Starting a Drug Testing Program

You’ve made the decision — you want a drug-abuse testing program. Aproperly conceived, designed and implemented program will help make yourworkplace safer, more efficient, and drug free. If not properly designed andimplemented, your drug-testing program can cause more problems than it prevents.

A policy
The first step in setting up a drug-free work place and a drug abuse testingprogram is a well conceived and written policy. A good policy defines the goalsof your program, what substances are tested for, how the urine specimens arehandled and tested, what types of information are conveyed to your company,whether you have an employee assistance program or not, the consequences of apositive test, etc.

It’s difficult to cover every possibility and outcome of drug testing inyour policy. That’s why many companies include a provision which states thatif a situation is not covered in their policy, then they follow the Departmentof Transportation regulations, interpretations, and suggestions.

There are many sources of “canned” policies. However, it’s bestto have a policy that is specific to your company and addresses your specialsituations and circumstances. In addition, you want to be sure your policyfollows the rules and regulations of the state(s) where the testing will occur.

When are tests performed
There are six different times urine drug abuse tests are performed:

• Pre-employment — It has been determined that a drug abuse test is nota medical procedure and, therefore unlike a physical examination, may bedone as a pre-employment process.

• Random — Tests performed on employees as a deterrent to drug use.

• Post-Accident — Performed as soon as possible after an accident todetermine if the employee had any drugs in his/her system. Some employersperform post-accident tests after accidents of any size while others performthe test only if the accident resulted in a certain level of injury,property destruction, etc.

• For Cause — If you have an employee who is exhibiting bizarre orunusual behavior and you suspect drug use, then you may order a for-causetest. It’s essential that your supervisors are properly trained and welldocument the abnormal behaviors.

• Follow-Up – A test that’s performed after an employee has had apositive test and undergone appropriate treatment. Now you want to monitorthis employee’s abstinence.

• Return-to-Work — These tests are performed on employees who havebeen out of work for a specified length of time.

The urine collection process
The collection process is standardized and there are really few decisions foryou to make. The only important decision is whether you want a single specimenor a split specimen. The difference is that with a split specimen, the urine ispoured into two bottles. The first is tested and the second is saved in case theurine donor wants to have the urine tested by a second lab. All DOT-regulatedtests are split-specimen tests.

Testing the urine specimen
The testing should be performed by laboratories certified by the SubstanceAbuse and Mental Health Services Administration. These labs perform thousands oftests every month and know what they are doing.

The laboratory runs all urine specimens through a screening test called animmuno-assay. If the results are negative — no drug or metabolite (breakdownproduct) is detected — then the testing process is complete and the results arereported to the Medical Review Officer (MRO) as a negative.

If the screening test shows the presence of one or more drugs or theirmetabolites, then the urine is tested again using a different method – gaschromatography/mass spectrometry (GS/MS). Only if the drug or metabolite isfound in both tests is the specimen reported to the MRO as a positive.

Confirmed vs. verified results
This is an important distinction. What the lab reports is a”confirmed” result. In other words, the lab says that all confirmedpositive test results have been tested twice and the results of both tests werepositive. All this means that the drug is present in the urine — but saysnothing about whether the result indicates drug use or abuse.

That’s the role of the MRO who verifies the results. The MRO decideswhether a confirmed positive result is indicative of abuse or legitimate use. Ifthere’s no legitimate explanation, then the results are reported to theemployer as a “verified positive.” If the donor has an acceptableexplanation for the presence of the drug or metabolite, then the test isreported as a “verified negative” – the same report as if thescreening test had been negative.

The Medical Review Officer
An MRO is a physician who has experience in the evaluation and treatment ofchemical dependency. In addition, most MROs have completed an intensive 16-hourcourse on the evaluation of drug test results. Although not a requirement, manyMROs have earned certification by passing a written test.

The MRO or his/her staff reviews all negative test results. The MRO mustreview all confirmed positive tests. Under DOT regulations, the donor must becontacted by the MRO and given an opportunity to explain the positive testresults.

It’s the MRO’s job to determine if the presence of the drug or itsmetabolite is indicative of drug abuse or legitimate drug use. The MRO has manytools available to assist him/her in making this decision. Sometimes additionaltests will distinguish between legitimate use and abuse. Other times the donoradmits to abuse.

When there is legitimate use, the donor’s physician is requested by thedonor to provide the MRO with documentation substantiating the donor’s claimsof legitimate use. If the test is positive for opiates, then the MRO may requestthe donor be examined for signs of drug abuse. In most cases a telephoneinterview is all that’s needed.

The MRO serves a dual role. First, the MRO acts as a donor-advocate. The MROquestions the donor, trying to determine if the donor has a legitimateexplanation for the presence of the drug or the metabolite in his/her urine.Second, the MRO protects the employer from wrongly not hiring or firing a donorbased upon an incorrect interpretation of a drug test results.

A good MRO has to be both a good detective and a skeptic. Many donors know alot about drug testing and come up with stories which, on the surface, soundplausible. The MRO has to carefully evaluate each explanation to determinewhether the donor truly has a legitimate explanation or it trying to cover upillegal use of drugs.