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

Policy
The “Dear Colleague” letter issued by FTA Acting Administrator Nuria Fernandez in May 2000
requested that all recipients of FTA funding establish programs to review current policies on
employees’ use of OTC and Rx medications that could compromise public safety.
This section contains six current transit agency policies to serve as examples for employers in
creating a new policy or revising an existing policy on Rx and OTC medications. These
examples demonstrate three different policy approaches: (1) responsibility is placed on the
employees to determine their own ability to safely perform their duties while using medications;
(2) proactive involvement by the employer requiring authorization by medical practitioners that
may include a final determination review by the employer’s medical review officers (MROs) or
other physicians; and (3) use of a list of medications to guide employees and medical
practitioners on which medication may or may not be used, and those medications that must be
approved for use.
An information sheet precedes each example. It includes a summary of the policy, and an
analysis of its advantages and disadvantages. The example policies are:
(1) Utah Transit Authority, Salt Lake City
(2) Maryland Transit Administration, Baltimore
(3) Orange County Transportation Authority, California
(4) Municipality of Anchorage Public Transportation Department
(5) Bi-State Development Agency, St. Louis
(6) ATC/Vancom of Nevada, Las Vegas
As implied by the “disadvantages” category on the information sheets, none of these examples
contain all the provisions of an “ideal” policy. In fact, those policies that are based solely on the
employee’s perception of impairment are not recommended, as employees are commonly unaware
or unable to ascertain their degree of impairment. Thus, programs that rely solely on employee
self-assessment may not be as effective as those that require medical input, and are therefore
discouraged.
Based on a review of these policies, FTA has developed a list of recommended provisions for
Rx/OTC policies:
• A procedure for obtaining medical input into employee’s fitness for duty associated with
prescription/OTC use
• A procedure for removing employees from safety-sensitive duty who are impaired by the
Rx or OTC medications
• An attendance policy that reflects Rx/OTC use-related absence and limitations on use of
sick leave