A critical first step in diversion prevention is employee screening; concern with personnel security must start before an employee is hired. Pre-employment screening to identify potential security problems is important when choosing new employees to work in or around areas where controlled substances are handled. The screening program should include a careful evaluation of the applicant’s personal and previous employment references. Criminal background checks with local law enforcement authorities and with DEA are equally important. Similar precautionary measures should be taken before transferring established employees to new jobs in areas where controlled substances are manufactured, processed, stored, shipped, dispensed, or handled in any way.
In order to fairly assess the likelihood of an employee committing a drug security breach, it is essential that non-practitioner registrants carefully screen individuals before hiring them. Of the utmost importance is a determination of convictions for crimes and unauthorized use of controlled substances. To this end, DEA recommends that the following two questions become a part of and employer’s comprehensive screening program:
1. Within the past five years, have you been convicted of a felony, or within the past two years, of any misdemeanor, or are you presently charged (formally) with committing a criminal offence? Do not include any traffic violations, juvenile offences on military convictions, except by general court-martial. If the answer is yes, furnish details of conviction, offense location, date, and sentence.
2. In the past three years, have you ever knowingly used any narcotics, amphetamines, or barbiturates, Other than those prescribed to you by a physician? If the answer is yes, furnish details.
DEA also recommends that an authorization, in writing, be completed by a person who is allowed to or is considered for work in a controlled substances area. This authorization should permit inquiries to be made of courts and law enforcement agencies concerning pending charges or convictions. Information on employees criminal records should then be used as follows:
1. Locally by name, date and place of birth, and other identifying information, inquire at local
courts and law enforcement agencies for records of pending charges and convictions; and
2. Nationally by the same identifying information make and inquiry at the appropriate DEA Field Office.
In addition, pre-employment screening should be by written application which covers such areas as credit checks, residences, educational background, military history, character, reputation, and past employment. All applications should strongly warn that any falsification will result in dismissal and that data will be verified. Post-employment screening is also very important. Events in employees lives can change their reliability and integrity. Employees and supervisors should be encouraged to be on the lookout for troubled employees. Payroll and personnel offices should advise security officers of inquiries by creditors or attempted garnishment of wages. When employees are considered for promotion to positions of greater responsibility, additional comprehensive screening may be appropriate.