Report on Drug and Alcohol Policy Survey

Report on

Drug and Alcohol Policy Survey

For

Business Leaders Health and Safety Forum

Lead Consultant: Mike Cosman, Managing Director

Date of report: 26 August 2013

Disclaimer: This report has been produced by Impac Services Ltd

using our professional judgement based on information provided by

BLHSF. Impac accepts no responsibility for the accuracy and

completeness of the information provided.

D&A Survey- BLHSF

Version number: 1.1 Status: Draft

3

Contents Contents ............................................................................................. 3

Executive Summary ........................................................................... 4

Key Findings ................................................................................................................... 4

Recommendations .......................................................................................................... 5

Introduction ........................................................................................ 7

Question 1&2–Size of business and industry ................................................................................................... 8

Question 3-Formal D&A polices ....................................................................................................................... 8

Question 4-Safety sensitive roles or areas ....................................................................................................... 9

Questions 5-13 Alcohol .................................................................................................................................... 9

Questions 14-18 Drugs. ................................................................................................................................. 13

Question 19 Prescribed or over the counter medication ................................................................................ 15

Question 20 –Just cause................................................................................................................................ 15

Question 21 Post-incident testing. ................................................................................................................. 16

Question 22- Random testing ........................................................................................................................ 16

Question 23- Non-negative results ................................................................................................................. 17

Question 24 –Involving staff ........................................................................................................................... 18

Question 25 –Education and socialisation ..................................................................................................... 19

Question 26- Contractors ............................................................................................................................... 20

Question 27-Rehabilitation ............................................................................................................................. 20

Other information ........................................................................................................................................... 21

Conclusion .................................................................................................................... 22

D&A Survey- BLHSF


4

Executive Summary Understanding issues of impairment whether by drugs, alcohol, fatigue or stress is becoming

increasingly important as we move to create safer workplaces in New Zealand. This survey of

drug and alcohol policies amongst Forum members has shown a high level of interest, as

evidenced by the response rate, but also a wide disparity of approaches to this complex subject.

There is a lack of authoritative guidance to support decision makers looking to put in place

policies that reflect best practice and considerable uncertainty around the web of legal issues

covering health and safety, employment relations, medical and privacy law. The extent to which

the workplace can set standards which impact on personal behaviour out of work time is also

contentious, although there is little doubt that anyone who presents themselves for work in an

unfit state is both a risk to themselves and others around them and potentially in breach of the

good faith requirements of their employment agreement.

Forum members have engaged with these complex issues in a range of ways determined by the

context of their operation and the expectations of others. Whilst it is clear that considerable effort

has been applied to developing policies and procedures there remains a lack of consistency

around who, when, where, how and how often to test. For those contracting companies who work

across multiple client sites this can be confusing, time consuming and expensive. With highly

mobile workforces the burden of repeat testing can be inefficient if there is no consistency of

approach or pooling of information.

This survey has provided a wealth of information to help inform the Forum membership and as a

basis for determining next steps.

Key Findings

98% of respondents have a drug and/or alcohol policy

50% apply this policy only to defined parts of their business i.e. safety sensitive roles

Only 7% ban alcohol completely from worksites

Friday night drinks or other officially endorsed events at which alcohol is served are found

in 75% of member companies.

Alcohol thresholds vary widely from zero to 400mg/ml (the adult driving limit).

D&A Survey- BLHSF


5

Testing, where done, is mainly post-incident or just cause (>80%), pre-employment or

random (>60%). Criteria to trigger testing (other than pre-employment) vary widely

The response to a non-negative test generally involves a stand-down, contractors are

likely to be excluded from site and a formal HR investigation and/or counselling will follow

Most formal testing is done by external contractors but screening i.e. via breath test may

be done internally

>90% of member companies test for illegal drugs, but only 50% include “legal” highs

Circumstances for testing are broadly as for alcohol but 80% undertake some pre-

employment testing. Urine sampling is the preferred method by >90% again undertaken

by an external contractor

There is a general expectation that staff will declare over the counter or prescription

medication that may be contra-indicated (may cause drowsiness). Few test for it.

Many members provide training for managers and check lists of symptoms to enable

them to interpret physical signs of impairment to trigger Just Cause testing. Post-incident

testing is often only triggered if the Just Cause threshold is reached rather than as a

matter of routine

The ratio of staff/contractors subject to random testing (for those who operate it) varies

widely from 2-100% per year.

