Sheet Metal Northwest Anti-Drug Program (SNAP)

Just by the random nature of these selections, some participants will be selected by the computer more than once a year, while others may go longer than one year before being selected. The fact that anyone can be tested on any day makes random testing an effective deterrent. The SNAP program tests at a 100% random rate, so being tested once a year is only average

Companies are still experiencing a delay in getting results for new apprentices and new material handlers. The SNAP program has been receiving complaints from DERs that Local #66 and #55 are dispatching new workers who haven’t had “baseline test” or have had a test but are not listed in database. This problem appears because until a name appears in the Union’s database, there is nothing to match test results to. So, SNAP must contact the Local Union (or company if it is a non-bargaining worker) to get name entered. Pragmatically, new workers can expect a 48-hour turn-around time for the entire process even though test results are received within 24 hours.

The Program Administrator’s response is slightly too long to fit in the FAQ format. See the document list above “SNAP Medical-MJ FAQ.” 

Yes, a post-accident drug/alcohol test may be performed or collected at a medical clinic or hospital that is not the list of SNAP-approved collection sites provided that this is where medical treatment for the injured worker is received AND the facility’s test meets the federal standards required by the SNAP program.
This exception applies to post-accident testing situations only. Remember that “instant drug tests” and/or urine alcohol testing are NOT allowed by SNAP as they do not meet federal (DOT) standards.
SNAP requires that first aid and/or medical treatment always take precedence over the drug/alcohol test. In many on the job injury incidents, the treatment facility may have the ability to perform the drug test collection and a federally approved breath or saliva alcohol test. This procedure should help to minimize the extra travel and waiting time for the injured worker while still maintaining the integrity of the SNAP testing program.
If the facility has this ability, and is willing to do so, here are options for how to do this:
1. Furnish the facility with the following pieces of information for recording on their forms:
SNAP’s LabCorp Account Number: 092049 Non-DOT;
SNAP’s PacLAb/PAML Account Number: PA2192 Non-DOT;
SNAP’s MRO contact information: Dr. Dee J. McGonigle, Drug Free Business, 18912 North Creek Parkway, Ste 202, Bothell, WA 98011 Phone: 866-448-0651 Fax: 425-489-0832.
Make sure your company name is added to all custody and control forms.[This information can be taken from the collection site information at the top of the standard SNAP Drug Testing Authorization Form which is available in the SNAP Documents section.]
2. In unusual situations, if no pre-printed forms are available, always require that federal collection procedures be followed and that the above information is recorded on all documentation.
3. Instruct the facility to directly bill your company for the collection fees. You may forward the testing invoice to Drug Free Business when you receive it.

You can click on the existing links at the top of the SNAP home page or go to https://www.drugfreebusiness.org/rmw . Detailed instructions on how to use the website are available or call Drug Free Business 800-598-3437.

A general contractor, or project owner may require additional testing that is outside of the SNAP program as a contract condition or condition for entering the job site. These additional tests are allowed under the SNAP program. Because these tests are often so- called instant tests, and have been performed outside of the SNAP guidelines, they cannot be used to replace a test required under the SNAP program.

However, information received from outside the SNAP program, e.g. a recent failed test, may be used by an employer in making a reasonable-suspicion test decision under the SNAP program. See FAQ “What should a SNAP employer do if notified by a general contractor that one of our employees has failed one of these instant tests or any other test under the general contractor’s own program?” below.

Participants in SNAP are eligible to receive Employee Assistance Program (EAP) benefits through Fully Effective Employees. Fully Effective Employees, Inc. is a separate company from Drug Free Business although for purposes of this program, they will operate in a consortium. Full service, confidential employee assistance is made available to all participants, their families, and/or significant other person. Information and resources are available online at http://www.fee-eap.com.

Participating employees with substance abuse problems are encouraged to obtain confidential help through the Employee Assistance Program before they are lottery selected. They will be assisted and referred to an appropriate treatment program if needed. In most cases today, substance abuse treatment is handled on an out-patient basis so that an employee is not required to miss any work.

Voluntary self-referrals or referrals by family and concerned co-workers are always treated confidentially by the Employee Assistance Program. Employers, union officials, and the program administrator are not notified.

