“Reporting for Duty” Means Being Fit For Duty

Melissa Ralph
Fitness For Duty Specialist

Watching over a nuclear reactor’s controls or supervising nuclear power plant maintenance are jobs that need a person’s full attention. Nuclear plant workers can’t perform properly if they’re overly tired, dealing with a medical concern or under the influence of drugs or alcohol. For those reasons, the NRC has strict “fitness for duty” requirements so companies can spot impaired workers and keep them out of the plant.

Human factors were in the spotlight after the Three Mile Island accident in 1979. Afterward, we closely examined how human behavior affects nuclear plant safety. In 1989 the agency issued the first fitness for duty rules covering anyone with unescorted access to a nuclear plant, as well as workers whose duties affect safety, security or emergency preparedness.

drugsDrug and alcohol testing is the program’s most obvious feature. New hires are tested before they get access to the plant, and companies must also conduct random, unannounced drug and alcohol tests for workers. The tests must cover a specific minimum set of drugs (including marijuana, cocaine and amphetamines) and companies can expand the test for additional drugs.

The rules also say workers can’t drink alcohol for at least five hours before their shift, and blood alcohol concentrations as low as 0.02 constitute a “positive” test. (For comparison, driving while impaired in the United States requires a 0.08 blood alcohol level.)

Plants must also test on-duty workers if they seem impaired or are behaving oddly, and workers must report anyone they think is impaired to management. Workers who feel impaired from being too tired must report themselves.

Workers are automatically drug and alcohol tested and assessed for being overtired if they’re involved in an onsite accident or event possibly caused by human error. Plants also test workers when they’re working extended shifts. All of these multiple layers of testing help ensure plant workers are fit for duty.

Plants give the NRC information from all these tests regularly. Reviewing this information shows that most of the positive tests – two out of three – comes from pre-access testing. So these impaired individuals never get into the plant. In the other cases the worker’s access is promptly revoked.

What happens to a worker with a positive test? The first bans the worker from the site for at least 14 days; a second revokes the person’s access for five years. If the worker has a third positive test or tries to cheat on a drug test the person is permanent banned from access to the site. Workers who want to restore access after a first or second positive test must go into a treatment program and have follow-up tests.

In 2008, we updated NRC regulations to strengthen the drug and alcohol test requirements and to enhance how companies manage work hours to prevent worker fatigue. Since then, the overall positive test rates have remained steady at about 0.62 percent. Last year 179,135 tests spotted 1,114 cases where a worker was positive for either alcohol or a drug.

We continue to examine new information about fitness for duty, as well as improvements in testing technology. We’re working on proposed updates to our rules based on this information. You can read more about today’s fitness-for-duty requirements on our website.

Author: Moderator

Public Affairs Officer for the U.S. Nuclear Regulatory Commission

11 thoughts on ““Reporting for Duty” Means Being Fit For Duty”

  1. Nice article, Very informative regarding BAC. I agree that there is no way around human error.

  2. You are using the term “positive” more liberally than your regulations. The regulations do not say a first test result of 0.02 is an initial positive, all it says is that it requires a confirmatory test. And to my original point, if a worker was tested immediately after arriving at work and tested initial and confirmatory at 0.02, that would not result in the test being declared positive. To be positive immediately after arriving at work, he would have to test 0.04 (which is why you can’t draw a parallel between 0.02 and the 0.08 driving limit).

  3. The NRC requirements use a time-dependent blood alcohol concentration (BAC) for an alcohol test to be confirmed positive and a sanction applied to the worker. A worker with a BAC of 0.02 percent or greater is identified as initially positive. The test is confirmed positive if a worker has a BAC of 0.02 percent or higher and has been in a work status for at least two hours or for at least 1 hour with a BAC of 0.03 percent or higher. A BAC greater than or equal to 0.04 percent BAC will always result in a confirmed positive alcohol test result.

    Melissa Ralph

  4. To say that 0.02 constitutes a positive test and comparing it to a 0.08 standard for driving is not accurate. 0.02 is a positive test only if the person has already been at work for the past two hours, which means that either they consumed alcohol at work or they arrived to work with a BAC of at least 0.04. A person arriving at work and immediately testing at 0.02 would not be considered to have tested positive. I think saying that 0.04 is the nuclear standard for positive is far more accurate statement than 0.02.

