ML20206M599
| ML20206M599 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 11/18/1988 |
| From: | Firlit J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Knighton G NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| FRN-53FR36795, RULE-PR-26 53FR36795-00329, 53FR36795-329, NUDOCS 8812010130 | |
| Download: ML20206M599 (40) | |
Text
-
~
1M
$SMU=
g;3 pg,3g79ff @
RACRAMENTO MUNICIPAL UTIUTY DISTRICT C 6201 S Street. P.O. Box 15830. Sacrawnto CA 958521830.1916i h 524211 AN ELECTRIC SYSTEM SERVING THE HEART OF CAllFORNIA CEO 88-377 23 Pl2:07 November 18, 1988 fI U. S. Nuclea,- Regulatory Commission Attn:
Document Control Desk Hashington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 NRC FITNESS-FOR-DUTY PROPOSED RULE COMMENTS Attention: George Knighton In response to Federal Register Vol. 53, No. 184, the Sacramento Municipal Utility District submits comments on the NRC Fitness-for-Duty Program.
The attachment contains comments on the proposed rule, and compares the Sacramento Municipal Utility District's program with the proposed rule.
Members of your staff with questions requiring additional information or clarification may contact Mt. Ellen Banaghan at (209) 333-2935, extension 4917.
Sincerely,
'D Q,auf]L/:.,,
1> sX
/ Joseph F. Firlit "Chief Execut've Of ficer Nuclear Attachment cc:
A. D'Angelo, NRC, Rancho Seco J. B. Hartin, NRC, Halnut Creek 8812010130 001110 PDR PR 26 53FR36795 PDR D4/e RANCHO SECO NUCLEAR GENERATING STATION D 14440 Twin Cit <es Road Herald CA 95638 9799;(109) 333 2935
Attachment Fitness for Duty I
U I
t l
I l
4 a
.I i
i 1
i i
i h
l
)
i i
i 4
1 l
l i
l 1
1 4
i f
i l
i i
l 1
HP9191L D-1533A FITNESS FOR QUIY Rancho Seco Nuclear Generating Station applauds the effarts the NRC has made to have licensees implement a more comprehensive fitness for duty program, specifically a random urine drug screening process to aid in detection of and act as a deterrent to substance abuse.
Rancho Seco has had in place a random screening program called the Medical Clarification Examination hereaf ter referred to as HCE. Qag comoonent of this examination is to assess a randomly selected individual, with a designated "vital access badge," for potential substance abuse.
The HCE's goals, content, and performance data are covered in Section IV of this response.
Rancho Seco requests that the NRC evaluate whethe' t.is program's characteristics are contributing to the goals as e.tablished by the NRC in 26:10 "General Performance Objectives."
The NRC rule suggesting that random drug testing is a necessary element of an effective program presumes that the Supreme Court will uphold its use if challenged. When Rancho Seco tried to impose this rule in 1986, an injunction was granted against collection of random arines.
Rancho Seco was able to negotiate a settlement with the International Brotherhood of Electrical Workers (IBEH 1245), in which the random process to deter and detect substance abuse, would take the form of the HCE, as one component of a talAl fitness assessment.
Rancho Seco offers comment on all other proposed Fitness for Outy elements and will compare its overall program with the proposed rules in an effort to evaluate our FF0 strengths and weaknesses.
Rancho Seco feels its program fully addresses the subject of Fitness for Outy both physically and psychologically.
It does not stop with merely looking at the question of substance cbuse but goes on to assess "fitness" with respect to the whole person.
He urge your careful consideration of this program.
JA!!LL0f CONTENTS PAGE SECTION I - Comments on General Provisions 2
SECTION II - General Comments on Fitness ter Outy Testing 11 SECTION III - Comments on Additional Questions Posed by the Commission
?8 SECTION IV - Background and Discussion of the Medical Clarification Ex.mination (HCE) 23 SECTION V - Drug Information References and Results of Studies Done by DR, Forrest Tennant 31 1
SECTION_I - C0004ENTS ON GENERAL PROVISIONS 26:1 Puroose This part prescribes requiret.ents and standards for the establishment 4
and maintenance of certain aspects of Fitness for Duty and procedures for licensed Nuclear Power Plants.
I I
f
]
26:2 (a) Rartcho Seco sees great logistical difficulty in applying Fitness for j
Duty regulations to all persons granted unescorted access to J
protected areas. He question the validity of the security /public
[
safety risk of an individual delivering to the plant vs. an l
individual working full time on ite plant.
The impact of the first l
individual on protected or vital areas would be limited vs. the
[
second individual who has access everyday and could well be a risk f
to plant safety.
[
j Adding TSC and EOF personnel to this would require us to interface j
l with people who are not our employees, and who may have specific and j
i different policies regarding drug testing.
I l
(b) No recomended changes
{
i 1
i I
26:3 Definitions
[
i l
i It is recommended that this section be deleted.
He agree with the
)
objeci: ion NUMARC cited in the word "impairment."
It is a subjective f
determination.
There is no agreed upon definition, nor is there any 4
scientific / medical guidance to determine "impairment on the job" for any 2
i r
specific reason.
j t
i f
I I
l l
i l
I i
2 i
j
...~_
i I
"Suitabu incbiry" is particularly disturbing.
a,laase of Security, Medical...a EAP information is confidential information. The NRC is i
attempting to build a bridge in an area where there can't be one.
I i
If an employee resigns, this is an issue between employee and company.
l No adverse information goes on the record, even if it involved drugs.
z' If The NRC wants this informat'an, it will interfere with the employer /
l i
employee relationship.
l r
j 26:4 Interoretations I
J No recommended changes.
I i
26:6 Exemotioni r
i
)
No recommended changes.
j c
j 26:7 I n fo rma t i en_Co l l e c t i on R ecu i r eine n t s : OMB Acoroval l
[
I See changes per KMC draft.
i i
26:10 General Performance Ob.iectives i
i These are laudable goals, but the processes established to achieve them do not meet performance objectives as stated.
f t
Random urinalysis will cover the cherrical use aspect and detection i
i aspect, but it will not cover mental, physical aspecu.
}.
t f
Eptly detection is available through the MCE process, and we feel this is a necessary tocl for Fitness for Duty evaluation.
(
f i
3 t
26:20 Proaram Elements and Procedures The NRC is asking licensees to establish a policy for abuse of legal drugs (alcohol, prescription and over the counter), but is providing no guidelines or direction.
26:21 Policy Communications and Awareness Trainina He concur with the KMC comments that general educational programs, as outlined, are simply not needed for viable fitness for Outy programs.
They are unreasonable and the practical aspects of running such programs would be staggering. He also require furtter clarification of the role of the Medical Review Officer, both in definition and intent of this person.
26:22 I 31nine_of_Sygervisors and Escorts Rancho Seco agrees with KMC's comments that portions of training as only related to Fitness for Outy should not be "lifted" from access l
authorization and made a stand alone requirement.
