
A. Pre-employment Drug Testing
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All individuals who will be covered by this policy must pass a drug test as
a post-offer condition of employment.
B. Reasonable Suspicion Testing
Employees subject to this policy shall submit to a drug and/or alcohol test
when a trained County supervisor reasonably suspects that the employee
is under the influence of drugs or alcohol in violation of this policy. A
referral for testing will be based on contemporaneous, articulable
observations.
Alcohol testing for reasonable suspicion may only be conducted just before,
during or after an employee operates a commercial vehicle. If removed
from duty based on reasonable suspicion of alcohol use, the employee will
not be allowed to perform or continue to perform covered functions until:
1) an alcohol test is administered within two (2) hours and the
driver®s breath alcohol concentration measures less than 0.02;
or
2) 24 hours have elapsed following the determination that there
is reasonable suspicion to believe that the employee has
violated this policy concerning the use of alcohol.
C. Post-Accident Testing
Following an accident (as defined in Article IV) involving a commercial
vehicle, the driver is required to submit to alcohol and drug tests. Testing
should occur as soon as possible, but may not exceed eight hours after the
accident for alcohol testing and 32 hours after the accident for drug testing.
A driver who is subject to post-accident testing must remain readily
available, in a paid status, for such testing and may not take any action to
interfere with testing or the results of testing. Drivers who do not comply
with post-accident testing requirements will be considered to have refused
to submit to testing and will be subject to sanctions for refusal to test as
provided in this policy.
D. Random Testing
Employees covered by this policy will be subject to random, unannounced
alcohol and drug testing.
E. Return to Duty Testing
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Employees who have violated this policy, including those who have tested
positive on a drug or alcohol test, and who under the discipline policy are
allowed to return to work, must test negative prior to being released for
duty. A return to duty test following alcohol misuse must be an alcohol
concentration of less than 0.02.
F. Follow-up Testing
Except for unusual circumstances agreed to by the parties, an employee
who is referred for assistance related to alcohol misuse and/or use of drugs
is subject to unannounced follow-up testing for a period not to exceed 12
months as directed by a Substance Abuse Professional. The number and
frequency of follow-up testing will be determined by the Substance Abuse
Professional, but will not be less than six tests in the first 12 months
following the employee's return to duty.
G. Re-tests
Employees who test positive for drugs may request a test of the other
portion of the split sample within 72 hours of notification of a positive test
result by the Medical Review Officer.
VIIII. REFUSAL TO TAKE AN ALCOHOL OR DRUG TEST
No employee shall refuse to submit to an alcohol or drug test as directed under
this policy. A refusal to submit shall include, but is not limited to:
a. a failure to provide adequate breath for testing without a valid medical
explanation after the employee has received notice of the requirement for
breath testing in accordance with the procedures manual;
b. failure to provide adequate urine for drug testing without a valid medical
explanation after the employee has received notice of the requirement for
urine testing in accordance with the procedures manual;
C. intentionally engaging in conduct, following notification of the requirement
for testing, that obstructs the testing process.
Refusal to submit to a test shall be considered the same as a positive test result.
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Vill. SECURING INFORMATION FROM PREVIOUS EMPLOYERS
If a person is to be hired into a position subject to this policy and during the
previous two years has worked as a driver of a commercial vehicle, that person
must authorize a request of all employers of the driver within the past two years
to release information on the following:
a. Positive alcohol or drug tests
b. Refusal to be tested
This information must be obtained before the person is employed by the County.
However, if the information has not arrived by the anticipated start date, and if the
person has passed the pre-employment drug test, the person may be hired and
the requested information must be obtained from the previous employers within 14
calendar days of the date of hire. If the information has not been received within
the 14 calendar days, the person will not be permitted to drive commercial vehicles
until the information has arrived. If the information obtained from previous
employer indicates either a positive test or that a refusal to be tested occurred
within the past two years, that person will not be permitted to drive commercial
vehicles unless subsequent information indicates that an evaluation by a Substance
Abuse Professional was made and return to duty testing was administered.
IX. CONFIDENTIALITY AND RECORD RETENTION
All records related to drug and alcohol testing will be maintained in a secure
location with controlled access. Such access is limited to the County's Human
Resources Director and the County's Administrative Services Director. These
records will be kept separate from records pertaining to all other employees.
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X. CONSEQUENCES OF ENGAGING IN PROHIBITED CONDUCT OR POSITIVE
DRUG OR ALCOHOL TESTS
A. Discipline
An employee will be subject to discipline up to and including discharge from
employment if the employee has engaged in prohibited conduct as outlined in
Section V.
Notwithstanding the above, an employee who has engaged in prohibited conduct
as outlined in Section V, paragraphs F and/or H; or whose post-accident drug or
alcohol test was positive and the employee received a citation fora moving
violation shall be discharged from employment.
An employee who tests positive for drugs and/or alcohol in violation of this policy,
other than as specified in the preceding paragraph, shall not be subject to
discharge from employment if they successfully complete a rehabilitation program
as prescribed by the S.A.P., and adheres to the provisions of the return to work
agreement.
All employees regardless of disciplinary action taken will be advised of resources
available to the employee in evaluating or resolving problems associated with drug
use or alcohol misuse.
B. Alcohol Concentration of 0.02 but less than 0.04
Employees having a breath alcohol concentration of at least 0.02 but less
than 0.04, shall be removed from duty requiring the driving of a commercial
vehicle for 24 hours.
X1. EMPLOYEE ASSISTANCE PROGRAM/VOLUNTARY REFERRAL
The County supports employees who volunteer for treatment of alcohol or drug
abuse. Employees are encouraged to seek treatment voluntarily and to utilize the
Employee Assistance Program. Any employee who comes forth and notifies the
County of alcohol or drug abuse problems will be given the assistance extended
to employees with any other illness. Any such program, however, may not
interfere with the tests required by these rules. For example, a driver may not
identify himself/herself as unfit to drive after having been notified of a random or
reasonable suspicion test and expect to avoid the consequences for a positive test
or a refusal to test. In addition, voluntarily seeking assistance does not excuse any
failure to comply with all of the provisions of this policy or other policies of the
County.
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Sick leave, vacation leave or leave of absence without pay will be granted for
treatment and rehabilitation as in other illnesses. Insurance coverage for treatment
will be provided to the extent of individual coverage. Confidentiality of information
will be maintained as much as possible at all times.
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ATTACHMENT B
VIRGINIA MASON OCCUPATIONAL MEDICINE
DOT Urine Testing for Drugs of Abuse
Split Specimen Collection Procedures
All drug screens for this contract will be collected following the stringent procedures of the
Department of Transportation and the Substance Abuse and Mental Health Administration (SAMHSA)
for federally mandated testing.
These instructions are intended for use by persons already familiar with the existing detailed urine drug
screen single specimen collection procedures for Department of Transportation. The following
instructions define how split specimens may be collected using a Split Specimen Cup Pack. The split
specimen requirement was implemented on August 15, 1994.
