Kathleen: NO, you CAN’T implement random drug testing under the circumstances you describe even if you wanted to. Not sure if you’ve heard, but last week, the AB Q Ct issued an injunction barring Suncor from enforcing its random drug policy on privacy grounds. And believe you me, their safety compulsion was significantly greater than the one you describe.
Remains to be seen whether Suncor injunction survives appeal but for now at least, Suncor can’t do random drug testing and neither can you. And while Suncor has a good shot at ultimate vindication for random testing, if you have no safety-related drug problems at your site, your chances of random testing (under 2013 S Ct Irving decision) are zero.
Thx.