D-54

• This document outlines the Drug and Alcohol Policy for the Philadelphia Fire Department, aiming to ensure a safe workplace and promote employee health.
• It was issued as directive #54 in October 2014.

Policy and Rationale

• Philadelphia Fire Department is committed to providing a safe working environment, promoting employee health, and ensuring reliable emergency services for citizens.
• The Department aims to maintain a work environment free from the adverse effects of drug and alcohol use.
• The mission of Philadelphia Fire Department is to protect and serve the public.
• Members must be alert, ready, and able to act rationally and professionally, unaffected by drugs or alcohol.
• Public trust is rooted in full confidence in the integrity of Philadelphia's Firefighters and Paramedics.
• The use of drugs or alcohol may affect a member's mental and physical condition.
• The Department mandates full compliance with all provisions set forth in this directive.
• Expected work conduct includes members reporting fit for duty, free from drugs/alcohol or impairing medications, and not posing a hazard to themselves or others.
• Random drug and alcohol testing procedures follow the United States Department of Transportation standards and federal regulations for safety-sensitive positions.

Definitions and Abbreviations

• CLR: Contracted Laboratory Representative
• FCC: Fire Communications Center
• MRO: Medical Review Officer
• SAMHSA: Substance Abuse Mental Health Service Administration
• DHHS: Department of Health and Human Services
• MEU: Medical Examination Unit
• DOT: Department of Transportation
• BAC: Breath Alcohol Concentration
• NLCP: National Laboratory Certification Program
• Accident: An occurrence involving a City of Philadelphia Fire Department vehicle resulting in death, bodily injury requiring immediate medical treatment away from the scene, or disabling vehicle damage.

After Care

• Outpatient follow-up is vital after rehabilitation/treatment to maintain a sober lifestyle.
• Support includes counseling under a Substance Abuse Professional (SAP) and AA/NA or EAP Peer Group sessions.

After Care Contract

• All members in After Care must sign an After Care Contract for continued employment; examples in Appendix #3, #5, and #7.
• The contract typically defines the member's responsibilities during After Care and must be signed before returning to active duty.

Alcohol Level

• Percentage of alcohol by weight/volume in a tested person's blood or breath.

Alcoholics Anonymous (AA)

• Fellowship of men and women sharing experience, strength, and hope to solve their common problem and help others recover from alcoholism.

Chain of Custody

• Departmental procedure where a bonded carrier transports 'POSITIVE' blood, urine, and hair specimens from one testing facility to another, following evidentiary procedures for collection, security, transportation, processing, storage
• Necessary documentation and supplies are provided by testing facilities.

Clear Cut Negative

• A "NEGATIVE" result on a specimen that is not diluted, adulterated, or manipulated, thus medically qualifying a member for duty.

Confirmatory Test

• A second analytical procedure, independent of the initial test, using a different technique/chemical principle to identify drugs, metabolites, or alcohol for reliability and accuracy.

Confirmed Use of Drug and/or Alcohol

• A "POSITIVE" result on a specimen utilizing an initial screening method followed by a confirming test method specified or recommended is considered confirmed use of drug and/or alcohol
• All specimens are subject to the designated chain of custody.

Consent Form – Substance Abuse Testing

• The first form a member signs in an on-duty drug/alcohol incident.
• Failure to cooperate results in a 30-day suspension with intent to dismiss.
• This form, required by law, allows test results to be released to the Department's representative.

Detoxification

• In-patient programs assist members to withdraw from drugs and alcohol in a protective environment.
• Addressing medical problems and education/motivation are part of the recovery phase.

Director of Employee Assistance Program Unit

• Oversees daily Unit activities under the Employee Relations Officer (ERO)’s guidance, coordinating functions and assisting in program development.

Employee Assistance Program (EAP)

• A confidential program offering counseling for emotional, behavioral, and substance abuse issues, staffed by full-time counselors under the ERO's direction, with "back up" counselors available on each platoon
• Supervisors at the Fire Communication Center can make contact.
• A PFD supervisor can request "on call" assigned staff counselor involvement if backup contact fails to resolve situation.
• EAP is at 990 Spring Garden Street Suite 702, staffed Monday, Friday, and Saturday from 0800-1630, and Tuesday, Wednesday, and Thursday from 0800-2130
• Hours may vary by Fire Commissioner decision.
• The EAP telephone number is 215-685-HELP (215-685-4387); off-hours have a recording for instructions.
• The mission is to provide advice, assistance, and support to members and families.

Employee Relations Officer (ERO)

• Officer who supervises Employee Assistance Program Unit goals under direction of the Human Resources Officer.
• Ensures member compliance with After Care Contract provisions and oversees first voluntary disclosures, After Care Contract, and scheduling follow-up testing.

