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Appeared in May/June 2004 issue of The Synergist, the magazine of the American
Industrial Hygiene Association (AIHA
By Elena Carr
In their efforts to improve the health and well-being of workers and their
families and communities, industrial hygienists and other occupational health
and safety professionals are increasingly expected to perform a variety of functions
that expand their reach and impact. One example is the management of occupational
medical services, which may encompass employee substance abuse testing. As such,
it is important that practitioners understand the many issues surrounding this
multifaceted and often controversial topic.
The AIHce 2004 roundtable "Current Issues in Employee Substance Abuse Testing"
provided participants with an opportunity to become familiar with current knowledge
on the relationship between substance abuse testing and occupational accidents and
injuries, key policy considerations when implementing testing and how testing fits
into the larger goal of saving lives, improving quality of life and increasing productivity.
Post-Accident Drug Testing
Donald Whorton of WorkCare in Alameda, Calif., began the panel by providing a
general background on drug testing and then specifically addressed one particular
type of drug testing-post accident. In particular, he discussed it within
the context of the U.S. Department of Transportation regulations as prescribed in
the Omnibus Transportation Employee Testing Act of 1991, which requires transportation
industry employers who have employees in "safety-sensitive" positions to
have drug-free workplace programs that include both drug and alcohol testing.
Under DOT rules, employers must test for five substances (amphetamines/methamphetamines,
cocaine, marijuana, opiates and PCP) plus alcohol, follow specific procedures for collection
of urine and transport of samples to certified laboratories, confirm results through medical
review officers and submit annual reports on all testing activities and specific reports on
post-accident testing.
According to Whorton, non-DOT mandated employers have more latitude in handling drug
testing as they see fit. Although many choose to test for the same substances and follow
the same procedures as DOT, others test for additional drugs for which there are no DOT
protocols. Since there is no federal law that specifies how these employers may conduct
drug tests, they must take into account any state or local laws that may impact how
testing can be conducted.
Whorton then discussed advantages and limitations of different drug-testing modalities,
including traditional urine tests and the relatively new method of hair analysis. Overall,
he said urine is more useful for determining short-term presence of drugs and is therefore
most appropriate in post-accident situations. Although hair analysis offers a longer window
of detection and can reveal a history of use, it is not useful for current events and thus
is not appropriate for post-accident testing. Furthermore, hair analysis is controversial,
he said. Privacy advocate groups point out potential privacy issues, including the argument
that it discriminates against pregnant women, due to different enzymes produced by the body
during pregnancy, and African-Americans, due to differences between minerals produced in
the hair of African-Americans and those produced in the hair of Caucasians. Some also cite
cases of alleged false positives because of individuals’ hair absorbing drug residue
present around them.
Whorton closed by providing recommendations for procedures to follow if a company
chooses to implement post-accident testing including using urine drug testing and breath
alcohol testing, accompanying workers to the testing site, following the DOT protocol
and using accredited laboratories, a confirmation testing technology and a medical
review officer.
Drug Testing And Occupational Injuries
Paul Rountree, Houston Endowment Distinguished Professor of Environmental Sciences
at the University of Texas Health Center at Tyler, summarized trends in illicit drug
use over the past two decades and reviewed the origins and current state of the workplace
drug-testing industry. He said that 38 million drug tests are performed each year at a
cost exceeding $1 billion, and that an estimated half of the nation's workers are employed
by firms that conduct testing. Furthermore, research indicates that the vast majority
of workers believe that testing deters drug abuse and reduces accidents.
According to Rountree, a natural connection has been drawn between work site safety
and drug testing, due in part to a handful of accidents in which drugs or alcohol were
found to be involved, such as the 1981 U.S.S. Nimitz aircraft carrier crash, the 1987
train collision in Maryland and the 1989 Exxon Valdez environmental catastrophe. However,
thus far scientific research does not support a significant correlation between drug use
and workplace accidents, he said. Few studies have been published on the subject, and
those few have significant limitations. For example, studies rarely compare accident
rates of drug users with matched groups of nonusers, many address illicit drugs but
not alcohol and reports rarely take into account other confounding data such as time
of day, weather and other circumstances.
Rountree went on to provide participants with a brief overview of the relevant
literature to date and closed by summarizing currently proposed changes to the federal
government's drug-testing program overseen by the Substance Abuse and Mental Health
Services Administration. Among these proposals is the plan to incorporate alternative
methods of testing, including analysis of hair, saliva and sweat.
Policy Considerations In Drug Abuse Testing
Elena Carr, drug policy coordinator at the U.S. Department of Labor, told participants
that many of the complex issues surrounding drug testing stem from organizations failing
to recognize that it is only one element of the larger goal of a safe, healthy and drug-free
workplace. Although it can be effective in terms of deterring and detecting drug use,
testing alone does not achieve a workplace free of the hazards created by employees'
abuse of alcohol and other drugs, she said.
Carr provided a brief overview of the price businesses pay if they do not effectively
address workplace substance abuse. In addition to increased accidents and other obvious
physical safety concerns, businesses may experience lost productivity, high turnover and
absenteeism and increased health care costs and workers' compensation claims, she said.
The good news is that employers can protect their businesses by educating employees about
the dangers of alcohol and drug abuse and encouraging individuals with related problems to seek
help, and, depending on the organization, drug testing may be one of several appropriate
strategies for doing so, said Carr. However, if the decision is made to test, it is critical
that employers adopt a balanced approach that protects the interests of both employer and
employee with consistently followed policies and procedures.
Carr said DOL's stance is that drug testing should be one part of a comprehensive
drug-free workplace program that also includes a written and widely communicated policy,
training for supervisors on signs and symptoms of substance abuse, employee education on
the dangers of substance abuse and assistance and support for employees with related problems.
In contrast, a punitive, risk-averse approach characterized by vague policies, inconsistent
procedures, minimal employee education and supervisor training and little or no assistance
for employees does little to achieve positive outcomes for employers, employees, families
and communities, she said.
Before deciding to test, employers need to consider several key policy factors, including
who will be tested, consequences of a positive test, what substances will be tested for, when
testing will be conducted, cutoff levels and safeguards and confirmation procedures. In addition,
employers must be familiar with any local, state and federal laws or any collective bargaining
agreements that may impact drug testing.
Carr described Web-based tools available free from DOL to help employers develop sound
policies and effective, balanced drug-free workplace programs. She closed by summarizing
the many ways businesses benefit from being drug free, including safer workplaces, higher
quality applicants, improved productivity and reduced medical, insurance and liability costs.
Moreover, by providing employee education and assistance, drug-free workplaces significantly
contribute to occupational health and safety professionals' larger purpose-safer, healthier,
drug-free workers, families and communities.
Carr is with the U.S. Department of Labor, Washington, D.C.
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