Release Authorized by: / Danny Trahan, Safety Director / Manual Rev 4
TESTADMINISTRATOR’S GUIDE
SECTION I
1.The purpose of the Substance Abuse Prevention Program is to have a drug-free and therefore safe workplace for our employees.
2.This guide provides general information that should be helpful as you begin substance abuse testing at your site/facility as required by your substance abuse prevention program.
3.There are legal ramifications in many areas of substance abuse testing. Testing technology and laws are changing rapidly.
4.This guide is not all-inclusive, so you may have questions that are not covered here. If so, contact P2S HSE Substance Abuse Prevention Program Administrator Kendra Winchester (225) 202-5747.
SUBSTANCE ABUSE PREVENTION PROGRAM MANUAL
A Substance Abuse Program is mandatory for all P2S sites/facilities. The Substance Abuse Prevention Program Manual is your textbook for drug testing at your location. If you read it carefully, you will find answers to most of your questions. Like all high level manuals, this is a management document. Keep it in your office or other secure area. Let other designated managers become familiar with it, such as the site personnel/Human Resources (HR) Manager and the site HSE Representative. These persons may be helping to implement and carry out the program with you. If you have a question about the manual or a question for which the manual does not give an answer, call the P2S HSE Substance Abuse Administrator before acting. Remember the Substance Abuse Prevention Program is site specific and cannot be carried from one site to another.
STATEMENT OF POLICY FOR APPLICATIONS
This statement should be attached to or a part of applications for new hires. This statement notifies applicants that they will be drug tested if an offer of employment is made to them. Some may read it and leave knowing they cannot pass such a test. We are letting potential employees know what we expect of them and of our commitment to a drug-free and safe worksite. This statement does not need to be signed by anyone.
STATEMENT OF UNDERSTANDING / SITE LETTER
All employees and candidates for hire are to be informed that P2S is a drug–free workplace. All employees who are within the scope of Policy HR-1505 will be required to sign a Statement of Understanding acknowledging their agreement to abide by the terms and conditions of policy.
CONSENT TO URINALYSIS
This form is a legal document that records identification of the subject about to be tested.
Under no circumstances should a test subject be asked about medications prior to a test. Only if the results are confirmed non-negative by a SAMSHA-certified laboratory, may the subject be questioned about what he/she has been taking, and then only about drugs in the category in which the sample tested non-negative. The consent form, Chain of Custody documentation, and the test results should be kept in a separate, secure file with limited access.
FOR CAUSE OR REASONABLE SUSPICION
The decision to test for cause or reasonable suspicion is based on supervisor observation. Should an employee be suspected of being under the influence of drugs or alcohol, a Description of Suspicious Behavior Form should be completed. This form requires the signatures of 2supervisors or 2members of the site. The description must be based on observed signs and not by hearsay or rumor. Always keep in mind: the behavior that raises suspicion should present itself in the workplace and/or affect the work of the employee.
SECTION II
ALERE QUICK TEST GUIDELINES FOR SAMPLE COLLECTION
This section is for the persons designated to perform the collection of samples for testing at your site. You should designate at least 2such people. Make sure that all such designated persons are trained, certified, and thoroughly familiar with the entire process. This is an important procedure and mistakes can lead to liability. The important thing is to take one’s time in filling out the documentation and to take the subjects one at a time through the entire process before starting on the next subject. Any questions about this should be directed to the P2S HSE Substance Abuse Administrator, Kendra Winchester (225) 202-5747.
Should you use a clinic or other outside source for collection, be sure that those persons are familiar with P2S’s policies, practices, procedures, and HSE forms, laboratory forms, and DOT Urine Specimens Collection Guidelines. Outside sample collections should be arranged through the P2S HSE Substance Abuse Administrator, Kendra Winchester (225) 202-5747.
Strict procedures must be followed in the collection of urine samples in order to ensure the integrity of the sample and to provide an accurate and legal chain of custody. These procedures prevent mix-ups, tampering, and misplaced documentation. The documentation furnished by the approved testing laboratory may vary in some small details, but the principles are the same.
GENERAL
Before any collection can be made, the site or collection location must have a site specific Substance Abuse Prevention Program that has been developed and approved by the P2S HSE Substance Abuse Administrator.Any other testing is against corporate policy.
Each location must designate a restroom facility that will be used for urine specimen collection. It is not necessary to set aside facilities exclusively for collection, but the designated facilities should be the only place collection is performed. The facility should provide privacy as well as security against tampering. A bluing agent should be placed in the bowl, and water in faucets, etc., turned off during
testing. The facility should be free of bleach, cleaning agents and other material that could be used to dilute or alter a sample.