A. Operatiag Administrations Effected.
Employers with employees subject to drug testing in the following operating administrators
SHALL use split specimen collection: Federal Highway Administration, Federal Railroad
Administration, Federal Transit Administration, and Federal Aviation Administration.
Employers with employees subject to drug testing in the following operating administrations MAY
use split specimen collection: Research and Special Program Administration and United States
Coast Guard.
B. De
signation of Collection
The collection site person will use the area or areas defined as the designated collection site. The
collection will provide an enclosure for private urination, a toilet for completion of urination, a
source of water for hand washing, and a clean surface for the collection site person to utilize for
writing.
C. General
1. Collect urine specimen from only one person at a time.
2. Document and maintain the chain of custody at all times.
3. Double check the accurate labeling and sealing of the specimens.
4. Have the donor watch the process of completing paperwork and sealing the specimens.
5. Do NOT list the donor's name on the laboratory copy of the chain of custody.
A Chain of Custody.-
Chain of custody shall be properly executed by authorized collection site personnel upon receipt of
specimens at the clinics. Handling and transportation of the urine specimens to the laboratory shall
always be accomplished through proper chain of custody procedures. Once at The laboratory a
strict use of chain of custody is followed. The purpose of these procedures is to maintain control of
specimens/aliquots until testing is completed. All specimens received at The laboratory and
aliquots derived therefrom are handled with an internal chain of custody from the time of receipt
through the final disposition. In addition, all appropriate spaces on external chain of custody
documents are filled in as required by DOT.
1. Internal chain-of custody. Each transfer of custody must be documented on the chain of custody
form in the appropriate space. At each step the person releasing and receiving the
sample/aliquot must sign (or stamp and sign) the form, record the date, purpose of transfer,
and where appropriate, record the condition of the security seal(s). At this point, the person
receiving the specimen/aliquot is responsible or it must be locked in a secure area or
container. At no time may the specimen/aliquot be left unattended in a non-secure area.
The individual specimen requisition chain of custody form is used to document external chain
of custody and for documentation of specimen receipt, accessioning, and storage prior to
testing. The handling of individual specimens for any other purpose must be documented on
a special Handling Chain of Custody Document. Batch chain of custody forms document
aliquoting of specimens for screening, confirmation testing, and disposition of specimens
and/or aliquots. The batch chain of custody is signed and dated by all persons releasing and
handling or assuming custody of any specimen, aliquot or extracts derived from the aliquots
listed on the form.
All chain of custody forms are part of the forensic record and are stored with the specimen
requisitions in either short or long term storage as appropriate. These forms are part of the
forensic record and must be available for access in the event that subsequent testing or
handling is needed, or in the even that a legal package is requested.
2. Chain of custody for send-out specimens. An MRO (on instruction from the specimen donor) may
request that a split specimen be sent to another SAMHSA certified laboratory for
reconfirmation. In this case, the split specimen will be sent under chain of custody. A
Special Handling Chain of Custody will be used to document the specimen recovery from
storage and the packaging for shipment.
E, Access Limited to Authorized Personnel
No unauthorized personnel shall be permitted in any part of the designated collection site where
urine specimens are collected or stored. Only the collection site person may handle specimens
prior to their being secured in the mailing container. In order to promote the security of specimens
and to avoid distraction of the collection site person and ensure against any confusion in the
identification of specimens, a collection site person shall conduct only one collection procedure at
any given time. For this purpose, a collection procedure is completed when a urine bottle has been
so-aled and initialed, the urine custody and control form has been executed and the employee has
departed the site.
—PdYaCX.
The collection site person will be responsible for using procedures for collecting urine specimens
which allow the donor privacy unless there is reason to believe that a particular donor may have
altered or substituted the specimen to be provided, as further described in this paragraph.
For purposes of this plan, the following circumstances are the exclusive grounds constituting a
reason to believe that the donor may alter or substitute the specimen:
1. To deter the dilution of specimens at the collection site, toilet bluing agents shall be placed in
the toilet tanks wherever possible, so the reservoir of water in the toilet bowl always remains
blue. Where practical, there shall be no other source of water (e.g. no shower or sink) in the
same enclosure where urination occurs. If there is another source of water in the enclosure, it
shall be effectively secured or monitored to ensure it is not used (undetected) as source for
diluting the specimen.
2. When a donor arrives at the collection site, the collection site person will ensure that the
donor is positively identified as the employee selected for testing (e.g. through presentation of
photo identification or identification by the employee's supervisor). If the donor's identify
cannot be established, the collection site person shall not proceed with the collection.
3. If the donor fails to arrive at the assigned time, the collection site person shall note the
discrepancy and alert the designated employer contact.
S. Collection Procedures:
1. Collection site person asks the donor to remove any unnecessary outer garments such as a
coat or jacket that might conceal items or substances that could be used,to tamper with or
adulterate the donor's urine specimen. The collection site person shall ensure that all personal
belongings such as a purse or briefcase remain with the outer garments. The donor may
retain their wallets.
2. Instruct Donor to wash and dry their hands prior to urination.
3. After washing hands, the donor shall remain in the presence of the collection site person and
shall not have access to any water fountain, faucet, soap dispenser, cleaning agents or any
other materials which could be used to adulterate the specimen.
4. Have donor choose a split specimen collection cup pack.
5. Collection site person completes a custody and control form for each donor. Write the
donor's Social Security or ID number in the grid at tope right comer. Verily and complete
information requested in Step 1 (up to temperature) of the custody and control form. Write
date and donor Social security or ID number on the bottle label AND on split label.
4
6. Collection site person opens the cup pack selected by the donor and applies a bottle label
found on the custody and control form to the first bottle (primary specimen) and the split
sample label to the second bottle (split specimen). Give the donor the collection cup and
show hi/her the approximate level for 45 mL volume to be collected. Have the donor collect
at least 45 mL urine.
7. Donor may provide their specimen in the privacy of a stall or otherwise partitioned areas that
allow for individual privacy.
8. Collection site person shall note any unusual behavior or appearance on the custody and
control form.
9. Collection site person pours 30 mL urine into the primary specimen bottle and at least 15
mL urine into the split specimen bottle. Tighten lids securely.
➢ If less than 45 mL urine is collected, the collection site person will instruct the donor to
drink not more than 24 oz of fluids and, after a period of not more than two hours again
attempt to produce a complete sample using a new fresh cup pack. The original
insufficient specimen will be discarded. If the donor is still unable to provide an adequate
specimen, discard the insufficient sample, discontinue the test and notify the employer of
the donor's inability to provide 45 mL of urine for testing within the allowed time period.
10. Collection site person measures temperature of the specimen from temperature strip on
primary specimen and complete the last line of Step 1 on form.
