The Haverford Township School District Policy Committee on May 15 reviewed a proposed new consolidated employee policy on prohibited controlled substances, drug and alcohol use (Policy 350) and an accompanying administrative regulation that preserves extra testing rules for covered school bus drivers.
Committee members said the consolidation pulls together three or four older policies into a single employee-focused policy and asked staff to confirm how state medical-marijuana law and federal drug-testing rules interact and what numeric alcohol thresholds the district must use for drivers.
Justin, staff member, said the draft combines definitions from previous policies, adds a reasonable-suspicion section and moves driver-specific testing rules from former Policy 810.1 into an AR labeled 350 AR‑1. “We reorganized, really all four of those together and made uniform definitions throughout,” Justin said. He told the committee the driver testing language largely comes from federal regulation and the former 810.1 policy.
Why it matters: the consolidated text would set the district’s approach to employee testing, on-duty conduct and how the district treats employees who hold state-issued prescriptions for marijuana or other controlled substances while also receiving federal funding.
Committee discussion and key details
- Medical marijuana and prescriptions: Committee members asked whether the policy should explicitly tell employees with state-prescribed medical marijuana or other prescriptions to notify administration and make clear that being under the influence on school property remains prohibited. Justin said guidance the state promised years ago was not issued and that the district must balance state law with federal grant obligations, adding, “you still can't be utilizing it or in possession of it on school property.” Committee members asked staff to add language that employees with prescriptions notify administration and that the “under the influence” rules still apply.
- Definition of alcohol: Members noted the policy’s current definition of alcohol refers only to “beverage” and recommended broadening it to “any beverage or other substance containing alcohol” to avoid loopholes for liquid medicines or nonstandard formulations.
- Driver testing thresholds and legal alignment: The AR for covered school bus drivers preserves numeric thresholds that committee members found inconsistent or possibly outdated (references to blood-alcohol concentrations of 0.02, 0.04 and a struck 0.1). Committee members asked staff to verify whether the AR should align with Pennsylvania’s current 0.08 per‑se limit and which specific numeric triggers come from federal regulation for drivers. One committee member said federal rules drive some required numbers for drivers; another noted the operational point that testing often follows observed behavior and that a later test result may not reflect the level at the time of duty.
- Reasonable-suspicion testing and observable behavior: The committee emphasized that reasonable-suspicion determinations are intended to be based on observed behavior and that testing frequently follows an incident or assessment rather than preceding duty. One member summarized: “The standard is really the observations of how an individual is behaving.”
- Random testing and scope: Staff confirmed that transportation already uses a contracted vendor to conduct federally required random testing of drivers; the committee asked the AR to explicitly allow district-run random testing as well as federal testing.
- Driver definitions: Committee members asked staff to clean up an older definition that used the phrase “casual, intermittent or occasional” drivers and to replace it with clearer terms (for example, “part-time driver”) or remove it if unnecessary.
Direction to staff and next steps
- Staff were directed to: (1) check the Pennsylvania Medical Marijuana Act and any Pennsylvania Department of Health guidance; (2) compare the AR’s numeric alcohol thresholds to current Pennsylvania law and federal driver regulations; (3) update the alcohol definition to include “other substance containing alcohol”; (4) remove or clarify antiquated phrasing such as “casual” drivers; and (5) add explicit language describing the district’s practice that employees with a prescription should notify administration and that being under the influence on school property remains prohibited. Justin indicated he will review PSBA model language and applicable statutes and return with revisions.
Ending: The committee treated Policy 350 and the driver AR as linked items and agreed to hold both for further legal and model‑policy review before advancing them to a first reading.