drug testing in the workplace: an overview of legal and philosophical issues

Employee Responsibilities and Rights Journal, 1Iol. 2, No. 1, 1989

Drug Testing in the Workplace: An Overview of Legal and Philosophical Issues

Patricia A . Greenfield, 1 Ronald J. Karren, 1 and Jane K. Giacobbe 2

This article examines a range o f legal and philosophical issues related to the drug- testing debate. The discussion o f legal issues includes potential litigation on constitutional grounds (for public employees), statutory and tort grounds, or on the basis o f civil rights legislation. Arbitration standards are also examined for situations involving unionized employees. The article further highlights pragmatic issues including the accuracy and costs (economic and noneconomic) o f drug tests as well as the dis- tinction between a positive drug test and impaired performance. Finally, the article addresses the delicate balance between an employer's right to unimpaired performance and an employee's right to privacy.

KEY WORDS: drug testing; legal and philosophical aspects of drug testing; arbitration and drug testing; accuracy and costs of drug testing.

INTRODUCTION

Item: Jane Doe comes into work Tuesday morning. Instead of reporting to her desk, she is told to go to the ladies' room with all other employees and a supervisor and to produce a urine sample for the purpose of testing for drugs. She tests positive for illegal drugs and is told she must either attend a drug rehabilitation program or be dismissed. She will be retested at the end of the rehabilitation period and if the test is again found positive, she will be dismissed.

This scenario, which has been repeated in a number of workplaces over the last several years, has given rise to much public debate over the appropriateness of drug testing in the workplace. The debate has involved a variety of groups, including poli- ticians, doctors, lawyers, scientists, arbitrators, managers, unions, and individual workers, and has encompassed a range of legal, attitudinal, economic, arbitral, ethi- cal, and policy issues.

The articles in this symposium address a number of questions concerning these issues. Questions include: Where does the law stand in regard to drug testing? What

1Department of Management, School of Management, University of Massachusetts, Amherst, Massachusetts 01003.

2Department of Management, The University of Texas at Arlington, Arlington, Texas 76019.

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0892-7545/89/0300-0001506.00/0 �9 1989 Plenum Publishing Corporation

2 Greenfield et al.

factors (costs and benefits) do employers take into account in deciding whether or not to test for drugs? Is drug testing a factor in a prospective employee's decision to join an organization? Do union, as opposed to nonunion, firms take different approaches to drug testing? What factors do arbitrators consider significant in their examination of drug testing cases? What range of attitudes exists toward certain employer actions, including drug testing?

These questions give rise to a set of broader normative questions related to employee and employer rights and responsibilities. Should the employer have the right to test employees for drugs? Should employers test applicants and/or employees for drugs if the tests are inaccurate or are not indicative of on-the-job drug usage? Should employers take into account the attitudes of employees and applicants in determining whether or not to drug test? Do employers have the right to condition employment on the results of a test that may or may not reflect job performance? Should employees have the right to refuse to be tested for drugs? If they are to be tested, should they have protections from certain forms of testing? Do employees owe their employer the obligation to be "drug-free"? Should employers assume the role of police officers in enforcement of narcotics laws?

These normative questions relate to individual and institutional value judgments and, thus, cannot be answered in any definitive manner. It is the purpose of this article to identify, discuss, and refine these questions and to raise considerations that may lead to intelligent and informed discussion and decision making.

Much of the debate over employer and employee rights and responsibilities concerning drug testing has been reflected in judicial and arbitral rulings. We will begin our discussion with an examination of the legal issues raised by the above questions. This is not to suggest that the law always tells us what is "right," but in setting out certain accepted standards of legal conduct, the law often reflects and directs societal value judgments. Arbitration rulings will also be discussed because of their important role in unionized workplaces. The cases referred to in the following section are discussed in detail in Greenfield (1989) and Seeber and Lehman (1989), in this issue.

