Logistics drug and alcohol testing procedure

This procedure supports managers in Logistics to put the Co-op Drugs and Alcohol Testing Policy into practice.

Any colleagues within a role that involves working within the depot environment, could be asked to take a drug and alcohol test. This includes non-operational colleagues who are based within a depot and those colleagues who regularly visit a depot as part of their role. It also includes contractors and visitors.

Our 3PL partners and Supplier Inbound Drivers are not currently included within the policy as they are covered by their own drug and alcohol testing policies.

Pre-employment Testing - Colleagues

Any colleagues appointed to a role that will involve working within the depot environment, should be offered the role subject to a drug and alcohol test before commencing employment. This includes non-operational colleagues who are based within a depot and those colleagues who we know will regularly visit a depot as part of their role.

All candidates for depot based operational roles should be tested as the final part of the selection process before an offer of employment is made.

Declaring Medication

Any candidate who is taking medication that may affect their ability to operate machinery/drive will be given the opportunity to disclose this part of prior to the drug and alcohol test. As part of this they will be asked to sign a declaration and risk assessment form to say that the disclosed medication is not impairing their judgement and that if appointed they will inform their line manager should anything change (see risk assessing medication below).

The candidate would then be asked to consent to taking the Drug Wipe Dual test skin/saliva test (which is likely to return a non-negative result). After which a urine test would be required to check that the substance detected by the Drug Wipe Dual is the same medication as declared, at expected level, in the body.

Any candidate who is found to be non-negative, and has not already disclosed prescribed medication, or whose results show anything other than what was disclosed, would not normally be considered suitable for employment with the Co-op. However, candidates will be asked about the initial test result and if they believe it is inaccurate would be given the opportunity to have a urine test. If they choose to go ahead, the sample would be sent to the laboratory for analysis to determine what has triggered the non-negative result.

Pre-employment Testing – Agency Workers

Operational agency workers (excluding agency Drivers) assigned to the Co-op should be tested for drugs and alcohol as part of the pre-assignment assessment following the same process applied to recruiting Co-op colleagues. This is carried out by the agency before offering the assignment.

Agency Drivers will be tested by the Co-op. This will normally be carried out by a Driver Assessor prior to carrying out a driving assessment. However when an Agency Driver is brought in at short notice i.e. fast track or relocation, testing will be carried out as part of the fast track induction and administered by the manager who is responsible for the induction.

It is the Agencies responsibility to inform the Agency Worker of the Co-op Drugs and Alcohol Policy before they come for assessment or in the case of fast track/ relocation Drivers, before they come for their induction. Any fast track/relocation Driver who is taking opiate based medication should be advised against taking an assignment with the Co-op until they have been tested and risk assessed as able to drive, as if they test non-negative they will not be permitted to drive and will be asked to leave. Where the Agency Driver is able to provide a letter from their GP stating that they are safe to drive on the prescription this can be considered as part of the risk assessment process.

After an Incident

For cause drug and alcohol testing would occur if a colleague has been involved in an accident or incident which caused death or injury to a colleague, contractor or member of the public. This also includes incidents with the potential to cause death or injury, as well as those where non trivial damage has occurred to Co-op property or property of a member of the public. In these situations the Co-op Accident Investigation Procedure should be followed.

Drivers who have a minor road accident should be tested when they return to depot. Those involved in a major road accident should be tested by the police. The attending Co-op representative should also carry out a drug test as the Drug Wipe Dual tests for a wider number of substances than the Police currently do.

If an accident or incident occurs at the end of a shift then it would normally be reasonable to carry out the initial drug and breathalyser test as it takes approx. 10 mins to complete. If the test returns a non-negative result the colleague will not be forced to stay to carry out the Urine test however this will be arranged for the start of shift the following day. It is recognised that the drug may have left the body by the beginning of the next shift. In this case if the urine test is negative the manager should let the colleague know that they may test them unannounced in the following weeks under the ‘for cause’ policy due to the delay between the tests.

Reasonable Suspicion

Reasonable suspicion includes if a colleague is showing signs of being under the influence of drugs or alcohol they should also be tested. This would also include acting on the basis of information provided from either other colleagues or the public or where a test result has indicated that a colleague may have been above the limit for alcohol when in the depot. For example where a test is just below the limit but it has been taken at the end of the shift indicating that the colleague was probably above the limit at the beginning of the shift.

Random Testing

10% of all colleagues and visitors who are present within a depot environment should be tested each year.

