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Fitness for Duty Prescription/Over-the-Counter Medication Use and Medical Qualification Robbie L. Sarles RLS & Associates, Inc. May 31, 2012. History. 2002: National Transportation Safety Board (NTSB) challenge to all FTA grant recipients: Review Rx/OTC Policies.

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Presentation Transcript
slide1

Fitness for Duty

Prescription/Over-the-Counter Medication Use

and

Medical Qualification

Robbie L. Sarles

RLS & Associates, Inc.

May 31, 2012

history
History
  • 2002: National Transportation Safety Board (NTSB) challenge to all FTA grant recipients:
    • Review Rx/OTC Policies.
    • Educate operators of potential risks associated with Rx/OTC use.
  • 2003: FTA Released Rx/OTC Medication Toolkit:
    • “State-Of-The-Practice” at that time.
history1
History
  • NTSB Satisfied by Responses, but:
    • Further research needed to establish nature of relationship between Rx/OTC medications and transit accidents.
history2
History
  • 2009: RLS & Associates, Inc. Conducted 2 Surveys:
    • Gauge progress on Rx/OTC policies & procedures.
    • Inquire about accident investigation practices.
    • Update the FTA Rx/OTC Medication Toolkit.
history3
History
  • Survey Respondents indicated:
    • Rx/OTC policies in place, but were limited in scope and rarely enforced.
    • Most were not collecting Rx/OTC medication information.
    • If Rx/OTC medication information was collected, little was done with it.
    • No correlation between that information and accident investigations.
history4
History
  • 2009 Rx/OTC Survey Recommendations:
    • Standardize the collection and reporting of Rx/OTC medication use.
    • Conduct fitness-for-duty assessments.
    • Expand TSI post-accident procedures to address Rx/OTC.
    • Educate transit systems.
    • Educate physicians.
history5
History
  • 2011: RLS & Associates Convened Expert Panel to Review 2009 Survey Results.
  • Recommendations from Expert Panel:
    • Focus on safety and ensuring that safety-sensitive employees are medically-qualified.
    • Develop standard for retaining Rx/OTC medication information.
    • Educate safety-sensitive employees on meaning of fitness-for-duty.
    • Establish medical qualification standards for industry.
history6
History
  • Recommendations from Expert Panel:
    • Collect information before and after implementation to enable cost/benefit evaluation.
    • Study extent that Rx/OTC medication is a causal or contributing factor in transit accidents.
    • Research legal/liability issues of Rx/OTC policies
      • HIPAA
      • ADA
      • Labor Unions
actions to date
Actions to Date

Rx/OTC Toolkit issued April 2011

To download the FTA Rx/OTC Medication Toolkit,

go to:

http://transit-safety.fta.dot.gov/Publications

Click on Drug and Alcohol Program.

actions to date1
Actions to Date

Advisory Group reviewed Draft Rx/OTC Medication Study and Recommendations April 2011

Final Study and Recommendations completed October 2011

Follow-up Post Accident Questionnaire initiated December 2011

general guidance recommendations
General Guidance Recommendations
  • Encourage transit systems to test for additional substances under their own authority following accidents.
    • 10-panel or more.
    • Expanded opiate testing.
    • Expanded benzodiazepine testing.
    • Methadone and other drugs should be considered.
    • In addition to DOT 5-panel drug test.
  • Incorporate Rx/OTC medications with common side effects that can impair driving into future Post Accident Testing Heuristics (PATH) studies
2011 2012 post accident questionnaire
2011-2012 Post Accident Questionnaire
  • 277 Total Systems Contacted for Initial Online Questionnaire: 4,196 Accidents
    • These numbers were the total reported to NTD for 2010
  • Of the 277 systems initially contacted:
    • 79 Systems responded – 1,820 Accidents
  • Of the 79 Respondents:
    • 67 Systems collect Rx/OTC information – 1,692 Accidents
  • Of the 67 Systems that collect Rx/OTC information:
    • 50 Systems provided follow-up data on selected accidents-1,202 Accidents
summary of responses
Summary Of Responses
  • Of the 1,202 possible accidents:
    • Data for 376 (~31%) out the total 1,202 accidents reported to NTD has been provided.

Large Urban

64%

Small Urban

32%

Rural – 4%

summary of responses2
Summary Of Responses
  • Is it a standard practice for your system to ask about Rx/OTC information as a part of all Post-Accident investigations?
summary of responses3
Summary Of Responses
  • Were any Rx/OTC medications discovered as part of the Post-Accident Investigation?
    • Yes – 4 Accidents (~8%)
    • No – 45 Accidents (~92%)
  • Were any Rx/OTC medications pre-disclosed, prior to the accident?
    • Yes – 17 Systems (34%) / 55 Accidents (~14%)
    • No – 33 Systems (66%) / 321 Accidents (~86%)
    • 98 Unique Rx/OTC medications discovered from the 55 Accidents.
reported rx otc summary
Reported Rx/OTC Summary
  • Of 376 accidents studied
    • 146 instances of medication use reported
    • 96 unique medications
  • 54 Medications (56%) with potential side effects that may impair driving
    • Dizziness/lightheadedness (30)
    • Drowsiness/fatigue (19)
    • Impair Judgment (3)
    • Cause anxiety/insomnia (2)
reported rx otc summary1
Reported Rx/OTC Summary
  • 20% (28) were antihypertensive medications (commonly prescribed for high blood pressure)
  • 40% were Rx pain relievers (12)
  • Sedative/hypnotics (2)
  • Muscle relaxers (6)
  • One report of Chantix for smoking cessation
trends other information
Trends & Other Information
  • Most systems (85%) that responded to the questionnaire are collecting Rx/OTC medication information:
    • Very few are integrating the Rx/OTC information with Post-Accident investigations.
    • After collecting Rx/OTC information from the employee, nothing is done with that information.
    • After an employee reports Rx/OTC medication use, systems do not track how long the employee is expected to take the medication(s).
trends other information1
Trends & Other Information
  • The most common response from systems when asked why they do not inquire about Rx/OTC information as a part of Post-Accident investigations was fear/uncertainty of violating HIPAA.
  • Many systems only ask employees about Rx/OTC medication use as a part of initial physicals, annual physicals, and bi-annual physicals.
list of reported medications
List of Reported Medications

