U.S. Department Prescription and Over-the-Counter Of Transportation Federal Transit Medications Tool Kit Administration Office of Safety and Security April 2011 Table of Contents TABLE OF CONTENTS Section Page Disclaimer 1 Introduction 2 How to Use this Toolkit 5 I. Rx/OTC Medication Overview and List of Commonly Used Rx/OTC Medications I‐1 II. Rx/OTC Medication Policies and Procedures II‐1 III. Accident Investigation Procedures III‐1 IV. Forms IV‐1 V. Training V‐1 VI. Resources VI‐1 Appendices Summary Table of Best Practices 1 Frequently Asked Questions 2 OTC Medications with Alcohol 6 Table of Contents FTA Prescription/Over­the­Counter Medication Toolkit Page i Disclaimer DISCLAIMER The policies, procedures, and other information contained in this Prescription and Over‐ the‐Counter (Rx/OTC Medications) Toolkit does not constitute Federal Regulation. The content is a presentation of the best practices and model forms and policies being used at various transit systems throughout the U.S. at the writing of this Toolkit. Neither does the information presented reflect the only practices to be followed for the monitoring of Rx/OTC medication use, but rather it should be used as a baseline for a program to be molded to fit the individual needs of each transit system. Sound medical knowledge and understanding of the pharmacological properties of prescription and over‐the‐counter medications, together with detailed knowledge of an employee’s medical history and safety‐sensitive job duties, must guide each transit system’s final assessment of potential risks to the public. This document is draft and confidential. Information contained within is intended only for use by the authors, RLS & Associates, Inc. and the Federal Transit Administration (FTA). If you are not the intended recipient, you are hereby notified that any disclosure, copying, or distribution is strictly prohibited without permission. Thank you. Disclaimer FTA Prescription/Over­the­Counter Medication Toolkit Page 1 Introduction INTRODUCTION In 2000, the National Transportation Safety Alcohol Testing, a regulation, nor a list of Board (NTSB) issued a directive to the approved/not approved medications. As a Federal Transit Administration (FTA) to direct result of the Toolkit, many within the educate transit agencies on the potential transit industry initiated and/or enhanced safety risks associated with the use of their Rx/OTC program by establishing prescription (Rx) and over‐the‐counter (OTC) policies, creating training programs, and medications by employees who perform implementing reporting mechanisms, many safety‐sensitive duties. using the samples contained in the Toolkit. The NTSB directive recommended that all The NTSB applauded FTA for its progress and transit rail agencies require employees in leadership in addressing the safety risks safety‐sensitive positions to inform their posed by the use of Rx/OTC medications in agency about their use of Rx/OTC the transit industry. The NTSB also medications. Knowledge of the employee’s subsequently recommended that the FTA use of medication would provide the transit establish a comprehensive toxicological rail agency with the opportunity to have testing requirement for a sample of fatal qualified medical personnel determine the transit accidents to identify the role played by potential effects of the medicines on common Rx/OTC medications. To meet the employee performance, and to train the NTSB expectation, the FTA would be required employees about their responsibility under to develop a standardized methodology to the agency’s Rx/OTC policy. collect the information on the role that Rx/OTC medications play in transit industry Shortly thereafter, in response to the NTSB fatal accidents and establish a meaningful directive, the FTA issued a challenge to all way to analyze and report the findings. FTA grant recipients to: ♦ Review policies related to employee use of Rx/OTC medications that could potentially compromise public safety; and ♦ Educate transit operators and their safety‐sensitive employees about the risks and potential dangers associated with the use of Rx and OTC medications. Subsequently in 2002, the Federal Transit As a first step in this effort, FTA undertook a Administration (FTA) published the comprehensive assessment of the current Prescription and Over­the­Counter Medication status of Rx/OTC policies within the transit (Rx/OTC) Toolkit as a tool to help educate industry to determine the extent to which transit systems about the potential safety transit systems were collecting and risks associated with Rx/OTC medication use maintaining data regarding the role Rx/OTC by transit system employees. The toolkit medications play in fatal accidents. This contained a collection of policies, procedures, assessment included an extensive data training aids, and post‐accident procedures. gathering and analysis process and the Its purpose was safety and technical national evaluation of policies, procedures, assistance. Its purpose was not Drug and Introduction FTA