THE LEGAL AND ARBITRAL ISSUES

What are some of the critical criteria in determining Jane Doe's legal rights? If she is a public employee, she is entitled to constitutional protections including those against unreasonable search and seizure, invasion of privacy, and governmental action without due process of law. If she is a unionized employee, she has a right, through her union, to bargain about the implementation of the drug test and to pur- sue points of disagreement to arbitration. If she is a nonunion private employee, her main rights of legal action lie in a variety of state and federal statutes and common law tort and contract claims. Her position as a current employee gives her more potential legal rights than if she were a job applicant. If her job involves safety issues, then the courts, arbitrators, and state statutes or local ordinances limiting drug testing are more likely to allow her to be tested. The examples noted above illustrate a significant assumption underlying our concept of employment rights: the rights granted to an employee by the State and, thus, the balance of power in the employer- employee relationship, depend to a significant extent on her employment status, including the nature of her job.

Drug Testing in the Workplace

The law also raises questions concerning basic concepts of individual privacy. A drug test is by its very nature intrusive, qualifying under constitutional law as a "search and seizure." In cases involving public employees and thus implicating constitutional rights, the courts have at tempted to balance legitimate governmental in- terests in conducting such a search against the employee's right to privacy both inside and outside the workplace. A number of courts have noted national concern over illicit drug use, citing the President's Executive Order, the prevalence of private employer drug testing, and the costs of employee drug use (e.g., National Treasury Em- ployees Union v. Von Raab, 1987). The Iron Raab court also noted, however,

The seriousness of the problem has led to efforts to combat drug use by the use of novel methods, such as compulsory testing~ Adoption of these methods, however, has created concern that constitutional rights may be abridged in the process. Even the war on crime must be fought by constitutional methods for the Constitution protects the guilty as well as the innocent and proscribes condemned means even when they are used to laudable ends. (p. 173)

Thus, even where the courts acknowledge the existence of a national problem, certain recognized rights must be respected. To determine, for example, whether an individual's constitutional privacy rights are violated inside the workplace, one must examine the type and degree of invasion that takes place. If, for instance, in our hypothetical case, Jane Doe is accompanied into the stall of the ladies room by a supervisor who watches her urinate, the courts are more likely to find a level of hu- miliation constituting a violation of privacy rights than if she were left on her own (Capua v. City o f Plainfield, 1986).

Drug tests implicate privacy rights outside the workplace because these tests do by their nature inform the employer of off-work drug use; Jane Doe can test positive for mar i juana Tuesday morning even if she used the drug at a Saturday night party. The test's inherent element of monitoring off-work behavior is of great concern to arbitrators, who tend to look for evidence of on-the-job impairment in determining whether to uphold discipline based upon a positive drug test (Denenberg & Denenberg, 1987). This concern about monitoring off-work behavior is also evident in a number of court rulings that look for some e v i d e n c e - m o s t often in the form of reasonable individualized s u s p i c i o n - o f work-related drug use, before deciding to uphold an employer's decision to test or to rule for an employee or union challenging the test on the basis of constitutional or common law. The issue of the relationship between drug use and work performance has also been raised by the American Medi- cal Association House of Delegates. This organization advocates limiting drug testing to situations where there is reason to believe performance is impaired and to preemployment examinations for positions that affect other individuals' health and safety (Bureau of National Affairs [BNA], 1987a).

In addition to concerns regarding standards of p roof and the relationship between work performance and drug use, courts and arbitrators look for certain due process protections in deciding whether a particular drug test is justifiable. These protections may include: whether advance notice of the test has been given to the employee, whether the test used has a record of accuracy, whether a qualified labora- tory evaluates the test, and whether an employee has a right to challenge the test.