Bold = Name of Medication as Reported by the Transit System

overview
Overview
  • In 2011, the Indiana DOT mandated a Medical Qualification (MQ) Program for all of its 45 Section 5311 Grantees. The MQ Program includes:
    • A comprehensive MQ Policy
    • Physical and Cognitive medical assessments for all safety sensitive employees
    • Rx/OTC Medication Policy
indiana medical qualification program1
Indiana Medical Qualification Program
  • Indiana Council on Specialized Transportation (INCOST) conducted a procurement for a vendor to perform medical qualification assessments and other services under the oversight of a Medical Determination Officer
indiana medical qualification program cont d
Indiana Medical Qualification Program, cont’d
  • Each Section 5311 system has entered into a contract with the selected vendor
  • Medical Assessments are underway
indiana medical qualification program cont d1
Indiana Medical Qualification Program, cont’d
  • Assessments Completed September 1, 2011 through January 20, 2012
    • New Hires 93
    • Annual 404
    • Return to Active Status 1
    • Supervisor Observation Concern 1
    • Post Accident 0
indiana medical qualification program cont d2
Indiana Medical Qualification Program, cont’d
  • New Hire Results
    • 89 granted one year qualification
    • 2 were temporarily disqualified and referred for additional testing that resulted in qualifying status
    • 2 were deemed unqualified
indiana medical qualification program cont d3
Indiana Medical Qualification Program, cont’d
  • Annual Assessment Results
    • 337 granted one year qualification
    • 19 granted three month qualification
    • 1 granted six month qualification
    • 114 were referred for additional testing
    • 44 of the 114 were temporarily disqualified, however 35 of the 44 now meet MQ requirements
    • 3 were deemed unqualified
indiana medical qualification program cont d4
Indiana Medical Qualification Program, cont’d
  • Referral Reasons
    • Blood Pressure 46
    • Vision 23
    • Hearing 19
    • Diabetes 11
    • Sleep Apnea 9
    • Physical Abilities 4
    • Cardiovascular 2
indiana medical qualification program cont d5
Indiana Medical Qualification Program, cont’d
  • Other Assessments
    • The Return to Active Status employee was granted qualification
    • The Supervisor Observation Concern employee was deemed unqualified
indiana medical qualification program cont d6
Indiana Medical Qualification Program, cont’d
  • Average number of prescription and over the counter medications reported
    • New Hires average number of medications = 1.78
    • Qualified for one year employees average number of medications =4.48
    • Qualified for six months employees average number of medications = 5.69
    • Qualified for three months employees average number of medications = 6.08
indiana medical qualification program cont d7
Indiana Medical Qualification Program, cont’d
  • The Indiana Medical Qualification Program Medical Assessment requires individuals to complete a Health Risk Assessment questionnaire. The results of the questionnaire are used as a tool for the Medical Determination Officer to evaluate the overall health of the individual and to provide the individual will wellness information if desired.
indiana medical qualification program cont d8
Indiana Medical Qualification Program, cont’d
  • The following slides contain a summary of the self reported Health Risk Assessment results from November 1, 2011 through January 20, 2011.
participant age
Participant Age

Average Age: 57.43

self identified risks
Self Identified Risks

Average # Risk Factors: 3.3

medical determination officer comments
Medical Determination Officer Comments
  • The Medical Determination Officer identified several conditions that are cause for concern for safety sensitive transit employees. The conditions causing concern in no particular order are:
    • Sleep Apnea
    • Cardiovascular Disease
    • Diabetes
medical determination officer comments cont d
Medical Determination Officer Comments, cont’d
  • Cerebrovascular Disease
  • Hypertension
  • Musculoskeletal Disorder
  • Cognitive Decline
  • Physical Agility Concerns
  • Medication Issues
  • Physician/Patient Relationship
  • Wellness and Self Care Issues
indiana medical qualification before and after survey results
Indiana Medical Qualification Before and After Survey Results

Indiana’s 5311 transit systems were asked to complete a survey to determine the impact of implementing the Medical Qualification (MQ) Program.

  • The survey focused on safety-sensitive transit employees only.
    • The financial impact of implementing the MQ Program.
    • The impact implementing the MQ had on staffing and employee time off from safety-sensitive functions.
    • Management perspective of safety-sensitive employee wellness and safety.
before and after data
Before and After Data

The survey captured data for the year prior to implementing the MQ Program (2010) and data the year the MQ Program was implemented (2011) to allow for implementation impact comparison.

survey participants
Survey Participants

Indiana has 48 designees required to participate in the Indiana Medical Qualification Program.

  • 42 designees had established MQ Programs at the time of the survey.
  • The designees safety-sensitive staff range in size from 3 employees to 150 employees.
    • Survey participants staff ranged in size from 3 safety-sensitive employees to 150 safety-sensitive employees.
    • 24 designees completed the survey representing 57% of designees with established MQ Programs.