11. Have donor verify accurate labeling of specimens. Donor to initial and date bottle security
seals and place over caps and down two sides of both bottles. Do not obscure the labels.
12. Have donor complete and sign Step 3 on Copy 3 of custody and control form. Collection site
person completes and signs Step 4 on Copy 1 of custody and control form.
13. Collection site person places each sealed bottle in a seXspecimen shipping
bag and fold flap to seal.
14. Collection site person removes shipping bag seal from custody and control form and seal
junction of front pouch of specimen shipping bag. Sign and date seal.
15. Collection site person complete Step 2, custody record, on custody and control form.
16. Collection site person separates copies of custody and control form and place copies 1, 2, and
7 in back pouch of specimen shipping bag. Mail Copy 3 to the MRO, give donor Copy 4,
keep Copy 5 and mail Copy 6 to employer contact person.
17. Collection site person secures specimens until shipped to the laboratory via daily courier.
Breath Alcohoi Testing
✓ Check patient's picture I.D.
✓ Explain test procedure
✓ Complete Step I of DOT BAT Form
✓ Patient completes and signs Step 2 of DOT BAT Form - If patient refuses to sign the form, it
is considered a refusal to take the test. Note the refusal in the "Remarks" section.
✓ Verify sequential test number on the EBT with the patient and document in Step 3
✓ Insert ticket when EBT message states to do so
✓ Enter required information into EBT
✓ Open sealed mouthpiece in view of the patient and attach to EBT
✓ Collect breath sample by instructing the patient to take a deep breath and blow steadily into
the mouthpiece of at least 6 seconds or until adequate sample has been obtained
✓ Show patient the result displayed on the EBT
✓If Nezative:
Date and Sign the certification in Step 3
✓ Sign Evidence Ticket
✓ Have patient read, sign and date the certification in Step 4 - If patient has already given a
breath sample but does not want to sign it is NOT considered a refusal; but you must note
that the patient refused to sign in the "Remarks" section.
✓ Attach EBT Ticket copies to the designated space on appropriate copies of DOT BAT Form.
✓ Distribute copies as follows:
Copy 1 - Employer (Confidential-Phone Call, FAX, Mail or In Person as noted in
protocol)
Copy 2 - Employee
Copy 3 - Forward to MRO Office (Gl-1311). If done with a SAMHSA drug screen
attach to MRO copy of chain of custody.
If Positive (.02 or greater):
Do confirmation Test as follows:
✓ Observe 15 minute waiting period and explain restrictions to activities during this time period
✓ If patient has not complied with instructions during the waiting period, note in "Remarks"
section
✓ Continue with testing procedure
✓ Use a new mouthpiece which has been opened in view of the patient
✓ Collect breath sample and show patient the result displayed on the EBT
✓ Have patient read, sign and date the certification in Step 4 - If patient has already given a
breath sample but does not want to sign it is NOT considered a refusal; but you must note
that the patient refused to sign in the "Remarks" section.
✓ Attach EBT Ticket copies to the designated space on appropriate copies of DOT BAT Form.
✓ Distribute copies as follows:
Copy 1 - Employer (Confidential-Phone Call, FAX, Mail or In Person as noted in
protocol)
Copy 2 - Employee
Copy 3 - Forward to MRO Office (Gl-BH). If done with a SAMHSA drug screen
attach to MRO copy of chain of custody
✓ Ensure IMMEDIATE transmission of results to employer to allow employer to prevent the
employee from performing safety-sensitive function.
lbatproc-f:Idata Iboh
DRUG PROOF
I'Irild•�•rci.r I ri_iJ lnnrrlurr-
12r1,Madison
Suite 500
Seattle. MCA 08,10-F
DRUGS OF ABUSE LABORATORY PROCEDURES Tel 200.38,0.200 1
800.898.0180
Fax 200.38,0.2-f:30
EMIT METHOD INFORMATION
The name EMIT stands for Enzyme-Multiplied Immunoassay Technique. This
technique is used for the microanalysis of drugs in biological fluids. Urine is mixed
with two reagents. Reagent #1 contains antibodies specific to the particular drug,
the coenzyme NAD (nicotinamide adenine dinucleotide) and the substrate G6P
(glucose 6 phosphate). Reagent #2 contains a drug derivative labeled with the
enzyme G-6PHD (glucose 6 phosphate dehydrogenase). Reagent #1 is added to
the sample and the antibody binds to any drug molecule in the donor sample it
recognizes. Reagent #2 is added next and the enzyme labeled drug combines with
any remaining antibody; the binding decreases the enzyme label activity. The
enzyme that remains unbound (therefore still active) relates directly to the
concentration of drug in the sample. The active enzyme converts NAD to NADH,
resulting in an absorbency change that is measured spectrophotometrically.
GAS CHROMATOGRAPHY-MASS SPECTROMETRY (GC/MS)
GC/MS is an analytical technique which allows one to separate substances based
on their differential migration rate through a gas chromatographic column and then,
virtually unequivocally, identify them based on their mass spectrum and the
migration time. The technique has been generally accepted as a reference method
for legal applications. GC/MS does have limitations related to sensitivity, the range
of masses measurable and the requirements for sample volatility and thermal
stability. s
In general, however, for drug analysis, GC/MS is the most specific method
available.
The GC/MS in use in the Laboratory of Pathology is a Hewlett-Packard model, 5970
B, which uses electron bombardment to produce a "finger print" mass spectrum of
each analyte as it elutes from the capillary column in the gas chromatography. An
on-board computer correlated the mass spectrum with a stored library of
compounds and produces a report of the probable substances in the sample.
GC/MS is used as a confirmation of positive EMIT screens in our laboratory.
A ,
5
Social Circumstances:
1 Employer designated collection site notavailable. In the exceptional event that an employer
collection site is not accessible and there is an immediate requirement for specimen collection
(e.g. an accident investigation) a public restroom may be used according to the following
procedure: a collection site person of the same gender as the donor accompanies the donor
into the public restroom which has been made secure during the collection procedure. If
possible, a toilet bluing agent shall be place in the bowl and any accessible toilet tank. The
collection site person remains in the restroom, but outside the stall until the specimen is
collected. If no bluing agent is available to deter specimen dilution, the collection site person
shall instruct the donor not to flush the toilet until the specimen is delivered to the collection
site person.
After the collection site person has possession of the specimen, the donor shall be instructed
to flush the toilet and to participate with the collection site person in completing the chain of
custody procedures.
2. Temperature..outside range. If the temperature of the specimen is outside the range of 90.5
degrees to 99.8 degrees Fahrenheit (32.5 degrees to 37.7 degrees Celsius), that is reasons to
believe that the donor may have altered or substituted the specimen, and another specimen
shall be collected under direct observation of a same gender collection site person and both
specimens 'shall be forwarded to the laboratory for testing. The donor may volunteer to have
their oral temperature taken to provide evidence to counter the reason to believe the donor
may have altered or substituted the specimen caused by the specimen's temperature falling
outside the prescribed temperature range.
