Alcohol screening policy

HPCA

Aboriginal and Torres Strait Islander Health Practice

Policy

Published on 1 June 2018

This policy and its related procedures outline how to comply with conditions requiring NSW health professionals or students (does not apply to Psychology) to undergo alcohol screening, and the consequences of any non-compliance.

Applies to: NSW health professionals and students required to undergo alcohol screening; Health Professional Councils of NSW, their delegates and HPCA staff. There are separate policy and procedure documents for the Medical Council and the Nursing and Midwifery Council.

Date of endorsement	Endorsed by	Publication date	Review date
1 June 2018	Health Professional Councils of NSW	1 June 2018	1 June 2023

1. Purpose

To ensure that NSW health professionals and students who are required to undergo alcohol screening comply with conditions imposed on their registration, and explain the consequences of non-compliance.

2. Introduction

The Council uses alcohol screening to monitor NSW health professionals and students where there is a history of or concerns about alcohol misuse or dependence. The Council uses the following screening tests either on their own or in combination to monitor participants:

Breath-testing for alcohol
EtG screening
CDT screening

The Council understands that alcohol screening can be inconvenient, intrusive, and expensive. However, negative alcohol screening results are an effective way for the Council to protect the public, by knowing that a participant is not affected by alcohol and can continue safely in practice or training.

3. Definitions and abbreviations

Term	Explanation
breath-testing for alcohol	a screening test to ensure a participant is not under the influence of alcohol
CDT	Carbohydrate-Deficient Transferrin – a screening test designed to identify excess consumption or harmful use of alcohol
Council / we / our	relevant Health Professional Council
EtG	Ethyl-glucuronide – a screening test to monitor compliance for abstinence from alcohol, by detecting the presence of EtG (an alcohol breakdown product) in urine
the guidelines / the national guidelines	Australian Guidelines: To reduce health risks from drinking alcohol, as revised from time to time
HCCC	Health Care Complaints Commission
HPCA	Health Professional Councils Authority
participant / you / your	a registered health professional or student participating in alcohol screening because a condition on their registration requires it
the Standard	the AS/NZS 4308:2008, Procedures for specimen collection and the detection and quantitation of drugs of abuse in urine
substance	any substance listed in Schedule 1 of the Drug Misuse and Trafficking Act 1985; or pharmacist only, prescription only or controlled drug medication as contained in Schedule 3, 4 or 8 of the Poisons Standard (SUSMP)
the Tribunal	the Civil and Administrative Tribunal of New South Wales

4. Mandatory requirements for alcohol screening

4.1 Compliance with this policy

Participants must comply with all aspects of this policy, the Council’s related alcohol screening procedures and all alcohol screening conditions on their registration.

If a condition is inconsistent with this policy or the procedures, the condition prevails.

All aspects of screening, including the type of screening and how often participants must attend, will be overseen by the Council. Compliance will be monitored by our monitoring team.

4.2 Non-compliance with alcohol screening

Non-compliance with alcohol screening is any failure to follow the requirements of this policy, the Council’s alcohol screening procedures, and any alcohol screening conditions on a participant’s registration.

If a participant does not comply, the Council will ask them for a written explanation, and may also ask the breath-testing supervisor and breath-testing device manufacturer, or pathology provider for more information. The Council will then consider whether further action is required. In some cases the Council may take action without asking the participant for an explanation.

Non-compliance with alcohol screening includes, but is not limited to, the circumstances listed in the following table.

Screening type	Circumstance
All	a positive alcohol screening result the participant fails to commence screening within the required timeframe the participant fails to attend for screening when required the participant provides samples for screening outside of the approved collection and testing regimen the participant fails to complete request forms as required (not for breath-testing) the participant provides samples that do not meet the chain of custody (not for breath-testing) the participant uses, makes, alters or possesses an object or product to defraud an alcohol screening test the provided sample is inadequate or unsuitable for testing the participant fails to provide supporting information about any absences from screening within the required timeframe a pattern of participant behaviour raises concerns about their compliance with this policy, the related procedures or related conditions on their registration.
Breath-testing for alcohol	the participant fails to provide the Starting breath-testing for alcohol form within the required timeframe or the information submitted is inadequate or insufficient for approval the participant fails to maintain their breath-testing log as required the participant fails to provide their breath-testing log to the Council the participant fails to service their breath-testing device as required the participant fails to make alternative arrangements for breath-testing while their device is being serviced.

Screening type

Circumstance

All

a positive alcohol screening result
the participant fails to commence screening within the required timeframe
the participant fails to attend for screening when required
the participant provides samples for screening outside of the approved collection and testing regimen
the participant fails to complete request forms as required (not for breath-testing)
the participant provides samples that do not meet the chain of custody (not for breath-testing)
the participant uses, makes, alters or possesses an object or product to defraud an alcohol screening test
the provided sample is inadequate or unsuitable for testing
the participant fails to provide supporting information about any absences from screening within the required timeframe
a pattern of participant behaviour raises concerns about their compliance with this policy, the related procedures or related conditions on their registration.

Breath-testing for alcohol

the participant fails to provide the Starting breath-testing for alcohol form within the required timeframe or the information submitted is inadequate or insufficient for approval
the participant fails to maintain their breath-testing log as required
the participant fails to provide their breath-testing log to the Council
the participant fails to service their breath-testing device as required
the participant fails to make alternative arrangements for breath-testing while their device is being serviced.

If a participant does not comply the Council may:

give the participant a warning and explain any other action the Council may take if they do not comply in the future
increase the frequency or length, or change the type of alcohol screening
require that the participant attend an interview or hearing to consider the matter further
take immediate action, such as imposing more restrictive conditions (including a critical impairment condition) on or suspending the participant’s registration and refer a complaint to the HCCC
refer a complaint to the HCCC.

4.3 Compliance with critical impairment and critical compliance conditions

There are two types of critical conditions that can be imposed on a participant’s registration that have specific consequences for non-compliance. The following table shows which bodies can order these conditions and which participant group is affected.

Condition type	Ordered by	For
Critical impairment condition	Relevant Health Professional Council of NSW	a NSW health professional
Critical compliance condition	The Civil and Administrative Tribunal NSW	a NSW health professional or student

If a participant does not comply with a critical impairment or critical compliance condition, the Council must take action. The following table shows what action is taken if the Council considers that a participant has breached one of these conditions.

Condition type	Action taken
Critical impairment condition	The Council must refer the matter to the HCCC
Critical compliance condition	The Council will immediately suspend the participant’s registration and refer the matter to the Tribunal, which must cancel the participant’s registration if it is satisfied that the condition has been breached

5. Implementation

Implementing party	Key actions required
NSW health professionals and students	comply with this policy, its related procedures and related conditions imposed on their registration.
HPCA monitoring team	monitors compliance with this policy, its related procedures and related conditions imposed on a participant’s registration, on behalf of the Council.
Councils	make decisions about a participant’s progress with screening and compliance with this policy, the related procedures and any related conditions imposed on their registration.

6. Legislation and references

Laws and standards: AS/NZS 4308:2008, Procedures for specimen collection and the detection and quantitation of drugs of abuse in urine.

Fact sheets: The Council has a range of fact sheets providing information about alcohol screening.

Note: this policy does not apply to Psychology. Separate policy and procedure documents exist for the Medical Council and the Nursing and Midwifery Council.

Last updated on 1 June 2018

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