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Prescription and Over-the-Counter Medications Tool Kit ... - Home

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Policy<br />

System Name: ATC/Vancom of Nevada<br />

Contact: Trudi Hrisoulas<br />

(702) 636-0623 ext. 2143<br />

trhrisoulas@atclv.com<br />

Summary: The Rx/OTC medication policy is included as a section of <strong>the</strong> larger<br />

drug <strong>and</strong> alcohol testing policy. The policy requires all safety-sensitive<br />

employees to notify <strong>the</strong> agency of all Rx <strong>and</strong> OTC medications. The<br />

policy describes <strong>the</strong> required notification procedure including <strong>the</strong> use of<br />

<strong>the</strong> prescription/non-prescription notification form. The employer<br />

makes <strong>the</strong> determination regarding <strong>the</strong> employee’s ability to work based<br />

on <strong>the</strong> physician’s statement. If a determination cannot be made, <strong>the</strong><br />

opinion of <strong>the</strong> agency’s MRO is sought <strong>and</strong> his/her determination is<br />

considered final. Employees are not allowed to come on duty while<br />

taking <strong>the</strong> medication until <strong>the</strong>y have been authorized to do so. The<br />

policy also defines <strong>the</strong> absenteeism policy <strong>and</strong> alludes to no-show/missout<br />

unauthorized absence, implying that excessive absence due to<br />

Rx/OTC medication use would be treated accordingly.<br />

Advantages: The policy is concise <strong>and</strong> clearly worded. The employee’s responsibility<br />

<strong>and</strong> employer authority are clearly defined. Procedures are well defined.<br />

The notification reporting process is defined <strong>and</strong> includes a timeline,<br />

contact persons, <strong>and</strong> alternates. A signed notification form is required<br />

for both Rx <strong>and</strong> OTC medications.<br />

Disadvantages: The policy does not address confidentiality. It does not provide<br />

consequences for failure to report use, only <strong>the</strong> consequences for<br />

falsification of records. Uses an MRO in a non-MRO role. Rx/OTC<br />

reviews should be made by <strong>the</strong> company physician who might also serve<br />

in <strong>the</strong> role of <strong>the</strong> MRO for drug <strong>and</strong> alcohol test reviews (see OCTA<br />

policy discussion).

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