Rx/OTC Medications Los Angeles Metropolitan Transportation Authority Carol Holben, LCSW, CEAP, SAP Medical Standards & Compliance Administrator Human Resources – Standards & Employee Programs Metropolitan Transportation Authority

Los Angeles County Metropolitan Transportation Authority Service area of 1,433 square miles Approximately 2,500 buses Three light rail lines and one heavy rail line with a total of 79 miles of service Fourth light rail to open in fall 2011 Approximately 7,200 safety-sensitive employees 417 FTA post accident tests in 2010

History of Medication Reporting Agency had drug testing prior to federal regulations. The 1986 Drug & Alcohol Policy included requirement for employees to report to supervisors medications that may impair and included section on physical examinations. In 2004 the reporting requirement was included in new Fitness-for-Duty Policy and removed from Drug & Alcohol Policy.

Procedures for Reporting prior to 2004 Employees submitted form with name of medication to supervisor. Form was sent to Human Resources. Medication was compared to a list and determined to be: –Approved to take or –Restricted and not allowed to be taken within 8 hours of reporting for duty or while on duty Employee might be advised to contact physician for alternate medication or alternate dose schedule.

Areas of Concern Prompting Revision Desire to emphasize impairment and distinguish prescribed medications from illegal drug use. Understanding that some medications (e.g. anti- depressants) require maintenance of therapeutic levels, conflicting with 8 hour restriction. Recognition that medications affect individuals differently. Awareness that employees might not be taking medications they needed and posing a greater safety risk. Recognition that the use of medications on a long-term basis for chronic conditions was increasing.

Fitness for Duty Policy Applies to all employees, but only safety- sensitive employees are required to report their medications. Establishes standards and procedures for assessing fitness and establishes requirements for medical examinations. Gives employee’s personal Health Care Provider (HCP) responsibility for assessing safety and impairment.

Current Procedure Exempts some common medications from reporting, e.g. aspirin, antibiotics, creams, birth control pills. Identifies some common ingredients in OTC medications that should not be taken while on duty or for 8 hours prior (e.g. diphenhydramine). Requires employee’s HCP to complete form and make determination as to whether medication is safe to be taken while on duty or restricted while on duty and for specified period of time prior.

Medication Reporting Form Features Employee signs release allowing HCP to discuss determinations with Metro HR representative. Employee agrees to abide by HCP determination. Provides HCP with brief description of safety- sensitive functions. Encourages HCP to discuss specific job functions with patient and seek alternative medications that are less likely to impair.

Options for Human Resources If employee submits form without HCP determination and signature, HR representative can provide interim determination via memo. If determinations raise concerns, HR representative can contact HCP and discuss. When concerns are significant, employee can be sent to doctor at Metro contracted clinic for evaluation.

Additional Fitness-for-Duty Policy Elements Commercial drivers in California are required to have a medical examination to assure they meet FMCSA requirements at least every 2 years. A medication review is part of this exam, and employees are asked to bring a current medication reporting form to exam. Employees returning from medical leaves of absence of 30 days or more are also required to have a medical exam and are asked to bring completed reporting forms to the doctor at Metro’s contracted clinic.

Exams and Drug Testing Metro does not employ a medical director. Metro contracts with five local clinics to provide medical examinations. Clinics are required to submit medical exam documents; these are reviewed by HR. Metro performs drug tests for DOT-5. Drug tests are performed under company authority as a part of the biennial commercial driver physical exam.

Issues for the Future Provide additional training to employees on medication use. Consider more rigorous enforcement and consequences for failure to report medications as well as significant medical history. Consider data tracking system.

Accident Investigation On-scene supervisor does not inquire regarding medications. In serious accidents, the accident investigation team completes a thorough investigation and verbally asks operator about medication use. In some cases, the medical file is also reviewed by HR for documentation of medications and risk assessment by personal HCP and/or Metro contracted physician.

Metro’s Experience Complaints initially about HCPs charging fees to complete form, but these have abated. Protest filed by one union which was later dropped. General compliance by employees. Medication Reporting Form acts as educational tool for employees and HCPs. Doctor determinations have been prudent and consistent. Biennial and return-to-work medical exams have also been important opportunity for assessing prescription medication use.