Evidential Breath Test (EBT)

• Measures alcohol concentration in breath.
• Devices must meet NHTSA specifications and be on the “Conforming Products List (CPL).”
• Confirmation tests require printed results in triplicate, a unique number per test, and printing the manufacturer’s name, serial number, and time of test.
• The instrument must differentiate alcohol from acetone at 0.02% concentration, test an air blank, and perform external calibration checks.

Follow-Up Testing

• Happens after reinstatement from voluntary or disciplinary disclosure.
• Confirms alcohol and substance abstinence and is essential for aftercare treatment.
• It may be initiated by SIO or SAP, with SAP or ERO initiating it after the first voluntary disclosure.

Initial Test

• An immunoassay test for controlled substances or an initial breath test yielding results less than 0.02% BAC.
• Eliminates 'NEGATIVE' urine or breath specimens from further testing.

Joint Drug and Alcohol Committee

• Fire Department and Local 22 members review Directive 54 implementation, interpretation, and modification, and is comprised of representatives from Human Resources, Special Investigations Officer, Local 22 (up to four representatives), Employee Relations Officer/Employee Assistance Program, Medical Review Officer, Technical Expert, and one additional person designated by the Fire Commissioner.

Mandatory Rehabilitation Program Evaluation

• Required for continued employment after drug or alcohol incidents, except for documented SAP recommendations.
• A rehabilitation program may include detoxification and/or in-house treatment at a professional facility, along with a mandatory After Care Program.

Medically Unqualified

• A determination made by the Medical Review Officer of the Medical Evaluation Unit indicating a clear "NEGATIVE" result was not established per this Directive or Joint Drug and Alcohol Committee, precluding active duty.

Narcotics Anonymous (NA)

• Fellowship sharing experience, strength, hope to solve problems and help others recover from addiction.

Onsite Testing

• Testing at a Fire/City facility.
• Certified breath alcohol technician (BAT)/qualified urine specimen collector uses an evidential breath testing device (EBT) or performs a urine specimen collection per 49 CFR Part 40.

Peer Group Counseling

• EAP counseling program sponsored, maintained, and operated by Philadelphia Firefighters and Paramedics, part of a member's required After Care plan.
• Staffed by Firefighters and Paramedics with training, skills, and collaboration with related professional organizations.

"Positive" Test Result

• A drug test exceeding established cut-off levels.
• An alcohol test that has an alcohol level over 0.02% or higher.
• Random testing levels include:
  • “STAGE 1 POSITIVE”: 0.02% to 0.039% alcohol level.
  • “STAGE 2 POSITIVE”: 0.04% or higher alcohol level.

Rehabilitation

• Inpatient or outpatient experience involves learning about the effects of drug and alcohol abuse and dealing with the problems.
• An outpatient program provides support systems to help in a successful return to daily life; intensive counseling is also provided.

Return to Duty

• Firefighters and paramedics in safety sensitive positions need documentation treatment facility and/or SAP MRO approval to return to duty
• A member reports to the Medical Evaluation Unit with required documents after voluntary disclosure.
• A medical evaluation must be administered by the Medical Evaluation Unit, and they must have a negative drug/alcohol test.
• Test result delays will be reviewed by the SIO when test results exceed 72 hours of delay.

Special Investigations Officer (SIO)

• The Chief Officer, under the Fire Commissioner, ensures that all parts of the drug/alcohol policy are carried out, becomes actively involved in disciplinary matters.

Substance Abuse Agreement

• The second form a member signs outlines responsibilities en-route to recovery following a drug/alcohol disciplinary process or voluntary disclosure
• Must be signed when free from drug/alcohol effects and adhere to all provisions, usually done upon release from detoxification.

Substance Abuse Professional (SAP)

• Trained/experienced in treating drug and alcohol dependence per federal regulations 49 CFR Part 40 Subpart O.
• Authority to recommend follow-up testing up to 60 months.
• Those choosing SAP evaluation must be evaluated within five business days voluntarily or due to disciplinary reasons.
• The initial evaluating substance abuse professional is the SAP. The declaration must be chosen within 48 hours of disclosure, must be sent to the EAP, ERO or SIO.
• Those undergoing evaluation must comply with SAP recommendations, requiring initial/subsequent evaluations by the SAP for compliance and documentation to the Department's SIO.
• A written report will be sent to the SIO by the SAP within seven calendar days after initial evaluation via fax, email, and/or certified mail. The ERO will oversee first voluntary disclosures.
• Members choosing SAP do so at their own expense.

