A workable testing program begins before the first employee is sent to a collection site. Employers need a written policy, clearly assigned responsibilities, appropriate test types, a reliable collection and laboratory process, confidential records, and a plan for applying the policy consistently.
What should an employer decide before testing begins?
Start with the reason for the program. Safety-sensitive work, customer requirements, federal regulation, state drug-free-workplace incentives, workers’ compensation considerations, and company culture may lead to different program designs. Identify which positions are covered, which substances and specimens are appropriate, and which testing situations the policy will permit.
SAMHSA recommends assessing workplace needs, identifying available resources, developing a written policy, considering employee-assistance resources, deciding whether testing is appropriate, and preparing education and supervisor training.
Which testing situations should the policy address?
- Pre-employment testing before a covered applicant begins work
- Random testing when required or permitted
- Post-accident or post-incident testing under defined criteria
- Reasonable-suspicion testing based on documented, current observations
- Return-to-duty and follow-up testing when applicable
- Periodic, site-access, or client-required testing when lawful and included in policy
The correct mix depends on regulation, state and local law, collective-bargaining obligations, and the employer’s written policy.
Who needs a defined role?
Name the person authorized to order tests, receive confidential results, respond to collection problems, and make employment decisions. DOT-regulated employers refer to this person as the Designated Employer Representative. Supervisors should understand what they may observe and document, while laboratories, collectors, Medical Review Officers, and third-party administrators each perform separate functions.
How should the program be launched and reviewed?
Before launch, communicate the policy, effective date, covered positions, prohibited conduct, testing circumstances, consequences, confidentiality practices, and available employee resources. Confirm that ordering, collection, result reporting, and escalation workflows work in every location. Review the program when laws, workforce locations, job duties, or service providers change.
Frequently asked questions
Does every employer need the same testing program?
No. Program design varies by industry, regulation, workforce location, safety exposure, company policy, and applicable law.
Should a policy be reviewed by counsel?
Yes. Employers should have qualified employment counsel review a testing policy for the states and localities where employees work.
Can Lab Test Solutions coordinate a multi-state program?
Yes. We help employers organize testing options, collections, account workflows, and result delivery across the United States.
Authoritative sources
Use the current official rules and qualified counsel when making program or employment decisions.