This is the third in a series of articles on non-DOT drug testing ...
Items that C/TPA owners/managers should know or be aware of!
There are several areas of knowledge that the owner of the C/TPA in the drug and alcohol testing industry should know or where to go to get answers that may be posed. As the C/TPA acquires clients, questions arise from current clients or potential clients. There are several things that the successful C/TPA should know or be aware of to effectively manage substance abuse testing programs for non-regulated clients. For instance the successful C/TPA manager/owner should know something about the following items:
- The business type or model of each of the clients. As substance abuse testing expands into the non-regulated companies, these companies are becoming increasing aware of the importance of having a drug-free workplace. This becomes ever more important as people that are substance abusers seek employment in companies that are not regulated. There is also the spread of marijuana for both medical and recreational purposes. It behooves the astute C/TPA to know the business type or model of each of their non-regulated clients.
- Position(s) in each of those companies that can be important to the success of the company. These positions can range from security type of personnel, to cable installers to drivers of small delivery vehicles and to cashiers. For instance what would the positions be in a movie theater subject to testing? How about a car wash and those that drive the cars? Parking garage attendants who handle cash transactions? Auto repair shops and mechanics employed? The list of personnel can go on and on but is dependent upon the business what positons are important to the successful operation of the company.
- What, if any, are the applicable local or state laws regarding the implementation of substance abuse testing? There are several jurisdictions that can local laws or ordinances that can affect the implementation of a testing program. These laws can also include state laws. There are several states that do not allow random drug testing or random testing of only certain personnel. Some examples of local jurisdictions with ordinances are Berkeley and San Francisco, CA and Boulder, CO. Certain states have certain stipulations in place for random drug testing, i.e., Rhode Island, which prohibits random testing with certain exceptions by private employers and Maine requires that the policy be approved before testing can happen by the Department of Labor Bureau of Labor Standards are just some of the examples.
- What is the company policy regarding substance abuse and testing for controlled substances? If yes, what is contained in the policy? Does the policy address what personnel will be subject to testing; the circumstances of when testing will be conducted; how and when will reasonable testing be done along with post-accident causation testing. Other concerns to be addressed are the handling test results and what should take place in there is a policy violation. These are just some of the factors to be considered in formulating or perfecting policy. Does the policy conform to existing state law and or local laws/ordinances?
Because of all the above factors, an astute C/TPA should have knowledge about security, human resources, medical issues, treatment/rehabilitation programs among other areas that can be related to substance abuse and substance testing.
Robert C. Schoening