How Cognitive Impairment Testing Can Improve Your Drug Testing Program

Current Challenges in Workplace Drug-Testing Programs

Workplace drug-test positivity reached new highs in 2020. Obviously, this is due in large part to increased substance use amongst workers in these industries.

See table below. 

If your goal is to keep your workplace safe and productive amidst alarming drug test positivity rates, it's important to consider the influence of contributing factors that are within your control. Instead of focusing on your applicants/workers' off-time behavior, focus on the following root problems: 

• Labor shortages in many industries have made workers less willing to comply with drug testing requirements, especially in states where cannabis has been legalized. 
• Increased mental health issues have contributed to increased substance use, especially during the pandemic. (CDC, 2020)
• Pre-employment drug tests are not utilized in a manner that makes them effective at keeping habitual users out of the workplace. 
• Random drug tests have become too predictable and/or infrequent to be strong deterrents to drug use. 
• Random drug testing has become too costly and disruptive for safety-sensitive industries to implement in a way that is frequent and unpredictable.
  
  

When looking beyond the surface of drug test positivity rates, it becomes obvious that there are many other factors at play.

A revamp to your workplace culture and drug testing program becomes inevitable. A successful revamp should yield the following results: 

• Reduced drug test positivity. 
• Increased ability to attract and retain safe, responsible, quality workers.
• Improved safety metrics: Reduced worker's compensation claims, reduced TRIR, reduced damages, liability, etc.
• Improved safety culture metrics: More communication, accountability, responsibility, proactivity. 
• Improved operational metrics: Higher productivity, efficiency, quality. 
• Improved mental health metrics: Reduced absenteeism, presenteeism, turnover. 

So, how can workplaces go about such a renovation of their drug testing program? How do you identify problem areas? What are the costs involved? What results can you expect? 

First, let's look at the pros, cons, and costs of different types of workplace drug tests. Then, we'll discuss how each can be improved based on your industry and its requirements.

Pros, Cons, and Costs of the 4 Most Common Types of Drug Testing Programs:

Pre-Employment Drug Program Tests:

• Pros: Pre-employment drug testing allows workplaces to filter out habitual drug users and workers with substance abuse problems.
• Cons: Habitual drug users can limit their use and/or drink detox drinks to clear their system in the weeks preceding a drug test. Thus, pre-employment drug testing alone isn’t strong enough to deter workers from continuing to use drugs after passing their initial test. According to a 2021 report by Quest Diagnostics, "The positivity rate of post-accident test results grew faster than the rate of positivity for pre-employment testing." This could indicate that habitual drug users are in fact becoming more skilled at passing pre-employment tests with temporary abstinence, detox, etc. only to continue drug use once hired.
  
  

Random Drug Program Tests

• Pros: Random drug testing serves as a deterrent to drug use when it is done frequently and unpredictably. If fully embraced by management and implemented effectively, it can reduce drug test positivity and improve safety. 
• Cons: In many industries, random drug testing has become too inefficient to serve its purpose as a drug use deterrent or safety measure. Workers on remote worksites have to invest more time and travel to get tested. Reduced productivity and lost time often amount to higher costs than drug test. Accounting for the cost of each test means there is a limit on how many workers can be randomly tested in a given time period, reducing the frequency and thus, effectiveness. Further, with the legalization of cannabis, there is a fear that workers who are currently sober and alert will test positively due to marijuana use in the recent past. Firing a sober worker for legal cannabis use outside work hours is not a risk many workplaces are willing to take in a tight labor market. On the other hand, even if a drug test did back negative, habitual drug users may take advantage of an infrequent testing schedule by celebrating their "passing" with drug use. The costs, inefficiency, fears of a "false positive," and the potentially incentivizing nature of "false negatives" have culminated in a general hesitance to use random drug tests.

According to Quest Diagnostics, marijuana positivity in the US general workforce has increased by 16% in urine testing; 35% in saliva testing, and 22% in hair testing. Since the greatest positivity increase was seen in saliva testing, a test that reveals the most recent impairment, these findings may further indicate that random drug tests are not serving as deterrents to continued cannabis use at or outside work.