In a 1986 arbitration case, arbitrator Edward Koenig wrote about the connec- tion between the concepts of fairness and due process and the issue of employee impairment:

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Since the employer does not have the right to become involved in the employee's lifestyle until or unless it adversely affects his/her work performance, conduct, or safety on the job, or adversely affects the company image or operations, or leads other employees to refuse to work with him/her, the employer must be meticulously fair in how such discovery is made. This is doubly important since the employer may be faced with carrying the burden of proof of just cause before an arbitrator or answering a personal damage or liability suit in front of a judge. (Oil Transport Company, 1986) [Emphasis in original]

While the courts and arbitrators emphasize the significance of a range of employee rights of p r i v a c y - b o t h during work and in regard to off-work l i f es ty le -and due process, they also address issues of employee responsibility. This concept of responsibility relates only partially to the performance owed the employer; if Jane Doe's job performance went down drastically and there was some reasonable suspicion of drug use, most courts would allow an employer to test for drugs.

The law, however, often takes into cons ide ra t ion-and sometimes even con- siders p r i m a r y - t h e employee's responsibility toward the general public and fellow employees. Such responsibility is particularly important when an employee is in a position dealing with the safety and health of the public or government positions defined as "critical," a term that often relates to law enforcement or government drug policy. Courts are more likely to allow random drug testing of Jane Doe and her fellow employees if they are nuclear power plant employees than if they are clerical workers. States and municipalities that have limited employer's rights to test for drugs often allow testing of employees in certain types of jobs, including those that are "safety-sensitive" or present a danger to others. On the other hand, responsibility for public safety does not automatically justify drug testing, as illustrated by a number of the court cases that reject the use of random drug tests for police and fire- fighters.

As the foregoing discussion illustrates, laws, arbitration decisions, and employers' policies are still in the embryonic stages, although some societal norms appear to be emerging. Therefore, it is difficult to clearly define all of the conditions under which an employer absolutely may or may not conduct drug testing. However, if we assume for the moment that testing, per se, is lawful, there are a number of important issues that arise with respect to the test itself.

TESTING ISSUES

In this section, we examine some issues related to the testing of Jane Doe. Should we test Jane Doe for drugs if the test we use is not very accurate? Jane Doe has been tested with the Enzyme Multiplied Immuno-Assay Technique (EMIT), a urinalysis procedure that is relatively inexpensive, at a cost of $6-$15 per sample. The problem with this test and many others like it is their level of accuracy. Although the esti- mates differ, many of those who test positive for drugs are actually false positives; that is, they are incorrectly labeled with drugs in their system when they are actually "clean." A Northwestern University study of the EMIT tests found that 25o7o of the positive EMIT tests were false positives (Dentzer, Cohn, Raine, Carroll, & Quade, 1986). One of the problems is that many over-the-counter drugs and common foods have been found to trigger a false positive result. The high error rates are also the result of deficiencies in the technology, and mistakes in handling and interpreting

Drug Testing in the Workplace 5

the test results (O'Keefe, 1987). If employees are falsely identified with the EMIT test and no further testing is done, innocent people will be stigmatized as drug users and could lose their jobs.

There are more accurate tests, such as the GC/MS (gas chromatography/mass spectrometer), that are suggested by many experts to confirm samples that initially test positive. The reason they are less popular is that their cost generally ranges from $30 to $65 per sample (Roth, 1987). Should companies be expected to confirm a positive EMIT test with these more expensive procedures? Is it possible to exonerate Jane Doe when she already has been identified as a drug user from the less accurate EMIT test?

If the more expensive tests are always used and the company believes that its tests have near-perfect accuracy, should Jane Doe be tested if she has been a success- ful performer? In reality, 100% accuracy is an inappropriate assumption since we have already identified a number of problems regarding all forms of urine screening such as labeling, handling, and preservation of samples (Roth, 1987). However, for the sake of argument, let us assume that we have attained this level of accuracy. Then, is drug use or an individual's job performance the proper criterion? In other words, should the employer be concerned about drug use or should the concern be job impairment?

It is very possible that Jane Doe took drugs during a Friday night party over a week ago, is performing at high levels while at work, but tests positive. A positive result does not indicate the recency of use and it does not distinguish an addict from a recreational user. Should the company intervene when there is no evidence that the drug has affected Jane Doe's performance on the job? Furthermore, deficient performance may be due to a variety of factors unrelated to drug abuse (e.g., personal problems, poor health, or a bad match between the employee and the job). This con- fusion is compounded when we realize that different drugs have very different effects.