3. Adulterated specimens. Whenever there is reason to believe that a particular donor has altered or
substituted the specimen a second specimen can be obtained as soon as possible under direct
observation of the same gender collection site person. All specimens suspected of being
adulterated shall be forwarded to the laboratory for testing.
4. Employer notification. The donor's employer shall review and concur in advance with any
decision by a collection site person to obtain a specimen under the direct observation of a
same gender collection site person based upon the circumstances listed above.
1. Hgkted Specimens:
Samples will be rejected if.
> Specimen bottles lack the unique requisition number.
> Specimen label does not exactly match the unique requisition number of the custody and
control form.
> Bottles have no security seals, security seals are broken, there is evidence to tampering, or
security seals are incorrectly placed on the bottles.
6
The chain of custody is blank.
➢ The specimens arrived at the laboratory without the chain of custody form.
➢ The primary specimen contains less than 30 mL urine.
/drugcoll.doc
12194
ATTACHMENT C
VIRGINIA MASON OCCUPATIONAL MEDICINE
MRO Review Process
and
Standard Procedures
The Medical Review officer's single most important function is the review of the laboratory positive
test results and the determination of alternative medical explanations for the positive results. Your
Virginia Mason MRO is a licensed physician who has knowledge of substance abuse disorders and has
appropriate medical training to interpret and evaluate positive drug test results.
A. ftiaja Maso HHO R=0flS&&k--
The employer and employee depend on the MRO accomplishing his/her vital duties according to
49 CFR, Part 40 and the DOT agency rules. The list of primary responsibilities below is followed
by Virginia Mason operating procedures necessary to carry out those responsibilities:
> Receive rest results from the laboratory.
➢ Notify the employee of a confirmed positive test result.
> Review and interpret each confirmed positive test result.
➢ Provide an opportunity for employee to discuss positive test result in person or
by telephone.
> Review employee's appropriate medical history.
);- Review appropriate medical records.
> Verify laboratory results.
➢ Notify employer of verified positive test.
➢ Make return-to-duty or decision to hire recommendation.
> Ensure return-to-duty or decision to hire requirements are accomplished.
B. Virginia Mason MRO Procedures:
Standard procedures for the MRO in carrying out the responsibilities listed in the previous section
are described as follows.
Step 1: Receipt of Laboratory Test Reports
A strict chain of custody procedure, initiated at the time of specimen collection, is required for
handling all specimens throughout the urine specimen collection, testing, reporting and review
process. Employers and certified forensic drug testing laboratories utilize a standard urine custody
and control form (carbonless manifold) that accompanies each specimen to the laboratory. The
form becomes a permanent record of employee identification, urine specimen collection and
laboratory testing data.
Part 1 and 2 of the form accompany the specimen to the testing laboratory. After the specimen is
tested at the laboratory, Part 1 is retained by the laboratory and Part 2 is sent to our MRO
Department with the laboratory results recorded on it. Part 3 goes directly to our MRO Department
from the collector. Part 4 is for the employee, Part 5 is retained by the collector, and Part 6 is
forwarded to the employer anti-drug program manager. Part 7 accompanies the split specimen. (if
one has been collected) to the laboratory or storage site. The order of custody and control form
parts as described above may differ, depending on the supplier of the form (i.e. DrugProof,
Regional Toxicology Services, Drug Scan, etc).
The MRO copy (Part 3) of the custody and control form, will contain information, including but
not limited to:
➢ The type of test conducted(random,post-accident, etc.)
➢ Employee's printed name and signature, daytime telephone number, date of birth,
Social Security or employee identification number, and a unique preprinted
specimen identification number.
➢ Name of the collector, date of collection, collection site, and signed certification
statement by the collector.
The Virginia Mason MRO Department has two coordinators who receive all SAMHSA test results
directly from the testing laboratory. Some laboratories will additionally transmit a separate report
providing test results. The transmittal of results may be by secure electronic means or by mail.
Results are never transmitted by telephone.
The MRO is not required to substantively interpret negative test results. However, the MRO and
the MRO Department shall administratively review the results, ensuring that:
1. Employee identification information on the laboratory test report and the custody and control
form match so that the individual is accurately identified as having a negative test report.
2
2. Negative test results are reported to the employer representative according to the employer's
established reporting procedure. Copy 2 of the custody and control form shall not be
provided to the employer. All negative results, whether laboratory negative or negative as a
result of the MRO verification process will be reported in an identical manner to the employer
representative.
Step 2: Positive Test Report - Verification Process
The NMO verification process of a positive laboratory report requires several specific actions.
Upon receipt of a positive test result from the laboratory the NMO shall:
a. Review Positive Report Documents:
> Review the documents for completeness (e.g. Are the forms properly filled out
with all relevant information?) and ensure that information on Part 2 matches the
already received MRO copy (Part 3).
> Review the document for content.
If the MRO is not satisfied with the documentation or if information contained in the
documents gives rise to doubts about the test analysis, the MRO has two options. These
options are:
> Requesting the laboratory records regarding the specimen to determine if correct
procedures were.followed.
> Requiring the retest of a specimen should questions arise as to the accuracy or
validity of a positive test result. (Only the MRO is authorized to order a
reanalysis of the original sample.)
The MRO review of a positive laboratory report requires several specific actions. The first
responsibility of the MRO is to review the documentary record of the test for completeness
and accuracy and to identify any special problems that may require resolution. This will
involve review of any standard laboratory report (such as might be received at a remote
printer) and Copies 2 and 3 of the custody and control form. The objectives of this review are
to ensure:
> That the test results reported are those for the specimen collected from the
employee identified on Copy 3 of the form;
> That the collector, employee and laboratory have completed the required
certifications (or any failure has been properly documented); and
> That external chain of custody is intact.
3
In addition, careful review of the form may indicate information critical to interpretation of
the test. For instance, where an initial sample falls outside the normal temperature range (and
oral temperature does not explain the discrepancy), a second specimen should be collected
under direct observation. In such a case the MRO would want.to ensure that the two results
are reviewed together and that, as appropriate, a full adulteration panel is run on the initial
specimen(specific gravity, creatinine concentration,pH).
Specimen identification. The following steps will be followed in verifying specimen identity:
1. Compare the specimen identification number contained on Copies 2 and 3. They should
be the same, and the same number should also be contained on any separate computer-
generated laboratory report.
2. Note that the Social Security number is the same on both copies and on any separate
laboratory report (if used).
3. If the specimen identification number or Social Security number is different on any of
the three documents, the results will not be reported at this time. If the error appears to
be at the laboratory, the MRO will request a full report with supporting documentation.
The MRO will not verify the positive until they are fully satisfied that the results
reported are those for the specimen identified to the subject employee. If there is any
doubt concerning correction of a laboratory clerical error, the MRO will order a retest
and have the certifying scientist personally inspect the original specimen container to
ensure it was properly accessioned.