The involvement of staff in the development of D&A policies varies considerably from

those engaged on day 1 to representatives being advised immediately prior to roll out.

Some companies used health and safety representatives to help roll out the programme

and explain it to other staff in order to engender widespread support for the initiative

Rehabilitation and counselling for those staff recording a non-negative result is mostly

provided through existing Employee Assistance Programme (EAP) providers.

Recommendations

Opportunities for the Forum to demonstrate leadership in this space might include:

Organising a conference or workshop to allow the issues raised by this survey to be

discussed and debated more widely

D&A Survey- BLHSF


6

Developing guidance for Forum members around the issues, standards and processes

including a model D&A policy

Engaging with MBIE/WorkSafe NZ to understand their expectations around what is legally

required to meet the all practicable steps duties under the HSE Act

Developing a mechanism to allow confidential sharing of data and intelligence amongst

Forum members about D&A issues

Considering ways to reduce repeat testing by encouraging acceptance of testing results

from other Forum members

Negotiating preferential rates for D&A service providers for Forum members

Using this issue to promote wider discussion amongst Forum members about Just

Culture concepts and their application

Impac would like to thank the BLHSF for engaging us to work with you on this important project

and look forward to offering further support in future.

D&A Survey- BLHSF


7

Introduction Impac Services Ltd was engaged by Julian Hughes, Executive Director of the Business Leaders

Health and Safety Forum (BLHSF) to develop and administer a survey of its membership

regarding the nature and extent of their polices with regards to drug and alcohol issues in the

workplace.

Drugs and alcohol in the workplace (D&A) are an increasing concern in New Zealand and

worldwide. Many employers recognise the need to put in place appropriate arrangements to

prevent, deter and detect impairment; however to date there is no authoritative guidance or

generally accepted standard to guide the development of these policies. As a result there is

considerable confusion, uncertainty and inconsistency of approach.

Forum members determined that surveying current practice would be a good starting point in

helping them decide whether to develop their own standards and as a means of sharing

information.

Methodology The survey was developed using best practice principles of survey design, based on an initial

assessment of the main subject areas of importance to the BLHSF. Questions were mostly

framed as asking respondents to indicate which from a series of statements they currently

applied. In a number of cases an opportunity was provided for free text comments.

The survey was applied using the commercial tool Survey Monkey and administered by email to

nominated contacts in all BLHSF member companies. It was accompanied by a request from the

Executive Director to participate and a foreword from the Forum Chair at the start of the survey

reinforced this.

98 respondents (76%) completed the survey.

Results were analysed with a report for each question and a list of narrative comments (where

applicable). Results are presented as a percentage score based on agreement with the

statement. Figures are rounded up to the nearest whole number. Basic demographic information

was also collected and some cross tabulation was carried out to identify differences by sector or

company size

D&A Survey- BLHSF


8

Review Team

The survey was designed and analysed by Mike Cosman, CMIOSH, Managing Director and

Principal Consultant of Impac. Mike has over 34 years’ experience in health and safety in a

variety of roles including as a regulator and in policy, strategic and corporate environments. He

has studied industrial psychology and human factors as part of his tertiary studies and now

teaches these and other issues on the NEBOSH International Diploma course. Mike was a

member of the recent Independent Taskforce into Workplace Health and Safety.

Impac Services Ltd is a member of the Forum but did not complete the survey to avoid any bias.

Discussion

Question 1&2–Size of business and industry

Respondents were asked about the number of employees and contractors in their business in

New Zealand. Not surprisingly the majority of members are larger firms, many engaging large

numbers of contractors.Error! Not a valid link.

The Steering Committee of the Forum asked for a free text response on industry sector as there

was concern that the 9 standard categories used in the Benchmarking tool did not accurately

reflect the type of work undertaken. As a result the answers reflect a diverse range of activity

from the energy sector to forestry. Policies tended to be more established and robust in high

hazard industries and amongst companies operating in multiple jurisdictions. Companies who

largely provide services to others tended to be very reactive to their clients demands

Question 3-Formal D&A polices

This question provided an opportunity to describe in general terms whether respondents had

policies in place for drugs and/or alcohol and who they applied to. Anyone without a policy on

either topic could exit the survey at this point. Only 2 firms had no drug policy and only 1 had no

alcohol policy.

