ML23181A103
| ML23181A103 | |
| Person / Time | |
|---|---|
| Issue date: | 07/13/2023 |
| From: | Brian Zaleski NRC/NSIR/DPCP/RSB |
| To: | |
| References | |
| ML23181A091 | |
| Download: ML23181A103 (1) | |
Text
Presentation to the Nuclear Energy Institutes Access Authorization and Fitness for Duty Workshop Fitness for Duty (FFD) Programs - 10 CFR Part 26 FFD Performance and Trends July 13, 2023
FFD Program Performance and Trends Slide 2 Note: All 2022 FFD Program Performance results are DRAFT
FFD Program Performance Results, 2018-2022
- Positive = Positive drug and alcohol tests, adulterated and substituted validity test results, and refusals to test All results in presentation are MRO verified Slide 3 2018 2019 2020 2021 2022 Number of Facilities Reporting 71 70 70 69 64 Individuals Tested 145,797 131,417 124,678 114,150 111,854 Individuals Testing Positive*
1,187 1,085 1,048 1,112 1,082 Identified at Pre-access Testing 69.6%
67.3%
67.4%
66.5%
70.3%
Identified at Random Testing 17.8%
21.8%
22.7%
24.8%
20.4%
Pre-Access Testing Positive Rates 1.02%
1.03%
1.01%
1.17%
1.20%
Licensee Employee 0.43%
0.44%
0.38%
0.64%
0.85%
Contractors/Vendors 1.08%
1.10%
1.08%
1.17%
1.26%
Random Testing Positive Rates 0.37%
0.45%
0.49%
0.61%
0.52%
Licensee Employees 0.17%
0.19%
0.23%
0.28%
0.31%
Contractors/Vendors 0.68%
0.86%
0.92%
1.15%
0.87%
Average Worker Population 99,569 91,954 89,205 82,512 77,306 Licensee Employees 59,913 56,152 54,190 50,094 46,957 Contractors/Vendors 39,656 35,802 35,015 31,608 30,349
FFD Program Performance Results by Test and Employment Categories, 2022 Slide 4 Tested Positive Percent Positive Tested Positive Percent Positive Tested Positive Percent Positive Pre-Access 9,476 81 0.85%
53,855 680 1.26%
63,331 761 1.20%
70.3%
Random 26,632 82 0.31%
15,908 139 0.87%
42,540 221 0.52%
20.4%
For Cause 66 11 16.67%
150 29 19.33%
216 40 18.52%
3.7%
Post-Event 70 0.00%
171 1
0.58%
241 1
0.41%
0.1%
Followup 2,694 21 0.78%
2,832 38 1.34%
5,526 59 1.07%
5.5%
Total 38,938 195 0.50%
72,916 887 1.22%
111,854 1,082 0.97%
100.0%
Test Category Licensee Employees Contractor/Vendors (C/Vs)
Total
% of Total Positives Test Category Tested Positive Percent Positive Pre-Access 63,331 761 1.20%
Random 42,540 221 0.52%
For Cause 216 40 18.52%
Post-Event 241 1
0.41%
Followup 5,526 59 1.07%
Total 111,854 1,082 0.97%
Pre-Access Testing (1990-2022)
Positive Rates by Employment Category Slide 5 0.95%
Licensee Employees 0.85%
1.54%
Contractor/Vendors 1.26%
0.0%
0.2%
0.4%
0.6%
0.8%
1.0%
1.2%
1.4%
1.6%
1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012 2014 2016 2018 2020 2022 Percent Positive
Pre-Access Testing, 2022 Distribution of Site-Specific Positive Rates by Employment Category Slide 6 34 4
6 7
5 5
7 3
14 22 11 3
3 1
0
> 0% - 0.5%
> 0.5% - 1%
> 1% - 1.5%
> 1.5% - 2%
> 2% - 2.5%
> 2.5% - 3%
> 3% - 3.5%
Number of Sites Percent (%) Positive Rate Licensee Employee (n = 62)
C/V (n = 64)
Random Testing (1990-2022)
Positive Rates by Employment Category Slide 7 Licensee Employees 0.31%
Contractor/Vendors 0.87%
0.0%
0.2%
0.4%
0.6%
0.8%
1.0%
1.2%
1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012 2014 2016 2018 2020 2022 Percent Positive Beginning in 1994, the NRC reduced the minimum annual random testing rate from 100 percent to 50 percent of the subject population
