Elementary, My Dear Watson Here are the elements every policy should include to achieve clarity: • Contact person for questions regarding the policy
• Prohibited behaviors, on and off duty • Jurisdiction(s) of policy • Employee responsibilities • Management responsibilities • Existence of Employee Assistance and contact information (whether or not your company has a zero tolerance policy)
• Testing occasions • Methods of testing • Testing process (lab, instant, use of lab results or Medical Review Officer) • Substances tested
• Cutoff levels (tolerance—particularly important for alcohol
• Violations other than a positive test • Consequences for violations • Other requirements and responsibilities Let’s review these elements more
thoroughly. It is always a good idea to identify the person or person(s) responsible to answer questions on the policy. If the referral is simply to “ask your supervisor or manager if you have any questions,” the employee may not receive a full or accurate answer. Be sure the contact person is available during regular business hours. Some federal agencies require an individual person be named (usually the Designated Employer Representative or DER), others may accept the position title and contact information. Tis allows the
incumbent to change without the need to revise and re-publish the policy. Prohibited behavior should be clearly
detailed. Many policies contain language prohibiting the presence of drugs or drug metabolites in a person’s system. But, in addition, good policies will outline prohibitions on: • Paraphernalia on company premises • Possession, dispensing, manufacturing, or trafficking drugs
• Refusal to test (cooperate) with drug or alcohol testing Consequences for these violations should
be the same or possibly more punitive than a positive test if your policy allows for rehabilitation. Make it clear in your policy (and to your management team) that consequences apply in the absence of a
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