Writing a Drug and Alcohol Policy for a Maritime Organisation seems simple right? This is not always the case; however it can be simplified if you consider all of the relevant variables right from the beginning.
Vessels and ships are very different from other workplaces in that they are mobile so need to take international legislation/guidelines into account, whilst also being a home and workplace.
Our Policy experts have years of experience helping our customers with their Drug and Alcohol Policies, from reviewing them, advising on content or helping to write a Policy from scratch – here’s an opportunity to take advantage of their considerable experience and advice on the factors to consider.
Form a working group
Involving key stakeholders right at the beginning of the process has multiple benefits:
- It creates a good working relationship.
- It helps unions or working groups understand the policy.
- Input helps with buy-in as concerns can be raised and addressed.
Defining key terms
The wording used within a Drug and Alcohol Policy is important and needs to be thoroughly considered. Defining key terms, such as ‘misuse’, ‘drugs’ and ‘positive result’, to name a few, is necessary because it is part of setting the ground rules in a clear manner. Once agreed all key terms should be listed upfront and used consistently throughout the policy.
Something else to take into account is distinguishing between impairment due to the inappropriate use of drugs and/or alcohol, and dependency or personal problems resulting from the use of these substances, as these terms can be reflected in Employment Law concepts of ‘conduct’ and ‘capability’.
Finally differentiating between ‘drugs’ and ‘alcohol’ is also significant due to the accepted nature of blood alcohol levels and impairment for alcohol, where as a positive drug test shows use, but not the when, where or if the Seafarer was impaired at the time of testing.
Setting the rules
This is essential so Seafarers know exactly what is expected of them. It’s important to be fair and reasonable, to set these rules following staff consultation, to be clear and to ensure they are communicated to all marine staff and finally that they will be applied reasonably and consistently.
Using a drug and alcohol testing programme
Testing for drugs and alcohol is a tool that has enormous value as a deterrent, and provides a visible record of the success of a policy. Include details around which Seafarers will be tested, when they will be tested and how they will be tested. It must be clear what the consequences of positive test results, refusals to take tests, or the deliberate interference with test procedures will be and any other actions which will be considered a breach of policy, resulting in disciplinary action outside of testing.
Educating your employees
As the use of drugs and alcohol is effectively a lifestyle choice, education plays a key role in successfully introducing and implementing a Drug and Alcohol Policy. Topics to cover include both the purpose of a policy and the health and safety factors Seafarers should consider. Those that implement the policy should also be confident in the procedures; their education is a key cornerstone to consider.
Providing support for your employees
Supporting staff that either come forward or are identified from the drug and alcohol testing programme to be problem users is something to be prepared for. Consider what information about the types of help is available, are they given advice about taking medicines at work and can they access an employee assistance programme.
Legislation to consider
There could potentially be various legislations that you may need to consider, including local, international and industry related legislation – this is going to be specific to each Maritime Organisation. Here are a few Maritime related codes, guidelines or requirements to consider:
- IMO International Safety Management Code (ISM Code)
- IMO International Convention on Standards of Training, Certification and Watchkeeping (STCW) Regulations
- Oil Companies International Marine Forum (OCIMF) Drug and Alcohol Guidelines
- Exxon Mobil Tanker Time Charter Party
- United States Coast Guard (USCG) requirements for the drug and alcohol testing regulations in Title 46 Code of Federal Regulations (CFR) Parts 4 and 16
Now you know the seven considerations why not visit our website to download our free ‘Policy Guidance Notes’ and learn more about what our Drug and Alcohol Policy Experts can do for you.