Random Testing (2018-2022)
Distribution of Site-Specific Positive Rates by Employment Category Slide 8 2018 2019 2020 2021 2022 2018 2019 2020 2021 2022 0
29 34 30 25 19 28 35 26 26 25
> 0% - 0.25%
22 17 17 10 13 4
1
> 0.25% - 0.5%
16 15 10 19 16 14 6
6 5
5
> 0.5% - 0.75%
4 3
8 12 12 6
6 8
6 10
> 0.75% - 1%
1 4
1 2
10 6
5 6
6
> 1% - 1.25%
1 5
5 10 7
8
> 1.25% - 1.5%
1 7
3 3
2
> 1.5% - 1.75%
1 1
3 4
5 1
> 1.75% - 2%
1 4
2 2
> 2% - 2.25%
1 2
> 2.25% - 2.5%
1 1
4 1
> 2.5% - 2.75%
1
> 2.75% - 3%
> 3% - 3.25%
1 1
> 3.25% - 3.5%
1
> 3.5% - 3.75%
1 2
> 3.75% - 4%
1
> 4%
1 1
Positive Rate Range (%)
Licensee Employee C/V
Detection Trends - NRC Testing Panel Percentage of Total Positives by Substance Tested Slide 9 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 where no specimen is tested (at least 60% of subversion attempts each year) marijuana cocaine alcohol amphetamines opiates PCP 0.0%
10.0%
20.0%
30.0%
40.0%
50.0%
60.0%
70.0%
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 2018 2019 2020 2021 2022 Percent of Total Positives
Results by Employment Category, 2022 Slide 10 Licensee Employees (38,938 tested, 195 individuals positive)
Contractor/Vendors (72,916 tested, 887 individuals positive)
Marijuana 45.5%
Alcohol 36.5%
Cocaine 5.0%
Refusal to Test 6.0%
Amphetamines 6.5%
Opiates 0.5%
n = 200 Marijuana 53.8%
Alcohol 12.0%
Cocaine 8.3%
Refusal to Test 19.5%
Amphetamines 5.7%
Opiates 0.2%
Other 0.4%
PCP 0.1%
n = 918
Pre-Access and Random Positive Rates - Marijuana Slide 11
Alcohol Positive Results, 2022 Effectiveness of Lower Cutoff Levels Slide 12 31% of alcohol positives due to time-dependent cutoff levels (BAC < 0.04)
Must abstain from alcohol use at least 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> prior to arrival for work 52 42 17 14 10 9
2 7
14 11 2
2 0
10 20 30 40 50 60 70 80 Pre-Access Random For Cause Post-Event Followup 0.04 or greater 0.03 and in work status at least 1 hr 0.02 and in work status at least 2 hrs n = 182 0.04 or greater 125 0.03 and in work status at least 1 hr 28 0.02 and in work status at least 2 hrs 29 n = 182
Results by Labor Category, 2022 Slide 13 0%
20%
40%
60%
80%
100%
Maintenance (general facility)
Facility Support Security Other HP/RP Engineering Maintenance (safety-significant)
Non-Licensed Operator Supervisor Licensed Operator FFD Program Personnel QA/QC SSNM Transporter 388 56 46 20 23 17 17 8
8 1
1 100 16 11 15 5
9 7
6 8
4 1
152 26 3
4 3
2 1
46 5
6 5
1 1
1 64 6
4 1
6 3
2 2
1 Other, 1 PCP, 1 Marijuana Alcohol Refusal to Test Amphetamines Cocaine Opiates Other PCP
Total Substances by Labor Category, 2022 Slide 14 754 109 70 45 35 30 30 17 17 5
1 1
0 Maintenance (general facility)
Facility Support Security Other HP/RP Engineering Maintenance (safety-significant)
Non-Licensed Operator Supervisor Licensed Operator FFD Program Personnel QA/QC SSNM Transporter
Subversion Attempt Trends (2017-2022)
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) 2017 2018 2019 2020 2021 2022 Number of Subversion Attempts 305 298 307 288 272 268 Percentage of Drug Testing Violations 31.9%
31.0%
34.5%
34.3%
29.3%
29.8%