The EAP is an integral part of this program. When a participating employee fails a drug/alcohol test or otherwise becomes not o.k. to work under this program, the administrator will confidentially notify the EAP and make drug testing results available on request to speed up the assessment and return to work process.

If you have tested positive, i.e. failed or refused to take a drug or alcohol test, you must contact the EAP as soon as possible to arrange for an assessment.
Fully Effective Employees (EAP) 425-454-3003 or 1-800-648-5834

Please see the “What happens when you test positive chart” in the SNAP Documents.
The EAP will complete the assessment and make a recommendation. You may be referred to educational, counseling and/or treatment resources. If the assessment determines that you have no significant problem, the EAP may authorize your return to work. However, in either case the EAP serves as a gatekeeper and must authorize your return to work after determining that you are compliant with their recommendations. In addition, you must successfully pass a return-to-duty drug/alcohol test before returning to work. Your EAP counselor will give you instructions for this test.

Once you have returned to work, the EAP counselor will remain in contact with you in case you need additional or specialized help. You will also be subject to follow-up testing for a period of two years after returning to work.

Remember, you must take the first step: Call Fully Effective Employees at 425-454-3003 or 1-800-648-5834.

The answer to this question is found in the Admin Guide on page 13 (Failure to appear for collection within the time limit). The program administrator (DFB) should be notified and then you would immediately suspend the worker and refer him/her to the Employee Assistance Program. Use common sense in making this determination. Keep in mind that many of the collection sites have limited hours and may not be convenient considering the particular employee’s hours or remote location, so schedule your date and time of notification accordingly.

Administrative Guide – Page 13
A refusal to test is treated like a positive test. Employees who refuse to take a drug or alcohol test, or appear for testing will be treated as if the test was positive. The following is considered a refusal to test:

Failure to appear for collection within the time limit.
Refusal to sign the chain-of-custody forms.
Engaging in conduct that clearly obstructs the testing process as defined in the Urine Specimen Collection Handbook for Federal Workplace Drug Testing Programs.
Tampering or adulterating specimens.
Failure to provide an adequate urine sample or an adequate breath sample without a valid medical explanation.

Collectors will follow the “shy bladder” collection procedures outlined in the Urine Specimen Collection Handbook for Federal Workplace Drug Testing Programs, which provides for the donor to drink 8 ounces of fluid every 30 minutes up to a maximum of 40 ounces or until the donor has provided a sufficient urine specimen, whichever occurs first.

Because DERs (employers) may choose any day during the month to notify a specific worker that he/she has been randomly chosen and must appear for collection, the program administrator (DFB) has no way of knowing whether the worker showed up within 24 hours. Therefore we must rely on you to report this to us whenever a worker blatantly ignores your instructions to report for a required test. You can verify the date and time of collection from information received from the Medical Review Officer (MRO).

Here are some addition things to keep in mind (from Random Selections Instructions)

• You may choose any date during the current month to notify the employee that he/she has been selected; however everyone on this list must be notified and tested before the end of the month.
• You will probably want to print out 2 copies of the individual selection notice; one for the employee to sign and you to keep as proof of notification date. The second copy you can give to he worker.
• You must keep this selection information confidential up until the actual notification of the selected employee. Selection for random testing is to be unannounced and unanticipated.
• The employee will need a SNAP Testing Authorization Form which is available in SNAP Documents to the left.
• Employees must complete the drug testing collection process within 24 hours of notification. Keep in mind that many of the collection sites have limited hours and may not be convenient considering the particular employee’s hours or remote location, so schedule your date and time of notification accordingly.
• Being randomly selected is not an accusation or a suspicion of drug use, however for most employees this is still a sensitive issue. This program requires that notifications be made in a confidential and discreet manner without any other workers being aware of the notification. The wellness benefit check will be issued to each bargaining unit employee after passing his/her random test.

Please give the SNAP Administrator a call if you need additional information or clarification.

SNAP requires that employees randomly selected for a drug test in any particular month have the specimen collected during that month. (Remember that once notified, the test must be completed within 24 hours). The random selections database gets its information from both the Local #66 and Local #55 workers database. If a worker has been laid off, terminated or released without notifying the Union, sometimes this data may be out-of-date.

As an employer (DER), if you reasonably believe that the selected worker will return to work for you in the near future, simply keep the fact of his selection confidential until he returns to work – and test him then. This should take care of situations where a worker is temporarily off work due to injury, illness, vacations, out-of-state assignments, etc.