Responsibilities: Members

• All members of the Philadelphia Fire Department are responsible for their physical/mental condition and must keep their performance free from adverse effects of drug/alcohol abuse.
• Each member is responsible for familiarizing themselves with this directive.
• All members adhere to confidentiality regarding testing and reporting, with results shared only with authorized personnel.
• Breaching confidentiality may result in discipline.
• Members selecting SAP evaluation bear the costs for SAP evaluation following a positive test.

Required Member Actions

• Consent to testing, sign the consent form, with a photo ID.
• Conduct themselves in an acceptable, non-threatening, cooperative manner.
• 'POSITIVE' tests mean members MUST comply with Section 5.2 and the After Care Program.
• Members MUST follow the Department's Substance Abuse Agreement/SAP recommendations at the earliest possible time.
• This often occurs upon release from detox or after consulting with SAP.
• Before returning to active duty, members MUST sign After-Care Contract/written SAP letterhead documentation showing recommendations and follow up testing frequency/number.
• Member failure to comply with mandatory employment conditions results in immediate dismissal proceedings.
• If the Department learns a member tests 'POSITIVE' for Schedule A controlled substances and there was no medical reason they did not report it, it will be classified as disciplinary disclosure with consequences in Section 5.2.

Responsibilities: Company Officers

• Company Officers must check that all members are fit to duty; provisions of this directive should be followed if members are believed to be unfit.

Responsibilities: Battalion Chiefs & Deputy Chiefs

• Three options for non-routine testing when responding to a fire:
  • Request an onsite collector Breath Alcohol Technician to conduct testing.
  • Transport member to Medical Evaluation Unit.
  • Transport member to contracted medical facility.
• Based on location, time of day, and other factors, the most efficient and productive process is done.
• If a test is deemed necessary by a deputy chief, the deputy chief must request it and both tests will be performed.
• The battalion chief will not have input into the testing procedure.

Responsibilities: Prescription Medications

• It's each member's responsibility to tell their doctor their duties and that this effects their sensitive position as a firefighers/paramedic.
• Members self report to the City's Medical Review Officer no later than their return to duty by notifying personnel if they were perscribed an opiate or benzodiazépines (anti-anziety).
• Members must present an appendix confirming knoledge and dosage will not pose a safety risk.
• Validity of medications is determined by if perscriptions were issued within the pasttwelve months.
• Failure to disclose any drugs will result in dissapline, but test results will be reviewed by MRO before any dissapline happens.

General Information: Enforcement

• Disciplinary action will be taken against a PFD member that is found to use illegal drugs, abuse controlled substances, or refuses to test; will be immeditaley suspended for for 160 hours.
• As a condition of continuted employment each member who has a first “POSITIVE” drug test must enroll in an after care program.

General Information: Voluntary Disclosures

• The Department recommends employees to share any substance abuse problems and look for care.
• This is made according to Directive 5.
• Employees are allowed to use their accrued paid time while getting treatment if they voluntarily declaired they needed it.
• Notify EAP ot ERO that they are making a first report.
• Inform that they will be out sic.
• If this happens during duyt the company officer will remove the member and notfiy chief, and get in touch with EAP.
• The declartion must be made beforhe anything related has been started.
• if a member has sought help to their probelms without sharing, it will be regarded as a voluntary share at the conclusion of Directiv 5.2.

Two Voluntary Disclosures

Mandatory After Care Contrat Program is required and may be extended for a max of of 18 months increments of 2 months.

• They will have an assessment, and this declairation is effective in decreaing alochol/substance abuse.
• They will be assesed by SAP.
• They member that choose SAP have 48hours after declaring they had a problem.
• If positive for drugs of alcohol during the intial volunatry period its a “relapse voluntary disclosure.
• This happens automatically during the intital six months after care contrat, whcih resets to 15months.

###Testing levels

• during scheduled physical checks, drug/alcohol screening is done
• BAC, Urinalysis, and or hair tests, may be ordered - any hormone is considvered a steroid.
• S hedule A and B dont incorperate every drug.
• The medication are chosen are by the communitys usage and how each one effects the memebrs.
• Comittes need to contact Local # 22.

Cut-off parameters

• Testostrone will be regareed as “POSITIVE.” T
• Test results will be evaluated and reviewed by the MRO

Routine Testing

• When a member has had 4 routines/ or non routine, positive tests for drug abuse Commanding Officers are requred to go though a "Fitness for Duty Assessment

Non-Routine Testing: Post-Accident

• Philidelphia drivers that had part in the incident with humans or serious veichle damage test right away.
• testing isnt auto placed when pending posy acicident tests.
• Most testing will happen while the Batallion Chief is there during the first check.