Drug and Alcohol Testing

Total Group provides Occupational Health and Safety (OHS) drug and alcohol testing support for workplace programmes. The service listed on the Total Group HSE hub covers pre-employment, post-incident and random screening contexts. Each context should be connected to a written policy, a defined safety purpose and a process for handling sensitive personal information.

Plan the programme around the work

Before testing is arranged, confirm the site jurisdiction, employment jurisdiction, worksite controller, job duties and any client, collective-agreement or project requirements. Identify which roles are safety-sensitive and why impairment could create a direct and significant risk to a worker, other people or the environment. The Government of Canada uses this safety-sensitive concept in its federal workplace guidance, while noting that testing is governed by case-specific labour, human-rights and court decisions rather than one universal testing rule. Government of Canada workplace impairment questions and answers

Testing is one part of an impairment programme. The policy should also explain how supervisors raise a concern, how an unsafe situation is controlled, and how workers can report that they are not fit to work safely. CCOHS guidance recommends defining the policy’s purpose and coverage, the circumstances and methods of testing, the drugs included, the criteria for testing, and how results will be interpreted. It also addresses privacy, accommodation, support and return-to-work processes. CCOHS: Impairment at Work - Policy and Recognition

Pre-employment, post-incident and random screening

Pre-employment screening should be considered within the employer’s hiring process and applied only where the programme has a clear, defensible purpose. Candidates should receive understandable information about what is being collected, why it is required, how it will be handled and who may receive the result.

Post-incident screening should sit within the incident-response process. First address immediate safety, medical needs and scene controls. The employer’s policy should then set out when testing is considered, who authorizes it, what records are created and how testing is kept separate from assumptions about cause. A test result does not, by itself, establish current impairment or replace an incident investigation.

Random screening requires particular care. In federally regulated workplaces, Government of Canada guidance says random testing in safety-sensitive positions may be permissible only in limited circumstances, including a demonstrated workplace problem, a proportionate response and continued accommodation obligations. Alberta’s current impairment guidance states that legislation does not address testing for impairment and recommends legal advice on human rights, labour and employment law, privacy and OHS before an employer implements a testing programme. Government of Alberta: Impairment in the workplace

Roles and process controls

The employer sets the purpose, scope and decision rules in its policy. Supervisors need a clear route for responding to observed safety concerns without diagnosing a medical condition or substance-use disorder. Workers need to understand reporting expectations, privacy boundaries and what happens when they cannot safely perform the assigned task. A health and safety committee or representative, and a union where one is present, may have a role in policy development. The testing provider’s role, including collection, result reporting and escalation, should be confirmed before the programme begins rather than assumed from the service name.

Document the programme in a way that can be followed consistently. The planning record may include the approved policy, worker notice or consent materials where required, the testing trigger, authorization, collection and result records, communications, accommodation steps and retention rules. Access to results should be limited to people who need the information for the identified purpose. The Office of the Privacy Commissioner of Canada recommends limiting collection, use, disclosure and retention; explaining practices openly; maintaining safeguards; and restricting access on a need-to-know basis. Office of the Privacy Commissioner of Canada: Privacy in the Workplace

Jurisdiction and privacy context

Alberta: Government guidance says current legislation does not address testing for impairment and advises employers to obtain legal advice before implementing a testing programme. It also recommends a policy that accounts for privacy, confidentiality, job duties, multiple jurisdictions, fitness to work, reporting and accommodation. This is regulator guidance, not a statement that every Alberta workplace may or may not test.

Federally regulated workplaces: Government of Canada guidance describes a case-specific legal framework that balances safety with privacy and human rights. Random testing is not presented as a routine default. The applicable workplace, employment and privacy framework should be confirmed for the undertaking and the roles involved.

Other provinces and territories: Requirements can differ. Ontario’s official workplace guidance, for example, describes employer duties to assess and control impairment hazards and maintain an OHS policy and programme, while warning that other laws may apply. It should not be treated as the controlling rule for an Alberta workplace, a federal undertaking or another jurisdiction. Government of Ontario: Drugs, alcohol and workplace health and safety

Discuss your requirements

Tell Total Group where the work will take place, which workers or applicants are in scope, whether the need follows a hiring process or incident, and what policy or client requirements already apply. Total Group can then discuss the intended testing service and the practical information needed to plan it. Before implementation, have the employer’s policy, jurisdiction, privacy approach and accommodation process reviewed by the appropriate qualified legal, human-rights or privacy adviser.