NOTE: The laboratory will have verified that the numbers shown on the custody and control
form are the same numbers on the specimen. The laboratory will leave identifying
marks on the specimen bottle for later verification, should any question arise.
Certifications. The MRO will inspect Copy 2 to verify that the required certifications were
completed by the collector, employee and the laboratory certifying scientist. Signatures are
required (stamps and initials are not sufficient). If the employee has not signed the
certification on Copy 3, the test will be considered valid only if the collector has properly
noted the declination and has recorded any explanation provided. Note that the laboratory
will be unaware of any missing signature on Copy 3 or any explanations that may be placed
there by the collector. Note further that refusal to sign may indicate a collection site problem
that will be discussed with the employee at the time of the medical interview.
Chain of custody. The chain of custody block will have been reviewed by the laboratory, and
any break in external chain of custody will have resulted in canceling the test. However, the
MRO will separately review the chain of custody block. The DONOR entry is preprinted,
and the donor should initial or sign the chain of custody block. The most likely defect in the
form will be a failure by the collector to show transfer for shipment. This is considered a
break in the documented chain of custody since from the paperwork is appears that someone
else may have handled the specimen in that interval.
4
Administrative items. The custody and control form contains additional information that is of
an administrative nature or that documents the circumstances of the collection. Improper
completion(or failure to complete) of these items may give rise to concern over the quality of
the collection as whole, but they are not fatal to the integrity of the testing process and will
not ordinarily provide the basis for treating the test as a negative. As noted, the laboratory
will also follow standard procedures to verify the quality of the collection documentation that
is receives, including markings on the specimen bottle.
If the records from the collection sites or laboratories raise doubts about the handling of a
sample, the MRO may deem the urinary evidence insufficient, the NMO will conclude that
the test result is negative. Administrative errors in chain of custody documents can result in
inappropriate attribution of a positive test result. It is imperative that no employee suffer
unwarranted accusations because of a mislabeled specimen or because of errors in the chain
of custody.
Should any question arise as to the accuracy or validity of a positive test result, the MRO is
authorized to order a reanalysis of the original sample. In reanalyzing a specimen to
determine the accuracy of the reported test result, it must be noted that some analytes
deteriorate or are lost during freezing and/or storage. Therefore, quantitation for a retest is
not subject to a specific cutoff requirement, but must provide data sufficient to confirm the
presence of drug or metabolite.
b. Notifying EMPIOYea of Positive Test Result:
The MRO's notification to an employee of a positive test results will occur promptly after the
MRO has received the positive laboratory test report. The MRO may initiate contact with the
employee immediately after test results are transmitted electronically from the laboratory.
However, the MRO will not complete the verification process until both Copy 2 and 3 of the
chain of custody form have been received. MRO contact with a positive test employee will
be made directly between the MRO and the employee only.
Interview. Regulations Require that the MRO must provide an opportunity for an interview of
an employee testing positive as part of the verification process. This can be in person or via
telephone. If the employee declines the opportunity for an interview, the MRO will proceed
with the verification. If the MRO is unable to locate the employee or the employee does not
return the telephone calls after a reasonable attempt from the MRO; the MRO may contact the
employer representative.
Reasonable attempt. The employer representative must contact the employee and inform
him/her to contact the MRO ASAP, prior to the employee performing his/her next safety-
sensitive function. If the employer representative is unable to contact the employee, the
employer representative may place him/her on medical leave or temporary medically
unqualified status. Please note that the test is still not a verified positive. In order to prevent
undue delays by a n employee's refusal to contact the MRO, the MRO could verify a
confin-ned positive result, only if five days after documented contact of the employer
representative has passed.
5
By declining to contact the MRO after being informed to do so, the employee has waived the
opportunity to present information concerning possible explanations of the test results. This
action will also result in a verified positive. The MRO, however, could reopen the
verification process if the employee could demonstrate circumstances (i.e. the employee
produced medical reports indicating an injury that prevented a response to the
MRO/employer attempted contacts.).
c. Employee Request for Retest:
The DOT agency rules provided an employee who tests positive the right to retest hi/her
original specimen. The employee may be required to pay the cost of the retest, including
handling and shipping costs. The MRO will be careful to note for the employee that the retest
will be conducted using GC/MS confirmation and ONLY a SAMHSA certified laboratory.
The result will be reported positive if any detectable drug metabolite is found.
Retest/reanalysis is not subject to cut-off levels. Furthermore, the MRO is not required to
withhold notification of the positive result to the employer,pending the outcome of the retest.
d. Split Samples Testing:
A split specimen procedure is one in which the employee provides a minimum of 45 mL of
urine, with 35 mL as the primary specimen and 15 mL as the secondary specimen, at the time
of the collection. The first specimen is tested at the laboratory, the second specimen bottle is
stored for testing at a later time should the first specimen the test positive. Upon notice of a
positive test on the first specimen bottle, the employee may requested within 72 hours (or
longer if specified in DOT agency rules) that the second specimen bottle be tested, in
accordance with the employer's policy. The MRO will authorize the testing of the split
specimen. Testing of the split specimen is performed ONLY at a SAMHSA certified
laboratory by GC/MS for the presence of drug metabolite only, and is not subject to specific
cut off levels. In the event the split sample is found to contain no drug metabolites, the MRO
will declare the test results negative. Actions required by the DOT regulations as a result of a
positive test are not stayed pending the result of the test on the second specimen.
Step 3: Reporting of a Verified Positive Test Result
If after appropriate review, the MRO concludes that no legitimate medical reason exists for a
positive test, and that the chain of custody and laboratory procedures were correct, the MRO must
report a verified positive test according to the established company procedure. In addition to
reporting a verified positive test result to the employer representative, the MRO will refer to the
employee to the employer's employee assistance or rehabilitation program if applicable.
a. Reporting to Management:
After the MRO reviews the laboratory positive test results and related matters and verifies
that the positive report is evidence of unauthorized drug use, the MRO will sign the
verification statement on Part 2 of the custody and control form. The MRO may notify the
6
employer representative of a verified positive by telephone, electronically, or in writing. The
Copy 2 of the custody and control form may be sent to the employer, or another form
providing the employee's name, identification number, specimen ID number, date of test,
result and substance found in the urine, may be used. In making a determination of either
verified positive or negative, .the MRO will document, for his or hero files, a summary
statement of the basis for determination.
b. Disclosure of Information:
Except as provided in this paragraph, the MRO will not disclose to any third party medical
information provided by the individual to the MRO as part of the verification process.