This should be calculated on a depot level taking into account the average number of colleagues and visitors at the site considering the previous year.
A high level test plan should be drawn up by each depot on an annual basis running January - December.
The number of colleagues who need to be tested will determine how many days testing is required within the year in line with what the operation think is feasible.
When devising the depot plan each shift should be considered so there is equal chance of colleagues on any shift being tested.
The following groups need to be included in the plan:
Colleagues – anyone who works in the depot including non-logistics colleagues
Agency Workers
Visitors – this includes regional colleagues and those attending events
Contractors
The site plan should be confidential to those colleagues appointed as responsible in the depot and they should be asked to complete a non-disclosure form (NDA).
The site plan should also include names of responsible Team Managers who are trained and can carry out the tests on any given day.
Rooms should be booked in advance to ensure an appropriate private location for testing to take place.
It is suggested that fully equipped box(es) are prepared in advance with the kits, breathalyser, forms, guidance, gloves to ensure Managers have everything they need.
The plan should also assume that Synlab may need to be called out and build in provision for this by making Synlab aware of the overall timescales.
Team Managers should be told on the day and not before, that random testing is happening to avoid colleagues becoming aware that testing is planned.
On the day that testing is to be carried out Site Support Assistants will collate a list of colleagues on site via Kronos, the transport desk sheet and visitors book.
Site Support Assistants would need to add any colleagues who are not captured o Kronos.
The list of those on site should be captured at the beginning of a shift to allow for testing to happen and give enough time for Synlab to be called if there is a non-negative result.
A random selection will then be made using a randomiser. A witness should be present to oversee that the random selection is applied correctly.
Those selected will be recorded on a separate list which the Site Support Assistant will send to relevant Team Managers to inform them which operational colleagues they need to test. At this point Team Managers will be asked to sign an NDA.
Site Support Assistants may administer tests for any visiting or office based colleagues who have been randomly selected. They will be supported by a Team Manager should a non-negative result occur.
The ‘drug and alcohol testing process’ should be followed (see below).

Testing at the end of Shift

If a Driver is selected for random testing but is out on a run the Team Manager should ensure the test is carried out when the Driver returns to depot. Should the time taken to complete the testing go beyond the end of their shift, colleagues will be paid for the time taken to complete the tests. The Breathalyser and Drug Wipe are quick and easy to administer and should not detain a colleague unreasonably. If a colleague provides a non-negative result Synlab will be called to undertake a urine test at the earliest possible opportunity. If a colleague refuses to stay at site until Synlab has completed its testing, the test may be conducted the following day. If there is suspicion that a colleague is deliberately and unreasonably trying to avoid testing, then this will be taken into account in any investigation process that may follow. The non-negative result will be considered as part of that process.

Visitors and Contractors

Any regular contractor who visits a Co-op depot should be made aware of the Policy to potentially randomly test anyone who is on site at the time of random testing. Anyone who is not permanently based at the depot should sign into the visitors book on arrival in line with our standard operating procedure. On signing visitors should be aware that this data may be added to a list to be use for random selection purposes. Information about our policy and how we use visitor data should be visible to all visitors on arrival and included in the site induction process.

If a contractor is selected they may chose to decline the test and leave the site. The Co-op will inform the contract manager from the company. If the contractor consents to the test they will follow the same process as an agency worker. If there is a non-negative result and the contractor challenges it they will be given the opportunity to have a urine test to determine the source of the substance, following which they will be asked to leave the site. The contract manager will then be informed of the situation for them to consider under their own policies.

Drug and Alcohol Testing Process

In any of the situations where drug and alcohol testing is required this process should be followed: - The colleague should be informed by a trained individual that a drug and alcohol test will need to be carried out immediately and the reason why i.e. for cause/random/pre-employment. - As part of this they will be asked if they wish to have a witness present. This should be someone who is available and may be a trade union rep but should not cause a delay to the testing process. - The colleague will be accompanied by the trained individual to a private room. - The colleague will be asked to sign a consent form agreeing to a drug and alcohol test. - A trained individual will then administer the drug and alcohol testing.

Breathalyser Test

Alcohol within the system is measured by vapour.
The colleague will be asked to blow into a tube to produce a reading which will determine the level of alcohol within the blood.
If the result is zero the alcohol testing is complete.
If there is alcohol present a second reading will be taken 20 mins later - this will be the reading that any actions are based upon
Where an alcohol reading is returned that is above the Co-op advisory limit the colleague will normally be suspended and asked to leave the premises pending investigation.
The colleague should be advised to make alternative arrangements that does not involve driving a car if they are above the legal drink drive limit.
If a colleague tries to drive a vehicle whilst above the legal limit then the trained individual should advise the colleague that they are going to call the police.

Drug Test

Drugs within the system are identified by the Drug Wipe Dual which tests for drugs present in both saliva and sweat on the skin.
Trained individuals will be provided with disposable gloves should they wish to use them.
For the skin test a trained individual will wipe the test kit 6 times across the hair line, behind the ears and at the nape of the neck.
For the saliva test the second part of the kit will be wiped across the tongue 6 times to get a sample.
The test will take 5 minutes to determine if any of the detectable drugs are within the body.
Where a drug test shows a non-negative result the trained individual will telephone Synlab, our agreed testing provider, who will come out to the depot and take a urine sample to confirm the presence of the drug and provide further information on the exact substance.
The colleague will be asked to remain in the room for up to approximately 2 hours (Synlab call out service level time) with a manager present whilst waiting for Synlab to arrive.
Once the urine sample has been taken it will be sent to the Synlab laboratory and the result will be returned within 3 days.
The colleague will be suspended from work until confirmation of the lab result is returned when they will be telephoned with the outcome.
If the test is negative they will be asked to return to work but advised that they may be selected for a ‘for cause’ test in the near future at an undisclosed date and time.
If the result is found to be in line with previously disclosed medication then the current risk assessment will be reviewed and a decision will be made whether the colleague can return to work.
The trained individual who has administered the test should take the consent form and ensure that all the details are entered onto the data base.

