How to build a procedure for drug testing in the workplace

A policy is just paper without a working procedure that ensures it is followed in practice. This guide goes through how to build a procedure that actually works — from decision to day-to-day operations.

Step 1: Risk analysis and decision

Start by mapping your specific risk situation:

• Which roles are safety-critical?
• Are there external requirements (clients, insurance, industry standards)?
• Have you had incidents or warning signs before?
• What level of programme is proportionate?

The decision must be documented and anchored in management. It is the foundation for all justification.

Step 2: Write or revise the policy

With the risk analysis complete, write (or update) your alcohol and drug policy. Seven elements must be included: purpose, definitions, rules, testing procedures, consequences, confidentiality and embedding. A detailed review is available in our guide How to write an alcohol and drug policy.

Step 3: MBL negotiation

Drug testing is a matter covered by Section 11 of the Co-Determination Act (MBL). Carry out primary negotiation with the relevant union counterpart. The collective agreement may contain specific provisions that must be respected. Document the minutes of the negotiation.

Step 4: Define test types and frequency

Three common test types are combined in most programmes:

1. New hires: baseline screening before starting work. Communicated in the job advertisement and the contract.
2. Random checks: a recurring programme with a digital selection draw. Frequency is calibrated against risk: 5–10% per year (low risk) up to 50%+ (high risk).
3. Suspicion-based testing: in the event of documented observations or after an incident.

Step 5: Choose a testing provider and collection method

Provsvaret offers three set-ups: a mobile team at your premises, sample collection via a partner unit, or self-administration with a kit. Choose based on volume, location and frequency.

Step 6: Communicate with employees

Random programmes are least controversial when employees know they exist. Communication points:

• On recruitment — as part of onboarding
• In the annual performance review
• When the policy is updated
• As a reminder at each testing occasion

Poor communication is one of the most common reasons a procedure fails in the Labour Court.

Step 7: Train managers and safety representatives

Managers need to know how to:

• Document observations when there is suspicion
• Conduct a structured conversation
• Handle a positive result
• Avoid discriminatory behaviour

Provsvaret offers training covering the entire chain.

Step 8: Set up documentation and a GDPR procedure

• Define the group of recipients (HR + immediate manager)
• Specify the retention period (often 6 months for negatives)
• Update the record of processing activities
• Carry out a DPIA for systematic programmes
• Enter into a data processing agreement with Provsvaret

Details in our GDPR guide.

Step 9: Set up the selection draw for random testing

Use a digital draw from the HR system. Manual selection is problematic because it opens up a risk of discrimination. Define which roles are covered and the frequency in the policy.

Step 10: Define an action plan for positive results

How do you respond to a confirmed positive? A structured process: immediate suspension from safety-critical duties, confirmation analysis, MRO review, rehabilitation assessment and a structured return-to-work programme. The entire process is covered in our action plan guide.

Step 11: Ongoing follow-up

Have a recurring routine (quarterly or every six months):

• Number of tests carried out per category
• Results (positive/negative)
• Time from notification to sample collection
• Rehabilitation cases and outcomes
• Union reactions and adjustments

The documentation is valuable both in a Labour Court dispute and for continuously improving the procedure.

Summary

A working procedure is about structure, communication and documentation — not just about testing. Provsvaret helps you build the entire chain from policy to ongoing implementation. Book a call and we will go through your specific needs.