Contractor and Subcontractor Fitness for Duty
Authors: Frangos Stephen A. , Rands Duane F. , Fagade Olubukunola A. , Saavedra Monica M. , Hall Danny B. 
Published: September 2012

The goal of a Fitness for Duty (FFD) process is to ensure that all workers are able to safely perform the essential physical, psychological and cognitive requirements of their jobs without risk to self, co-workers or the environment and are not impaired by drugs, alcohol or disabling medical conditions. Every employer and every worker share common goals of workers health and safety, zero accidents and zero injuries. During the last ten years, large employers began implementation of comprehensive medical FFD processes for their employees. The next step in the evolution of the fitness for duty process is to develop and implement FFD processes for contractors and subcontractors.

A general outline of the Fitness for Duty processes for contractors and subcontractors includes the following: 1)Communicate FFD expectations and integrate these expectations into contract requirements.2)Analyze and address implementation gaps, including availability of clinical resources needed for medical evaluations and treatment, and business unit resources (Human Resources, Health, Environment and Safety and Line Management) for program implementation.3)Identify and train job evaluators and clinical providers to perform functional capacity evaluations.4)Prepare a written description for each job that includes a clear description of the essential physical requirements and working conditions of the job and identifies whether the job position is "safety-sensitive".5)Perform FFD determinations for workers against these job-specific physical requirements. The scope of the evaluations may include post-offer/pre-placement, job transfer, periodic evaluations for current workers, for cause (evaluations when a potential health or safety risk is identified or following an incident in the workplace), return to work (evaluations when a worker returns from a leave of absence for medical reasons of greater than five days, emergency responder health, expatriate health and business traveler health.6)Assign only workers who meet the essential functions of their job position, with or without accommodation.7)Maintain records that document the completion of the above requirements.8)Develop a Competency Verification Process to ensure that all workers meet the job specific requirements that are documented for their job position and that all workers performing specific job tasks are certified, registered or licensed as required by applicable laws. In addition, ensure that medical records are maintained in compliance with data privacy regulations and appropriate medical confidentiality.9)When contractor and subcontractor FFD processes are in place, an audit process will be utilized to ensure process compliance and identify opportunities for process improvements.

Definitions: – Employer: the company with operational control of the worksite or business operation – Contractor and Subcontractor: a company or individual hired by the employer to perform work – Job evaluation: documentation of a job's physical requirements and working conditions – FFD Determination: assessment of a worker's ability to meet the essential physical, psychological and cognitive requirements of the job. – Remedial action plans: recommended exercises and activities to enable an individual to meet the essential physical requirements, psychological and working conditions of the job; also includes consideration of work accommodations or alternate work. – Safety-sensitive positions: job positions where workers have direct or indirect control of situations that can result in undesirable events. The worker's immediate supervisor and the next level of management are also included because of their ability to control the acts their workers. Process, maintenance, and transportation operations that include hazardous chemicals, toxic materials, flammable liquids and gases, high pressures, combustible dusts, underground operations, and vehicle or motor equipment operation are safety-sensitive because of their potential adverse impact on co-workers, company operations, the public or the environment.