He further question the need for the extent of training required for escorts. As anyone could be an escort, this kind of training would place an undue burden on the Plant and people and is also inconsistent with general performance objectives, i
26'23 ContractoIl 1
He believe subsection (b) should be entirely deleted. A contractor cannot be directed by NRC regulation to prevent assignment of an employee to "contracted work" if that person were denied access at any nuclear power plant.
4
26:24 Chemical Testing Chemical Testing is a means to deter and detect the use of illegal drugs, not drug abuse.
The requirement that "at least 90% of the individuals within the scope of the rule are tested each year" is unreasonable and the 300% random test rate is excessive, f
He are in agreement with the NUMARC statement that the requirements of this last paragraph discount deterrence and use the program for detection only.
1 l
He further agree that the Armed Forces may need this kind of random test rate due to its "youthful and nonpermanent" populations, but tu s is not the case in this country's Nuclear Power Industry.
He note that utilities having random testing programs have a less than 1% positive drug screen.
Our MCE process has a 1.3% positive result and is indication that there is not a large drug culture.
)
Random screening can be applied successfully through the MCE process and we feel it acts as a deterrent and early detector of substance abuse.
j In (a) (4), the word random should be deleted and the word "unannounced intervals" be added.
i He tould further stress the issue of more frequent testing early on in the process of dealing with an individual who tested positive for drugs.
There should be a policy statement mandating weekly urinalysis--during the initial quarter after return to work with reduction to monthly after that time.
l I
}
He also agree that licensees would have legal challenges if their j
standards (e.g., lower cutoff levels) were dif','erent than the Fed 3ral
]
ones in HHS.
If base lines are not the same, information would not be l
able to be passed on, usefully, to other licensees.
I i
I 5
26:24 4(d) We question thether licensees should conduct preliminary tests on j
body samples.
There would be a need to duplicate QA measures, and all staff would have to be trained / certified in doing this.
26:25 EAR EAP should not be mandated for contractors.
This is the responsibility of the particular companies. Rancho Seco seeks clarification of the word "hazard" when it requests that EAP shall inform licensee management when a determination has been made that a self-referring individual's condition constitutes a hazard to himself/herself or others.
Licensees need to be informed of all instances of hazard, not just "self-referring".
EAP definition in this regulation means discioline not voluntary ref erral for confidential assistance.
The NRC needs to recognize the clear difference between company-mandated discipline (help) vs. employee voluntary self-referral to EAP.
26:27 Muutgement Actions and Sanctions to be Imoosed The requirement that a company release to another company the 'dentity of persons denied unescorted access and the circumstances of d2nial, and test teruits confilets with tne medical, EAP, and employment records as being considered confidential.
It should be made clear why a 14-day suspension is a requirement of a first positive. At Rancho Seco, the process begins immediately.
The individual goes to the Chemical Dependency Physician for evidence of dependency, then secondary evaluation by a Chemical Dependency Counselor before a determination is made about returning to work.
Rancho Seco feels that the use of hair analysis as a follow-up measure could be very useful to determine patterns of use and continued abstinence.
6
Ef an individual etolates company policy, specifically by the sale, use, or possession of illegal drugs within the plant and is terminated, there should be no provision that could be interpreted by the terminated employee that he would be allowed back into the plant after a set amount of time.
This interferes with the employee / employer relationship.
Major violations of company policy dictate the strongest of measures.
An individual who has used off-site assistance and has undergone rehabilitation should be tested more frequently than every three months. At Rancho Seco, an individual is on probation for one year. A rehabilitated individual should be subject to an intense drug screening program to insure a drug and alcohol free work environment.
(c) If an individual resigns, this impacts on the employee / employer relationship which dictates that an employee who chooses to resign rather t:1an suffer the consequence of testing, resigns voluntarily.
The Company has no alternative per the rule than to record this as negative.
The alternative of resignation without prejudice would be lost to an employer under these circumstances.
26:28 App 1111 No changes are recommended.
7
i l
26:29 Pro 9ectinn of Information (b) It'is necessary to determine what is medical, employment or security information and what releases would be required to divulge this information.
Concern over the relation of state law and federal j
regulation is of serious importance in this portion of the rule.
26:70 Inseections (d) Rancho Seco his concerns that the NRC could inspect copy or take away confidential medical information under prov'.sions of this ruling. Such an action is inconsistent with California privacy standards.
26:71 Recordkeanino Reauirements (d) He are in agreement - NUMARC and KMC that (d) should be deleted.
The Program Performance Data Form would require a great deal of work and the information asked for could be taken out of context or misused.
He agree with KMC coments regarding the role of the medical officer in confirming positive results before referral.
This is inconsistent with requirements for the removal of access authorization prior to a confrontation regarding a dismissal.
26:80 Audit No recommended changes.
26:90 Violations No recommended changes.
8
FITNESS FOR DUTY PROGRAM ELEMENTS NOT INCLUDED _
IN THE PROPOSED 10 CFR 26 Rancho Seco is in agreement that the individuals stated in (1) could impact : plant's safety and performance and requests guidance in how to meet this concern.
Items a), b), c), and d) are very necessary measures to meet the requirement of a drug free work environment.
c I
9
UTNESS FOR DUTY PROGRAM PERFORMANCE DATA (1) "B" ard "E" are the same.
(2) The form is inconsistent on drugs identified - alcohol is on it.
(3) He are unsure of what exactly "total manhours" means.
(4) He do not have an EAP program for contractors.
10
SECTION II -SENERAL CC$NENTS ON FITNESS FOR DUTY TESTING A.
Take no Alternative Action - No comments offered.
B.
Testina Before Erolovment or Badaina SHUD's policy is to have a work environment free from the effects of drug and alcohol use.
Candidates for employment at Rancho Seco are required to undergo a screening for drugs and alcohol as part of the hiring process.
The designated lab does perform a preliminary test.
If it yields positive results, the lab automatically conducts a confirmation test on the sample using a similar technology.
The only test results reported to SHUD as positive are those from a confirmation test, in all cases gas chromatography /
mass spectrometry.
Rancho Seco assumes that the NRC's use of the word "positive" means confirmation by GC/MS as per the HHS Guidelines.
Rancho Seco does not believe that prescreening addresses substance abuse or dependency problems and thus utilizes for cause and random Medical Clarification Exam (HCE) to augment its FF0 policy.
C.
Ettlndic _Orua Testina (Annaunted Testing 1 Rancho Seco concurs that this process is less effective than random HCE, screening for cause and random drug screening.
However, experience at some plants does show that continuing users are screened out as a result of such tests.
11
0.
Enr CM se Testing SHUO's Policy to have a work environment free from the effects of drug and alcohol use requires that an employee undergoes a drug / alcohol screening in cases where:
i 1.