Prescription/Over­the­Counter Medication Toolkit Page 2 and post‐accident investigations utilized by One‐on‐one interviews were conducted as FTA recipients. part of Step 3. It was through this process that information was gained to guide the A three‐step data collection approach was latter stages of the project. Finally, Step Four, used: a followup of randomly selected accidents as reported through the NTD, was conducted. It 1. Conducting a data search which included was here that much of the data that guided the National Transit Database and any the recommendations of the study was data or research conducted by other gathered. federal agencies, such as the Federal Motor Carrier Safety Administration, In the nearly nine years since the original Federal Aviation Administration, Federal effort, many transit systems have refined and Railroad Administration, etc.; enhanced their Rx/OTC policies and 2. Surveying public transit systems programs as evidenced by the surveys. receiving FTA funding; and Nearly two‐thirds of the participating 3. Conducting one‐on‐one interviews with systems indicated that they do address selected transit systems. Rx/OTC medications as part of their organization’s Substance Abuse Policy. This Into the project, based on the information is a significant finding, on one hand, because that was collected, or not collected, as part of in 2002 transit systems were in the infancy the survey process, it was decided to add a stages of addressing Rx/OTC medications as fourth step to the study: part of their overall Drug and Alcohol Testing Program. However, there are still several 4. Conduct a follow‐up of randomly selected concerns. First, a full one‐third of survey transit accidents as reported via the respondents still do not address Rx/OTC National Transit Database (NTD). medication use as part of their substance abuse awareness program. Second, and Four years of NTD data were studied as part perhaps of even greater concern, further of Step 1, as well as data from the Federal research with the transit systems that do Motor Carrier Safety Administration (FMCSA) address Rx/OTC medication use revealed that via their National Truck Causation Study. the majority actually do nothing with the Step Two included two online questionnaires information they collect. Thus, there is still which provided much of the information much to do to address Rx/OTC medication contained in this toolkit. The first use as it impacts transit system safety. questionnaire solicited information regarding a transit system’s accident investigation This toolkit includes a variety of best procedures, data collection methodologies, practices from those systems and a model and methods used to determine the role Rx/OTC Medication Program that one State Rx/OTC medications play in accidents. The has implemented for its FTA Section 5311 second questionnaire solicited information transit operators. For the transit systems regarding each transit system’s Rx/OTC that have yet to address the use of Rx/OTC policy. medications by safety‐sensitive employees, this Toolkit will serve as a baseline for The information obtained from the 300 plus implementing such a program. It will also be systems that completed the surveys as part of a useful toolk for those transit systems that Step 2 formed the basis for this update of the are currently reviewing their existing Prescription and Over‐the‐Counter (Rx/OTC) programs and can serve to enhance or expand Medication Toolkit. those programs. Introduction FTA Prescription/Over­the­Counter Medication Toolkit Page 3 To read the Final Report of the Prescription and Over‐the‐Counter (Rx/OTC) Medication Study, or obtain additional copies of this Toolkit, contact the FTA Drug and Alcohol Hotline at (617)494‐6336 or via e‐mail to [email protected]. Introduction FTA Prescription/Over­the­Counter Medication Toolkit Page 4 How to Use This Toolkit HOW TO USE THIS TOOLKIT What is the Rx/OTC Toolkit? For example, if a transit system is only beginning to develop its Rx/OTC policy, or is This Toolkit is a compilation of policies, looking to revise its existing policy, the Policies procedures, forms, and training resources that and Procedures Section provides several represent the best practices being used examples of excellent working policies as well throughout the U.S. by a variety of transit as a model policy for “fill in the blank” that is systems. It does not represent all of the currently being used in one state for all of its effective means that transit systems are using FTA Section 5311 transit operators. Use partial to address and monitor Prescription (Rx) and or entire sections of the samples or use them in Over‐the‐Counter (OTC) medication use, but is their entirety as it fits each transit system’s the result of an extensive effort by the Federal needs. The same is true of all Toolkit sections. Transit Administration (FTA) to compile a Whether a transit system is re‐starting from broad range of materials as examples and scratch or simply trying to evaluate or update models.