Let’s be honest about something; most workplace drug and alcohol policies are terrible. 

Not terrible in a dramatic or even in a legally explosive way, but nonetheless terrible in the way that makes experienced HR managers quietly cringe. They’re copy-pasted from somewhere on the internet, stuffed with language nobody actually speaks and then they’re filed away in a shared drive that hasn’t been opened since the document was created. 

Half the workforce doesn’t even know the policy exists and the other half signed something at induction and immediately forgot about it!

Then something happens on site. Someone turns up clearly impaired. A post-incident test comes back positive. A manager has to make a call in real time, under pressure and in front of other workers… and there’s no clear procedure to follow because the policy is either non-existent, out of date or written so vaguely it could mean almost anything.

That’s the gap this guide is designed to close. Not just having a policy, but having one that actually does something.

Why Every Workplace Needs a Drug and Alcohol Policy (A Real One)

Safe Work Australia is pretty unambiguous on this point. Managing impairment risk is part of an employer’s primary duty of care under work health and safety legislation of the relevant state or territory. State regulations also provide practical guidance, such as the Queensland Government’s guidance on managing alcohol and other drugs in the workplace (here is the Queensland government’s guidance on this).  

The obligation isn’t to have a document. It’s to identify the hazard, assess the risk and to put controls in place. A written policy is the foundation of that.

What is surprising for a lot of employers is the fact that not having a policy isn’t simply a gap in compliance, it is a potential liability for your business or organisation. If a worker is injured and there’s no documented policy, no testing procedure and no evidence that the organisation took the risk seriously, this could become an important consideration during a  WorkSafe or workers’ compensation investigation, depending on the circumstances.  

And without a written and properly implemented framework, every situation becomes a discretionary call made by whoever happens to be the supervisor on the day. Two workers, same behaviour, different managers, completely different outcomes. That’s how discrimination claims start. That’s how unfair dismissal cases get traction. A consistent approach provides protection for employers and employees alike.  

For anyone who’s in construction, mining, transport or utilities, a drug and alcohol policy isn’t optional at all. Principal contractors routinely require subcontractors to have one before a worker sets foot on site. Some federal and state regulatory frameworks make it a condition of operating. 

Scope That Covers Everyone: What Do Policies Typically Include

The policy has to be clear about who it applies to and the answer should be everyone. Full-time staff, casuals, contractors, labour hire workers and in some circumstances, visitors. 

Policies that only technically cover direct employees tend to develop gaps exactly where the risk is highest, simply because in a lot of Australian workplaces, a significant portion of the workforce isn’t on a direct employment contract.

The policy should also identify who is responsible for implementing it, including managers, supervisors, contractors, workers and any third-party providers involved in testing.

The Prescription Medication Problem

Most policies either ignore this entirely or handle it so awkwardly that it creates more confusion than clarity. 

But here’s the practical reality; workers have a right to privacy around their medical treatment, but they also have a safety obligation. Someone who is operating a forklift while taking a medication that causes significant drowsiness is a hazard, regardless of whether the medication is legal and legitimately prescribed.

A workable policy creates a confidential disclosure process. Workers notify a nominated person (typically HR or an occupational health contact) and not their direct supervisor. The conversation is about managing the safety risk and not interrogating someone’s medical history. 

Reasonable adjustments might be available. The goal is to keep the person safe and keep them working, not to punish someone for having a health condition.

The same principles may also apply to over the counter medications that have the potential to impair a person’s ability to work safely.

Cut-Off Levels That Match the Standard

This is the technical piece that many policy templates skip over; however, it matters enormously. If the workplace conducts testing (more on that below), the cut-off concentrations in the policy need to align with AS/NZS 4308:2023 for urine testing and AS/NZS 4760:2019 if they are doing oral fluid testing. Where breathalysers are used, they should comply with AS 3547:2019 (Breath Alcohol Testing Devices).

If a workplace policy references outdated standards, it should be reviewed and updated. Policies don’t need to reproduce the technical requirements contained within the standard, but they should reference the current versions and ensure workplace procedures align with them.

Testing (When, How and What Happens Next)

The policy needs to spell out the testing framework in plain language. What triggers a test? Pre-employment screening, random testing, reasonable cause and post-incident testing…each is a different situation with a different process, so the policy should address them separately.

Random testing, in particular, is an area where vague policy language causes real operational headaches. “Random testing may be conducted from time to time” is not a testing programme. 

A defensible random testing framework should specify the selection methodology, frequency of testing, who administers the tests, which devices are used and how a not-negative screening result is managed pending laboratory confirmation. 

Getting this right in the policy document is exactly what allows the employer to act decisively if a positive result comes back.

The policy should also explain how confirmatory laboratory testing is managed following a not-negative screening result and who is responsible for communicating the outcomes.

Consequences That Are Actually Proportionate

Here’s where a lot of policies over-correct in one direction or the other. 

A proportionate framework usually looks something like this: a confirmed positive in a safety-critical role (operating machinery, driving, working at height) has more immediate consequences than the same result in a low-risk role. 