An employee is involved in an on the job accident requiring medical treatment beyond first aid, reportable under provisions of the Occupational Safety Health Act (OSHA).
i 2.
An employee's job performance or behavior suggests the employee may be under the influence of alcohol / drugs.
l
]
3.
SMUD receives information or allegations which, after investigation, provide reasonable cause to believe the employee may be involved with drugs / alcohol.
1 Rancho Seco agrees that "for cause" screening is highly dependent on the ability of managers, Security or the regular medical staff to identify employees who are at risk, and requires, as well, strong support from company management.
i l
t E.
Eehavior Observati_on Proaram i
FFD training and behavior observation training is provided to managers by l
Rancho Seco trainers.
SMUD has monthly educational meetings with the Medical
}
Chemical Dependency Consultant.
(
i Rancho Seco agrees that the supervisors may not have enough time to j
exercise observational skills they have received.
Some supervisors have utilized the on-site HCE practitioner as a resource person, and some have requested advice in evaluation of employees who clearly are not performing.
All supervisors are notified when one of their team members is selected for a random HCE and if they desire, will state their concerns about this
[
j individual.
The practitioner can then ask appropriate questions in the 1
interview process and evaluate the employee's perception of a stated concern i
from the supervisor. All discussions are confidential and the practitio9er I
l will make appropriate referrals, if indicated.
12
G.
gmoloyee Assistange Prggtimi Rancho Seco has some concerns that "EAP" is used almost interchangeably with "Rehabilitation" which Rancho Seco sees as two separate processes.
Rancho Seco utilizes EAP both on and off-site to assist those experiencing personal problems which are affecting their work performance.
Some of these problems may be alcohol related.
EAP referrals may be self, after "for cause" incidents NB--Not mandatory, from supervisors or on-site medical staff, from the Medical Clarification Examination (HCE) and after the Chemical Dependency Medical Specialist has examined an individual who tested positive.
Rancho Seco has been interested in developing educational tools with the EAP clinical staff to conduct and enhance employee / supervisory awareness in i
behavio, Mservation, but has not done so due to time, financial restraints, and the lack of a designated FFD Co-ordinator.
If the NRC believes that EAP can play a significant function in detecting substance abuse problems, ther. surely the same could be said for the HCE process.
Pancho Seco does not believe EAP alone can assure a work place free of the effects of alcohol / drugs.
A tess Authorization Program H.
l Rancho Seco is awaiting implementation of this program as contained in a policy statement issued for public comment on March 9, 1988.
What Rancho Seco does not want to see is any duplication of any part of this program in the FFD policy.
I.
Bork Place Security Heasures Rancho Seco would like to use more frequent ranine searches, plus utilize tindercover Security measures as it did prior to initiation of its FFD HCE process.
13
J.
Employee Awareness and Educational Programs FFD is discussed in safety teaching and other related new employee orientation. A FF0 handbook has been provided to all employees and contractors.
Rancho Seco does not concur with the NRC Statement that "behavior is notoriously resistant to change on the basis of knowledge alone."
An educational component of the HCE process has evolved in which the practitioner has given information in light of a family history of drug abuse, has acted as resource person to this employee in guiding him to confront his I
own (or family member's) substance abuse problem or in helping him deal with a troubled co-worker.
Although there are no objective measures to assess educational information programs in reducing drug abuse, Rancho Seco feels employee awareness and education, whatever the process, contributes to a drug free work place.
I l
l
[
l 14 l
l
8V. Rata of Random Tqili If Rancho Seco is permitted to carry on the MCE process which takes 30 to 45 minutes to administer, plus conduct random urinalysis at the 300% level, the strategy would be extremely burdensome, costly and space would be a major problem. Current staffing ratios do not permit one individual to devote his/her time to collecting the number of urine specimens called for.
In addition, the need to have large samples for QA control measures would be staggering.
There currently is no facility capable of furnishing control samples in the quantities necessary to conduct random urinalysis at the levels in the NRC proposal.
V.
Cutoff Levels Rancho Seco would encourage the NRC to mandate more stringent guidelines for cutoff levels and should change subject to advances in technology.
See initial comments to questions posed by the Ccmmission on page 36796 of the Federal Register, specifically our response to question #4.
VI. Number of Positive Tests The approach by the NRC regarding ":ero tolerance" is laudable.
Therefo,, its statement "...Use, possession, sale of illegal drugs would result in removal from activities within the scope of the rule for a minimum of 3 to 5 years..." interferes with the employer / employee relationship.
In addition, its statement "Public health safety would be well served if employees are encouraged to voluntarily seek help before their problem is manifested in observable abnormal behavior." ties in with the intent of the MCE process, 3,2 to 4 % of the individuals selected randomly voluntarily sought help when confronted in the intsrview process, 15
VII. ReinsQitgtion of Unescorted Arfess and AeyelonmenQ of the Treatment Follow-uo and Future Emoloyee Plans Rancho Seco has mandated that an individual be assessed for potential substance abuse as soon as a urinalysis is confirmed as positive by GC/MS. An I
individual is placed on sick leave, their access badge is pulled and the individual is cent to the Chemical Oependency Physician for asse:sment.
Rancho Seco utilizes three categories in assessment:
1.
Category I - Casual user individual is identified via urinalysis and would be returned to work but would be required to undergo 12 months of surveillance screening and also would be required to go through a drug education program focusing on policy, conditions of employment, frequency of screening and consequences of continued drug use (i.e, Termination).
Additionally, information on the specific effects of the drug on the body are provided.
Training is given to the employee i
and the supervisor.
j 2.
Category II - Individual identified as not necessarily addicted, but at significant risk and would be required to go te Chemical Dependency Counseling and the Chemical Dependency Specialist would determine if the individual goes back to work or sent to rehabilitation.
3.
Category III - An individual with a full blown addiction would be required to undergo rehabilitation and decision would be made by SMUD and the Chemical Dependency Specialist as to when this individual would come back to work and that he did not constitute a threat to sarety.
If the NRC recognizes that the task of evaluation of a potential (or Actual) substance abuse problem should be left to the trained judgement of a medical professional qualified in substance abuse disorders, then Rancho Seco has more than met this objective by utilizing:
1.
A qualified nurse practitioner for initial l'sessment during the random unannounced screening 16
2.
A medical physician trained in chemical dependency to evaluate, categorize and diagnose the extent of the substance abuse problem.
3.
Qualified substance abuse counselors in EAP/ rehabilitation who will specifically identify the nature and the extent of the individual's substance abuse problem and formulate a treatment plan.
17
SECTION III - COM4ENTS ON ADDITIONAL 00ESTIONS POSED BY_THE. COMISSION i
t 1.
Rancho Seco feels the practical alternative to random drug testing is
)
the Medical Clarification Exam.
The MCE history and development, along I
with performance data, are discussed in detail in section IV.
