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A new federally regulated role for clinicians

September 1, 2009
by Reed Morrison, PhD
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Three decades ago, the Three Mile Island nuclear reactor in Middletown, Pennsylvania lurched into a partial meltdown that sent the Nuclear Regulatory Commission (NRC) into a mad scramble to tighten its focus on public safety. The date was March 28, 1979, long before Homer Simpson demonstrated to the nation that nuclear power and unrestrained human frailty did not mix. A full 10 years later, in June 1989, after wending its way through many proposals and amendments, the NRC succeeded in establishing far-reaching rules for the creation of a mandatory Fitness for Duty (FFD) program to be operated at regulated facilities nationwide. The FFD program addressed safety-related problems associated with drug and alcohol abuse as well as mental and physical health issues.

These regulations, referred to as 10 CFR Part 26, were amended several times over the years; the most extensive amendment was published on March 31, 2008. Among the issues delineated in the most recent changes to the FFD program were establishing regulations for managing employee fatigue, addressing FFD issues for plant construction contractors, tightening protocols for drug and alcohol testing and, last but not least, establishing specific qualification guidelines for the role of an “SAE” (Substance Abuse Expert). The new amendments go into effect on March 31, 2010.

The identity of the SAE was hinted at, but never fully fleshed out in the original FFD program. Until the recent amendments, the SAE performed functions that were unofficially in sync with those prescribed for the Substance Abuse Professional (SAP) by the U.S. Department of Transportation. In fact, qualified SAPs were the ones who frequently acted in de facto SAE roles. But next year, the game will change, as the NRC clearly spells out the “who,” “how” and “what” of the SAE role.

The list of who is eligible to become an SAE will be familiar to SAPs: licensed physicians, licensed or certified social workers, licensed or certified psychologists, licensed or certified employee assistance professionals, and alcohol or drug abuse counselors certified by the NAADAC Certification Commission or the International Certification and Reciprocity Consortium (ICandRC).

How to qualify

The road to SAE qualification follows a path that is parallel to SAP qualification in that the prospective SAE must take a qualification training course. There will be no SAE certification. Training courses are in development and are expected to be available this fall.

The NRC, like the Department of Transportation, will not assume a credentialing role. Finally, as in the case of SAP qualification, SAEs will have to provide documentation for 12 CEUs per three-year term in order to maintain qualification status. Beginning on March 31, 2010, SAEs must have qualification credentials.

A warning is in order: SAPs should not assume, because of the structural similarities of the qualification processes, that the content of SAE and SAP training will be the same. This is not the case. SAPs will be familiar with the general outlines of SAE procedures, but the regulations and responsibilities are by no means identical.

For example, the SAP who aspires to become an SAE must learn the procedural and regulatory differences between NRC Fitness for Duty and DOT Return-to-Duty, subtle variations in clinical reporting, testing cutoff level alterations that are permitted by the NRC, and of course the many challenges implicit in learning a new regulatory nomenclature replete with unfamiliar acronyms and regulatory idiosyncrasies.

Take the opportunity

So why should an addiction professional invest time and money in yet another credential? The answer is simple: The SAE designation creates a fresh opportunity for addiction professionals.

This is an opportunity for addiction professionals to demonstrate value, to step forward as uniquely trained professionals who play an indispensable role not only in saving the lives of those suffering from addiction, but also in protecting public safety.

There are more than 100 working reactors in the United States and 32 more in planning stages. (More than 370 new plants are on the drawing board worldwide.) Whether or not we agree with the politics and/or subscribe to the environmental issues surrounding nuclear power, today's energy crisis has rehabilitated this technology as a first-line non-petroleum energy alternative that is well-established and available now. Safety will be the key to its continuing viability-and this guarantees that the SAE will be needed to play a crucial role.

Reed morrison, phd
Reed Morrison, Ph.D. Reed Morrison, Ph.D. is a licensed psychologist and a Substance Abuse Professional who is CEO of American Substance Abuse Professionals (ASAP;

http://www.go2asap.com), a national SAP services provider. His e-mail address is

rmorrison@go2asap.com. Addiction Professional 2009 September-October;7(5):54