When I started in the coal industry some twenty years ago as an underground miner fitness for duty was not discussed, but here we are in the year 2000 with the proposed introduction of a new Coal Mining Act and fitness for duty a very important topic.
The new Coal Mining Act gives us a direction and understanding of what is required in fitness for duty.
As the years went by I saw the introduction of self-testing alcohol wall-mounted units and then on to random selection testing with hand held units. Today we have four major aspects of fitness for duty - alcohol, drugs, fatigue and psychological impairment.
Given the experience I have had in occupation health and safety in both New South Wales and Queensland, and the implementation of a fitness for duty policy in the coal mining industry, it is my view that the following recommendations should be considered when designing and implementing a fitness for duty policy.
The first step in creating a policy is the formation of a fitness for duty committee.
Fitness for duty committee
Ã Ensure the personnel are from a cross-section of the workforce.
Ã The personnel on this committee should only be those who will give a positive and committed input.
Ã Expose the group to as much information as possible about the issues:
1. Ensure the committee is familiar with Division 10: "Fitness for Duty" section of the new Coal Mine Regulations Act.
2. It is important to make the committee aware that a fitness for duty policy is not only a drug and alcohol policy but it also covers two other important sections - fatigue and psychological impairment.
3. Expose the group to people who have had experience with the implementation of fitness for duty policies, not sales personnel (it is important for the committee to understand the real problems and solutions of implementing the fitness for duty policy).
4. Ensure the information-gathering phase involves some first hand empirical evidence about the risk posed to the mine and to individuals by the various aspects of the fitness provisions. It is important to establish a realistic picture of the real risks posed to the mine.
Ã The committee should meet no less than once a month while creating the fitness for duty policy, with the whole of the committee present at all meetings.
Ã After the policy has been introduced the committee should only meet for a policy review every three months, or sooner if problems arise.
The areas covered within a fitness for duty policy, and my recommendations, are as follows:
Alcohol testing is the pioneer of the fitness for duty policy. Alcohol testing has been around for quite a while and several types of alcohol measuring instruments have been designed and used from hand-held to wall-mounted units.
Important points to look for are:
Ã Simple to use units.
Ã Calibration time frames and location of calibration service centre.
Ã Backup hand-held unit.
Ã Private location for testing.
Ã Hygienic disposal of consumables.
Ã Appointed testers.
Ã Approved training program for testers.
Ã A private out of the way location for self-testing wall-mounted units.
Ã A dedicated person to maintain the wall unit.
Unlike alcohol testing, only in recent times has onsite drug screening become available. The most common of these is the urine drug screen, but in recent times we have seen the introduction of a saliva drug screen. Although the urine screen is the most used method, I have found saliva screening creates a new method of drug testing with the following benefits:
Ã Tests for levels of impairment (does not look for a trace of up to six weeks) a true indication of fitness for duty.
Ã Simple and clean test.
Ã The sample cannot be contaminated.
Ã Quick indication of result.
Ã No calibration of equipment.
Ã Easier supervision of test subject.
Prior to implementing drug screening a number of methods should be looked at and the most appropriate method selected. Once a method has been selected the following steps have to be applied:
Ã Educate the entire workforce in drug awareness and testing procedures.
Ã Ensure a codeine free workforce.
Ã Nominate and train personnel to carry out screening (where possible use independent personnel).
Ã Ensure that stocks of drug screening equipment are readily available.
Ã Ensure a process for conformation of positive results is in place.
Ã Allocate a room, away from main activity, for testing.
Ã Ensure privacy and confidentiality of results and testing.
Fatigue and psychological impairment
Minimising the risk of fatigue and psychological impairment involves the thoughtful design of the workplace to minimise excessive stress and fatigue, and the education of personnel towards lifestyle management. The experiences I have had with these aspects of impairment suggest that we should look at finding the problems and removing the causes wherever possible.
Just identifying the problem is not a solution. The process of addressing the problems is through an education program, consultation, risk assessment and the production of a standard operation procedure.
When conducting risk assessments it is important for the majority of personnel involved to be from the workforce, however input from outside professionals should be sought and considered. All personnel involved in this process require training and familiarisation in the risk assessment process.
The education process is a very important part that involves the entire workforce. The major objectives of an education program is to provide personnel with relevant information, challenge those attitudes and beliefs that expose individuals to increased risk, and to encourage each individual to take on a responsibility for their fitness for duty.
It is important that any education program be ongoing. We found that an initial two-hour session for operators that allowed them to understand and identify problems at home or at work and to control and resolve these problems worked well. Initially, supervisory personnel should participate in a four-hour training course that enables them to identify problems within their workforce and deal with them under the fitness for duty policy.
Take time, step by step and do it right.
Although the process of creating and implementing a fitness for duty policy is a long one, the above recommendations can make it a smooth process that will enhance the safety of all personnel.
Greg Hunt now works as an OH&S Consultant and is contactable on 0438 547 456.