Answer Options Drug

policy

Alcohol

policy

Response

Count

Yes, it applies to certain staff only 12 12 12

D&A Survey- BLHSF


9

Yes, it applies to all staff 47 45 47

Yes it applies to staff and contractors (including

sub-contractors) on our sites

33 31 33

Yes it applies to all staff and contractors wherever

and whenever they are working for us or under our

control

47 47 47

We don't have a policy but we still do some testing

(please explain below)

2 2 2

No. We don't currently have any arrangements in

place around this area.

2 1 2

49 respondents provided narrative comments about the scope of their policy. These displayed

wide variations in approach, sometimes determined by global polices, by client requirements or as

a result of having had to negotiate them with their unions. Further analysis of these variations is

discussed below.

Question 4-Safety sensitive roles or areas

Just fewer than 50% of all respondents had defined safety sensitive roles that some or all of their

policies applied to. Responses referred to those working in defined areas such as control rooms,

parts of sensitive sites such as operational areas (but excluding administration areas) or roles

such as plant or vehicle operators. Several respondents indicated they were moving towards

applying their policies universally.

Questions 5-13 Alcohol

This group of questions probed more deeply into alcohol policies and practices. 18% had a

general policy on alcohol which was not prescriptive and did not define testing regimes or specific

levels of impairment. The majority 82% had more detailed regimes in places.

Alcohol is banned completely from only 7% of sites with a further 75% allowing some degree of

flexibility subject to senior management approval. Friday night drinks still feature for 25% of

respondents while 9% don’t impose any formal controls, putting the onus on their staff to act

D&A Survey- BLHSF


10

responsibly. One company does not even allow staff to possess alcohol on site –for example in

shopping or luggage.

Answer Options Response Percent Response Count

Not permitted under any circumstances,

including when away on company business

6.8% 6

Permitted with specific senior management

approval i.e. Xmas, approved functions

75.0% 66

We have Friday night drinks 25.0% 22

Alcohol is sometimes available during work

hours e.g. at Board and SMT meetings,

networking and client hospitality

19.3% 17

If alcohol is served after work we take

responsibility for monitoring use and ensuring

people get home safely

40.9% 36

We don't impose any controls-we trust our staff

to behave responsibly

9.1% 8

Other variants include allowing alcohol at off-site functions, often combined with a responsible

host policy, having a designated manager overseeing alcohol consumption at company functions

and permitting alcohol only in a Social Club.

Testing for alcohol varied widely. 10% do not test at all. About 60% do pre-employment and

random, whilst a higher number >80% do post-incident and reasonable cause testing. A small

number test for alcohol every day on arrival at work on sensitive sites –particularly in the

upstream oil and gas sector and related activities (Heliport).

Answer Options Response

Percent

Response

Count

We don't test for alcohol 10.4% 10

D&A Survey- BLHSF


11

There is no generally accepted level of alcohol that is set by companies as a measure of

impairment. 42% use the adult drink driving limit of 400 micrograms/ml, whilst a similar number

use 100 micrograms/ml and about 20% set zero alcohol limits. Others have variable limits based

on age, lower levels for safety sensitive roles or other levels ranging from 50 to 250. One

company has a zero level at work or for those on call but a 100mcg limit for second response staff

that might get called back to site.

Responses to a non-negative test result also vary widely as shown below


Percent

Response

Count

It depends, we don't have a formal process 2.2% 2

We stand the person down automatically, pending

further enquiries

80.4% 74

We offer them counselling initially 33.7% 31

We embark on an HR process 50.0% 46

Exceeding our threshold levels is a strict breach of

our safety rules and will trigger a formal investigation

54.3% 50

If it's a contractor we ask they leave the site and don't

come back (at all or for a period)

38.0% 35

We undertake pre-employment alcohol testing 60.4% 58

We undertake post-incident alcohol testing 81.3% 78

We undertake just/reasonable cause alcohol testing 86.5% 83

We undertake random alcohol testing 61.5% 59

In certain high risk environments we test everyone, every day 9.4% 9

D&A Survey- BLHSF


12

A number of respondents have follow up testing carried out either on-site or by a designated

person and several indicated that the company response would sit within the framework of their

Just Culture process.

Alcohol policies are mainly part of the OHS system (58%) or HR system (28%) but in 31% of firms

it is a standalone policy to indicate the significance they attach to it. Only 21% have negotiated

their D&A policy with their staff or union.

Testing is mainly carried out by an external contractor and may be either a breath or urine test.

No respondents use a saliva or blood test. Breath testing is sometimes administered locally as the

primary screen but a non-negative result would then trigger a urine test. 2 companies make

provision for staff to self-screen.


