Presented for: 3 rd Annual FTA Drug and Alcohol National Conference April 30 – May 1, 2008 Presented By: Robbie Sarles 1

 2000 – National Transit Safety Board (NTSB) issued a directive to the Federal Transit Administration (FTA) Educate transit systems on potential safety risks associated with the use of prescription and over-the- counter medication use by employees who perform safety-sensitive duties Create reporting mechanism Incorporate medical review Train employees 2

 2000 – FTA issued a “Dear Colleague” letter to all grant recipients Establish prescription and over-the-counter drug policy Institute educational programs that address the potential dangers of prescription and over-the-counter drug use 3

 2001 – NTSB called for nationwide changes in how transit agencies monitor employees’ medical and drug-related problems Increased pressure following MTA accidents 4

 2002 – FTA responds Dedicated page of newsletter to prescription and over-the- counter medication use awareness Incorporated discussion in FTA-sponsored/supported workshops and conferences Conducted survey of transit agencies on prescription and over- the-counter policies and procedures Created toolkit of sample policies, procedures, and training materials Investigated procedures used by other modes 5

 2003 – New York City ferry boat accident Pilot of ferry was under the influence of prescription painkillers (Tramadol) and diphenhydramine as found in over-the-counter allergy remedies Known side effects include drowsiness, dizziness, and confusion NTSB determines probable cause of accident was pilot’s “unexplained” incapacitation and failure of New York City DOT to implement and oversee safe, effective operating procedures 6

 2006 – Prescription and over-the-counter medications listed in top ten contributing factors in truck accidents Large truck crash causation study assessed 1,000 factors Prescription medications ranked third of the most commonly-cited factors in major truck crashes (cited in 26.3% of major crashes) Over-the-counter medications ranked eighth, cited in 17.3% of major truck crashes Prescription medication was the number one cause in driver- related factors Over-the-counter medication ranked fourth among driver-related factors Illegal drug use and alcohol use did not make the top twenty 7

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 Published employer prescription and over-the-counter medication policy guidelines 9

 Purpose of Policy Acknowledges risks associated with Rx/OTC use Emphasizes safety Balances the treatment of medical conditions and the requirements of performing safety-sensitive job duties Not intended to force employees in need of medical attention to work or keep employees who are eligible to work off duty for receiving treatment of a medical condition

 Define processes and procedures that implement the policy, such as: Medical review/authorization Reporting Use of leave benefits; limitations

 Define Consequences of Violating Specific Policy Provisions Use of Rx/OTC that contribute to cause or increase the severity of an accident Failure to report use Failure to obtain medical authorization Other policy provision violations

 Ensure that the policy emphasizes and maintains confidentiality Records Interaction with medical practitioner

 Defined Roles and Responsibilities Employees Management/Supervisors Medical Practitioner (Physician, Dentist, Physician’s Assistant, Optometrist, Chiropractor, Other) Pharmacist Employer MRO/Physician

 Provided guidance and understanding on reading and understanding over-the-counter medication labels  Published safety-sensitive employee guidelines for use of prescription and over-the-counter medication 15

 Be cautious – all Rx/OTC have the potential to be dangerous  Inform your medical practitioner Sensitive duties performed Other Rx/OTC/dietary supplements taken Provide complete medical history  Solicit information from your pharmacy  Read warning labels  Do not over-medicate  Cite the strength/dosage of the prescription 16

 Never take anyone else’s medication  Always monitor your reaction  Avoid Rx/OTC that have caused problems in the past  Ask for alternative treatments or dosage schedule DO NOT perform safety-sensitive duties while impaired! 17

 Provided guidance on documenting prescription and over-the-counter medication involvement in accidents  Guidance on developing an effective employee awareness training program 18

 Introduction Purpose of Rx/OTC policy o Balance treatment of medical condition with safe performance of job duties Applicability – Safety-sensitive employees or all employees Employee responsibility for treatment and safe performance of duties

 Training Elements An overview of your system’s Rx/OTC policy An overview of your system’s procedures o Medical authorization o Notification/reporting o Forms if applicable Consequences of policy violations Leave policy o Sick leave/paid time off o Limitations on use

 Training Elements Risks associated with Rx/OTC use Definition of Rx and OTC How to read a label How to read Rx information sheets Side effects of concern Common sense rules for taking medication

 Published sources of training materials 22

 US Food and Drug Administration  Consumer Healthcare Products Association  Center for Drug Evaluation and Research  National Council on Patient Information and Education  Agency for Healthcare Research and Quality 23

 Provided list of steps to evaluate the risks and benefits of a prescription medication  Model transit Rx/OTC approach 24

 Medical Authorization Employee obtains medical authorization form from employer Employee asks about side effects and potential impact on ability to perform duties o If no adverse impacts – Medical practitioner signs release indicating employee may perform duty o If adverse impacts – Medical practitioner signs indicating employee must be off of duty for a specified amount of time Employer may or may not keep form for documentation

 Medical Authorization (cont’d) Form may be reviewed by the employer’s Physician/MRO o After discussing with prescribing physician, may overturn authorization.

 Published alerts Antihistamines Dietary supplements Ritalin Combining over-the-counter medications Obtaining prescription and over-the-counter medications online Misuse and abuse of prescription and over-the-counter medications 27

 Many transit systems have initiated/enhanced their programs Established policies Created training programs Implemented reporting mechanisms 28

 Applauded FTA for its progress and leadership  All but one of NTSB’s recommendations have been met  One outstanding concern FTA, in concert with other US DOT modal administrations should establish a comprehensive toxicological testing requirement for a sample of fatal transit accidents to determine the role of prescription and over-the-counter medications FTA needs to establish a standardized method for collecting and analyzing data that provides insight into the role of prescription and over-the-counter medications on fatal accidents within the transit industry 29

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 Develop three-year snapshot of transit industry safety record NTD fatal accident source data NTSB transit accident case summaries FTA drug and alcohol audit reports  Identify and evaluate causal methods used by other industries FMCSA FRA NTSB 31

 Elicit information from industry Web-based questionnaire o Policy o Education and training o Employee use reporting methodology o Medical practitioner involvement o CDL physicals o Accident investigation methodology o Post-accident testing o Causal and contributing factors identification process o Post-accident fitness for duty assessments 32

 In-depth interviews Internal data collection procedure Accident investigation procedure Accident reports Employee Rx/OTC records Conduct confidential survey of employees involved in fatal accidents  Evaluate large system case studies  Obtain input from advisory panel Transit industry professionals Medical experts 33

 Recommend data collection methodologies  Identify regulatory modifications  Revise/update toolkit 34

 Complete web-based survey  Make FTA aware of your approach – effective, cost beneficial  Volunteer to be on the advisory panel 35