  5. What difference does it make if an employee is fit or not? In 2001 after 9-11 we were told there could be from 14,000 to 17,000 trained Islamic terrorists already infiltrated into the country. Just a couple platoons of such guys, thoroughly trained and heavily armed, would probably not have any trouble overpowering (killing) nuclear plant employees, armed or not, fat or not, able to run or not. They don’t even have to get control of the facility, for that matter, just attack key components, which you the NRC can’t really defend. Health of employees is a joke of a matter for discussion. Sorry to be unneighborly, but remember, all criticism is beneficial in pointing out things we need to know but may not see ourselves. Your guys’ way of making a living, happens to involve an industry, which has the capacity to accidentally destroy the nation, or be used to deliberately destroy the nation. No amount of ‘cheap’ power is worth that risk. Again, in the odds-vs-stakes analysis, the odds are there and too high considering the stakes. If a coal plant has a problem, its a dust explosion or pile fire or mercury contamination from the ash heap. If a nuclear plant has a problem, half a nation become uninhabitable, forever. The commons sense thing that should have happened at Fukushima was the immediate dry-casking of all the common SFP contents. Nobody can even get that right.

  6. Great article. Brings back a lot of memories, working wil Loren Bush as he championed this relatively unwelcome requirement. His tireless leadership and expertise transformed the program in to an extremely valuable asset. Next, do an article on the BOP! Keep up good work

  7. Considering that the most notorious of modern catastrophes such as the failure of the Space Shuttle Columbia and the crash of the Exxon Valdez have been attributed to human fatigue, the NRC Fitness for Duty Rule (10 CFR Part 26) is essential to safe nuclear plant operation.
    The NRC recognizes 8, 10, and 12-hour shift schedules and requires 2 to 3 days off per week depending on the type of work being performed. Armed security responders and reactor operators are among those with the most restrictive requirements.
    Not surprisingly, a 2004 study found that workers across a variety of occupations who worked 12-hour night shifts were more likely than their day-shift-working colleagues to experience physical fatigue, smoke and abuse alcohol.
    As a result of fatigue science, it was found that by exposing experimental subjects to intermittent bright light during their night shifts and having them wear sunglasses on their way home and sleeping in very dark bedrooms, it was found that within about a week, they can shift someone’s circadian rhythm to align perfectly with working a night shift and sleeping during the day.

    But that’s unrealistic for most people. The problem is that adapting completely physiologically would leave you a nocturnal person, unable to sleep until very late on days off and being out of phase with regular day-working people.
    So researchers developed a compromise system in which people who work permanent night shifts adapt their circadian rhythms just enough to function well at night, but still be lively during their days off. It works like this: On his or her day off, the worker goes to sleep as late as possible (in the experiment, participants went to bed at 3 a.m. and woke up at noon). On a workday, he or she would be exposed to intermittent bright light, wear sunglasses on the way home from the night shift, then go to sleep as early as possible. So the difference between sleep on their night shift days and their days off would likely be less than what most shift workers have now. Tests showed that you don’t have to be fully adapted to the night shift to get the benefits of shifting your circadian clock.

    However, it was pointed out that so far there is NO solution for workers who have a combination of night and day shifts because it’s impossible to keep shifting their circadian rhythms to keep up with an ever-changing work schedule. It therefore falls on employers to assign shift work in blocks, giving workers enough time to adapt.
    You can’t phase shift the circadian clock with a rapidly rotating shift schedule because the clock can’t move that fast. The only thing you can do is symptomatic relief, meaning you’ll have very sleepy people working at night, which is dangerous.
    In my reading of Part 26 there does not appear to be anything in the rule that requires nuclear plant workers to be assigned shift work in blocks so that workers are given enough time to adapt properly.

  8. I have a concern about the trend toward 12-hour shifts for nuclear plant workers. Years ago 8-hour shifts were common, now, I believe 12-hour shifts are common. Has it been proven that 12-hour shifts are safer from a human performance standpoint? Operators love 12-hour shifts because they can get more days off in between shifts but aren’t those shifts more demanding than shorter shifts?
    Also isn’t rotating shift work, that is working nights, then days, then nights, tougher on workers than working straight shifts, i.e. all nights or all days? Bottom line, shouldn’t fitness for duty requirements specify the best shift hours and the best shift rotations from a human biorhythms standpoint? Leaving working hours and shifts up to the workers may not be the best from a safety standpoint. I do not believe airline pilots or air traffic controllers work 12-hour shifts. Neither should reactor operators.

  9. Fitness for duty is just as important as protecting whistle-blowers from job harassment since both are related to power nuclear plant safety. Sadly harassment is much harder to spot since employees must call attention to what is happening and once they speak out the NRC responds in ultra slow motion which makes it easy for the Utility to sidestep any personnel issues.

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