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Best Practices For the contractor organizations with safety-sensitive employees working for multiple operators, the key to overall com- pliance is to have these employees meet the most stringent requirements. Having designated the most stringent requirements allows the contractor the versatility of each safety-sensitive employee being eligible to work for any of their customers. • Testing Panel: Develop a panel that meets the most stringent initial and confirmation cut off levels of any operator. Make sure to look at all the specified requirements designated in the master service agreements with each operator. Diagram 1.2 contains an example of a client, non-DOT panel that meets and/or exceeds the most stringent testing levels in the oil and gas industry.


• Testing Pool and Specimen Type: Develop a pool to meet all operator test- ing requirements. All contract employees go into this pool and are subject to the highest random testing percentages required by any operator. Depending for whom the contractor is working, it may be necessary to include random hair test- ing. Consider spliting hair testing into a smaller pool to be more cost effective and efficient as there are fewer operators who require hair testing.


• Auditing Agencies: Become familiar with the reporting forms and frequency requirements of the different agencies. Be proactive and learn what they will require. If the workload becomes too much to handle, find a TPA or service provider who does this regularly and can provide assistance. Tere are many qualified companies who can help navi- gate these requirements.


www.datia.org


A Look Forward At the 2012 International Forum for Drug and Alcohol Testing (IFDAT) in Rome, Italy, atention was brought to the chal- lenges contractors face in meeting operator drug and alcohol testing requirements. Many operators in the oil and gas indus- try were in atendance to hear firsthand from contractors who spoke about their individual struggles in meeting the require- ments of their operator clients. Some operators understand the


struggles. “We are encouraging an industry standard organization to take the lead and develop a standard,” said Rocco Iannapollo, Global Programs Manager at ConocoPhil- lips. “Te current state of affairs can be improved significantly through a collabora- tive approach with other operators and key stakeholders.” Some organizations that could potentially take the lead include: the International Petroleum Industry Environmental Conservation Association (IPIECA), Oil and Gas Producers Associa- tion (OGP), American Petroleum Institute (API), IFDAT and DATIA. Although program standardization is an


industry talking point, contractors must be proactive in facing their current compliance challenges. Te best practices above provide a framework to develop a cross-operator complaint program for contractors. By tak- ing the time to create a program that meets all operator requirements, contractors can remove many of the compliance obstacles inherent in working for multiple operators. ❚


Footnotes 1


The Census of Fatal Occupational Injuries database of oil and gas extraction workers from 2003 to 2010.


2


ConocoPhillips Workforce Total Recordable Rate (TRR) for Safety Performance Data. For additional information visit: http:// www.conocophillips.com/sustainable-development/reporting/ performance-data/Pages/default.aspx#EMPLOYEES. TRR measures the number of jobsite injuries per 100 workers.


Diagram 1.2 Substance


Amphetamines Barbiturates Benzodiazepines Cocaine Marijuana MDA/MDMA Methadone Methaqualone Opiates Oxycodones Phencyclidine Propoxyphene


6-Acetylmorphine 10 ng/ mL


ng/mL 200


ng/mL 200


ng/mL 150


ng/mL


20 ng/ mL


ng/mL 300


ng/mL 300


ng/mL 300


ng/mL 100


ng/mL


25 ng/ mL


ng/mL 300 250 300


Initial Confirmation 10 ng/mL


100 ng/mL 100 ng/mL 100 ng/mL 50 ng/mL 10 ng/mL 200 ng/mL 100 ng/mL 200 ng/mL 100 ng/mL 100 ng/mL 10 ng/mL 100 ng/mL


The above drug testing panel is an example that could meet or exceed the most stringent testing levels known in the chemical and/or oil and gas industries. It is advised to have an industry expert help develop a drug testing panel to meet all requirements. This is a client, non-DOT panel.


Sammie Dabbs currently works as Client Solutions Business Analyst at Advanced Workplace Strategies, Inc. (AWSI), where she is a key resource for many contractors in the oil and gas industry. Dabbs is the Editor-in-Chief of the International Forum of Drug and Alcohol Testing’s (IFDAT) Global Insider and obtained her degree in Journalism from California State University of Fullerton.


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