Regular inspections of the designated facilities must be made to prevent the presence of such material. The facility should also be in close proximity to the area where documentation will be completed.
TRAINING
P2S’s illicit substance and alcohol abuse awareness training program provides management, supervisors, and employee’s education onthe dangers of drug and alcohol abuse, drug identification, symptoms and methods of drug and alcohol use. It also provides information on P2S’s policies and procedures concerning drug and alcohol abuse in the workplace and penalties to be imposed for violation of the policy. The training program emphasizes the practical factors in dealing with substance abuse and the available substance abuse counseling, rehabilitation, and employee assistance programs. This training program is for field project site management and supervisors and is highly encouraged for all field project employees.
BEFORE TESTING
Subjects to be tested should be individually directed to the collection area. The collection process requires strict concentration and sequential procedures. Trying to deal with several subjects simultaneously leads to confusion and may result in mishandling of samples. Therefore, the entire collection process must be completed for each subject before proceeding with the next subject.
COLLECTION PROCEDURE
Collection Facility – Adhere to DOT Guidelines
On Site Testing – Follow Laboratory Procedure
- With the subject, review the Consent to Urinalysis and Chain of Custody (COC) Form. Complete the identification information at the top.
- Have the subject provide picture identification. This prevents any attempt to have a “clean” person give a sample in place of the proper person. This should be accomplished by driver’s license, state ID card, or company ID card. For employees being tested for random or for-cause testing, the supervisor’s identification of the subject will be sufficient if other identification is not available.
- Collector completes Section C (Name/I.D.) on the chain of custody form by writing in the subject’s last name, first name and job number in available spaces.
- Collector completes Section D (Donor SSN or Employee ID No.) with social security number.
- Collector completes Section E by checking the reason for the test.
- Subject completes Step 5.
- Subject’s outer garments and personal belongings are to be left outside collection area. Wallet may be retained.
- Instruct subject to wash hands before collection.
- Open the quick screen collection kit in front of the subject and give it to the subject. No personal observation should be made during the process unless the first sample is suspected to be tampered with; and then only indirect observation is allowed. The two possible reasons for indirect observation are: temperature is not in the acceptable range or the test results show low specific gravity or low creatinine. If indirect observation is necessary, ALWAYS have subject and observer of the same sex. Make sure that the subject takes no personal belongings into the stall, such as purse, lunchbox, etc. Make a visual search of the subject before they enter the facility to see if there are any bottles, etc., on them. Ask the subject to empty the pockets before going to the facility. The subject must retain possession of his/her wallet. Accompany the subject to the facility.
- Have the subject provide a sufficient sample of at least 60ml into the calibrated collection container with temperature strip.
- Check specimen temperature and record results in Step 2, acceptable range 90-100° F 32°/38°C.
- In full view of the subject, collector places the security seal over the top and down both sides of each specimen bottle.
- Instruct subject to date and initial the security seal that have been affixed to the specimen bottle. (Refer to your respective laboratory’s instructions for this). Complete the Laboratory Order Form/Chain of Custody form. Extreme care must be taken to assure that all required information is completed and correct. Mixed-up social security numbers, an omitted signature, etc., will result in a rejection of the sample by the laboratory.
- If on site testing procedures are to be done, adhere to strict guidelines provided by the Laboratory Product being used for testing.
- If on site collection is being performed, adhere to DOT Collection Guidelines.
If the test result is NEGATIVE:
- Fax the chain of custody to the P2S HSE Substance Abuse Administrator Kendra Winchester
Fax: (225)-753-1462.
- Discard specimen.
- Mail original to Kendra Winchester, 456 Highlandia Drive, Baton Rouge, LA 70810.
If the test results are NON-NEGATIVE:
- Place the original chain of custody form and the sealed sample into the biohazard bag for transport to the laboratory via express transport. Place the biohazard bag in the box and then place the box in the Fed Ex Clinical Pak with pre-printed laboratory labels for overnight delivery. Drop off at the nearest Fed Ex collection site or call Fed Ex for pick up.
- Fax a copy of the paperwork immediately to Kendra Winchester Fax: (225) 753-1462 or email to and so results can be monitored.
Note:Under no circumstances should you ask the subject about medication he/she may be taking before the drug test. Note any medication information provided by the employee voluntarily should be listed in the Remarks section of the chain of custody form.
