COMPLIANCE CORNER BY COLINDA HOWARD AND MIA HICKS, DISA


How to Build an Effective Drug Testing Policy That Stays Up-To-Date and Compliant


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uilding and implementing an effective drug and alcohol testing policy is key to creating


a competent, effective, and efficient workforce that gives you a competitive advantage in business. Employers with a quality workforce and efficient drug testing program oſten benefit from a safer and more productive workplace. However, maintaining that policy so it meets compliance standards, state and federal laws, and addresses safety-sensitive positions isn’t always an easy task. Tis past year, Gartner cited the top


business priorities for senior leaders across the U.S. in a national CEO survey. Predictably, the list of priorities referenced establishing the “right” corporate structure for business growth, product improvements, customer satisfaction, cost management, risk management, etc. However, these high-level business priorities take a second seat to the necessity of a competent, effective, and efficient workforce. Having the right staff, ensures you can deliver in a manner that drives a competitive advantage for customer satisfaction resulting in business growth and profits. If your organization does not have a


documented testing policy, today is a prime time to develop it because delays risk biased enforcement and inconsistent discipline, which can result in workplace complaints and liability. Creating a new drug testing policy can be a daunting task because of numerous decision points that must be made before the draſt stage, but spending the time to develop a well-craſted policy upfront oſten saves time and money down the road.


36 datia focus A critical consideration—employees


will inevitably look to the organization’s testing policy for greater clarity regarding boundaries for drug and alcohol use activities that can impact workplace performance and violations. Te hiring process is a complex and consuming process that hopefully results in hiring and retaining a highly competent employee that will bring significant value to your organization. But hiring a competent employee means very litle if your organization cannot retain that employee because they violated your organization’s testing policies. Seting this standard early on is oſten overlooked as a best practice but is critical to your program’s success. To minimize delay and labor, it is


common for employers to collaborate with a drug testing service agent like DISA for development consultation or to review policy revisions. You should consider the following topics when creating a policy or reviewing your current policy:


Determine the Internal Stakeholders to Lead Your Policy Development


Your policy development team may differ depending on the policy. It could include team leads, supervisors, managers, HR directors, or executives. Gathering a diverse group of stakeholders will ensure your policy(s) will meet the needs of all affected groups.


Staff Categories Identify the staff categories that will be mandated by the testing policy with consideration for: • Permanent employee • Fixed-term employees • Casual employees (on a “needed basis”)


• Apprentices or trainees • Temporary employees • Contractors and sub-contractors


Roles and Responsibilities Identify all job classifications that will be mandated by the testing policy with special atention to positions that may qualify as safety-sensitive roles.


Work Locations Draſt a roster of work locations, including each location’s city, county, and state for applicable staff and locations.


Identify Legislation and Regulations Impacting Your Business


• Several laws, regulations, and guidelines may apply to your testing policy based upon the applicable staff, their individual role and responsibilities, work locations, criteria for safety- sensitivity jobs, and parties required to approve such policies, including third-party auditors, state agencies, etc. before release to your workforce. Tese circumstances bring unique challenges as you develop and update your policy to ensure adherence with:


• DOT standards (if applicable) including relevant modals


• Non-DOT Standards—city, state, and state mandates for each of your work locations


• Industry-Specific Consortiums/ Testing Programs


“Say What You Mean and Mean What You Say”— The Brainstorming Phase


At a minimum, it is critical to determine preferred standards for:


2020 • Issue 2


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