Reasonable Suspicion/ Cause Drug Program Testing:

• Pros:  Reasonable cause drug testing is among the most effective types of drug testing because it is based on observations of employee behavior. If a worker is behaving abnormally or showing signs of impairment, a vigilant supervisor would utilize reasonable suspicion testing to ensure the worker is fit to work safely. Removal of the potentially impaired worker from the workplace could proactively improve safety on site. 
• Cons: Since reasonable cause drug testing relies on supervisor's subjective evaluation of a worker's behavior, it can be perceived as unjust by workers. If used unreasonably or excessively, reasonable suspicion testing can quickly culminate in a punitive and negative work environment. Alternatively, reasonable suspicion testing can make it easier for supervisors to "play favorites" and overlook dangerously impaired workers. Further, an overreliance on reasonable suspicion testing could become disastrous if supervisors are not always on-site with their workers or have too many workers to keep an eye on each one. Ultimately, the subjective, inconsistent, and labor-intensive nature of reasonable suspicion testing may become burdensome for supervisors, unfair for workers, and problematic for your safety culture.
  
  

Post-Accident Drug Program Testing:

• Cost:
  
  
  • Pros:  Post-accident drug testing serves to indicate the role of impairment in a workplace accident. It is an essential component of root cause analyses, which help workplaces identify dangerous trends or gaps in their workplace safety and drug-testing program.
    
    
  • Cons: By the time a post-accident reveals valuable information, an accident has already occurred. Thus, a post-accident drug test cannot be relied upon as a safety measure or expected to deter workplace drug use. Rather, it is how a post-accident drug test is positioned within the overall root cause analysis that determines how effective it is in improving safety and reducing substance abuse. There are two potential ways to utilize a post-accident drug test: as a scapegoat or as a band-aid.

If the post-accident drug test is positive, workplaces with a negative workplace culture might seize the opportunity to cease further investigation and turn a blind eye to other safety issues that could have contributed to the accident. In this case, the post-accident drug test becomes a scapegoat that permits other safety issues to continue unchecked. 

The second outcome is that the post-accident drug test will come back negative and the investigation will move ahead to measure the impact of other factors. While asking whether the employee received adequate training, what the environmental conditions were like, whether the equipment needed maintenance, etc. workplaces neglect to complete a full assessment of major human factors. In this case, the negative drug test is used as a band-aid to cover up more complex causes of human impairment such as stress, fatigue, or emotional distraction. After all, having an employee re-watch a training video seems a much easier fix than than optimizing shift schedules, implementing a fatigue risk management system, or increasing mental health awareness in the workplace. 

After recognizing the costs and the pros and cons associated with each of these types of drug tests, you may now consider where your workplace needs the most change. Your ability to improve how your workplace handles impairment will depend on your industry, location, your insurance provider, and existing company protocols. Talk to your legal department to get a better idea of what your company's specific restrictions regarding drug-testing are.

In the following section, we will provide a brief and general overview of industry-specific drug-testing regulations, suggest opportunities for improvement, and provide examples from real workplaces within these industries. 

How can DOT-Regulated Industries Improve Their Drug Testing Programs? 

According to the Omnibus Transportation Employee Testing Act of 1991, safety-sensitive transportation employees in aviation, trucking, railroads, mass transit, pipelines, and other transportation industries must be drug and alcohol tested at the following times: 

• Pre-employment: Before being hired or before beginning safety-sensitive work for the first time.
• Reasonable cause or suspicion: Upon observation of abnormal behavior. 
• Random: Workplaces must have a random drug testing program in place. What that program looks like might vary across specific industries, states, and companies. 
• Post-accident: Immediately after an employee is involved in an accident and before allowing an employee to return to duty following a testing violation.

In addition to these requirements, a DOT-regulated industries must utilize the services of a Medical Review Office to review drug test results and to provide employees with consultation services before the test result is reported to an employer.

Opportunities for Drug Testing Program Improvement:

Since DOT-regulated industries have very little flexibility within their drug testing programs, the best way to reduce drug-test positivity in these industries would be through increased education and coaching opportunities, and the introduction of cognitive impairment testing. 

Increased education and coaching would provide supervisors with the knowledge and confidence to use reasonable suspicion testing more effectively. By knowing how to identify subtle signs of impairment, supervisors can become more objective and consistent in their application of reasonable suspicion testing. Secondly, by having the confidence to use it when necessary, they can strengthen the deterrent effect of reasonable suspicion testing. 

