What Is the NRC Fitness-for-Duty Program?

The NRC fitness-for-duty (FFD) program rules are in 10 CFR Part 26. They apply to licensees authorized to operate nuclear power reactors, licensees that possess, use, or transport formula quantities of strategic special nuclear material, and certain construction-stage license applicants and permit holders, with different subparts applying to different groups. A contractor or vendor program is covered to the extent a licensee relies on it. Part 26 does not apply to spent fuel storage facility licensees or to non-power facility licensees that possess formula quantities of irradiated strategic special nuclear material (10 CFR 26.3).

FFD programs must provide reasonable assurance that individuals are trustworthy and reliable as shown by avoiding substance abuse, and that they are not under the influence of any substance, legal or illegal, or impaired from any cause that adversely affects their ability to perform their duties safely. Programs also provide for early detection of individuals who are not fit, workplaces free from the presence and effects of illegal drugs and alcohol, and management of fatigue (10 CFR 26.23).

At a nuclear power plant, the rules cover individuals granted unescorted access to protected areas and those required to report to the Technical Support Center or Emergency Operations Facility. Individuals who perform listed duties, such as operating safety-significant systems, fire brigade duties, or security duties such as armed security force officer, alarm station operator, response team leader, or watchman, are also subject to the work hour controls (10 CFR 26.4).

Program elements include:

• Drug and alcohol testing. Tests are given pre-access, for cause, post-event, as follow-up, and on a random basis. Random testing must equal at least 50 percent of the population subject to the FFD program each year (10 CFR 26.31(d)(2)(vii)). The minimum panel covers marijuana metabolite, cocaine metabolite, opioids, amphetamines, phencyclidine, and alcohol (10 CFR 26.31).
• Training. Individuals learn the FFD policy, the roles of others such as the MRO and EAP staff, and how to detect impairment. They pass an examination with a minimum score of 80 percent before initial authorization and complete refresher training on a nominal 12-month frequency, unless they pass an annual examination instead (10 CFR 26.29).
• Behavioral observation by individuals trained to detect signs of drug or alcohol use or impairment (10 CFR 26.33).
• An employee assistance program offering confidential assessment, short-term counseling, referral services, and treatment monitoring (10 CFR 26.35).

Part 26 also has separate subparts for fatigue management, construction sites, and facilities licensed under 10 CFR Part 53.