The HCE is random, and by this process, acts both as a deterrent and detector of substance abuse.
It is also fully accepted by the unions, particularly I
IBEN. Under the International President's Agreement, there has been no j
objection to the MCE from the AFL-CIO.
1 j
2.
In addition to assessing potential substance abuse, the MCE evkluates l
diminished physical or mental well being. Rancho Seco also utilizes j
input from supervisors and Security to evaluate unusual behavior; EAP j
counseling is provided on-site.
Rancho Seco, therefore, feels there is 2
a broad spectrum of Fitness for Duty processes that can be utilized to help employees when their general performance changes, 3.
The MCE process requires 30-45 minutes to administer.
By examining j
]
eight individuals per day, all individuals having vital access, l
theoretically, could be examined in one year.
If the NRC allows Rancho j
Seco to continue this process, there would be difficulty from the j
logistics point of view in administering MCEs and obtaining urinalysis l
on a 300% annual testing frequency.
Such a testing frequency is clearly detection oriented not deterrance oriented.
4.
Rancho Seco feels the HHS guidelines should be made more stringent for all five drugs or classes of drugs described in paragraph 2:1 (a) (1) and (2) of the HHS guidel,nes. More stringent measures left up to licensees could present legal challenges in court by exceeding specified federal standards.
Rancho Seco believes that, on consultation with j
local law enforcement authorities, other drugs of choice used in that specific geog.aphical locale and local work force should be added to the f
drugs test ' for as a specific reference.
18
Rancho Seco seeks clarification of the definition an Reeleo Officer" in reviecing final test results.
e cal a medical doctor can review these results?
Does this mean that only This would impact on our abilities to quickly expedite our responsibilities when a positiv screen is confirmed and action must be taken in accordan policies.
Pletse comment on who is designated as a competent medical authority and specify guidelines for such an authority.
i It should be pointed out that a "competent medical authority" is equally likely a "fitness for duty coordinator" to conclude that a GCHS confirmed co positive is grounds for discipline / rehabilitation.
ne for marijuana, PCP or methamphetamines are clear.Similarly positives The only time a "competent medical authority" might be specifically needed would be cases where "legal" or prescrioed drugs are confirmed positive.
5.
IBEH has expressed concern regarding the use of names on drug would prefer to have numerical references used in drug samples similar to those individuals undergoing HIV testing.
This is IBEH feels this would ensure privacy.
Such a provision might be incorporated in the proposed rules.
)
6.
Rancho Seco feels the NRC should provide guidelines for alcohol and prescription drug abuse.
Alcohol and prescription drug abuse are j
principle concerns in any fitness for duty program.
7 If the NRC dictates a rule regarding when an individual barred from could be reinstated, it would interfere with the employer / employee ess relationship.
Rancho Seco strongly feels that the employer should havt the right to decide di ciptine r* habilitation conditions and return to work options.
The.ule should be stated with a provision such as"...If an employer wishef to rehire..."
8.
The logistics of tuting all employees on site presents an administrati nightmare.
This strs tegy would be burdensome, expensive and difficult to ve administer.
9.
Rancho Seco finds the t roposed education program on drug effects interesting.
A Compan) handbook is provided discussing this particular issue, and the FF0 policy is discussed at employee orientation 19
B1VIEH OF ORUG INFORMATION The use of "impairment" should be deleted.
To presume diminished 1
performance requires an initial standard against which the person is measured.
This very subjective determination should not be defined in the l
rule because there is no agreed upon definition nor is there any scientific /
medical guidance to determine "impairment on the job" for any specific 1
reason.
l STATEMENT I
Rancho Seco agrees that the staff did in excellent job ir. describing the effects of marijuana, cocaine, opiates, phencyclidine, and amphetamines and of citing expert works to support their descriptions. Alcohol should have been l
added to this list.
i 1.
All of the drugs listed have documented effects on the eye, per extensive literature published by Dr. Forrest Tenciant, the Drug Recognition Expert l
program by Los Angeles Police Department, et al.
He have included these references.
1 2.
Drug users exhibit behavorisms that a trained individual can detect and l
assess. He agree with Comissioner Roberts document on page 36797
"...I
]
note that each ene of the categories of drugs to be tested have observable effects."
3.
Drug users exhibit deteriorating work performance that can be evaluated l
through change in work patterns, absenteelsm, accidents, mood swings, l
change in relationship to others in the work place and physical signs of j
use.
INumarc preliminary comments on the NRC proposed FF0 rule.
20 1
I
4.
. Rancho Seco believes that %he above situations can be evaluated using a combination of:
a)
A highly trained medical practitioner or other medical staff b)
A Chemical Dependency medical doctor c)
Input from co-workers / supervisors trained in behavior observation d)
EAP personnel 21
ALTERNATIVES TO URINALYSIS HAIR ANALYSIS Rancho Seco sees this as a useful adjunct to determine whether an employee is drug free once being allowed back on site following evaluation / treatment of a positive drug screen.
The process is expensive, but ir limited situations, could enhance our abilities to monitor those individuals on a surveillance program.
He feel clinical studies show promise of this being a useful tool.
Hair analysis can also be an excellent tool to determine patterns of drug use when assessing individuals for rehabilitation / counselling.
a 0 1111 3 The recent development of a process called "Ocular Kinetics" is of great interest.
A device measures eye movements precisely and objectively and
]
evaluates the information gathered to determine the drug or drugs that the 1
subject may have consumed or used.
1 i
This device could be utilized side-by-side with the MCE practitioner to evaluate the effectiveness of eye movement measurements and could lend further credence to the value of such a process in examining employees for substance j
abuse.
1 22
l I
SECTION IV - BACKG M m0 AND DISCUSSION OF THE l
MEDICAL CLARIFICATION EXAMIl%IlQg The Sacramento Municipal Utility Olstrict (SMUD) and Rancho Seco Nuclear Generating Station augmented its Fitness For Outy (FFD) program in 1986 incorporating the provisions of the available EE1 guidelines, including random urine selection screening.
Random screening, however, was objected to strongly by one Union representing SMUD employees (namely IBEW) and a lawsuit was filed.
Instead of pursuing litigation, the Union and SMUD management returned to the bargaining table and negotiated a solution which could serve as a model for other licensees or utilities.
The major objection was providing a urine sample which was viewed as an unreasonable invasion of privacy when required on a random basis without reasonable cause.
Discussions with the union led to the development of a process which evaluated fitness without the need to provide a urine sample unless fitness of the employee was called into question.
Employte fitness is determined by a medical evaluation called the Medical Clarification Examination (MCE).
SMUD consulted with its Employee Assistance Program counselor (Arlo Thomas, Ph,0,) and two Chemical Dependency Specialists--namely Dr. Forrest Tennant Executive Director, Community Health Projects. Associate Professor, UCLA School of Public Health Drug Advisor, National Football League LA Dogers, Training Consultant, California Dept. of Justice, California Narcotic Addict Evaluation Authority, California Highway Patrol Drug Abuse Advisory Committee, US Food and Drug Administration, and Author of over 175 articles and books on drug dependence.