If you reasonably believe that he/she will not return to work for you in the near future, then you should go to the roster web site and change his/her status from “Hired” to “Terminated”. This will remove your company from responsibility to perform the random test on this worker who is no longer employed by you.

The wellness benefit checks will be mailed out once per month. Thus a worker who is tested just after checks are mailed could experience a delay of 4-5 weeks until the next batch is mailed out. Please allow for a few days for postal delivery to your residence (as recorded by your Local Union).

Please note that checks are issued for baseline and random tests but NOT for unannounced tests that are required as part of the EAP/return to work obligations for up to two years following a failed test. Post-accident and Reasonable Suspicion tests conducted during work hours do not generate a check either.

Bargaining workers with out-of-area dispatch cards who are working for out-of-area contractors outside of the SMACNAWW jurisdiction when they are tested are not eligible for wellness checks.

Checks may also be delayed for the following reasons:

• There is no employee listed in the database to which test results can be matched. SNAP must investigate and get name added.
• The worker only provided the last 4 digits of the SS#. SNAP must look up and manually enter the other digits.
• There is no SS# or the worker’s name is not legible. DFB must investigate and manually enter the information.
• The worker has not kept his/her mailing address current with the Local Union and/or is unaware that a spouse has received and deposited the check.

Bargaining workers with out-of-area dispatch cards are eligible to receive wellness checks only if they are actively working in the SNAP jurisdiction when they are tested.

In accordance with the SNAP Admin Guide, only Local #66 workers are eligible to receive this payment.

We may have a few checks that have been returned because of “unable to forward” etc. If you believe that your check is missing, please call the SNAP Administrator.

If you registered a non-bargaining employee as a Designated Employer Representative (DER), your company has been invoiced for the $100 fee. In addition, you will be invoiced for your non-bargaining supervisors and managers who are required to participate in the program as described below.

The Trustees have agreed that any non-bargaining workers required or voluntarily placed in the SNAP program would cost each employer $100 per year. (Subsequent years are invoiced at $65 per non-bargaining employee). This is to cover the cost of the drug test(s) administration, and full EAP benefits. Pages 5 and 6 of the Administration Guide state:

This program applies to all bargaining unit members represented by Local Union 66 and 55 of the Sheet Metal Workers’ International Association under the Collective Bargaining Agreement with Sheet Metal and Air Conditioning Contractors National Association (SMACNA) – Western Washington, SMACNA Inland Empire, and others.

Non-bargaining employees (required): Testing will be required of all non-bargaining employees (including owners) who meet ANY of the following categories or descriptions:

• Are specific employees who act as Designated Employer Representatives (administrators) of this program for the employer. At a minimum, every employer must have one Designated Employer Representative in the program.
  
  
• Visit a shop or jobsite while performing supervision
  
  
• Perform on-site project management
  
  
• Are non-bargaining employees who work at the jobsite or in the shop on a routine or continuous basis
  Jobsite-required: Testing will also be required of all employees, bargaining and non-bargaining, when the owner or general contractor of a specific project requires testing as a condition of admittance to the jobsite.
  
  
• Non-bargaining employees (optional): Employers have the option to extend this program to include other non-bargaining employees, subject to an agreement to pay an annual fee per employee to cover program costs.

Additional bargaining units may be included in the program at a later time.

This system can only report results for valid and correctly matched social security numbers. In order to see a worker’s stutus, a valid social security number and/or name must have been used, and the worker must be in the system. Some reasons for not having testing results reported in the system are:

• A test simply has not been completed yet.
• The initial baseline test has not been done yet.
• In the collection process, an incorrect SSN was entered, thus creating unmatched information with the records in the SNAP system.
• The worker may have been entered by two employers resulting in a duplicate worker record – and test results have been linked to the ‘other’ duplicate record.

If you are a DER or Backup DER and need help resolving this, please contact Drug Free Business. Many times this is simply a data entry error, and the SNAP system actually is working just as it should be working.

Since the employer would have no “proof” it was a prohibited drug, or it was alcohol, just firing the person would subject them to union challenges. Instead, an observation of use is a “fact” justifying a reasonable suspicion test as per the Administrative Guide.