If your workplace wants to become more productive, time-efficient, and proactive in identifying and managing workplace drug impairment, real-time cognitive impairment testing can also be a very powerful tool. These tests take 60 seconds at the start of a shift and accurately reveal impairment in real-time. Although DOT-regulated industries must retain their random drug testing programs, there is no federal requirement mandating how frequently they must be used. Since cognitive impairment testing increases communication and real-time impairment awareness on-site, DOT-regulated industries that utilize cognitive impairment testing often find a reduced need for random drug testing. 

Drug Testing Program Example:

A transportation company integrated cognitive impairment testing into their existing truck-based tablets currently supporting their ELD/Telematics system. The drivers take the 60-second test before taking off, and each time a driver is struggling with alertness, their dispatch manager receives a notification. They contact the driver to have an objective conversation regarding their ability to work safely. 

"The platform is really well aligned with our expectations and it allows us to have the technology behind what our drivers are doing as well as compliance with DOT requirements.”

How can PMHSA Regulated Industries Improve Their Drug Testing Programs?  

According to the Pipeline Management and Hazardous Materials Safety Administration, operators and contractors of natural gas and other gas pipeline transportation, hazardous liquids pipeline transportation, and liquefied natural gas pipeline facilities must conduct drug and alcohol testing at the following times:

• Pre-employment
• Return to duty
• Reasonable cause or suspicion
• Randomly
• Post-accident
• Upon failure or refusal of test (additional random follow-ups with a Substance Abuse Professional)

Opportunities for Drug Testing Program Improvement:

Since these industries are also strictly regulated in terms of their drug-testing requirements, the opportunities for improvement are similar to those of DOT-regulated industries. Pipeline supervisors can benefit from increased training in recognizing the signs and symptoms of impairment. Cognitive impairment testing can be utilized in addition to random drug testing to increase real-time insights, increase communication, and reduce time spent traveling to get random drug tested. Adding a 60-second cognitive impairment test can quickly improve productivity and ensure workers are reporting to work in a sober and alert state of mind. 

Besides reducing the overreliance on random drug testing, cognitive impairment testing can be utilized to increase the objectivity and consistency that is required to make reasonable suspicion testing effective. A 60-second test can quickly and objectively identify workers who might be struggling, instantly notify supervisors to start a conversation, and result in a much more consistent application of reasonable suspicion testing regulations than the mere reliance on subjective and often inadequate supervisory vigilance.  

Drug Testing Program Example: 

A 24/7 oil and gas control room with 30 employees on 5-week rotating shifts utilizes cognitive impairment testing. Alarms are set at regular intervals throughout a shift to prompt operators to take the 60-second cognitive impairment test. This ensures that the operators remain awake and alert throughout long night shifts and that countermeasures are taken when required to stay alert. By mounting an iPad with the cognitive impairment test app on it, and taking the test during fatigue hot spots, the control room has increased visibility into fatigue and helped highlight potential problems in shift schedules. It has also increased workers' personal awareness of their cognitive well-being, empowering them to make decisions that support their alertness and giving them the feedback to take countermeasures when necessary. 

How Can Non-DOT Regulated Safety-Sensitive Industries Improve Their Drug Testing Programs?

In non-DOT regulated safety-sensitive industries, there is more flexibility in adjusting drug testing programs. If the business or organization has received a federal contract of $100,000 or more, or a grant of any size, "the Drug-Free Workplace Act of 1988 requires the creation and distribution of a drug-free workplace policy. Drug testing is not explicitly required" (Concentra). However, state regulations, union requirements, and insurance agreements may have stricter requirements for your company's drug testing programs. 

Regardless, in light of the latest data from Quest Diagnostics on rising positivity rates, the improvement of drug testing programs seems like a cause unions and insurance companies could, should, and often do support:

• Transportation and Warehousing: 41.9% increase in overall drug positivity between 2016 and 2020. 123.5% increase in marijuana positivity between 2016 and 2020. 
• Construction: At 0.3%, had the highest cocaine and methamphetamine positivity out of all industries in 2020.

Beyond the obvious substance abuse problem that drug testing has not adequately addressed, these industries are also suffering from labor shortages and a lack of guidance on how to manage legalized marijuana. A successful drug testing program should be able to address these issues by improving safety without risking the viability of the business. 

