Workplace Substance Abuse Programs at Department of Energy Sites
2021-11-04 2021-11-04
DOE-HQ-2021-0017-0002 DOE-HQ-2021-0017-0003
04:00:00 04:00:00
https://api.regulations.gov/v4/comments/DOE-HQ-2021-0017-0002 https://api.regulations.gov/v4/comments/DOE-HQ-2021-0017-0003
Christian Anonymous
Ruano Anonymous
To Whom It May Concern:The Department of Energys proposed rule Workplace Substance Abuse Programs at Department of Energy Sites, Code of Federal Regulations Citation 10 CFR Part 707 is a worthy attempt to better our surroundings. Department of Energy employees and contractors who have security clearances undoubtedly handle sensitive and important information that necessitates discretion and delicate handling. I believe that the inclusion of contractors to the list of individuals that would fall under this proposed rule is a well-intentioned understanding that although they may be employed by the government, and The Department of Energy more specifically, on an as need basis, their importance and handling of information may be the same as any regular employee. The Workplace Substance Abuse Programs proposed rule is significant for the sole fact that the employees and contractors here have the ability to affect the environment, public health and safety, or national security; testing these individuals to make sure that they are not in any way distracted or under another influence is imperative to continue The Department of Energys mission running unimpeded. Because of the importance laid out here, I believe that the agency should take additional measures to reinforce the idea that there is a zero-tolerance policy for substance abuse and that the work being conducted should not be conducted by individuals that cannot abide by the rules. One such additional measure that I believe could benefit The Department of Energy is increasing the size of the annual sample rate from 30 percent. The current proposed rulemaking lists those individuals in testing designated positions be tested at an annual sample rate of 30 percent, which I believe is not at a percentage high enough to ensure the departments continued safety nor the safety of everything that the department affects. At what percentage would safety concerns be duly covered I am not sure of, but at a higher rate from which it currently stands is needed. Moreover, as to 707.14(e), the department must add additional stipulations to the return of a contractor who was removed from the site for the use of illegal drugs. At the moment, the only requirement is that such individual who was removed from duty for such use of illegal drugs needs to notify The Department of Energy of their intent to return to a testing designated position and that The Department of Energy approve their return to such a position. I believe that because such individuals in these positions have already proven to show they interact with illegal substances, stipulations be added return to their post. Their approval to return to testing designated positions (which necessitate security clearances) should be conditioned on increased testing on their return. This would increase the likelihood that if such person decides to use illegal drugs again then the increased testing would increase the possibility of the department knowing about their refusal to comply with the departments policies. The people that are in these testing designated positions are individuals who make important decisions. They are protective force personnel, people involved in the construction/maintenance/operation of nuclear reactors, and personnel that deal with hazardous materials. The decisions these people make, and the mistakes they make as well, impact the public at large. Should they use illegal drugs the chances that mistakes, issues, and a host of other unfortunate situations arise undoubtedly increases. That is why The Department of Energy needs to increase annual sample rate as well as add conditions to the return of offenders of the policy. Thank you. Christian Ruano Implementing substance abuse programs at the Department of Energy Sites is a good idea. Monitoring employees through drug tests will keep the sites clean and prevent accidents from happening. I believe some drugs shouldnt be included in the test since some people use them for beneficial reasons. 