1. The MRO may disclose such information to the employer, a DOT agency or other
Federal safety agency, or a physician responsible for determining the medical
qualification of the employee under an applicable DOT agency regulation, as applicable,
only if-
> An applicable DOT regulation permits or requires such disclosure;
➢ In the MRO's reasonable medical judgment, the information could result
in the employee being determined to be medically unqualified under an
applicable DOT agency rule; or
➢ In the MRO's reasonable medical judgment, in a situation in which there
is no DOT agency rule establishing physical qualification standards
applicable to the employee, the information indicates that continued
performance by the employee of his/her sensitive-safety function could
pose a significant safety risk.
2. Before obtaining medical information from the employee as part of the verification
process, the MRO shall inform the employee that information may be disclosed to third
parties as provided in this paragraph and the identity of any parties to whom information
may be disclosed.
Any employee who is subject to a drug test conducted under the DOT rules shall, upon written
request, have access to any records to his/her drug test and any records relating to the results or any
relevant certification, review, or revocation-of-certification proceedings.
Imroproc
7
VIRGINIA MASON OCCUPATIONAL MEDICINE
MRO/EMPLOYEE INTERVIEW CHECKLIST
1. Identify yourself as a Medical Review Officer (MRO) for (Employer) , with
the duty of receiving and reviewing drug test results. Clearly state that you
are acting as an agent for (Employer)
2. Establish identity of the employee i.e., full name, social security number,
employee I.D. number, address/station.
3. If the employee holds a certificate under Part 67 FAR, advise the employee
that the information regarding the drug test results and information supplied
by the employee will be given to the FAA as required by the regulations.
4. Tell the employee you are calling about the specific drug test he/she
underwent on the specific date and at the specific location.
5. Briefly explain the testing process, discussing screening and confirmation
testing, and laboratory reporting.
6. When appropriate in the interview process, give the employee the specific
result.
7. Ask for the recent medical history:
Inform him/her that medical information may be disclosed to third
parties and identify all third parties involved.
Prescription drugs
OTC drugs
Dental, ENT, ophthalmologic, or other medical procedures
Food ingestion
8. Request medical records for review if applicable.
9. Give the employee an opportunity to discuss the results by phone or in person.
Set a specific date and time for an interview.
10. When appropriate, request an exam or interview.
11. Notify the employee that he/she may request a retest, and explain this process
to him/her. Explain that the cost will be the responsibility of the employee.
Tell the employee that a retest will not delay verification of the initial result.
12. If the verification process is complete, notify the employee that the
appropriate management will be notified.
13. Offer to answer any questions. Give employee your name and phone number.
CURRICULUM VITAE
Robert Douglas Petrie, M.D.
PF,RSONAL.
Birthdate: October 29, 1948
Work Address: Virginia Mason Occupational Medicine Clinic
6720 Southcenter Blvd., Suite #110
Tukwila, WA 98188
(206) 242-3651
PROFESSIONAL POSMONS
1987-Present Section Head of Occupational Medicine, Virginia Mason
Medical Center, Seattle, WA
Corporate Medical Director, Alaska Airlines
1979-1987 Occupational Medicine, Washington Industrial Occupational
Medicine Clinic, Seattle, WA
1985-1986 Medical Director, Orthokinetic Rehabilitation Center, Federal
Way, WA
1979-1982 Emergency Medicine at Seattle General Hospital, West Seattle
Hospital and Valley General Hospital in Renton
1977-1979 Clinical Instructor, Department of Family Practice
University of Illinois, Rockford, IL
Private Family Practice and Emergency Medicine
1975-1977 Private Family Practice, Toronto, Canada
BOARDS:
1978 Board Certified - Family Practice
1985 Recertified - Family Practice
1988 Certified F.A.A.- A.M.E.
1989 Board Certified - Occupational Medicine
1990 Designated Senior Medical Examiner, F.A.A.
PROFESSIONAL SOCIETIES:
American Academy of Occupational Medicine
Northwest Occupational Medicine Association
American Academy of Family Practice
King County Medical Society
American Medical Association
HOSPITAL STAFF:
Virginia Mason Medical Center
Valley Medical Center
West Seattle Hospital
Riverton Medical Center
Children's Hospital Medical Center
Overlake Medical Center
SUBSTANCE ABUSE TRAINING:
1984-Present Consultant for more than 300 companies regarding drug and
alcohol testing programs; including management training,
presentations and implementations of programs
1989-1991 Attended seven F.A.A. sponsored seminars on D.O.T. drug
testing rules, including M.R.O. raining and updates
1991 Attended A.L.P.A./F.A.A. training for medical sponsors
designated Medical Sponsor 1991
OLYMPIC RESOURCES
Substance use Professional (SAP)
Scope of Services
A Substance Abuse Professional (SAP), as contracted by Olympic Resources, is a (1) licensed
physician (Medical Doctor or Doctor of Osteopathy), or a licensed or certified psychologist,
social worker, or employee assistance professional, with knowledge of and clinical experience
in the diagnosis and treatment of drug- and alcohol-related disorders; or (2) an addiction
counselor certified by the National Association of Alcoholism and Drug Abuse Counselors
Certification Commission.
The following services will be provided by the SAP, pursuant to the AWC Consortium
member's policies, and the willingness of the test-positive employee.
0 Provide assessment of any affected employee testing positive. The SAP will
confer with the Medical Review Officer (MRO) to obtain results interpretation.
0 Oversee the placement of any employee in need in an appropriate treatment
facility. [The SAP will not make any referral to his/her own private practice, nor
to a person or organization in which the SAP has financial interest.]
• Assist the treatment professional in developing a plan of recovery.
• Upon the employee's return to duty, review the employee's recovery experience
and determine the appropriate conditions of return.
• Establish, with the input of the treatment professional and the City, a schedule for
follow-up drug and/or alcohol tests.
ATTACHMENT D
Association of Washington Cities
Drug and Alcohol Testiong Consortium
Employees Subject to Random Testing
Agency Name:
Please list each covered employee by social security #, last name, first name and middle initial.
Check if the employee is covered under Federal Highway Administration(FHWA), Federal Transit Administration
(FTA) or both.
Please indicate with a "y" for yes if the covered employee is also a supervisor.
(Use Additional sheets if necessary)
Social Security# Last Name First Name MI FHWA FTA Supervisor
After completing this form, return to: Association of Washington Cities
1076 Franklin Street SE
Olympia, WA 98501
FAX: (360) 753-4896
1 certify that the above information is correct and completely reflects our current list of employees
subject to drug testing.
Date:
First Contact: Title: Code Word:
[DC95:randmtst.frm]
A
Association of Washington Cities
Drug and Alcohol Testing Consortium
Confidential Monthly/Random Pool Update
Employer Name:
First Contact:
Mailing Address:
® You must add any new employees hired since the last report period. Place an "A" in the Add/Delete box after any
additions.
® Check if the employee is covered under Federal Highway Administration(FHWA), Federal Transit Administration
(FTA) or both.
a Please indicate with a "y" for yes if the covered employee is also a super-visor.
