Page 58 - OHS, June 2020

E m p l o y e e D r u g & A l c o h o l Te s t i n g
We know that substance abuse will likely increase in the coming months.
■ Information: 11.7 percent
■ Construction: 11.6 percent
The same report indicated that these industries have the highest
rates of alcohol misuse:
■ Mining: 17.5 percent
■ Construction: 16.5 percent
■ Accommodations and food service industry: 11.8 percent
■ Art, entertainment, and recreational fields: 11.5 percent
■ Utilities industry: 10.3 percent
Additionally, according to one major drug testing laboratory,
“Retail Trade is one of six sectors that saw year-over-year double- digit increases in positivity between 2015 and 2018. Five of these experienced an overall four-year increase in general U.S. workforce positivity more than double that of the national increase (6.2 per- cent) over the same time period.”9
■ Transportation & Warehousing: 34.5 percent
■ Other Services: 33.3 percent
■ Wholesale Trade: 20.0 percent
■ Retail Trade: 14.9 percent
■ Construction: 13.2 percent
■ Administrative Support, Waste Management and Remedia- tion Services: 12.2 percent
Finally, a 2018 report from the National Safety Council found that these are the industries with the largest number of workplace accidents, from highest to lowest:
1. Service (including firefighters and police) 2. Transportation/shipping
3. Manufacturing/production
4. Installation/maintenance/repair
5. Construction
There is clearly some overlap between the list of essential occu- pations and industries and the lists of industries with higher levels of substance abuse, increased positive drug test results and work- place accidents. Now we have a perfect storm in the making and employers must be vigilant.
Drug Testing Methods During the Pandemic
As the saying goes, unusual times call for unusual measures and we are living in unusual times, even traumatic times. Drug abuse levels are likely to increase at a time when they were already on the rise. Some of the industries and occupations deemed essential to our survival historically have higher rates of substance abuse and workplace accidents.
Now is not the time to stop or curtail drug testing. In fact, it is possible that drug testing has never been more important. In ad- dition to the increasing rate of substance abuse and its predictable impact on safety and workplace accidents, consider these other important factors:
■ The federal government continues to require drug testing of employers in certain safety-sensitive industries such as trans- portation, though special guidelines have been issued to address challenges employers and providers may be experiencing while
trying to comply with some of federal requirements during the COVID-19 pandemic.
■ State drug testing laws that mandate drug testing and/or regulate the how, when and who of drug testing have not been suspended, and compliance is still required when testing can be conducted (check applicable state laws to ensure compliance).
■ Traditional drug testing methods, such as lab-based urine testing, still work, but alternative testing methods may help em- ployers overcome the obstacles to testing that some companies are currently experiencing.
DOT Drug Testing. So far, the federal government continues to require drug testing. For instance, the U.S. Department of Trans- portation (DOT) issued the following statement:
“As a DOT-regulated employer, you must comply with ap- plicable DOT training and testing requirements. However, DOT recognizes that compliance may not be possible in certain areas due to the unavailability of program resources, such as collection sites, Breath Alcohol Technicians (BAT), Medical Review Officers (MRO) and Substance Abuse Professionals (SAP). You should make a reasonable effort to locate the necessary resources.”10
DOT continues: “As a best practice at this time, employers should consider mobile collection services for required testing if the fixed-site collection facilities are not available.” Additionally, employers who find it impossible to comply with any portion of the regulations must document the reasons why and always defer to the regulations themselves.
For service providers, DOT emphasized: “As a collector, BAT, laboratory, MRO, or SAP, you should continue to provide services to DOT-regulated employers if it is possible to do so in accordance with State or local mandates related to COVID-19. Should you have concerns about COVID-19 when testing or interacting with employees, please follow your company policy, directions from State and local officials, and guidance from the Centers for Disease Control and Prevention (CDC).”
The Federal Motor Carrier Safety Administration (FMCSA) has issued specific guidelines to address instances when covered employers are unable to comply with the regulations during the pandemic.11 Visit other DOT modal websites for specific guidance on complying with their respective regulations.
Lab-based Urine Testing. For more than 30 years, lab-based urine testing has been the most common drug testing method. Currently, many laboratories continue to offer urine drug testing services, and when essential support services—such as specimen collections at facilities away from the workplace—can be arranged, this testing method remains a viable option during the COVID-19 pandemic. However, there are reports that it is challenging to find collection sites that are open for urine collections while other facili- ties are simply not available. Mobile collection services represent an alternative that makes lab-based urine testing possible.
Lab-based Oral Fluid Testing. Recently endorsed by the fed- eral government,12 lab-based oral fluid testing eliminates some of the challenges employers are experiencing. Oral fluid collections, for example, do not require the use of an off-site collection facility where most urine collections typically take place or the use of a se- cured restroom, thus eliminating sanitation concerns. As employ-
54 Occupational Health & Safety | JUNE 2020
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