Percent

Response

Count

We use a breath test meter to AS 3547:1997 that

anyone can administer

26.1% 23

We use an external contractor on demand 81.8% 72

We have trained staff to carry out breath testing 23.9% 21

We use a breath meter for simple screening but call

in a specialist if we get a non-negative result

12.5% 11

We take urine samples ourselves and send them off

for analysis

2.3% 2

We get an external contractor to take urine samples 22.7% 20

We make provision for workers to self-screen 2.3% 2

NZDDA is by far the most commonly used external contractor, although some use a company

doctor, GP, occupational health nurse or other health provider as well as ESR and Canterbury

Health Labs.

58% of respondents have had a non-negative alcohol result in the last year. Many of these

involved contractors. Pre-employment screening was felt to be beneficial to weed out those with

D&A Survey- BLHSF


13

a potential problem before they are hired. Those with mature and well understood policies

reported very low or zero non-negatives as the required culture change has become embedded.

Questions 14-18 Drugs.

Given the wider range of potential drug issues we first asked what drugs are tested for. This

showed quite widespread variations in practice.


Percent

Response

Count

None 5.6% 5

Cocaine 91.1% 82

Cannabis 94.4% 85

Opiates (Codeine, Morphine & 6-monoacteyl

morphine)

92.2% 83

Methamphetamine (Meth/amphetamine & Ecstasy) 93.3% 84

Phencyclidine (PCP) 74.4% 67

Party pills and "legal highs" 50.0% 45

Other drugs tested for included prescription only drugs that may be used illegally such as

Benzodiazepines, Diazepam, Nordiazepam, Oxazepam, Temazepam, α-hydroxy-alprazolam,7-

amino-clonazepam, 7-amino-flunitrazepam, 7-amino-nitrazepam and heroin.

Drug testing is carried out in a wide range of circumstances, which broadly mirror those for

alcohol testing


Percent

Response

Count

We don't test for drugs 3.3% 3

D&A Survey- BLHSF


14

We undertake pre-employment drug testing 85.9% 79

We undertake post-incident drug testing 88.0% 81

We undertake just/reasonable cause drug testing 92.4% 85

We undertake random drug testing 64.1% 59

In certain high risk environments we test everyone,

every day

7.6% 7

Urine sampling is the most popular option along with saliva and hair. Blood testing was

sometimes carried out for confirmation of a non-negative result


Percent

Response

Count

We use urine samples 93.2% 82

We use hair samples 1.1% 1

We use saliva samples 12.5% 11

We don’t test 4.5% 4

93% use an external testing body and again NZDDA was the most commonly cited along with a

range of occupational health providers. One company had trained its own staff to collect samples

that are then sent away for analysis.

Perhaps the most contentious issue with drugs is the threshold limit and how this relates to

impairment as opposed to simply detection given that metabolites of certain drugs can be

detected days or even weeks after any effect may have worn off. This is an area of employment

law that is so far untested by the Courts and hence there was a degree of anxiety about how far

companies were able to use these tests for disciplinary action, as opposed to initiating a

counselling process. 70% use the trigger levels set in AS/NZS4308:2008 but 42% said any level

detected would require further investigation, often following an immediate stand down.

D&A Survey- BLHSF


15

Question 19 Prescribed or over the counter medication

As the survey was looking at impairment issues we also asked a question about whether polices

included medication that is either prescribed by a doctor or available from a pharmacy, but which

may affect performance. Narrative comments indicate that a self-declaration may be required

prior to a formal drug test so that a potential non-negative due to prescribed medication can be

handled appropriately. However, the wider concern was about how to interpret general warnings

such as “may cause drowsiness” on cough and cold medicines. In general an opinion would be

sought from a company medical adviser if in doubt.

No 8.0% 7

It depends. We ask people to tell us if they think

their performance may be impaired as a result

71.3% 62

If it says "May cause drowsiness" on the packet then

we expect people to self-declare and we seek

medical advice

44.8% 39

This is a difficult and sensitive issue. We have

people who are on long term medication for a variety

of ailments. If they told us about this how can we be

expected to know how it might affect them?

10.3% 9

Question 20 –Just cause

As many policies include provision for testing based on just or reasonable cause, we asked

respondents how they interpreted this. We had 84 narrative responses which indicate very wide

variation in practice. Example comments include:

Two people reporting concern

Visible signs of impairment, including smell, appearance and other physical signs

Erratic or uncharacteristic behaviour,

Mood change, attendance record

Being found in possession of drugs

D&A Survey- BLHSF


16

Many companies have trained their managers and supervisors on what to look for and a number

have checklists of signs that may be indicative of an issue

Question 21 Post-incident testing.