® Employees no longer employed by your company MUST be removed from the list. Place a "D" in the Add/Delete
box.
(Use Additional sheets if necessary)
Social Security# Last Name First Name MI Add Delete FHWA FTA Supervisor
After completing this form, return to: Association of Washington Cities
Drug & Alcohol Update
1076 Franklin Street SE
Olympia, WA 98501-1346
FAX: (360) 753-4896
I certify that the above information is correct and completely reflects our current list of employees
subject to drug testing.
Date:
First Contact: Title: Code Word:
[DC95:update.frml
A
ASSOCIation of Washington Cities
Drug and Alcohol Testing Consortium
Record Retention Requirements
Members shall maintain all records related to drug and alcohol testing for each driver in a secure
location with controlled access. Keep all documents sent by the laboratory or the collection site.
The following records shall be maintained for a minimum of five years:
a. Records of alcohol test results indicating an alcohol concentration of .02 or
greater.
b. Records of verified positive drug test results.
C. Documentation of refusal to take required alcohol and/or drug tests.
d. Evaluations and referrals.
e. Copy of annual report.
Records related to alcohol and drug collection process and training shall be maintained for a
minimum of two years.
Records of negative and cancelled drug test results and alcohol test results with a concentration
of less than 0.02 shall be maintained for a minimum of one year.
No records containing driver information required by this policy will be released except as
provided as follows:
a. Upon written request of the employee.
b. Upon written authorization of,the employee, records will be disclosed to a
subsequent employer subject to use as specified by the employee.
C. Upon specific, written authorization by the employee, records will be released to
an identified person, for use only as specified by the employee.
d. Records may be disclosed to a decisioninaker in a lawsuit, grievance, or other
proceeding initiated by or on behalf of the employee, including, but not limited
to, a worker's compensation, unemployment compensation or other proceeding
relating to a benefit sought by the driver.
[DC95:require.txti
SUPERVISOR TRAINING LOG
Agency:
Calendar Year:
The following is a list of all employees designated to determine whether reasonable suspicion
exists to require a driver to undergo testing for drugs and/or alcohol who have received at least
60 minutes each of training on alcohol misuse and drug use. The training covered the physical,
behavioral, speech, and performance indicators of probable alcohol misuse and drug use.
__
DATE OFT G
(DC95:train1og.txt]
Receipt of Informational Materials
Certification of Receipt
I acknowledge that I have received informational materials and instruction regarding the
following:
• The agency policy establishing alcohol and drug testing and prohibiting drug and
alcohol use among employees who hold a commercial driver's license.
• Reason why my position has been included in the drug and alcohol testing
program, which vehicles that I drive that are classified as commercial, and what
period of the day that I must be in compliance with the drug and alcohol testing
program.
• The procedures that will be used to conduct testing, protect the integrity of the
process, and ensure validity of results.
• Potential consequences if I violate the policy and rules regarding the use of alcohol
and controlled substances.
• Consequences if I refuse to submit to required testing.
• The effects of alcohol and controlled substance misuse on my health, work and
personal life as well as the signs and symptoms of misuse, and methods for
requesting intervention and referral assistance when I identify a potential problem
with alcohol or controlled substance misuse.
Date Employee Signature
Printed Name
[DC95:certrepffrmj
Drug/Alcohol Testing
Request Form
For After Hours Requests Call:
Drug Proof 1-800-898-0180
Kelly Wright
Agency
Contact Person Phone Number
Name and Place Where Samples are to be Collected
Address City State Zip
Test Required
(Check One)
❑ Drug & Alcohol ❑ Drug ❑ Alcohol
❑ DOT covered employee ❑ Non - DOT covered employee
Type of Test
(Check One)
❑ Pre-employment ❑ Post Accident ❑ Follow-Up Testing
❑ Random ❑ Reasonable Cause ❑ Return to Duty
❑ Other (specify)
Name and SS# of those to be tested (Please print)
Name Social Security Number
[DC95:request.frm]
Drug and Alcohol Testing
Consent Form
Date:
Employee Name:
Name of Super-visor
Requesting Exam:
Name of Supervisor
Accompanying Employee:
Medical Consent: I consent to the collection of breath/urine samples by an authorized
breath alcohol technician and/or laboratory staff to determine the presence of alcohol
and/or drugs, if any.
Authorization to Release Information: I authorize said laboratory to release any and all
medical information obtained during this testing procedure to
Name of Agency
I understand that my alteration of this consent form; refusal to consent or cooperate fully
with the collection of breath/urine samples; my tampering with any such samples; or my
refusal to authorize release information constitutes insubordination, violates the drug and
alcohol testing policy and maybe grounds for termination.
I also understand that a positive result on these tests is grounds for disciplinary action.
Employee Signature: Date:
Supervisor Signature: Date:
Supervisor Printed Name:
[DC95:consent.frm]
SAMPLE
Employee Notification of Scheduled Drug Test
Employee Name: Covered, Employee
Employee ID: SS#
Test Date:
Work Location:
Occupation:
Collection Site:
Your name has been selected for urinalysis drug testing by a computerized program of
random selection. Your selection does not imply that this agency has a specific cause to
suspect you of using illegal drugs. Nonetheless, the DOT regulations and this agency's
Drug and Alcohol Testing Program, require that the random testing urine specimen must
be collected.
You may provide the 60 ml (2 oz) urine specimen in the privacy of a stall. If you are
unable to provide a specimen of sufficient quantity, you will be given a waiting period and
encouraged to drink water. If you are not able to provide the specimen within the waiting
period, you will be deemed to have refused to provide the specimen.
If you refuse to provide the specimen, adulterate the sample, substitute the urine of
another person, or fail the drug test, you will be subject to consequences as specified in
the drug and alcohol testing policy.
Please bring your driver's license or other photo-identification with you for identification
at the collection facility. A copy of this NOTICE must also be presented at the collection
facility. This copy will be retained in your confidential drug testing files, together with
the Medical Review Officer's final determination of the drug test results.
Please sign the bottom of this notice to acknowledge its receipt.
Employee Signature: Date/Time:
[DC95:empnotJnTi]
Authorization to Conduct
Reference Check
Commercial Vehicle Drivers
I hereby request and authorize the acting by and through its
Name of Agency
designated represenative, to contact all previous employers and supervisors for whom I
have performed safety-sensitive functions as a commercial vehicle driver, in order to
access any and all informaiton regarding my commercial driving records.
I expressly authorize the to request information from the
. Name of Agency
previous two years regarding the following:
® alcohol tests with results .04 or greater
• positive test results for controlled substances
• documentation of any refusals to be tested
I understand that the may provide a copy of this form to
Name of Agency
present and previous employers and others that I have identified as appropriate references
to indicate that this information is being obtained at my request.