The other consultant 1.s Dr. Dan Ferrigno, a specialist in Chemical Dependency in clinical and private practice, Professor at California State University and Director of Sutter Chemical Dependency Unit.
23
From extensive discussion, a Medical Clarification Exam (HCE),
i incorporating physiological evaluations of chemical dependency, along with a physical and psychological status examination was developed and approved for use by the Manager, Safety and Loss Prevention Medical staff, Department Managers, area heads, personnel legal advisors, and EAP Ofrectors.
This introspective review gave SMUD/ Rancho Seco an opportunity to focus on an examination evaluating the Fitness for Outy of the WHOLE person.
Thus a true Fitness for Duty program evolved, incorporating review of chemical dependency, physical well being and psychological well being.
THE HCE PROCES$
The HCE establishes evidence of chemical use or dependency by using eye evaluation techniques such as pupil size, pupil reaction to light, the ability of the eyes to converge on an object coming toward the nose and tracking an object vertically or horizontally.
The eye is part of the central nervous system and anatomically located next to the brain.
Any drug which affects the nervous system or brain can almost always produce an influence on the eye.
Since proper eye function requires extremely good precision of very small nerves and muscles, even small doses of drugs can disturb normal physiological processes and produce physical signs.
Hence, the eye is the easiest part of the body to examine for drug 8
influence.
The insividuals skin, nose, and mouth are examined, neurological reflexes are evaluated, and components of the standard field sobriety test are administered.
All body systems are evaluated for drug dependency, diminished physical and mental status.
2"Rapid Eye Test to tect Urug Influence", Forrest Tennant HD, Or P.H.
24
An interviea process is used to elici9 the individual's perception of their health, work, and family issues.
If clues are picked up in this process, more detailed and confronting questions are asked.
The individual's behavior is observed.
The examiner has access to medical records, and upon notifying the supervisor of the notification to his employee to appear for Fitness for Duty MCE, the axaminer and supervisor can discuss concerns the supervisor may have about this employee.
The medical record gives information regarding number of accidents on-site, frequency of illnesses and other related medical information.
In addition, the examiner confers with the on-site medical staff to ask for additional information, if available.
The decision to use Dr. Tennant's format in Rapid Eye Testing (RET) came after a careful examination of the many clinical reports documenting the principal effects that the commonly abused drugs produce on the eye. He include his referenct material taken from one of many books he has pubitshed "Rapid Eye Test to Oetect Orug Influence".
He also include two studies to test for accuracy and reliability.
In one study, two experienced nurses performed eye ex ninations on 79 patients who were consecutively admitted to Dr. Tennant's treatment clinic between March and July 1987.
A positive Rapid Cye Test (RET) proved to be quite reliable (83%) in predicting that a drug was in the urine.
In the second study, 20 consecutive patients with a positive eye test were screened by urine test for opiates, benzodiazepines, cocaine, marijuana, PCP, amphetamines, alcohol, phenylpropanoline (PPA) and ephedrine.
A total of 17 (85%) showed one or more drugs in the urine.
Af ter debating the limitations of random drug testing and the limitations of the Rapid Eye Test (RET), SHUD elected to hi.e a nurse practitioner with extensive education and experience in chemical dependency assessment.
She participated in an extensive training with Dr. Tennant at his clinic in Los Angeles.
In addition, she partidpated in the Drug Recognition Expert Program (DRE) which was deeloped by the Los Angeles Polica Department utilizing Dr. Tennant as a training consultant.
25
The Drug Recognition Expert Program tas discussed in the Reviea of Technical Issues NUREG/CR-S227, itt:$ !.J..
- .les 5-23 to 5-27.
The practitioner examines five co o, ar "ical-access badged individuals per day, choosing randomly selected,a ssunel from a computer software program.
Input into the program is updated weekly from the Security list of badged vital acces; area employees.
The practitioner originally worked one day per week with the view of testing 30% of the population.
It was theorized that in a three year period, all individuals would be tested on-site. Management elected to increase her i
work schedule to four days per week and she can perform 5 to 8 HCEs per day, depending on iune and i;5ce.
Thus 20 to 28 employees are examined per week.
This would be 1040 to 1400 exams per year.
There are currently 1563 vital-acces.1 badged employees on-site, and 89.6% employees would be tested in one caler.dar year.
l When the MCE program was reviewed, Rancho Seco had not collected l
sufficient data to establish the effectiveness of the HCE approach.
In the NRC's review on page 36808 of the Federal Register, its comments that the intent of our program "...to establish a basis for the collection and testing of urine" is not accurate.
I The process of the MCE as described in the Federal Register is essentially correct and requires no further comment.
1 The statement that there has been a relatively low rate of testing, and of those few actually submitting urine specimens for testing, having less than one half test positive is also not accurate. He feel this was analy:ed out of context and without knowing the total situation or rationale, l
The following is the performar e data collected from the HCE process, in all three areas of assessment, as this is the intent of this program.
(1) Chemical use or dependency 1
(2)
Physical well being (3) Psychological well being 26
MCE RESULTS
}
April 1987 to August 1988 f
SMUD employees at Rancho Seco Contractort i
Total MCEs done 292 218 Opthanology referrals 1.4%
1.4%
Medical referrals 13%
14.6%
Dental referrals 6%
0%
EAP referrals 15%
6.4%
Chemical Dependency self 4%
3.2%
Specialist referrals spouse 1%
0.9%
Drug related referrals "Alanon" "Adult chlid of Alcoholics" "Tough Love" 3.8%
4.1%
Self referrals to MCE 1%
0%
Ftitures of Rapid Eye Test (RET) 3%
1.4%
'Of the failures. 50% of those failed refused to submit to urinalysis and were terminated or they resigned. No further data could be obtained. Of the remaining tested. 1.3% tested positive for drugs after submittirg to urinalysis and confirmation was obtained by GC/MS.
This is in keeping with the 1% positive drug screen results which utilities that have random testing programs have experienced. We note that the 00T has tested 720 employees and 0.6% tested positive, page 3:2 Technical Issues.
27
Of those tho had positive Rapid Eye Test (RET) but tested negative for drugs, one was subsequently picked up on a "for cause" 1ssus, another had medical referrals for acute glaucoma (which was picked up by the RET) and another was taking medication for a disease that he did not want anyone to know of.
It was subsequently confirmed by a pharmacist that this medication dilates the pupil and makes it slow to respond to light, l
1 l
28
ADVANTAGES OF THE HCE PROCESS 1.
The HCE is a truly random process and by virtue of this, acts as a deterrent and a detector of substsnce abuse.
~
2.
