The Drug-Free Workplace Program aims to create a safer, healthier work environment by eliminating the risks associated with substance abuse. This program encourages employers to adopt strict drug-free policies, protecting both employees and the organization. 

Establish a clear and comprehensive drug-free workplace policy that:

  • Provides the expectations for a drug- and impairment-free workplace
  • Defines roles and responsibilities
  • Describes the process for:
    • Supervisors (or equivalents) to detect impairment and respond to reasonable suspicion in the workplace
    • Monitoring the workplace for signs of impairment and initiating the reasonable suspicion process when warranted
    • Implementing the reasonable suspicion process, including:
      • Observing and documenting specific behavioral or physical indicators of impairment 
      • Consulting with a second supervisor, when possible, and discussing  observations with employee
      • Removing the employee from safety-sensitive duties
      • Transporting the employee safely for testing in accordance with the employer’s process 
      • Completing written documentation of all observations before and after the testing
  • Explains the consequences for violating the policy.
  • Describes how positive test results will be handled, including confidentiality protections, consequences, and conditions for returning to work.
  • Describers the process for managing employees who are taking legally prescribed medications that may cause impairment and present a safety risk to themselves or others.
  • Note: Impairment is the standard applied regardless of whether the substance is legally prescribed or lawfully obtained.

All employees are subject to reasonable suspicion testing. Employers are encouraged to implement at least one additional method of mandatory drug and alcohol testing, applied to all employees in the eligible population. Testing methods (in addition to reasonable suspicion) may include: 

  • Pre-employment — testing of candidates prior to employment 

  • Random — unannounced testing; the employer sets a percentage of random employees to be tested each quarter 

  • Post injury/accident — drug and alcohol testing done immediately following an accident requiring medical attention 

  • Employee Training (Annual): Conduct annual training sessions covering the dangers of substance abuse, the employer’s drug-free workplace policy and expectations, consequences of policy violations, and available EAP resources. Training attendance must be documented with signed attendance records or LMS completion data.  

  • Supervisor Training (Annual): Conduct annual training sessions for all supervisors covering their roles and responsibilities under the Drug-Free Workplace Policy, including recognizing behavioral and physical indicators of impairment, reasonable suspicion procedures, documentation requirements, chain-of-custody protocols for test specimens, and how to refer employees to the EAP. Training attendance must be documented.  

  • Reasonable suspicion training is required along with a list of employees that will monitor the entire workforce. Document the reasonable suspicion training and the required frequency based on the nature of the work. 

  • Employers selecting the Drug-Free Workplace for the first time must ensure the safety coordinator and any employees involved in implementation complete WSI's Drug-Free Workplace Program online course within the first 90 days of the eligible policy period.  

LMS Access: Email [email protected] for assistance accessing this course through WSI's Learning Management System. 

Employers must determine what level of formalized EAP they will offer employees. At minimum, employers must advise employees of the resources available for evaluating and resolving substance abuse problems, including the names, addresses, and telephone numbers of counseling and treatment providers.