A similar question on post-incident testing also showed wide variation in practice


Percent

Response

Count

We don't do post-incident testing 8.9% 8

A fatality 65.6% 59

A serious harm injury 73.3% 66

Any incident with the potential to cause death or

serious harm

80.0% 72

Certain types of "near miss" such as a vehicle or

crane incident

72.2% 65

We leave it up to the manager or investigator 15.6% 14

We test everyone in the workgroup 23.3% 21

We only test the operator/driver 14.4% 13

We test the injured person 32.2% 29

Interestingly a number of comments suggested post-incident testing would only occur if a serious

incident occurs and it is believed impairment is a factor, if drug and alcohol use is suspected or if

the investigator requests it. Others rely on external regulatory agencies to make the call e.g. road

accidents. Only rarely is post-incident testing seen as an adjunct to a random testing process

where everyone involved is testing as a matter of routine.

Question 22- Random testing

D&A Survey- BLHSF


17

Nearly 40% of respondents don’t currently undertake random testing but for those who do the

main process is either individuals selected at random (often by the external provider) or testing of

a whole site. Some company policies state the percentage of the total or safety sensitive

workforce who will be tested each year, which can be as high as 100%

Question 23- Non-negative results

We provided a range of possible answers here, which were not mutually exclusive. 80% said they

would stand someone down on full pay is they had a non-negative result pending further

investigation. 48% would automatically retest to look for a false positive result or to determine the

level of the substance detected more accurately. Only 7% would allow the person to continue

working in a non-safety-sensitive role –for example if they had a declared use of a prescribed

medication. Contractors were more likely to be dealt with summarily and excluded from site. For

pre-employment testing there was often a zero tolerance approach.

Employees were generally likely to be offered support and counselling, often accompanied by an

agreed plan of further testing over an extended period.


Percent

Response

Count

We automatically retest to confirm the accuracy of the

result

47.7% 41

We stand the person down on full pay pending the

outcome of a further test

79.1% 68

We allow the person to carry on working, but not in a

safety sensitive role, pending a further test

7.0% 6

We ask the (sub) contractor's employer to deal with the

situation as they see fit

14.0% 12

We exclude any (sub) contractor from site (either

permanently, for a period or until they return a negative

test)

52.3% 45

If a (sub) contracting company has a positive result for

one of their people we will consider terminating the

7.0% 6

D&A Survey- BLHSF


18

whole contract

We talk to the staff member and if they admit to taking

drugs or drinking we offer them counselling

47.7% 41

We talk to the staff member and if they deny taking

drugs or drinking we start a disciplinary investigation

31.4% 27

We adopt a 3 strikes policy 7.0% 6

Anyone who is undergoing counselling for drugs or

alcohol will get tested more frequently until they prove

they are clean

59.3% 51

Question 24 –Involving staff

We were interested to know how these D&A polices had been developed, negotiated and

consulted on. Responses varied quite widely from those that were simply imposed to a more

collaborative approach of development involving a working group including health and safety

representatives and those negotiated as part of a collective employment agreement.


Percent

Response

Count

We didn't 13.9% 11

We presented our policy to the health and safety

committee for sign off

43.0% 34

We set up a working group involving h&s reps to

draft our policy

39.2% 31

We asked our h&s reps to explain the policy to staff 13.9% 11

We undertook a survey of attitudes to D&A before

we started developing our policy

12.7% 10

We negotiated the policy as part of our collective 29.1% 23

D&A Survey- BLHSF


19

employment agreement/ER policies

Our policy was imposed on us from our parent

company

1.3% 1

We copied someone else's policy and just

implemented it

2.5% 2

Question 25 –Education and socialisation

A wide range of methods were used to introduce the policy and educate staff and managers

about how it was to be applied and why. Some companies used external experts to help develop

and ‘sell’ the policy, whilst others communicated it face to face as well as through posters,

newsletters and team meetings. Unions were actively involved in nearly half of all cases


Percent

Response

Count

We just issued it 12.5% 11

We put articles in our company newsletter 46.6% 41

We involved our unions 45.5% 40

We used posters and leaflets to explain it 42.0% 37

We ran road shows for staff 51.1% 45

We asked managers to brief staff at regular

meetings

60.2% 53

We got in an external provider 44.3% 39

We appointed "champions" from amongst the

workforce to be able to provide information and

answer questions

12.5% 11

D&A Survey- BLHSF


20

Question 26- Contractors

Given the large number of contractors involved in working for Forum members we wanted to

know how the D&A polices were communicated to contracting companies and their staff.

