Should I perform DOT drug and alcohol testing during COVID-19?
Since states began re-opening, we have fielded the question, “should I perform DOT drug and alcohol testing during COVID-19?” For a myriad of reasons, we cannot advise you and your business what to do in this circumstance. And everyone’s situation is different. However, we can offer some food for thought as you weigh the pros and cons of such a difficult question.
As I was writing this blog article, I received word that EMSI, a national drug and alcohol testing company, closed their doors as of Friday, July 3rd. Besides this, we hear of many more service agents who are barely holding on. I can’t and won’t pretend I have some magic wand or sage words to reverse the situation so many of you are facing. Trust me when I say that AlcoPro is experiencing similar business challenges brought on by COVID-19. So if you’re out there asking this question and looking for ways to “hold on” to your business, here’s our best support in those efforts.
DOT Drug and Alcohol Testing Hasn’t Gone Away
The demand for drug and alcohol testing may have slowed, but the mandate for DOT drug and alcohol testing hasn’t gone away, it’s only been slightly modified. In fact, in the agency guidance documents issued by ODAPC, employers who are capable of complying with testing regulations must continue to do so for the continued safety and welfare of the general public. This same testing guidance recognizes the service disruptions caused by the pandemic to the administration of drug and alcohol testing. Employers who cannot locate and secure testing resources must document specific reasons for non-compliance and the actions taken to identify alternative testing sites or other testing resources. I encourage you to read through the agency specific guidance to understand the DOT concessions.
If you do choose to continue providing services, I would encourage you to personally contact your DERs to let them know you are still available and to let them know of the safety precautions you are taking to mitigate infection risks to yourself and their employees. In short, have a plan that lets employers know that their employees will be tested in a safe environment and make current and potential customers know of your plan.
When Coronavirus ramped up in the U.S., and before the imposed lock-down, we published a blog article around drug and alcohol testing safety precautions. In that article, we offer good information on how to properly disinfect your breathalyzer, keep rooms disinfected, etc. I encourage you to read it. Aside from the standard known precautions such as social distancing, wearing masks and gloves, etc., here are some reminders and new considerations:
- Always use a new mouthpiece for the breathalyzer
- Wear a new pair of disposable gloves for every test
- Consider wearing a face shield along with your mask to stop airborne particles from entering eyes, nose and mouth (research shows it helps block more contaminates)
- Consider wearing other PPE such as disposable gowns or coveralls
- Consider doing testing outdoors in a covered, secured area (remember, the DOT only requires a secure/private area for testing)
- Breath alcohol testing can be performed completely outdoors
- Drug testing intake can be performed outdoors and then walk the employee to the restroom for the collection and back outdoors for specimen processing
- If you cannot perform testing outdoors, require employees to wait outdoors until they are called in for their appointment (this limits the amount of people in your testing facility)
- Conduct testing at the employer’s location in an area that is regularly sanitized
- Don’t share pens (give employees their own pen to sign the CCF or ATF…let them keep the pen)
- Offer other needed services such as rapid antibody testing to regularly screen the employee workforce (recommended if you have a licensed medical professional on staff such as a licensed phlebotomist)
By no means is this the long list of ideas and we want to hear all of your ideas. If we are truly in this together, we must share all the information we can to help one another “hold on” as best we can.