Does your agency have a drug-free workplace policy? With remote work being an option for many employees at this time, it is essential that the drug-free workplace policy be expanded to include these remote workplaces. One important aspect of the drug-free workplace policy is that of reasonable suspicion observations and testing. Supervisors and managers that are responsible for reasonable suspicion observations must be aware of your agency’s policy and properly trained to identify impairment.
The process for reasonable suspicion testing in the remote workplace must be properly documented in the agency’s policy. Once these policy elements and associated procedures have been put in place, all those responsible for identifying impairment should be trained on the agency’s policy regarding remote workplaces. The agency should also determine testing procedures for employees who are working remotely. Having clear procedures for timely testing of employees working in remote workplaces may help to prevent confusion in the future. Some options for testing may include a mobile collection service, or having the supervisor travel to the remote workplace and escort the employee for testing. Just as for a traditional worksite, employees working remotely who are suspected of being under the influence must not be allowed to transport themselves to a test collection site.
As some of the criteria for reasonable suspicion may be difficult to identify with only virtual observations, supervisors should visit the remote workplace in person before making the final determination that a reasonable suspicion test is required. Supervisors should not visit the remote workplace alone, there should be another individual trained in reasonable suspicion present at all times. This additional individual can confirm the need for a reasonable suspicion test. Any observations made by either of the individuals, whether virtually or in person, need to be well documented.
All agencies with a drug-free workplace policy should review their policies and ensure they contemplate remote workplaces. If changes to the policy are made, the supervisors and other staff responsible for reasonable suspicion observations should be trained on the new procedures.
If you have any questions, please feel free to contact PRISM Risk Control.