ML18346A370
| ML18346A370 | |
| Person / Time | |
|---|---|
| Issue date: | 12/04/2018 |
| From: | Harris P NRC/NSIR/DPCP/FCTSB |
| To: | |
| References | |
| Download: ML18346A370 (15) | |
Text
Presentation to the Drug Testing Advisory Board (HHS/SAMHSA)
Drug Testing at Commercial Nuclear Power Plants and Fuel Facilities 10 CFR Part 26, Fitness-for-Duty Programs A Direct Contribution to Safety and Security December 4, 2018
Disclaimer The information in this presentation is provided as a public service and solely for informational purposes and is not, nor should be deemed as, an official NRC position, opinion or guidance, or "a written interpretation by the General Counsel" under 10 CFR 26.7, on any matter to which the information may relate. The opinions, representations, positions, interpretations, guidance or recommendations which may be expressed by the NRC technical staff during this presentation or responding to an inquiry are solely the NRC technical staff's and do not necessarily represent the same for the NRC. Accordingly, the fact that the information was obtained through the NRC technical staff will not have a precedential effect in any legal or regulatory proceeding.
Slide 2
Discussion Topics
- Fitness-for-Duty (FFD) Program Objective
- Individuals covered by the FFD Program
- FFD Program Elements
- Assuring Safety and Security through a Defense-in-Depth Strategy
- FFD Performance
- Industry Activities/Initiatives Slide 3
FFD Program Objective Provide reasonable assurance that nuclear power plant personnel are trustworthy, reliable, and not under the influence of any substance, legal or illegal, or mentally or physically impaired from any cause, which in any way adversely affects their ability to safely and competently perform assigned duties or be afforded unescorted access to the protected areas of nuclear power plants, sensitive information, or strategic special nuclear material (SSNM).
An FFD program developed under Part 26 is intended to create an environment which is free of drugs and alcohol, and the effects of such substances.
Slide 4
Individuals Covered by the FFD Program
- Security
- Control Room Operators
- Maintenance & Surveillance (craft & supervisors)
- Health Physics, Chemistry, & Emergency Response
- Construct or Direct the Construction of Reactor Plants
- All other persons who have unescorted access
- FFD Program Personnel*
Fit for Duty Trustworthy Reliable
- FFD Program Personnel include the managers, technicians, collectors, Medical Review Officers, and Substance Abuse Experts who implement the program Slide Slide55
Assuring Safety and Security through a Defense-in-Depth Strategy People Education, experience, training, qualification, etc.
Drug and Alcohol Testing (pre-access, random, for-cause, followup, and post-event)
Behavioral Observation Fatigue Management Access Requirements (e.g., background checks, fingerprinting, psychological testing)
Physical Protection (e.g., vehicle barriers, blast walls, blast resistant enclosures, etc.)
Detection (e.g., cameras, infra-red, motion, explosive vapors, x-ray, etc.)
Programs for Insider Mitigation, Cyber Protection, and Information Controls Slide 6
Overall Industry Performance, 2017
[Draft]
148,357 Individuals drug & alcohol tested 1,143 Individuals tested positive for a drug, alcohol, or refused a test 2/3 identified prior to entering the facility - pre-access testing 1/3 identified inside the facility - primarily by random testing 0.44% Random positive rate 0.77% Overall positive rate Observations
- Contractor/vendors still testing 3-4x higher than licensee employees
- Subversion attempts continue to be identified
- FFD program personnel remain the Silent Heroes of our program
- FFD Program Personnel include the managers, technicians, collectors, Medical Review Officers, and Substance Abuse Experts who implement the program
- All results in this presentation are Medical Review Officer verified SlideSlide 7 7
Results by Test and Employment Categories, 2017
[DRAFT]
Licensee Employees Contractor/Vendors (CVs) Total Test % of Total Category Percent Percent Percent Positives Tested Positive Tested Positive Tested Positive Positive Positive Positive Pre-Access 8,513 36 0.42% 71,586 695 0.97% 80,099 731 0.91% 64.0%
Random 34,624 48 0.14% 25,100 212 0.84% 59,724 260 0.44% 22.7%
For Cause 111 14 12.61% 757 64 8.45% 868 78 8.99% 6.8%
Post-Event 136 - 0.00% 492 11 2.24% 628 11 1.75% 1.0%
Followup 3,044 13 0.43% 3,994 50 1.25% 7,038 63 0.90% 5.5%
Total 46,428 111 0.24% 101,929 1,032 1.01% 148,357 1,143 0.77% 100.0%
Where were the most tests conducted in 2017 (>90% of tests)?
Licensee Employees Contractor/Vendors Pre-access 18.3% Pre-access 70.2%
Random 74.6% Random 24.6%
Followup 6.6% Followup 3.9%
99.5% 98.8%
Where were most drug and alcohol testing violations identified in 2017 (>90% of positives)?
