by Lloyd Asher, CIH, CSP
Senior EHS Consultant

Maintaining a “drug free” workplace has been a long-standing challenge for employers everywhere, even with robust drug and alcohol abuse programs in place. While these programs are a great starting point for maintaining an alcohol and drug free environment, employers should also have a program and training for Reasonable Suspicion Testing to complement it.  Reasonable Suspicion Testing is a tool used by supervisors, human resources and other leadership positions to identify whether an employee is exhibiting signs or symptoms of drug and/or alcohol abuse on the job. Reasonable Suspicion training is separate from other types of testing programs as it is only utilized if an employer has observed changes in an employee’s behavior or is presenting abnormal symptoms, indicating possible drug or alcohol misuse.

Numerous companies implement a Reasonable Suspicion Testing policy due to the safety-sensitive nature of their work and job duties.  Simply put, safety-sensitive duties, are tasks in which a momentary lapse of attention or judgement could result in injury or death to oneself or others. In these positions, drug or alcohol impairment constitutes an immediate threat to the health or safety of those in the vicinity.  Examples of safety-sensitive job duties include operating motorized equipment or directing vehicle traffic.  It is therefore critical that front-line supervisors and leaders have the ability recognize the signs and symptoms of employee(s) under the influence of drugs or alcohol in the workplace so they can provide timely referral of the employee for Reasonable Suspicion Testing.  Leadership plays the single most important role in keeping the workplace a drug and alcohol-free environment, and safety is always first. 

This training also provides attendees with the tools needed by front-line workers to accurately describe the basis of suspicion for documentation. It should also cover the behaviors or symptoms that are associated with an employee who may be abusing drugs or alcohol on the job. These signs and symptoms may include, but are not limited to, bloodshot eyes, changes in speech (slurring) and lack of coordination.

Opioid Overdose Statistics
According to information from the Centers for Disease Control and Prevention, nearly 645,000 people have died from overdoses involving any type of opioid (prescription or illicit) between 1999 and 2021.  The increase in deaths has been outlined in three waves, beginning in the 1990s. 

How Reasonable Suspicion Testing Works

  1. The Supervisor/ Leader makes observations and notes any atypical behavior that could be due to alcohol or drug impairment. The Leader may request to work with HR, EHS, or a peer Leader for a second opinion.
  2. The Leader confronts the employee exhibiting atypical behavior in a private location, while maintaining confidentiality at all times.
  3. The Leader requests testing in partnership with HR, EHS, Security, or other key Business Partner.   

During this process, Leaders should document their observations on Reasonable Suspicion form within 24 hours of the test. This form is provided by the employer. It is recommended that observations are documented as soon as possible.     

The Role of Training
Employers should offer training to all supervisors and leaders during onboarding or as a part of the program implementation. In doing so, they will become familiar with the policy, its steps, required documentation, and information on the available drug/alcohol testing provider. It is imperative leaders clearly understand their roles and responsibilities in implementing such a program as there can be very real and long-term consequences in the event an employee is called in for the Reasonable Suspicion Test. Upon completion of the training, supervisors should feel confident and empowered to act quickly and confidently to prevent any dangerous situations from developing.

How We Can Help
The EI Group can offer training sessions to Leaders in a variety of formats.  Sessions can be tailored to an employer’s needs and with flexible class sizes.  We can also incorporate the employer’s own policy/procedure within the discussion.  Class durations can be as little as an hour or expanded to include additional regulatory requirements or employer policies.  Finally, scheduling is flexible for Leaders working all types of shifts.  For training inquiries, please contact Lloyd Asher at (859) 200-6721 or Eric Cureton at (540) 343-9595. 

References

Centers for Disease Control and Prevention.  “Opioid Data Analysis and Resources.”  CDC.gov, 8, Aug. 2023, https://www.cdc.gov/opioids/data/analysis-resources.html

Substance Abuse and Mental Health Services Administration. “Drug Testing Resources.” SAMSHA.gov, 27, Feb. 2024, https://www.samhsa.gov/workplace/drug-testing-resources

U.S. Department of Transportation Federal Transit Administration Office of Safety and Security.  “Reasonable Suspicion Referral for Drug and Alcohol Testing – A Training Program for Transit Supervisors.” Transit-safety.fta.dot.gov, 1, Mar. 2004, https://transit-safety.fta.dot.gov/DrugAndAlcohol/Publications/Documents/safety/ReasonableSuspicion/PDF/ReasonableSuspicion2004.pdf