Model Transit Rx/OTC Approach
In 2000, the FTA began an initiative to increase
awareness of the possible dangers associated with prescription (Rx) and
over-the-counter (OTC) medication use in the transit industry. In 2003,
the best policies, procedures and training materials that were available
in the industry were compiled into the FTA Prescription and
Over-the-Counter Medications Tool Kit.
Since that time, various systems and state Departments
of Transportation have worked to develop programs that meet the four FTA
objectives for an Rx/OTC program. These include:
- Develop a policy statement addressing the use of
Rx/OTC medications (See Updates,
Issue 24, Page 5).
- Educate safety-sensitive employees about the
potential dangers associated with the use of Rx/OTC medications (See
Updates, Issue 26, Page 7).
- Document Rx/OTC involvement in accidents (See
Updates, Issue 25, Page 5).
- Develop a procedure to have qualified medical
personnel determine the potential effects Rx/OTC medications may have on
employees’ performance and their fitness for duty.
The last of these objectives has proven
to be the most difficult to accomplish due to perceived operational
limitations, complexities of the health care system, logistical
impracticalities, and cost. However, a model approach is emerging that
promises to address these concerns. The approach is essentially a two
step process.
First, transit systems implement a bi-annual
fitness-for-duty physical examination that assesses the individual’s
medical history, current physical condition, current use of prescription
and OTC medications, and a discussion of anticipated future use of OTCs.
This physical provides a baseline fitness-for-duty assessment, provides
the physician with a comprehensive view of the individual’s physical
health and provides an opportunity to assess the impact of individual
medications and their combinations. All of this can be taken into
consideration in relation to the individual’s safety-sensitive functions
and encourages a dialog between the medical practitioner and employee
regarding their fitness for duty. The bi-annual nature of the
examinations provides for a periodic reassessment. To ensure an accurate
assessment of the risks to public safety, only medical practitioners
authorized by the employer should be used.
Employers that already conduct DOT medical examinations
for their employees with Commercial Driver’s Licenses already have the
mechanism in place and need only enhance the Rx/OTC portion of the
examination. Employers that do not conduct DOT medical examinations can
mimic the process. Even though the cost of a bi-annual physical exam may
be costly, the benefits in terms of increased safety and employee health
benefits are believed by many to outweigh the cost. This approach is
also consistent with the emerging industry focus on fitness for duty.
 Second, in the interim between physicals, employees are
required to obtain medical authorization from their prescribing
physician regarding the use of any additional prescription or OTC use.
The medical authorization forms are returned to the employer and then
forwarded to the company authorized medical practitioner that conducted
the bi-annual physical. By having the Rx/OTC authorizations reviewed by
the company authorized medical practitioner, the employer can be
confident that the employee’s safety-sensitive job duties, medical
history and physical condition are all taken into consideration and the
employee’s fitness for duty has been accurately assessed. The employer
reserves the right to overrule the prescribing physician based on the
recommendation of the company-authorized medical practitioner.
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Where to Find? .....
Conforming Products List
Evidential Breath Testing (EBT) Devices
July 21, 2000
Federal Register Vol.65
Pages 45419 - 45423
Primary Topic: Conforming Products List (CPL)
Website location: www.nhtsa.gov/
people/injury/alcohol
Note: This list will be updated periodically.
Non-evidential Testing Devices
May 4, 2001
Federal Register Vol.66
Pages 22639 - 22640
Primary Topic: Initial Alcohol Screening Devices
Note: This list will be updated periodically.
FTA Drug & Alcohol Discussion Forum:
http://transit-safety.volpe.dot.gov/
Safety/BBS
Drug and Alcohol Audit Questions
http://transit-safety.volpe.dot.gov/
Safety/DATesting/Audit
The information presented on this page should be used to update Chapter
5 of the revised Implementation Guidelines. |