TTC Drug Testing: Update

So the TTC has announced its intention to introduce drug-testing for employees, but it backed off significantly from its earlier threat to use random drug testing, a process that raises human rights issues.  Under the new policy, according to press reports, “TTC workers in safety-sensitive jobs will be tested if there is reasonable suspicion they have been using banned substances on the job or following an incident in which drug or alcohol use is suspected as a factor.”   In other words, there needs to be reasonable suspicion of drug or alcohol use, and the person must be in a ‘safety-sensitive’ job.  
More mysterious is the claim in the news stories that ‘applicants’ will be subjected to the tests.  It’s not clear whether that means all applicants, or just applicants that appear drunk or to be on drugs.  Do you think that the TTC can require job applicants to ‘pee into a jar’, to borrow the words of the Union President without running afoul of the Human Rights Code prohibition on discrimination on the basis of disability (which includes drug and alcohol addiction)?