The process is accepted by unions and employees.
3.
Rancho Seco has on-site an experienced practitioner who can act as a I
resource person in "for cause" assessment.
4.
The data shows that the intant of the HCE process, to examine FF0 in three areas, chemical use or dependencj, physical well being and psychologiesi well being has been successful and fits into the NRC's "General Performance Objectives."
5.
Based on the number of referrels made and the number o' failed Rapid Eye Tests, their disposition and folicw-up, Rancho Seco concludes that an experienced medical evaluator administering random MCEs has a higher probability of 1) detecting recent drug use, 2) evaluating early drug abuse, and by 3) her very presence on-site acts as a deterrent, as well as a detector of drug abuse.
6.
It is not a. ways possible to find drugs in the urine even though the drug may have been taken.
Drugs do not reach the urine for 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. A positive eye test can occur within 15 minutes af ter sniffing, inhaling or injecting a drug.
By utilizing neurological assessment via standard field sobriety testing, drug use can further be assessed and serum levels can be drawn.
7.
HCEs are not infrecuent.
They are administered by a highly trained Chemical Dependency practitioner and therefore Rancho Seco does not believe that the random medical screening alternative would be less effecti a than random urine drug testing at detecting and deterring drug use.
29
DISADVANTAGES Of.THE HCE PROCESS PARTICULARLY USE OF RAPID EYE TEST (RET) 1.
Rapid Eye Testing (RET) only detects abnorcal eye functions and sicas.
There are certain medict) and genetic conditions that can produce one or mors ibnormal eye signs. A trained medical practitioner would be required to assess this.
2.
The RET detects drug influence, but not the degree of influence.
]
3.
The RET can quite reliably determine the presence of drug influence, but cannot precisely determine which drug is causing the observed effect(s).
Various dosages, geneti. factors, drug combinations, and tolerance may all alter classic eye signs.
)
4.
Chronic users, including some severely addicted individuals may develop tolerance to the effects of drugs, and therefore, the eyes will not always react to the RET in a predictable way.
j 5
Some specific reasons for positive RET and negative urine tests include:
(a) A urine specimen is taken too soon after the drug is consumed.
)
(b)
The sensitivity of the urine test is too high.
l (c) A drug (s) is consumed which is not tested for.
2 (d) A collection, contamination or testing error is made, i
i 1
30
I-APPENDIX ST'!DY NUMBER ONE Accuracy and Reliability of RET g
Between Maren and July.1987 new pat:ents were a m:"ed to me 3
author's treatment chn:c One of two tra:nec nurses c.d a P.ET on eacn pat:ent A pos:tne RET was cons:dered to ce present f cnter:a met those ::stec in the section ent:*!ed. ^Cntena for a Pos:tne RETJ : e two c: more posene signs present Twenty n:ne C9. 36 7% had a posttne RET A unne test for one drug was core on eacn sub:ect Tre drug se:ected for tesung was cased on the drug tne pat ent reported to be us ng as weil as the nurse's iudgme The onmars drugs reponed to be used,ncludea cocaine. nanhuana. pnencici:d:ne IPCP) or amphetamines Heroin and a':conol were not reported to be a pnmarv drug problem by any of these sub:ects Pat:ents reponed their !ast use of drug to be from sa hours to several days pnor to RET a:.d unne 8
col'ect:en Unne anal,sts was done by Polanzed Fluorescent Immunoassay : Abbot TDX' l-TABLE Positive RET and Presence of Suspected Drug in Urine Drug Found in Urine Yes No Totals POSITIVE RET 24 5
29 NEGATIVE RET 24 26 50 TOTALS 43 31 79 SENSITIVITY OF TEST = Propon:en of post.ve unne tests which had a posit:ve RET 50 (50 OM
=
SPECIFICITY OF TEST = Prepon:en of negatne unr;e tests wh:ch had a negatwe RET S39 'S3 9 M
=
I 1
Predict:ve \\'
"e of a Propen:en of pos:ne RETs A
Pos;t ve RET ccrrect:y pretetec F
527 d2 7%
=
Pred:ctne Value of a Prcpon:en cf egaine RET s Negative RET correct:y pred:cted l
5204520 M "o
=
33 I'
~
d
l i
COMMENTS Th s stucy snows that the RET. when pos:tne. :s h:ghly suggest ve of drug mfluence The pred:ctabity of a pos::ve test was cser 50%. anc :t hke:y wouid hase been h:gher :f more than one crug had tea tested m the unne RET has a n:gh specie.ty c
~
cr a low rate of false pos:t:ves Put another way. the -resence of a d
pos:t:ve RET procably represents drug influence Unfortunately.
the RET.s not sery sens:t;ve in persons who are quite to erant to drugs In th:s study. oniv 50% of the persons w;th drugs :n the:r unne had a posit:ve RET Th:s :s hke;y because sub:ects here were chen to erant to drugs or had ceased use long before the RET was done Drugs can be found in utme for a cons;deracle pened aner tne ese signs have d:sappeared APPENDIX e
STUDY NUMBER TWO Eye Signs and Urine Test Results in a Group of Drug influence Cases In creer to prcede actual examp:es of the RET. 20 drug users wno viended the autner s c:;n:c on August 13 and 14.1987 and who snowed a pes;t:se RET are hsted here. The e
. for a pos;tive RET i
are mese gr.en :n tne sect;en ent:tled. "Cnte. tor a Pos;tne RET." t e two er mere s gns cresent Once the sub;act showed a pos:tne RET. an ceser.ed unne spee: men was cc.:ected and ana:szed fer ad of tne drugs at !be sens.t:v.t:es ;:stec :n the Tab:e entit:ed "Recommended Drugs to be Unne Tested to Conf:rm RET ' Urne samp:es were analyzed by Pehrzed F!acrescent !mr unaassay (Abbet TDX'1 and tn:n laser enromatograpn, Tex:. Lab ! '
M ale /
Eve Signs Drugs No. Initials female Found By RET fn Urine 1
DH F
Non.cen.ergence Y ar tuana m etabei.te 8
N>sta;mus 123 ng m l
2 DJ F
5:cw sup:. react t.
A:cenol 47 6 mg c:
Non cen.er;ence Egneanne N,m;mus
$;cw cor ea, nefex 3:
h I
O
_ _ _ _ =.. _.. -
i Male /
Eye Stans Lruge No. Initiale Female Found By RET in. Jrine l
3 DG F
Pupd 5:ze 2 S mm Manhuana i setabchte.
Red sclera 77 ng ml l
Slow pupd reaction Amphetamm e.
Non convergence 90 ng ml Coca:ne metacchte.
Nystagmus l
5:ow corneal ref:ex oser 5000 ng mi None Found 4
MB M
Pup::s non reactive Nystagmus Non convergence None Found 5
MN F
Glaz:ng Nystagmus Non convergance 6
LR F
Pupd s ze 2 5 mm Manhuana metabohte; 92 ng/ mi t
Non convergence Benzod azepines.
