We currently have a zero tolerance drug policy that has been working very well for
our company. Our zero tolerance policy would fit perfectly with the proposed law
except for one section Subpart E, 66.400 (b) Mine operators shall not terminate...
We operate 5 mines with 15 - 30 employees per shift. We do not have extra
people, we have to run our operations at a bear minimum. All our jobs would be
considered "Safety Sensitive". We cannot keep a job open while someone is off
for an indetermined time for treatment. We also feel there is a great liability to our
company by knowingly putting someone back to work who fail a drug test. We
currently train all of our employees' about the zero tolerance policy we meet with
all locations quarterly at a minimum to discuss drug abuse and its dangers in the
work force. This section of the law is unacceptable for our business.
Comment from Billy Orick, Twin Pines Coal
This is comment on Proposed Rule
“Alcohol-and Drug-Free Mines: Policy, Prohibitions, Testing, Training, and Assistance,” Notice of proposed rulemaking, Federal Register (73 FR 52136), Mine Safety and Health Administration, September 8, 2008.
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