ML20206C845
| ML20206C845 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/10/1988 |
| From: | Tscherne L INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-53FR36795, RULE-PR-26 53FR36795-00032, 53FR36795-32, NUDOCS 8811160434 | |
| Download: ML20206C845 (2) | |
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ML.CIO 3nternational ~Brailprl anh of Elcritical Burkraamm i
_ LOCAL union No. 2.45~
m 705 LIME CITY ROAD ROSSFORD. OHIO 43460 gg -
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lbverter 10, 1988
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Secretary of the Comission 5:
U. S. thelear Begulatory Cceniccion E-E T'.
Washington, DC 20555
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N Atta: Ibeketing and Service Branch g
Gentlemen:
This letter is in response to the propoced rule tefore the tbclear Be+;ulatory cccmission reguding Fitness-for-Euty.
The International Bmtherhood of Electrical Workers (IBEW) Lccal 245 is an organi::ed lator union with over 1,600 members. We are presently involved in representing over 300 IEEW members pemanently assigned to the Davie-Besse tbclear Power Station. Also at any given time a countless nuster of other utility and construction members can te assigned or rotated thmugh the plant perfoming various maintenance and service functions.
It must te understood that the IBEW eupports a dmg free work place, but is very much oploced to random testing.
Coenicsioner Boterts in hir corn 'nts ccceended the staff for the excellent job in describing the effects of Me five (5) dmga involved; marijuana, cocaine, opiates, thencyclidine, amthetamines, and that each one of the categories of drugs has visual otcervable effects.
Thic Local concuro with Ccenicsioner Boterts that tehavioral observation by well trained supervicorc will detect the drug atuser or any other unusual tehavior sith less intrusion of privacy and stand a tetter chance to te found to te constitutional. Again this Lccal opposes random testing. Testing levels are another concern. Of the thirty or nere nuclear power plants that the IBEW cervices with Fitnean-for-Duty programs they vary widely on cut off levels and confidentiality. Cut off levels for cur amters have varied between 20 nanograms in 1986 to the current level of 50 nanograms for tetahydrocannabinol (DiC). 'Ihese levels need to te consistent thmughcut the industry.
The IBEW and this local telieve that the cut off point shculd be the same as that of the military services (100 nancgrams). Confidentiality of all informtion must te accured.
This Local Union and the IEEW have in nany ways addreseed the concerns of a drug free workplace with the entire nembership.
It is only pr.per to note that a great number of cur esters are active particitante and serve, in a numter of volunteer grxure in their chumhes, schcols and ccccunities that eponsor "Just Say tO Ta Drugs" pmgrams.
8811160434 001110 PR PDR PDR 26 53FR36795 y
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Secretary of the Comicsion 13ovember 10, 1988 Washington, IC Being fully supportive of pregrame to addmss the national pmblems of drug abuse, the attention should not be colely focused on the lluclear industry, as the fluclear industry should not to treated any differently.
Having discussed support of a dmg free work place, random testing, categories of drugs, behavioral obeervation, cut-off levels, confidentiality and the cupport of addressing the national pmblem of dmg abuce, the licencees intention should focus on ecntnseling and rehabilitation to employees who, by testing positive, are shown to have a possible drug and/or alcohol pmblem. The l
licensees must realize that runitive action dces not replace the need for health eaucation in controlling and eliminating abuse problems. Attempts at l
rehabilitation either thrcugh the Employee Assistance Pmgram or other rehabilitative activities must te attempted prior to the Ccepany eubjecting the employee to diccharge.
We appreciate your considering these ccements, if you have any questions please feel free to call or write.
On behalf of IBEW, Local 245, Yours truly, l
Yemu Larry J. Tscheme, Asst. Basiness Manager IBEW, Local 245 LJT.nlm
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