Nystagmus Stow corneal refex 81 ng ml Cocaine metabohte.
850 nge m!
PCP.186 nge ml Benzodiazepines; 7
AR M
Nystagmus Non convergence 54 ngi m!
Manhuana metabohte; l
8 AW M
Pupd size 2.0 mm 138 ng/ ml Pupa non react:ve Benzodiazepines; Nystagmus 520 ngim!
9 JO M
S:ow react;ng pupd Manhuana metabchte; l
141 ng/ml Nystagmus j
Cocame metaboFte; Non convergence Abuat corneal reflex 1540 ng/m!
Op:cids; over 1000 ng mi i
)
10.
RO F
Puptl s:ze 6 5 mrn Cocai.te metabohte; l
Slow react:ng pupil oser 5000 ng ml Son convergence Opto:ds.
~ -
Slow cornea, reilex 500 ng ml G;az ng 11 KW M
Pupd stre 2 5 mm Manhuana metabohte.
Slow reacnng pupd 137 ng ml l
Op;o:ds Nystagmus oser 1000 ng ml
\\
35 i
s i
i h
I a
6 o'
I r*v-r- -
.sm--e~w-vosw-=
~-
I1 Male /
Eye Signe Druge No. Initiale Female In Urine 12.
JP M
Slow react:ng puptl PCP. 41 ng ml Nystagmus Mar:huana metacchte.
~
Non consergence oser 150 ng ml 13.
OF F
G'az:ng Manhuana metabohte:
Warenng over 150 ng, mi Nystagmus Non consergence Slow corneal ref!ex 14 WC M
Droopy eyehd Benzod:azepines:
l Stow reacting pupil 132 ng/ m.
Nystagmus Coca:ne metabohte:
Slow corneal reflex over 5000 ng, ml Is DF M
Slow react:ng pupil Manhuana metabohte:
e Nystagmus over 150 ng/ml Coca:ne metabohte:
over 5000 ngiml 16 RG M
Pupil sue 2 0 mm Opioids; i
Non react:se pup:1 over 1000 ngeml Nystagmus
{
17.
TR M
Pupil size 6 5 mm Manbuana metabohte:
i Nystagmus over 150 ng/ml Non convergence l
18 CB M
Pupil sue 3.0 mm Amphetamines:
Nystagmus 70 ngeml j
Manhuana metabohte:
106 ngemi Alcohol: 34 mg/dl Cpioids:
oser 1000 ng/ml 19 TE M
Pupils slow react:ng None Found Nystagmus Non convergence 20.
MF F
Pupil slow reacnng Man! uana metaechte l
Nystagmus 11 ng ml l
~
~
COMMENTS This study shows the w,de vanety of eye s:gns and drugs that may produce them Three of 20115 0% of these sue ects showed no drugs in unne. This b' ely represents the taking cf drugs which weren't tested n
for. laboratory error, and/or the coUect:cn of the unne specimen before enough drug had time to enter the ur:ne i
36 i
i 9
{
4 I
Il
.=
l REFERENCES
\\
I l
M Treat-ert of Ac.te Co; Atuw React :es Pe Meses, terre.
l 1
A:ra me* >c
- os7 Sept 11 29 s3-se ven.aaa E~eers en s.r e Akeroi aa
Adams AJ Bre*n G. F'ern MC et a A~er J Ocrem P%s o Opt 1975 52 720 735 2
P:s t'oa a. Nsrag s r Van D.r ag
.La, acwt,
Ascran G Bergsteet M Gocerg L et atQ/ Sr a A co e IMe l' 3904,5 3
i rd Aer A,coroi leton.caron Ascean G Bergvect M. Gocerg L pe EHect :t k-e Aa trame Drugs on l
3 56 140 70 90 4
P s t.cra. A,cenci Nota;m s Acts Cro-Lnesor S rp.The Irhenc l
I 3eaer MB O Bren FH N,va; ws A= J Orthamei 1946 2915411%2 Ider eg T res of Dr g triewat.or 2 ;e ow GE B ekei %K R: acre.lO et a:
Ptoces res n Har+s L5 et, e
A Laeoratorv E.a. vat en of sweet Examnata hoc e~s of Dm; Deceacence 1945 NDA Rese1*cs Moeograpn si Sa o se tre on Drug Abuse. RxkWe Mar.nnat 19% o 441 Bsn R Jano* P Barasn P et si Biood Conceatrat:oe anc P%scogj Aner Ptrarasai Appucit:on in Man in Einwood EH Kc.eev MM 1esu m Press NY 1977 pp d29 645 rd Ot ce Scmworu pia cem M vergeace and Accommocaton. V1 T c
Cohen M M 1069 91 515-525
+
Et a,oi on t e AC A Rato Arce Oreo. mot Edd, SB Ho*es HA Sr.c es of Memnine. CMere ano The: De Voc ac etW and D acetsimorynre and tre.t H,crogenated Dens 4
i No-oco, Erp Pe op 1935 53 430-439 Saevets B-r J Cptho-o og>
Els CJK The Pupa.ary L.g-t Refes in Norma:
13 WC e5 754 759Parner KD. Wrgne JA. et si Actons and Metadoism o per Eden HW Admastered h Connnvoys intrasenous Inksion to Man Cin Phomeco 11 E rect AG Heary GL Ma. ken CF The Uncoesc;ous Fnent Pa 1971 12 606 614 J
- 2 Sect R71 Feswr H Nash TL Van Horn GD et aJ Use of Mec EMeet un Es 1954 09 443 451
' 13 Ana gate Drugs :n Man A ea lar F*omoced>a i
Fraser MF. Iste1 H Pare scok tv a d Add < ton L semty of D( and
\\
a
- 4
?
