8 of 12 pillars flagged incomplete
Written Policy
Supervisor Training
Employee Education
EAP Referral
Testing Protocols
Chain of Custody
MRO Review
Return-to-Duty
Record Retention
DOT Categories
State-Law Alignment
Annual Audit

How many boxes can your
program actually check?

A compliant drug-free workplace program has twelve distinct components. Most organizations operate with six or fewer.
Scroll to audit yours.

Begin the audit
The Audit

Scroll through each pillar.
Watch your score in real time.

Each pillar explains what auditors look for, the most common failure points, and what a compliant version looks like.

Compliance Scorecard

Your program score updates as you review each pillar.

0/12
Critical Gaps
0% compliant
01 · Written PolicyFoundation
02 · Supervisor TrainingTraining
03 · Employee EducationTraining
04 · EAP ReferralSupport
05 · Testing ProtocolsTesting
06 · Chain of CustodyTesting
07 · MRO ReviewTesting
08 · Return-to-DutyCompliance
09 · Record RetentionCompliance
10 · DOT CategoriesRegulatory
11 · State-Law AlignmentRegulatory
12 · Annual AuditOversight
Pillar 01○ Pending

Written Policy

What it is

A documented, signed policy distributed to every employee stating prohibited substances, consequences, and testing triggers.

AUDIT FLAG: Unsigned acknowledgment forms. Policy last updated before state marijuana law changes. No version control.
Annual policy review cycle with dated employee signatures, legal counsel sign-off, and version-controlled distribution log.
Pillar 02○ Pending

Supervisor Training

What it is

Supervisors must be trained to identify reasonable-suspicion indicators — behavioral, physical, and performance-based — before requesting a test.

AUDIT FLAG: No documented training records. Supervisor "awareness" without formal certification. Training older than 24 months.
Minimum 60-minute reasonable-suspicion training with signed completion certificate, refreshed every 24 months.
Pillar 03○ Pending

Employee Education

What it is

Every covered employee must receive education on the dangers of substance abuse, company policy specifics, and available assistance resources.

AUDIT FLAG: Education delivered once at onboarding, never refreshed. No documentation of completion. No awareness of EAP resources.
Annual education session with sign-in sheets, materials distribution log, and post-session comprehension acknowledgment.
Pillar 04○ Pending

EAP Referral

What it is

An Employee Assistance Program (EAP) must be identified and communicated to employees before any testing is conducted.

AUDIT FLAG: EAP listed in policy but never communicated verbally. No referral process. No documentation of SAP referrals made.
Named EAP with contact information posted, included in onboarding packet, and referenced in every reasonable-suspicion conversation.
Pillar 05○ Pending

Testing Protocols

What it is

Defined triggers for pre-employment, random, post-accident, reasonable suspicion, return-to-duty, and follow-up testing.

AUDIT FLAG: Only pre-employment testing active. Random pool excludes part-time and contract staff. Post-accident threshold too high.
All six testing categories documented and active. Random selection through third-party TPA. Post-accident threshold at federally recommended level.
Pillar 06○ Pending

Chain of Custody

What it is

The documented, unbroken transfer of a specimen from collection to laboratory analysis — every hand that touches it, timestamped.

AUDIT FLAG: Collection site not SAMHSA-certified. Forms incomplete at transfer. No documentation of split specimen procedures.
SAMHSA-certified collection site, completed Federal CCF forms, documented specimen transfer with collector and donor signatures.
Pillar 07○ Pending

MRO Review

What it is

A licensed Medical Review Officer reviews all non-negative results, contacts donors, and issues final verified results to the employer.

AUDIT FLAG: Employer receiving lab results directly. No MRO in chain. Positive results acted on without MRO verification.
Contracted MRO receives all non-negatives. Employer receives only final verified results. MRO contact documented in program.
Pillar 08○ Pending

Return-to-Duty

What it is

After a violation, employees must complete SAP evaluation, prescribed treatment, and a return-to-duty test before resuming safety-sensitive functions.

AUDIT FLAG: Employee returned to work without SAP evaluation. No follow-up testing schedule. RTD test not documented as negative.
Formal RTD process with SAP-prescribed evaluation, negative RTD test, and minimum 6-test follow-up program over 12 months.
Pillar 09○ Pending

Record Retention

What it is

Federal regulations require specific retention periods for test results, training records, and policy documents — ranging from 1 to 5 years.

AUDIT FLAG: Records purged annually. Test results stored with HR personnel files (commingled). No secure, separate retention system.
Dedicated secure record system with DOT-compliant retention schedule: 5 years for positives, 2 years for negatives, 5 years for training.
Pillar 10○ Pending

DOT Categories

What it is

If any employees perform DOT safety-sensitive functions (CDL drivers, pipeline operators, transit workers), a separate DOT-compliant program is mandatory.

AUDIT FLAG: DOT-covered employees in general workplace pool. Incorrect panel (non-DOT 5-panel used for DOT positions). FMCSA clearinghouse not queried.
Separate DOT program for all safety-sensitive functions. FMCSA Clearinghouse enrollment and annual query. DOT-specific 5-panel with correct cutoffs.
Pillar 11○ Pending

State-Law Alignment

What it is

Thirty-eight states have enacted marijuana laws that affect employer testing rights, accommodation requirements, and adverse action procedures.

AUDIT FLAG: Policy not updated after state law change. No legal review since 2020. Off-duty marijuana use policy violates state statute.
Annual legal review of policy against current state law. State-specific addenda for multi-state employers. Legal counsel sign-off documented.
Pillar 12○ Pending

Annual Audit

What it is

A systematic annual review of the entire program — testing rates, vendor performance, supervisor compliance, policy currency, and record completeness.

AUDIT FLAG: No internal audit ever conducted. Third-party audit never commissioned. Program running on original setup from implementation year.
Annual third-party program audit with written findings, corrective action plan, and board-level reporting. Audit records retained 5 years.
Client Outcomes

Three industries. Three different
reasons the program had to be right.

94%
first-audit pass rate
across all clients
Manufacturing / DOT
100%
audit pass rate
"We had a DOT compliance audit scheduled for March. Shield came in January, found four critical gaps we didn't know existed, and we sailed through."
Marcus Delgado
Director of HR, Apex Industrial Components
Gary, IN · 2,200 employees · 340 CDL-covered positions
Construction / Insurance
31%
insurance premium reduction
"After our third failed random screen in 18 months, our broker put us on notice. Shield rebuilt the program from written policy to MRO contract. Premium dropped at next renewal."
Colleen Hartley
Owner, Hartley Site Development
Columbus, OH · 85 employees · General contractor, commercial
Education / Student-Athlete
0
legal challenges in 3 years
"We needed a student-athlete testing policy that could survive a parent challenge and a state audit simultaneously. Shield drafted something that held up to both."
Dr. Renee Okafor
Superintendent, Lakeview Unified School District
Sacramento, CA · 4,200 students · 6 varsity programs
Free Diagnostic

Run Your Free
Compliance Audit

A 4-minute guided diagnostic. Tell us your organization size, industry, testing volume, and policy age. We map your gaps against all 12 pillars and tell you exactly where you stand.

  • No form. No sales call required to start.
  • Results delivered immediately — pillar by pillar.
  • Specific remediation steps, not generic recommendations.
4 min
average completion time
Start Free Audit

Covers all 12 pillars · Industry-specific · Instant results

Download the 12-Pillar Checklist PDF

The same checklist our consultants use on Day 1 of every engagement. Print it. Put it in a binder. Check the boxes yourself.