Today the Construction Owners Association of Canada (COAA) and Energy Safety Canada (ESC) announced the release of the Canadian Model 6.1. The complete publication can be found here.
CannAmm’s processes have long adopted the leading practices within the Canadian Model. Our clients can rest assured that CannAmm can assist them in being compliant with new revisions and discuss the change management involved in any fit-for-duty program updates.
What is the Canadian Model?
The Canadian Model for Providing a Safe Workplace aims to contribute to a safe workplace for all workers by reducing the risks associated with the inappropriate use of alcohol and drugs. It seeks to articulate minimum industry expectations for a safe workplace while recognizing that some companies may require higher or alternative standards based on the specific nature of their operations.
What has Changed in this Version?
The COAA recognizes that the Canadian Model must account for new information, technologies, and trends. For this reason, the Canadian Model is periodically reviewed. Here is a summary of the changes that came into effect May 1, 2023:
Amendments to Section 3.2 (Employee Compliance)
Add new phrasing – “3.2.1: Prior to commencing work, an employee shall notify the supervisor or manager of the use of any drug that has potentially unsafe side effects that may impact the employee’s ability to safely perform their duties.”
Modifications to Section 3.2 review employee compliance expectations. The Model now states that each employee must report the use of any substance that could impact their fitness for duty. If diligently followed, this will ensure a safer workplace by mitigating the risks associated with the inappropriate use of alcohol and drugs.
Amendments to Section 4.8 (Oral Fluid Testing)
Replace 4.8.2 to include the phrasing – “Oral fluid laboratory testing may be permitted for site-access testing,” (following language remains unchanged).
Modifications to Section 4.8.2 review the use of oral fluid laboratory testing. The Model now allows urine or oral fluid laboratory testing for site access testing. Some companies and organizations are expected to move to laboratory oral fluid testing over the next few months. CannAmm encourages a review/consideration of the following:
- All methods of testing should be consistent with your policy or only used after a policy revision
- Policy updates generally require some advanced notice (e.g., 30, 60, 90 days)
- Collective agreements may have requirements for an addendum to the agreement or other steps to occur before adding a test method under the acceptable reasons for testing
- Projects or your customers may not accept the oral fluid for pre-access, despite the change in the Model. We recommend a stipulation that the pre-access test method will be determined based on contractual compliance with the customer and may be either urine or oral fluid.
What has NOT Changed in this Version of the Canadian Model?
The Canadian Model maintains that Point of Collection Testing (POCT) for oral fluid is not acceptable for any test reason, nor as a preliminary screening/risk assessment tool.
4.8.5 Point of collection tests (POCT)
Notwithstanding sections 4.8.1 through 4.8.4 and Appendix A, if a test is requested pursuant to section 4.4 (reasonable grounds) or section 4.5 (incident), the employer may use a point of collection test (POCT) as one of a number of options for assessing the risk of having the employee return to work, pending the medical review officer’s report on the oral or urine-based lab test. A POCT device used for this purpose must have Health Canada approval, must be intended for urine assessment only, and must be calibrated to the extent possible with the urine cut-off levels in section 3.1(b)(ii). Only collection personnel trained to U.S. DOT standards shall administer the POCT. Such collection personnel must comply with standard operating procedures that must, at a minimum, address chain of custody and quality control. Irrespective of whether this risk assessment option is used, a test must be completed in accordance with sections 4.8.1 through 4.8.4.
For More Information
Canadian Model Version 6.1, Supporting Documents, and Relevant Presentations by the COAA can be found here.
For CannAmm clients wishing to review their account or receive advice, please contact us via our web contact form here, or email us at sales@cannamm.com.