The current application of drug testing in many industries falls short in all of the above. Drug testing programs aim to improve safety by reducing workplace impairment. However, the data indicates that it is failing to achieve either outcome: 

1. Impaired workers are not being adequately filtered out of the workplace as indicated by the fact that post-accident positivity is rising faster than pre-employment positivity.
2. Safety hasn't been improved for the same reason--increased overall drug test positivity and increased post-accident drug test positivity indicate that the tests are not strong deterrents to drug use.
3. Drug-tests do not provide a way to test for real-time impairment from marijuana. This further complicates matters when there is a labor shortage and it is difficult enough to find quality workers, let alone a quality worker who hasn't smoked marijuana anytime in the past month.  
4. Labor-intensive industries like construction are at higher risk of false positives due to higher usage of pain medication among workers. (Concentra)

Opportunities for Drug Testing Program Improvement:

Non-regulated industries such as manufacturing and construction can resolve the aforementioned problems and improve their drug testing programs in one of three ways: 

1 - Remove THC from pre-employment drug screens. Treat cannabis like alcohol.

A couple of weeks ago, Amazon announced that they would go this route with all of their non-DOT regulated workers. Read all about it here. This approach directly tackles the labor shortage problem by instantly qualifying thousands of previously unqualified workers, including both medical and recreational marijuana users. Companies who remove THC from pre-employment screenings become more attractive to employees; in a time of severe labor shortages, the ability to attract employees can be a significant competitive advantage for business. 

This option might be preferred by companies in states/countries where marijuana has already been legalized, or is about to be legalized. See map below from Disa.com: 

In addition to the cost savings of removing pre-employment drug testing and wider access to quality workers, removing THC from pre-employment screenings allow workplaces to focus on safety measures that are stronger and more proactive deterrents to drug use and impairment. This is the perfect point to introduce a cognitive impairment test--employees will prefer it to invasive drug testing practices; HR and safety leaders will appreciate its proactive and comprehensive approach; your whole organization will benefit from improved safety, reduced risks, and reduced costs. 

Drug Testing Program Application Example:  

A Colorado manufacturing company removed THC from their pre-employment drug screens and entirely ended random drug testing. At the same time, they introduced daily cognitive impairment testing. This had several positive impacts within the first two years of implementation (verified by independent insurance provider): 

• Drug testing costs reduced by 90%
• Worker's compensation claims reduced by 70%
• Worker turnover reduced by 35%
• Productivity increased by 11%

Perhaps the biggest reward of all, however, was the company's ability to retain their quality employees who consumed cannabis outside of work in a manner that did not affect their alertness and safety while at work. It widened their applicant pool and gave the company a competitive edge while many other Colorado companies continued to struggle with labor shortages aggravated by marijuana legalization. 

End all random drug testing and use cognitive impairment testing instead.

As mentioned above, this approach proved extremely beneficial to a manufacturing company operating in a state where cannabis had been legalized. 

Since random drug testing has already been established as a weak deterrent to drug use, replacing it with cognitive impairment testing is an easy choice for many companies. Others will be more reluctant. Consider the following: 

• For random drug testing to be effective, it requires the time and money investment to utilize it frequently. Workers must report to work every day with the fear that they may be random drug tested. This is typically not the case, and even if it was, inciting daily fear in workers is not conducive to a healthy or positive workplace safety culture.
• The inconsistency of application in random drug testing can lead workers to believe they are being singled out while actually impaired workers go unnoticed or overlooked. This can lead to increased negativity and turnover without any improvement in safety. 
• As drug positivity rates for cannabis continue to climb, supervisors will grow increasingly reluctant to randomly test employees for fear of having a valuable employee test positive although being currently unimpaired. This reluctance can further decrease the overall effectiveness of the drug-testing program as it will make tests a lot less frequent and a lot more predictable. 

On the other hand, cognitive impairment testing offers the following benefits: 