First confirmed positive for someone without a prior history looks different from a repeat occurrence. Many workplace policies treat an unjustified refusal to participate in testing as a serious breach of the policy. Exactly how this is managed should be clearly explained within the policy and be consistent with employment obligations and applicable legislation. 

And somewhere in that framework, there needs to be a genuine pathway to support. Not as a get-out-of-jail-free card, but as a recognition that alcohol and drug dependency are health issues. An EAP referral, access to counselling and a return-to-work process aren’t soft options. They’re often what actually resolves the underlying problem rather than just removing the person from the immediate situation.

Managers and Supervisor Responsibilities

This section is missing from a lot of policies entirely and it’s arguably the most important operational piece. A manager who suspects a worker is impaired needs to know exactly what to do. 

That means: how to document observations in the moment (specific, behavioural, objective…not “seemed off”), how to remove the person from safety-critical duties without creating a confrontation in front of the team, who to call, how to initiate a reasonable cause test and what to do with the worker while results are being processed. 

Managers who don’t have this clarity either do nothing (because acting feels too complicated) or they otherwise improvise in ways that create procedural problems down the track.

Supervisor training isn’t optional if the policy is going to function in practice. The document can be perfect and the programme still fails if the people responsible for applying it aren’t equipped to do it.

What Should a Workplace Drug and Alcohol Policy Include?

Building a policy from scratch with all of the above in mind takes time and a reasonable amount of expertise. 

For most businesses, a well-constructed template is the smarter starting point, which is something that covers the key components correctly.  It needs to include guidance notes to help adapt the language to the specific workplace and doesn’t require starting from a blank page at eleven o’clock on a Sunday night before a new principal contractor requirement kicks in Monday morning.

When developing a Workplace Drug and Alcohol policy, it is recommended to consult Safe Work Australia’s guidance, the AS/NZS 4308:2023 and AS/NZS 4760:2019 standards, and any other applicable laws and standards, such as Privacy Acts and WHS requirements. This is to ensure it is actually usable rather than merely technically compliant.

In most Australian jurisdictions, employers also have obligations to consult with workers when introducing or changing workplace health and safety measures. Consulting employees during the development or review of a drug and alcohol policy not only helps meet WHS obligations but also improves understanding and acceptance of the programme.

A well-developed workplace drug and alcohol policy should clearly explain:

• why the organisation has implemented the policy
• who it applies to
• the roles and responsibilities of workers, supervisors and managers
• when testing may occur
• the testing methods used
• how results will be managed
• the support available to employees
• how and when the policy will be reviewed.

The level of detail will vary between organisations, but every policy should provide enough information that workers understand both their responsibilities and the organisation’s expectations.

Turning the Policy Into a Working Programme

A document in a shared drive is not a drug and alcohol programme. This is perhaps the most important thing to understand about where policies fail (and they do fail, regularly in workplaces that have technically ticked the box!).

Making it real means communicating it properly. Not just emailing a PDF. But actually covering it in toolbox talks and including it in inductions in a way that actually lands and not just a signature on a form. Making sure every worker genuinely understands what’s expected and what the consequences are.

It means having the testing programme in place before the policy references it. A policy that says “random testing is conducted in accordance with AS/NZS 4308:2023”, but the business has no testing provider, no compliant devices and no chain of custody procedure is going to have a very bad day the first time someone challenges a result.

And it means reviewing the policy on a real cycle. You should do this at least annually and whenever something significant changes. This is because legislation gets updated. Standards also change (as AS/NZS 4308 did in 2023). The workplace itself evolves, and a policy written for a team of eight looks pretty thin when the business has grown to sixty people with three subcontractors on site.

Where organisations conduct their own in-house urine drug testing, the programme should include documented testing procedures, product training, quality control processes and regular reviews to ensure ongoing compliance with the relevant Australian Standards.

Under AS/NZS 4308:2023, organisations conducting on-site urine drug testing should also have documented quality control procedures to verify ongoing device performance. Quality control is now an important component of maintaining a compliant workplace testing programme.

Does your Workplace Drug and Alcohol Policy Include? 

• Purpose and objectives
• Scope (employees, contractors and visitors)
• Roles and responsibilities
• Prescription medication disclosure
• Testing circumstances
• Testing methods
• Australian Standards referenced
• Chain of custody procedures
• Consequences and support pathways
• Manager responsibilities
• Review process

How Sober Check Supports Australian Workplaces 

Developing a workplace drug and alcohol policy is only the first step. Successfully implementing it requires the right testing solution, documented procedures and people who understand how the programme operates in practice.

Sober Check Australia helps organisations build practical workplace testing programmes by supplying compliant workplace drug and alcohol testing solutions including testing devices, product training, assistance with testing procedures and ongoing technical support.

Whether you’re developing a new workplace drug and alcohol policy, reviewing an existing programme or preparing for the requirements of AS/NZS 4308:2023, our team can help you choose a solution that’s practical, compliant and suited to your workplace.

Talk to the Sober Check team today to discuss the right approach for your workplace.