14% don’t do anything in relation to contractors -even though they have a D&A policy for some or

all of their own staff. Some indicated that they were in the process of considering this once their

own internal policy was well established. 43% refer to it in tender information they put out to

prospective contractors and over 50% ask for the contractor’s own D&A policy as part of pre-

qualification or procurement.

Surprisingly 58% only tell contractors after they have been appointed and only 71% include it in

site induction.


Percent

Response

Count

We include this as part of our tender information 43.3% 39

We ask contractors for their drug and alcohol

policies as part of pre-qualification

53.3% 48

We make it clear after contract award that

contractors and sub-contractors coming on our sites

must follow our rules

57.8% 52

We include it in our site induction 71.1% 64

We require all new contractor staff coming to work

with us to undergo pre-screening

18.9% 17

Is someone can produce a clear result that is no

more than a few weeks old we don't retest

4.4% 4

We don't do anything in particular for contractors 14.4% 13

Question 27-Rehabilitation

Our final question asked about how rehabilitation or treatment was offered to those who may have

a drug or alcohol issue. 80% use their existing EAP provider with a further 19% using an external

D&A Survey- BLHSF


21

specialist or company doctor. 13% would refer the person to their own GP. External specialist

agencies mentioned include Instep, Care NZ, Salvation Army and Step Ahead. Sue Nolan (ex

ESR) was also mentioned a number of times in relation to all aspects of D&A policies.

Other information

We asked respondents for any other information they thought might be relevant to the survey.

This elicited some interesting and wide-ranging comments.

With recent cases I am worried about how enforceable it may be.

We think that having a shared approach to dealing with drugs and alcohol throughout a wide

range of industries would help and that educating the workforce will remain a key component in

making the work place safer. We think that educating those about to enter the workforce to what

the requirements and standards are would go a long way to help changing the mind set of

individuals.

It is very important to consult, educate and emphasise the positives resulting from having a D & A

Policy. Also important to have an EAP to support it.

A NZ code or guideline that gives a framework of what good looks like inclusive of levels and

including synthetics. Also think it is extremely important that we recognise that D&A are only one

form of impairment and that there are much wider issues surrounding this.

Occasional use of Drug dogs for site inspections reinforces the messages. Key message to us is

that we expect people to present themselves fit for work. It is NOT about impairment or the

legality of the drug or alcohol.

Our policy is called an Impairment Policy and it looks at all forms of impairment, not just D&A. So

it looks at fatigue, psychological issues, prescription medication etc.

I have concerns about the privacy of individual’s results with the ballooning number of tests out

there. Not so concerned about failed drug tests but more worried about peoples need to disclose

possibly sensitive medications (e.g. cancer, depression or fertility related) Many customers are

insisting on seeing the actual test results but give no assurances about how they manage that

information. In some cases we have started refusing to supply anything other than our statement

that they have been tested negative

Education should focus on the full range of impacts of drugs and alcohol use including decision-

making, and work place relationships as well as awareness, alertness and reaction times. Driving

D&A Survey- BLHSF


22

vehicles is only one risk area. Setting a zero limit as an action threshold beyond which a

discussion takes place allows a habit or dependency to be picked up sooner before it impacts

safety in the workplace. If, at 7am at the start of shift, a person tests non-negative for alcohol, but

well below the legal driving limit it is still relevant to understand why. It may be that the person

drinks at breakfast (maybe a dependency) or they were drinking heavily the night before (and

possibly with hang over symptoms) or drinking moderately but very late the night before ( and

therefore possibly fatigued). In any case - any non-negative result should be followed up with a

discussion as a minimum response.

Conclusion

It is clear that D&A is an area of increasing concern for health and safety practitioners and that

the variation in practice reported reflects the maturing of understanding and application of specific

policies, but also the sensitivity of the issues involved. Companies do not want to become agents

of broader social policies and de facto police. However a broader understanding of the root

causes of injuries is clearly highlighting some of the more challenging underlying issues involved

and requiring a more sophisticated response to them.

Impac would like to thank all Forum members for their time and effort in providing such a valuable

source of information on this important issue.

0800 476 588 www.impac.co.nz

Report on Drug and Alcohol Policy Survey

Documents