Signature
Printed Name Date
[DC95:conduct.frm]
Consent to Disclose Information
for Reference Checks
Connnercial Vehicle Drivers
I hereby request and authorize the acting by and through its
Name of Agency
designated represenative, to provide information concerning my commercial driving
records and compliance with Department of Transportation rules and regulations applicable
to commercial license holders, to anyone conducting a reference check for potential
employment.
I expressly authorize the to provide information from the
Name of Agency
previous two years, in writing, concerning the following:
• alcohol test results of .04 or greater
• positive test results for controlled substances
• documentation from the last two years of any refusals to be tested
I hereby acknowledge that the above information is being disclosed at my express request
and that I will make no claim whatsover against the agency, its agents, or employees
arising out of disclosure of such information regarding my commercial driving records.
I understand that the may provide future reference seekers
Name of Agency
with a copy of this form, to indicate that this information is being provided at my request.
Signature
Printed Name Date
[DC95:inforeffrm]
W •impaired Behavior Incident Report Form
Use this checklist to describe the observed behavior that causes you to believe the employee's job performance is
impaired. Provide additional information in each comment section as necessary. You do not need to write in
complete sentences. Attach this form to the Testing Consent form. This checklist is to be kept confidential and
should be placed in the employee's drug and alcohol testing file.
Name of employee:
Location of employee while impaired:
Time impairment first observed: am/pm How long did you observe:
Names of other witnesses:
Did anyone complain to you about the employee's impaired behavior: If so, who:
Checklist of Possible Behaviors
® Physical mannerisms changed or unusual (staggering, gestures, posture)
8 Alcohol on breath
0 Excessive fatigue
0 Out-of-control displays of emotion
0 Unusual fear
0• Memory problems (difficulty recalling instructions, data, procedures)
0 Engaged in verbal or physical abusiveness
0 Excessive sweating or hand/foot tremor
0 Responsible for serious safety or security violation
0 Caused or involved in serious accident or near miss
a Demanding, rigid, inflexible behavior(s)
0 Clearly refused to do assigned work (when mixed with other behaviors)
0 Made significant error(s)
a Behavior which disrupted workflow
0 Interfered with or ignored established procedures
0 Complaints by co-workers or subordinates
Describe Incident:
Comments or Statements by Employee Indicating Possible Impairment:
Employee's Explanation for Impairment:
Supervisor's or Witness' Signature
Time am/pin Date
[DC95:behave.frml
Vehicular Incident Reporting Procedure
Supervisor's Cheddist
When a commercial vehicle driver is involved in an accident with a commercial vehicle that
results in either 1) a fatality or 2) a moving violation citation and injury to some person or
damage to one or more vehicles severe enough to require towing from the scene, the
employees who hold commercial licenses, and who may have been responsible for the
accident, must submit to alcohol and drug testing in accordance with Department of
Transportation rules and regulations. The following procedures have been developed to assist
you in dealing with this type of an accident and should be immediately implemented.
In the event of an accident, please complete the following checklist:
® Ensure that if the employee is injured, that he/she receives medical care. If seriously
injured, call 911 for assistance. After help arrives, follow the established procedures
for drug and alcohol testing.
® Notify the City's designated contact for drug and alcohol testing that the accident
occurred and that the employee is being taken in for testing.
a Remind the employee that, in accordance with Department of Transportation Rules,
they must make themselves available for drug and alcohol testing.
0 Have the employee sign the Testing Consent Form authorizing drug and alcohol tests.
0 If the employee refuses to sign the consent form, remind the employee that refusal to
test will be treated in the same manner as a positive test and handled accordingly.
Testing can occur without a signed consent form.
0 Contact the collection site to let them know that you will be bringing the employee in
for a post-accident drug and alcohol test.
0 Complete a Drug/Alcohol Testing Request Form and take the form with you to the
collection site.
® If the employee receives medical care, follow agency instructions for filing a Worker's
Compensation claim.
[DC95:supvchk.frmJ
X T
V ehicular Incident Reporting Procedure
Employee's Checklist
When you are involved in an accident involving a commercial vehicle that results in either
1) a fatality or 2) a moving violation citation and injury to some person or damage to one
or more vehicles severe enough to require towing from the scene, and there is a possibility
that your actions or decisions might have contributed to the accident, you will be asked
to submit to alcohol and drug testing. In accordance with Department of Transportation
rules and regulations, this testing must be conducted. The following checklist has been
developed to help you anticipate what will occur following this type of an accident.
0 If you are injured, ask someone to call 911.
0 Notify supervisor immediately of the accident.
® Do not drink alcohol until an alcohol test has been administered if one is
determined to be necessary by your supervisor.
0 In accordance with Department of Transportation rules, your supervisor will ask
you to make yourself available for drug and alcohol testing.
• Your supervisor will ask you to sign a Consent Form authorizing a drug and
alcohol test.
• Proceed to the testing site with your supervisor or designee.
If you refuse to take a drug or alcohol test, based upon agency policy and the rules
and regulations of the Department of Transportation, you will be treated in the
same manner as if you had tested positive for drugs and alcohol.
If you receive medical care, follow agency instructions for filing a Worker's
Compensation claim.
(DC95:empchk.frmJ
Association of Washington Cities
Drug and Alcohol Testing Consortium
1076 Franklin Street SE
Olympia WA 98501
(360)753-4137 FAX(360)753-4896
DRAFT ANNUAL SUMMARY FORM
FHWA FTA
Number of Covered Employees
DRUG TESTING INFORMATION
Type of test Number of Number of Number of specimens positive Number of positivelspecimens'for each drug
specimens collected negative specimens' for one or more drugs' Marijuana Cocaine Phencychdin® Opiates Amphetamines
Pre-employment
Post accident/non-fatal
Post accident/fatal
Reasonable Suspicion
Return to Duty
Follow-up
Number of persons denied a position following a positive drug test
Number of employees returned to duty following a positive drug test or refused a drug test
Ni1mber of employees who refused to submit to a non-random drug test 0
.oer of supervisors who received reasonable suspicion training- 0
ALCOHOL TESTING INFORMATION
yp er o on.irmation Tests Number of.ConfirmationQests;
T e ofaest Number of Number of Numb,
screening tests con Tirmatian tests: between.02 and A39 equal to or greater than.04
Pre-employment
Post accident/non-fatal
Post accident/fatal
Reasonable Suspicion
Return to Duty
Follow-up
Number of employees who engaged in alcohol misuse who were returned to duty in a covered O
position after complying with SAP recommendations
Number of employees who were administered drug and alcohol tests at the same time resulting in a positive
drug test an an alcohol concentration of.04 or greater
Other Alcohol Violations
Number of Drivers Action Taken
Driver used alcohol while driving a commercial vehicle
Driver used alcohol within 4 hours of driving a commercial vehicl
Driver used alcohol before taking a post accident test
Number of employees who refused to submit to a non-random alcohol test
Number of supervisors who received reasonable suspicion alcohol training
ATrACHMENT E
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