Managing an Effective Random Testing Program

By Brennen Portalski

andom testing has been a vital component of drug-free workplace programs for many years. Employers may be required to implement random testing programs in accordance with federal or Department of Transportation, or DOT, regulations, and all employers may choose to implement non-regulated random testing programs. Doing so can help secure a safe and drug-free workplace, but there are various components to consider to ensure the program is effective.

When an employer decides to implement random testing, the first step is to outline a plan for managing the program. The employee taking on this responsibility is known as the Designated Employer Representative, or DER. The DER must have knowledge of drug and alcohol testing requirements, company policies, and the authority to make decisions about how to manage the testing program. For this reason, many employers will choose a DER from Human Resources or Safety Departments, but other employers choose to hire employees specifically to serve as the DER. Some companies have one, and other companies have multiples DERs.

The next item to consider is what substances to test for. The answer may seem simple, however, companies with non-regulated testing programs can choose to test for any drugs that are of concern to the employer or industry they work in.

For example, most drug test panels do not test for fentanyl—a synthetic opioid that can have a serious impact on safety if employees are using the drug. Fentanyl is not easily accessible, however, employees in the healthcare field may have easier access, and thus healthcare employers may choose to test their employees for this drug.

In addition, a company may choose to include alcohol testing in a random testing program. Alcohol testing in workplace testing programs is typically ‘evidential’, meaning that the test can determine whether someone has alcohol—and the specific concentration levels—in their system at the time of the test. This helps employers ensure that employees are not working under the influence of alcohol, while also allowing employees personal freedom to use alcohol outside of work, should they choose to do so.

Once ready to begin making random selections, the company should determine at what rate they would like to randomly test their employees. Some companies choose to select a certain percentage (e.g. 25 or or 50 percent annually), and others choose to select a certain number of employees (e.g. 1 employee per month, 10 employees quarterly, etc.). All covered employees should be included in the selection process when the selection is made. This helps ensure fairness to all employees subject to the testing program. To ensure random testing is truly random, employers should utilize a computer-generated selection system, such as a random number generator, to make selections. Many employers choose to partner with a third-party administrator to assist with this process.

After random selections are generated, the next step is to notify the employees that were selected to report for testing. Best practice is for DERs or supervisors to spread testing out throughout the selection period (month or quarter) so employees do not pick up on a random testing trend (i.e. random testing always occurs at the beginning of each month or quarter). It is also imperative to ensure that once an employee has been notified they were selected for random testing, they stop working and immediately proceed to the testing facility. Limiting the amount of time between notification and testing will help prevent employees from attempting to cheat the drug test.

All components of the random testing program should be outlined in a written policy. The policy should include a list of all covered employees (job titles, positions) who are subject to the policy, the substances being tested for, when, why, and how testing will occur, and consequences for violating the policy. Educating employees on these rules helps bring awareness to requirements and violations. This practice also helps protect employers from possible litigation in the event action is taken against an employee for a policy violation.

Random testing programs are one of the most effective ways of ensuring a safe and drug-free workplace. Taking the steps to ensure the program is properly developed and managed will further the success of any company looking to uphold a strong safety culture and drug-free environment within their organization.