Send all documentation to HSE Substance Abuse Administrator, Kendra Winchester, for file retention after faxing. This information is not for general access. In the event of a confirmed non-negative result, the employee should be offered the opportunity to explain the non-negative results, identifying any drug he/she has taken that are in the same category of the non-negative result.
SECTION III
GENERAL SUBSTANCE ABUSE SCREENING INFORMATION
Who is subject to substance abuse screening on my job?
At P2S, all employees, both hourly and salaried, are subject to the drug testing requirements on your job. Temporary employees furnished by an agency are to be tested before coming to work for P2S. Contractor/subcontractor employees are also subject to testing.
When do I test new hires?
It is P2S’s preference to have all individuals screened and negative results received before access to P2S or Client property.
Do salaried transfers get a drug test?
Salaried transfers will be tested before their transfer to your job site if there is no drug screen performed in the last 90 days. If a transfer fails the drug test, the transfer will not be made. All testing must comply with corporate policy.
What if an hourly employee is promoted to a salaried position?
All candidates for hire to a salaried position in P2S are to be chemically screened before the actual hiring can be done. Since hourly employees are terminated then hired as salaried, they must be screened before the change in status can be effective. This also works the same way from salaried to craft positions.
What if the subject says he or she can’t void at the appointed time?
The test is a requirement for employment. Should someone indicate inability to void at the specified time, have them wait in the office area where they can be observed. Let them drink water (no more than 3 8ounce glasses within a 3-hour period. Usually within an hour or two the person will be able to void. If an acceptable sample cannot be obtained by the sites documented time limit, testing must cease, and the HSE Substance Abuse Administrator (Kendra Winchester (225) 202-5747 must be notified. The HSE Substance Abuse Administrator or Safety Manager must direct the employee to obtain, within 5working days, an evaluation from a licensed physician who has expertise in the medical issues raised by the employee’s failure to provide a sufficient specimen. If the referring physician determines a medical condition precluded, or probably precluded, the employee from providing a sufficient amount of urine, the test must be cancelled. If the referring physician does not determine a medical condition interfered with the provision of a sufficient amount of urine, this is considered a refusal to test. Any questions concerning this issue should be addressed with the HSE Substance Abuse Administrator.
Who should confront an employee with a non-negative result?
On P2S project sites, non-negative results are reviewed by the P2S Medical Review Officer. The MRO must determine whether there is a legitimate medical explanation for the confirmed positive, adulterated, substituted, or invalid test results. The MRO must conduct a verification interview with the employee. The MRO is also responsible for informing the employee of his/her right to have the specimen retested. The MRO may communicate test results directly to the employer. The MRO who transmits the results to the employer must ensure the security and limited access to the transmission. The HSE Substance Abuse Administrator is the person for MRO to contact. The results are a confidential document and should be kept in a secure location. Human Resources will be notified of any confirmed positive results which will result in termination and removal of employee from the jobsite (to be coordinated confidentially between Human Resources, Safety, and Site Upper Management).
What if the person denies ever taking drugs?
We have confidence in the laboratories we use for our drug testing. A drug test is not a determinant of whether someone is an addict or user; it is a determinant of whether the individual has certain detectable levels of drugs in his/her system. Using the laboratory methods we require, we have never had a result proven erroneous. As long as there was no mix-up of the sample before getting to the lab, we will stand behind the results. The employee does, however, have a right to appeal results and/or have specimen retested.
Do “over-the-counter” drugs show up on the drug test?
Some may show up on the initial screen, but very few will affect the GC/MS confirmation. However, in some people, antihistamines may indicate a non-negative for amphetamines. This is because some nasal sprays contain small amounts of amphetamine. Heavy use may ingest the system with sufficient amphetamine to show non-negative. In seasons conducive to colds and flu, pay close attention to the cold medication that the subject may be taking, even if it is a non-prescription drug.
Also, some non-prescription drugs may contain amounts of barbiturates such as Primatene tablets containing Phenobarbital. These may show up on confirmation as non-negative. Call P2S HSE Substance Abuse Administrator if you are at all unsure.
Does cocaine used in mouth and nose surgery show up on a drug test?
This is very possible, especially if the surgery is just before the drug test (2-3 days). While no one can legally have a prescription for cocaine, it is used as a packing for nasal and mouth surgery to stop blood flow when stitches are impractical. The cocaine enters the bloodstream and will show up if the person is tested within 2-3 days of the packing. This is why the MRO asks the subject, if they have visited a physician or dentist in recent weeks. If so, and the drug shows on the test, the person will be given an opportunity to bring a statement from the doctor or dentist that sets forth the medication given for MRO review.
What termination codes do I use?