Licensee Employees Contractor/Vendors Pre Access 32.4% Pre-access 67.3%
Random 43.2% Random 20.5%
For Cause 12.6% For Cause 6.2%
Followup 11.7% 94.1%
100.0%
SlideSlide 8 8
Detection Trends - NRC Testing Panel Percentage of Total Positives by Substance Tested
[Draft]
60.0%
marijuana 50.0%
Percent of Total Positives 40.0%
30.0%
cocaine alcohol 20.0%
10.0%
amphetamines opiates 0.0% PCP 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 Since at least 2014, this chart under reports the substances used by individuals with a drug testing violation. This is because of the high number of subversion attempts each year, and because in at least 60% of these subversion attempts, no specimens were tested.
SlideSlide 8 9
Results by Employment Category, 2017
[DRAFT]
Licensee Employees Contractors/Vendors (46,428 tested; 111 individuals positive) (101,929 tested; 1,032 individuals positive)
Refusal to Test 2.5%
Cocaine 11.8% Refusal to Cocaine Test 19.2% 12.3%
Amphetamines 13.4% Opiates Opiates Amphetamines 0.8% 10.8% 1.2%
Alcohol 35.3% Other Alcohol 1.7% Other 16.4%
0.2%
PCP 0.1%
Marijuana Marijuana 34.5% 39.9%
n = 119 n = 1,096 Slide 10
Additional Substance Test Results, 2011-2017
[Draft]
2011 2012 2013 2014 2015 2016 2017 Total Benzodiazepines 1 2 1 1 1 1 7 Buprenorphine 1 1 1 3 Fentanyl 1 1 Hydrocodone 1 1 1 3 Hydromorphone 1 1 2 Methadone 1 1 1 1 4 Norbuprenorphine 1 1 Oxycodone 1 1 1 1 4 Oxymorphone 1 1 1 1 4 Propoxyphene 1 1 Tramadol 1 1 Total 2 6 4 7 7 1 4 31 The 31 test results in this table reflect positive results for 24 individuals. That is, some individuals tested positive for more than one of the substances in the same testing event SlideSlide 12 11
Additional Substance Results by Test Category (2011-2017) [Draft]
Substances Pre-Access Random For Cause Followup Total Amphetamine; Marijuana; Hydrocodone; Hydromorphone 1 1 Amphetamine; Methamphetamine; Marijuana; Benzodiazepines 1 1 Amphetamine; Methamphetamine; Benzodiazepines 2 2 Amphetamine; Methamphetamine; Hydrocodone; Hydromorphone 1 1 Benzodiazepines 1 1 2 4 Buprenorphine 1 1 Buprenorphine; Norbuprenorphine 1 1 Cocaine; Benzodiazepines 1 1 Fentanyl; Oxycodone; Oxymorphone 1 1 Hydrocodone 1 1 Hydrocodone; Oxycodone; Oxymorphone 1 1 Marijuana; Benzodiazepines 1 1 Marijuana; Benzodiazepines; Methadone 1 1 Marijuana; Propoxyphene 1 1 Methadone 1 1 2 Oxycodone; Oxymorphone 2 2 Tramadol 2 2 Total 4 2 16 2 24
- 66% of individuals (16 of 24) tested positive on for-cause testing
- 25% of individuals (6 of 24) tested positive for one or more of the semi-synthetic opiates in the updated HHS Guidelines (i.e., hydrocodone, hydromorphone, oxycodone, oxymorphone)
- 57% of individuals that tested positive for an additional substance, also tested positive for a substance in the NRC-required testing panel (i.e., amphetamine, methamphetamine, cocaine, marijuana)
SlideSlide 13 12
Subversion Attempt Trends [Draft]
Subversion attempt - any willful act or attempted act to cheat on a required test (e.g., refuse to provide a specimen, alter a specimen with an adulterant, provide a specimen that is not from the donors body)
Sanction for a subversion attempt: Permanent denial of unescorted access (10 CFR 26.75)
Subversion Attempt Trends 2012 - 177 of 1,114 violations (15.8% subversions) 2013 - 148 of 1,007 violations (14.7% subversions) 2014 - 187 of 1,133 violations (16.5% subversions) 2015 - 232 of 1,200 violations (19.3% subversions) 2016 - 304 of 1,164 violations (26.1% subversions) 2017 - 298 of 1,143 violations (26.1% subversions)
Subversion Attempts in 2017
- 45 facilities with at least 1 subversion attempt
- 67% identified at Pre-Access testing (200 of 298)
- 98% by contractor/vendors SlideSlide 13 13
Industry Activities/Initiatives
- Oral fluid testing
- Expanded panel testing
- Auditing of HHS-certified laboratories
- Background checks and true identity determinations Slide Slide14 14
NRC Fitness for Duty Program Staff U.S. Nuclear Regulatory Commission Office of Nuclear Security and Incident Response Paul Harris, Senior Program Manager Paul.Harris@nrc.gov (301-287-9294)
Brian Zaleski, Fitness-for-Duty Program Specialist Brian.Zaleski@nrc.gov (301-287-0638)
Slide 15