Any colleague found to be positive for illegal drugs or undisclosed medication through the urine test, or above the advisory alcohol limit should be advised that they will remain suspended until a full disciplinary investigation has been carried out and a hearing has been held – see relevant disciplinary procedure for collective agreement. If the outcome of the hearing allows the colleague to return to work they should be re-tested before starting work.

Risk Assessing Medication

Any colleague who is taking medication that may affect their ability to operate machinery/drive (as stated in the patient information sheet) should inform their line manager as soon as it is prescribed. The line manager should ask the colleague to provide details on the declaration and risk assessment form along with physical evidence of the prescription and the patient information sheet.

The colleague will be asked to sign a form to say that the disclosed medication is not impairing their judgement and that they will inform their line manager should anything change.

It is a colleague’s responsibility to seek advice from their GP about any potential impairment when the prescription is made or any increases in dosage are prescribed.

The manager should make a judgement based on the risk assessment, however if they have any concerns about the impact of medication then they should ask the colleague to work on low risk activities and refer them to occupational health to be assessed.

Declaring an Drug Addiction

As per the Drugs and Alcohol Policy the Co-op will support any colleague who, in advance of any testing, declares they have a Drug or Alcohol problem (although this should be before the colleague has been told they will be tested). This will normally involve referring the colleague to occupational health.

The colleague may be asked to take time off work and follow specialist medical advice/treatment to enable a safe to return to work. A period of ongoing testing would normally be required following the return to work.

Disposing of kits

Colleagues should be offered the opportunity to keep the kit as it contains their DNA. If they chose not to keep the kit it will be disposed of through normal refuse procedure.

Record Keeping

All for cause test results as a result of an accident or incident should be kept in accordance with the accident testing procedure owned by H&S. The Drug Wipe Dual test kit should be included in the investigation pack, with the urine test results from the lab.

All test results should be recorded on the consent form and the outcomes should be inputted onto the drug and alcohol testing database. Consent forms will then be posted into the GDPR box to be filed on the personal file.

Management Information

Each depot will have a template for collating management information (MI).

MI should be collated and shared at the depot review meeting on a monthly basis.

All depot level MI should be sent to the MI Analyst Team for central collation on a monthly basis and it will be shared with colleagues as part of the weekly book.

Ordering Drug Testing Kits

Site Support Assistants are responsible for ordering kits in line with the depot Drugs and Alcohol testing plan and forecasts based on number of accidents/for cause tests required. All test kits should be stored securely i.e. locked away.

Calibrating Breathalysers

Site support Assistants will work with the provider to ensure that all breathalysers are calibrated correctly in line with industry set review dates.

Training

Before administering the testing colleagues must be trained on the process.

An appropriate number of Team Managers and Shift Managers should be trained to ensure that there are always trained individuals available to carry out testing for operational colleagues. We should also ensure that there are both female and male colleagues trained to test so that we can try where possible to accommodate anyone who feels more comfortable being tested by someone of the same gender.

Site Support Assistants will be trained and may carry out testing for office based colleagues and any visitor to the depot i.e. regional visitors or contractors.

Training will be provided for new starters as part of their induction.

Refresher training will be provided every 3 years.

Audit

This process is part of Logistics Internal Audit and will be tested for compliance and to ensure the effectiveness of the procedure. Any recommendations for change will be fed back and amendments to this procedure will be made.

Roles and Responsibilities

Site Support Assistants

Will order and store the kits, ensuring adequate stock levels.
Prepare boxes with full kit for random testing.
Will ensure breathalysers are calibrated in-line with the service schedule.
Will be trained to administer tests on visiting colleagues and contractors.
Ensure accurate up to date records of testing for visitors and contractors.
Collate management information (MI) for Depot Reviews and feed into central point of contact for network wide view.

Learning and Development Specialists

Will deliver initial training to Operational Managers and Site Support Assistants as part of the induction and refreshers in line with the policy.
Will test new non-operational colleagues where the depot is their base as part of their first day induction.

Shift and Team Managers

Will administer Drug and Alcohol Tests for all colleagues in line with the Drugs and Alcohol Policy and Procedure.
Will record all testing on the drug and alcohol database.
Will carry out a full investigation process to ensure records of drug and alcohol tests are kept on file.
Will ensure all positive tests and resulting investigations are logged with ER Services

Depot Management Team

Will be responsible for the overall implementation of the policy.
Will be responsible for setting up an annual random testing plan.
Will present MI as part of Depot review meeting, identifying and patterns/concerns and solutions to the Head of Depot Operations.

People Advisor

Will ensure the consistent application of the Drugs and Alcohol Testing Policy and Procedure and the Disciplinary. Procedure.
Monitor MI for patterns or issues and raise where appropriate.

ER Services

Will support Line Managers on individual cases Health and Safety Manager
Will be responsible ensuring that testing is carried out correctly in line with the accident investigation process.
Monitor MI for patterns of issues and escalate to the H&S forum where appropriate.