• 60-second long, unlimited tests: This is a significantly lower time and money investment than random drug testing. Workers can confirm their sobriety and alertness within 60 seconds of stepping on-site. They can do so every single day and even after lunch without having to leave the worksite, without incurring additional testing costs, and without disruptions to productivity.  Providing workers with the quick cognitive feedback at the start of each day allows them to mentally check in, stop thinking about the traffic they just sat through, and focus on making safety their priority for the day. This a 60-second investment to achieve a full day's worth of increased focus, safety, and productivity. 
• Objective, non-discriminatory tests for everyone: Supervisors don't need to "single out" workers for random testing. With cognitive impairment testing, every worker takes the test every day. The test is responsive to each person's individual cognitive behavior, making it a non-discriminatory, non-invasive, and easy procedure for every worker regardless of language, educational background, or technological savviness. 
• Real-time insights: Since cognitive impairment tests only reveal impairment in real-time, neither supervisors nor workers need to fear retribution for off-time behavior. If a worker consumed marijuana on their vacation the week before, they're most likely not impaired by the substance anymore. A cognitive impairment test will detect impairment only to the extent that it affects a worker's ability to work safely in the present moment. This means workers who are alert and sober don't need to show up to work fearing for their livelihood, and managers don't need to fear losing valuable, sober employees.  

Leave everything the same, add cognitive impairment testing. 

For workplaces that are reluctant or unable to adjust their drug testing programs — significant improvements to safety and significant reductions in cost can be achieved by the addition of cognitive impairment testing to your existing drug testing program.

There is a very wide room for impairment between the pre-employment test and the post-accident test.

Unless your supervisors have the time to meet with every worker every day, they're unlikely to pick up on every opportunity to utilize reasonable suspicion testing. The frequency and predictability of random testing differs between workplaces, but workers who intend to get away with drug use often find a way to do it, as indicated by the Quest Diagnostics data cited above. 

Cognitive Impairment Testing Fills These Gaps

It's used daily, meaning it picks up on impairment that occurs after the pre-employment and before the post-accident test. Although, by using daily testing and holding workers accountable for safety every day, you'll likely find a significantly reduced need for post-accident tests:

Workplaces that utilize cognitive impairment testing have experienced reductions in TRIR ranging between 20 and 35%.

If your workplace is concerned with the costs of using both drug testing and cognitive impairment testing, consider this: 

Workplaces that utilize cognitive impairment testing experience reductions in costs of accidents ranging between 15 and 55% and reductions in worker's compensation claims ranging between 25 and 75%. These savings more than justify the initial investment. 

To get an ROI assessment and a specific quote for your company, pick a time on our calendar. 

Conclusion

"Impairment, whether it be by drugs, alcohol, fatigue or stress, decreases the safety of the workforce." - Jenny Burke, Senior Director of Impairment Practice, National Safety Council. (SHRM)

Between all the rules, regulations, and paperwork, it's easy to forget that the entire purpose of drug testing is to improve workplace safety. It's meant to achieve this purpose by deterring drug use. With drug positivity rates reaching new highs, it's time to rethink whether drug testing is actually serving this purpose, or whether it's just a costly pat on the back that allows workplaces to overlook other dangerous and complex sources of human impairment. 

As society undergoes significant changes including increased mental health issues, improved detective and predictive technologies, legalized cannabis, and labor shortages, traditional drug testing programs have come under scrutiny. Are they still the best way to manage human risk factors? 

Legalized cannabis use in the distant past is no longer a pressing safety risk for many workplaces. Current intoxication is. Real-time, detective technologies are more effective in this regard. 

Mental health issues, emotional distress, and fatigue are significantly greater safety risks than the possibility of a worker having smoked marijuana a month ago. Predictive, proactive, comprehensive, and communicative risk mitigation is a more effective method of combatting these complex issues than the punitive and narrow focus of traditional drug testing programs. 

Of course, it's not one or the other. The greatest benefit of cognitive impairment testing is that it looks at every cause of impairment. If something is anything is affecting an employee's ability to focus and work safely and productively, the test will detect it. 

Regardless of the regulations of your industry, there is always room to improve safety, productivity, and efficiency.

With cognitive impairment testing with AlertMeter^®, you can overcome your safety and productivity concerns and maintain a healthy and productive workforce. Schedule a time today to get a quote for AlertMeter® and learn more about how cognitive impairment testing can be implemented into your specific workplace and industry regulations. 

More Resources:

How This Company Reduced Their Drug Testing Cost by 80%

Drug Testing Methods

Workplace Drug Testing: 7 Reasons Not to Drug Test Employees

Marijuana and Drug Testing

Today, Amazon Announced that it Will Significantly Curb its Use of Pre-employment Drug Testing for Marijuana

Does Your Company Need a WIRE (Workplace Impairment Recognition Expert)?

Legalized Marijuana and Workplace Drug Testing: Complete Guide

Cannabis in the Workplace Webinar