Identified at Pre-access Testing 67.5%
77.5%
73.3%
74.7%
72.4%
79.1%
Committed by Contractor/Vendors 97.7%
95.6%
97.4%
96.2%
94.5%
93.3%
Percentage of Sites Reporting At Least One Subversion 64%
70%
61%
70%
70%
75%
Subversion attempt sanction:
Permanent denial unescorted access, 10 CFR 26.75(b)
Slide 15
Subversion Attempt Trends by Labor Category (2017-2022)
Slide 16 Labor Category 2017 2018 2019 2020 2021 2022 Total Maintenance (general facility) 193 226 255 245 217 211 1,347 Facility Support 17 25 18 17 26 30 133 HP/RP 2
2 2
1 6
6 19 Maintenance (safety-significant) 9 14 10 10 2
5 50 Security 4
4 6
4 9
5 32 Other 77 16 7
6 6
5 117 Engineering 1
2 3
4 3
13 Supervisor 1
7 4
1 3
3 19 Non-Licensed Operator 1
2 3
6 QA/QC 2
2 Grand Total 305 298 307 288 272 268 1,738
Special Analyses Testing of Dilute Specimens 10 CFR 26.163(a)(2)
Slide 17
HHS-Certified Laboratory Performance, 2022 10 CFR 26.719 day event reports 1)
Concentration of marijuana metabolite in a blind performance test sample (BPTS) was not within 30% of the target concentration (February 2022).
Deterioration of the calibrator material resulted in a higher drug concentration.
The specimen was reanalyzed with a new calibrator and the result was within the target concentration.
2)
Concentration of marijuana metabolite in a BPTS was not within 30% of the target concentration (July 2022). The discrepant result was isolated random variability in the assay.
3)
Laboratory did not report test results within 5-business days of receipt, as required by 10 CFR 26.169(a) (February 2022). Delays due to quality control and batch failures that resulted in specimen testing on multiple confirmation batches.
4)
False-negative test result for a BPTS formulated to test positive for an expanded panel opioid (April 2022). An incorrect testing code (i.e., for the standard panel) was entered by the laboratory data entry operator.
Slide 18
HHS-Certified Laboratory Performance, 2022 10 CFR 26.719 day event reports 5)
An HHS-certified laboratory incorrectly sent 15 donor specimens to another one of its HHS-certified laboratories for testing (January 2022). Fourteen specimens were forwarded to the correct laboratory for testing. One specimen had already been tested and was discarded. The laboratory provided incorrect express mail shipping labels for the specimens.
6)
An HHS-certified laboratory incorrectly tested two donor specimens at another one of its HHS-certified laboratories (January 2022). Donor retest requests were made for both specimens, neither was shipped to another HHS-certified laboratory within 1-business day as required by 10 CFR 26.165(b)(5).
For one retest request, the specimen also was sent to the wrong HHS-certified laboratory. No information was provided on why the incorrect laboratory performed initial testing. The same laboratory technician processed the retest requests. High work volume and a data entry error resulted in the processing issues.
Slide 19
NRC FFD Program Staff Slide 20 Office of Nuclear Security and Incident Response Brian Zaleski, Specialist - Fitness For Duty / Access Authorization Brian.Zaleski@nrc.gov (301-287-0638)
Paul Harris, Senior Program Manager Paul.Harris@nrc.gov (301-287-9294)