caere BWi hreete 10o0 12 914 Fisc*o ot, G:4*a'er SD Fs,cnobg ca. S qnicance of Pm:ary Mosemeat l
l 15 SW 1972. '7 340 355 H -me seaca CK Stat es d Cena n Adicton Characte memaire-D iDesmcma ne ) et
- o N D:.t,crMesess
+erenre i Paramer; nan i Memuc 4creror:ree c Descode ae l ad
'e>
C -,crecesowcoce e C 1 Ava sco! Erp Pe ep 1939 e7 239 249 11 Stad es of l
' v t: en '
Accreas HL Sd es on Cc4sre Adtcton e
H race stacn CK Leo 194115311 PA,ua, Oe:va:eace on C:de ce Ps"e Hes em Rep H 3;an RE G wart, 23 Pe Re arcai o Be *ee, Tca c Vergeac 1995 5 43 51 l
Oca.c-otor hess Meec es Er aaoi Crias - c /%So< C:tof v
- 4 j
'etartei CE Verces K D sxs t ca 9
H 2*-sco< Per 1C3 13 923 930 Dcie C' a F6 hirso CR Mar.n AR Esa e a of a Sea F c':vapa c Yve4 'er Aswi 1 % 7 4 271 272 20 P pi D ameters Cu Fa e2c> DeeCW et a Hg en Repen hem iae NCA i
c Jas rw CR Cr, LJ. Gerxe 2%
Add cron Ceater PCP St.:es r Hrs L5 es F>e <*s e 21 i
6 D79 YDA Fenesech Waogesea 17 Scors.;re ta e on Cw; Ab M ar, and 19 M cp ol 64 Jan $$4 MP P 01 S ee aas E"es A Crtes Re, ea ci me Uerstare s e<e p
g 22 1973 14 311 329 1%0 Can Psic^oog>
-37 i
l I
\\
e l
A I
i i
1 e
1 e
j t
= - -
s i REFERENCES (Continued) 23 lawa c JJ E sen-am MW SArer CR et a. Cxa ae P'ai a C:aceana c-Re 4 en n F%s oopa4 aas 5.t ectae EMects se eace 1976 2C2 227 229 24 Kav DC Gorocetzn CW Maren %R Comparatae Edees cf C.ce ce aa:
M7n.a t e Ma9 J E'Or*ocor Erp T*e'201967 % l010 ;O;t 25 Lasara 1 Beverer HK The Ara;gesc EHectstaes of Coce ce aa: Yece - ce
- +
Ce ered i s Ph:r-sco, Era Therop 1954 112 3 %
1 24 L.dsaw A Kamerem G Seen 5 Pupu'ari React.oas *o s a; e L ;nt Pa ses.n j
Pisen a rc Pat ems ans Nor-a s J Neev Meat D s 1973 ;53 3io 291 27 L:weaste e O L:e* ente d i E:ectt:me PapJogream, A,ca Opra -o,1054 59 352 3u3 29 Mar n %R F sser. HF A Correarane 5ruds of P5s4co;cai sac 5.e vene E"vets cf Hero >n aad Meromre Adme stereo Imraseacus.s - P:5. a:: es J FAer-ocon Exp The op 1961. 133 386 399
~
21 McCar on MM Scrwue BW Thomp%n GA et si Acute P'eec',c. s ae Hein caten !ac cence of C;n<a. F nemqs in 1000 Cases Aen E-c.g Yes 1992 10 237 242 Edeet of Marr aae Upen Perpaera:
30 Messortz H Spar-a 5 McG;othn W u
V s.on as a Fs cton of the laf treat,on Prxess.ng De-aeds 1n Centra V s on a
Percept Motoa 5=fs 1972. 35 $75-982 31
%rt BG Jasmw DR Coraparson of Ir.trasenouuv Adem steres Methasore Moronme Heren and P:aceoo Fed P*oe 1973. 32 693 32 Safram AB Wa ser A A:th A et a: Infuence of Centra! Depressant Cogs on P pd Fune:on An Es a,uaton % ;th the Papa C,c.e le d acton Test Oprea mo cyca 1991. 193 214 219 33 sagares MJ Screening for Straesmus and Ame,opta Er>< P se tore,1992 Apnl 19 23 34 Stap;eton JM G tbre 5 Lnnoda M E"ecs of Akohol sad Otrer Pivchotrepic j
Drugs on Ese Mosements Re:evance to Trat9 Saferv J Stud A;comod 1956 47 426 432 35 5te amarn WC. Mistein ME. 5-ncia.e SH. Pupd:ary DCaron W th Trop < amide 1 % for Fundascemc screening A Study of Duranon of Auon Aan Irrern Med 19 % 107 151 154 16 5 ass ran EF Ts.aras. WG Seper KA Dagnos of D:atec Ese Disease JAMA 19 % 247 3231-3234 37 Temaart F5 Jr P%ereghd re PCP) Add eton Veract lac. West Cevra. C4Lf.
1956 38 Teer' ant FS Jr. Taner A Seecof B Cxame P!asma Concentraeons n Perseas A d m..t'e d to Ovparant T eatmect Reianorin p to Treatment Outecere
/ S.bst ace Abse Treatmear 19R 3 27 32 39 Tearact FS Jr Ident+,,ng tre Marh;aae User T$e N2*e C?ce 1966 May-J.re 43 72 40 Treiss KH Eb sce% AA. APerae W et a Cegree et To:erance aad tse Re:at.ces* ; Between P'as-a M rpm.re Ccree-trarce sad *e Pupd (>ameter g
Focoreg irns.eacus Hero'n a Man Ba J F"2
- e 1973 5 294 303 41 Ver-a SP N;s as a Ca.se cf F ies Dated Po s Acer Res.sc
- aron JAMA 19 % 255 3251 42 Wagn an iH Nessasen LM t%eace of Heas N ef %5 te L ee Upon Pol
-b Cnamver et te Human aas A re Rate t Soc Espe B or 2-d Med 1442 44 46e 470 43 Wa:ser A Sa'ren AB Seu P et a. E"ects of 5 a.1 D:ses of Br:~atepam on
(
Pupt.:4 v F act on aas en F'oer Pccept on a Neresi 5.5 ects J C' a Ps,c o-a paa,-:co,1967.7 59 VJ t
44 Wererman $T. Geir A Kemerewm F5 et al Q.a tane Vens re eat of Dews g.
k L2r,agesceev 1944 94 165 170 3S-1 I
3a r
4 l
L
\\
b
. -m.--
{
OTHER HANDBOCKS. MONOGRAPHS AND VIDEO TAFES AVAILABLE M
By Forest Tennant, bl.D. Dr. P.H.
HANDBOOKS / MONOGRAPHS IDENTIFYING THE HEROIN USER IDENTIFYING THE PCP USER IDENTIFYING THE COCAINE USER IDENTIFYING THE SfARIHUANA USER HOW TO IDENTIFY. PREVENT AND GUIDE TREATbfEhT OF DRUG ABUSE BY YOUTH PAREhTS GUIDE TO URINE TESTING PRlbfER ON THE NEUROCHEbflSTRY OF DRUG DEPENDENCE I
POST DRUG lbfPAIRbfEhT SYNDRObfE IDENTIFYING DRUG USERS IN THE WORKPLACE t
l VIDEO TAPES ACHIEVE Sf0RE MTTH BETTER BRAIN CHEbflSTRY g
HOW TO RECOGNIZE THE PHYSICAL SIGNS OF DRUG ABUSE SfEDICAL AND LEGAL IDEhTIFICATION OF DRUG USE l
l l
k For in:orrnat'en on c' ta:n ng these and other rnatena's contact.
e VERACT. INC 338 South Giendera Asenue W
I West Conna. Catfern:a 91790 1 800 624 4540 i
1 :00-8210775 iCA) f i,
I w
e
/
~
f 6
9 i
I
.