Write the alcohol policy and site work instructions separately

7 min read

When a workplace sets up an alcohol check program, placing testing equipment does not complete the operation. When the program covers people who must confirm they are in a safe condition before work or driving, such as workers at manufacturing and construction sites or transport workers, it must be defined who is checked and when, and who decides what based on the result. A breathalyzer is a device that measures breath and displays a result, but the procedure for using the device and the workplace's management principles are not content for the same document.

If you put all of this in one document, program principles and on-site operating methods get mixed together. Every time the device screen or contact details change, you would have to revise the scope and approval authority as well. Conversely, test staff might end up deciding on their own how to adjust work based on results. The appropriate approach is to separate them: the alcohol management policy holds the application principles and decision authority set by the workplace, and the site work instructions hold the sequence of actions to carry out at the testing location.

The policy sets the scope and decision authority

The alcohol management policy is a document that sets the purpose of the check, who it applies to, when checks take place, how results are classified, and the principles for action on each result. Whether to include contractor workers or visiting workers in addition to employees, and whether to check at arrival or before being put to work, are decided in the policy. To keep interpretations from differing from site to site, it is best to state the scope of applicable tasks, locations, and people together.

The policy should also name who can hold a person back from being put to work after a result, who decides whether to assign replacement staff, and who judges retest requests or disputes. Which roles can view information such as test results and whether a retest took place is also something this document should set. Rather than simply writing "notify a manager" in the work instructions, the policy should define the position to be contacted and the scope of that position's judgment, so that test staff do not end up making policy decisions.

If you link alcohol checks to risk assessment, the policy should record the work risks you aim to reduce and the management principles, rather than the check itself. Article 36 of Korea's Occupational Safety and Health Act requires the employer to identify hazards and risk factors arising from work and to set up and carry out improvement measures to reduce risk. However, this provision alone does not determine who is checked or how checks are run at an individual workplace, so the policy must spell out the workplace's work characteristics and internal decisions.

The work instructions show the sequence at the testing location

The site work instructions are a document that sets out the sequence test staff actually follow. Arrange the steps in order: confirming the person to be checked, guiding them to the testing location, preparing the device, checking the result, giving guidance when the result is not displayed normally, and the position to contact. Device button names and screen prompts can go in the work instructions, but explanations of device operation must not become the basis for work restrictions or HR actions.

In the instructions, separate actions test staff take immediately from actions that require approval. For example, a flow in which staff check the result, notify the designated site supervisor, and ask the person to wait at a designated place before being put on the next task can be placed in the instructions. By contrast, whether the person can continue working, whether to allow a retest, and whether to share the result further are linked to the policy's principles and the person with approval authority.

The instructions should also state what staff do when the device does not display a result or the test procedure is not completed. Here, rather than concluding that the cause is a device fault or the individual's behavior, it is appropriate to write a sequence for checking the displayed status and passing it along the set contact route. How to repair the device or judge whether it can test is outside the scope of these instructions.

Align terms and cross-references between the two documents

Even when the two documents are separate, terms such as "retest," "test procedure not completed," "dispute," and "work hold" must be used with the same meaning. For example, if both a situation where no result is displayed and a situation where the person did not finish the procedure are called "unable to test," it becomes hard to tell the next action needed on site. Defining each term's meaning and conditions of use in the policy, and using those exact terms in the work instructions, reduces confusion.

At the top of the work instructions, show the name, version, and relevant clauses of the policy that applies. In the policy, list the name and version of the linked work instructions so it is clear which procedure document currently applies. However, the documents must not merely point to each other. The place where the person waits and the position to contact must be easy to find directly in the work instructions, while the grounds for work adjustments and exception approvals must be checkable in the policy.

Category What to put in the alcohol management policy What to put in the site work instructions
Scope Who is checked, tasks covered, when checks take place Steps for confirming the person and guiding them to the testing location
Handling results Result categories, principles for adjusting work, approval authority Guidance and contact order for each result
Information management Result information to collect and roles that can view it Route used to enter and pass on results
Document control Revision approver and effective date Replacing screen prompts, contact lists, and site postings

Separating them as in the table prevents site staff from revising the policy's scope just because contact details changed. Conversely, when the information stored with results changes, you can examine the policy's information management items instead of treating it as a simple screen change.

Decide which document to revise based on the reason for the change

In a revision request, rather than using only broad wording such as "device screen change," it is best to state separately what changed among button names, result display, stored items, contact details, and approval authority. If only contact details changed, the main task is updating the contact list in the work instructions. If information stored with results has been added or changed, you need to review whether it also affects the policy, which defines why that information is needed and who can view it.

As a hypothetical example, consider a situation where an existing breathalyzer is replaced with another device, but who is checked and the principles for action on each result stay the same. First, check on the new device the screen test staff see, the result items that are printed or stored, and what is displayed when the procedure is not completed. If the observation shows that only the screen sequence changed, the action is to update the guidance text and operating sequence in the work instructions.

On the other hand, if you find that information not stored before is now stored, do not change only the work instructions. Review the policy's information collection items and viewing scope as well. The completion standard in this case is a state in which staff can stand in front of the new device, read the latest work instructions, and guide people in the set order; no information not defined in the policy is newly included in result records; and the effective dates and version markings of the two documents match. Dividing the scope of impact based on the screens and stored items that actually changed lets you avoid unnecessary full revisions.

Check for differences between documents at the distribution stage

Uploading the approved file to a shared folder does not automatically change the procedure on site. If old versions remain in the notice at the testing location, training materials, printed procedures, or the contact list kept by the site supervisor, different actions may result in the same situation. When revising, you can consider deciding together where the documents are placed, who will replace them, and how old documents will be collected or marked as no longer in use.

Before the effective date, you can also choose one situation that could actually happen and have test staff and the site supervisor each handle it using only the documents. For example, if, when a retest request comes in, one person directs it to be reported immediately while another decides alone whether work can continue, rather than concluding it is a training shortfall, you should look at which document is missing an explanation of conditions or authority. The purpose of writing the documents separately is to align the policy's principles and the work instructions' sequence so that the same situation leads to the same guidance and decision path.

References

#alcohol management policy
#work instructions
#document control
#decision authority
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