The relationship between drug usage and job performance is particularly important for compliance with equal employment laws. Drug testing of job applicants is, in fact, a selection device. Other selection techniques, such as cognitive ability tests, reference checks, and personal interviews, have been under close scrutiny since the passage of the 1964 Civil Rights Act. Generally, when a selection technique has a "disparate impact" on a protected group, the employer must demonstrate the validity of the selection technique. The most commonly used criterion for determining validity is whether the selection tool predicts future job performance. For example, typing tests for secretarial applicants would be generally considered as valid; person- ality tests for computer programmers would not.

As a selection tool, drug testing may also be subject to the job performance criterion. For example, Jane Doe is a member of a protected group (women). It is possible that members of protected classes (e.g., blacks, Hispanics, Asians, Ameri- can Indians, and women) may be overrepresented among those who test positive for drugs. If the result is that the drug testing program results in lower selection ratios (number selected divided by the number who apply) for members of these groups or a higher percentage of those fired, then the employer must be prepared to demonstrate job relatedness or business justification for the disparate impact (Uniform Guidelines, 1978). Since there is no direct link between a positive test and future or current job performance, it would not be easy to provide this type of justification (Lorber & Kirk, 1987).

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Furthermore, if Jane Doe were black, one of the errors related to the tests is the potential for racial bias. According to James Woodford, an Atlanta forensic chemist, melanin, which is a dark skin pigment, can break down in the urine in similar ways to the substance that indicates marijuana use. Thus, it is possible that per- sons with dark skin pigmentation have a higher probability of becoming a false positive for marijuana use (Lindsey, 1986).

This issue becomes more complicated when we realize that at any time, for any reason, members of one of the above protected groups may have a higher incidence of positive tests than the majority group. If the case is brought to the courts, the employer is still obligated to show that the test is a valid, reliable mechanism and its use is justified.

EMPLOYERS AS SOCIETAL GUARDIANS

Are organizations testing because they are trying to set societal policy through the monitoring of workers, or are they merely attempting to ensure efficient performance in the workplace? Is Jane Doe being tested because her job performance is impaired or is she being tested so that the employer can create a "drug free" work force? There is evidence that some companies are trying to set social policy. For example, in a Wall Street Journal article, a director of human resources stated: "We want to create a workplace mentality where people say, 'If I work at Kidder, I don't do drugs'" (Waldholz, 1986). In a similar vein, some 25 of the largest corporations in America have created a coalition to promote a drug-free environment. One of the purposes of this organization is to block state laws that limit the private employer's right to test for drugs (BNA, 1987b). President Reagan's Executive Order 12564 condemning federal employee drug use on or of f duty was also consistent with this concern with broader social policy.

If organizations were merely trying to ensure efficient performance, they would be more likely to directly identify impaired performance rather than test for drugs. As explicated in the previous section, there is little, if any, evidence that positive drug tests are linked to job performance. In addition, there is also a clear employer value judgment involved in the employer's decision to test for drugs as opposed to testing for alcohol (Wisotsky, 1987). In fact, the evidence indicates that alcohol abuse is a more prevalent and costly workplace problem in the United States than drug abuse. According to the Employee Assistance Society of North America, productivity losses due to alcohol were $30.8 billion, while losses due to drug abuse were $8.3 billion. Another analysis by North Carolina's Research Triangle Institute estimated productivity losses due to drug and alcohol abuse to be approximately $100 billion in 1983. Of these losses, alcohol abuse was twice that of drug abuse (BNA, 1986). Despite the easy availability of mechanisms to test for alcohol, most employer resources have been aimed at testing for drugs.

One may defend the inconsistency in drug as opposed to alcohol testing because many drugs are unlawful. However, if the employer's concern is job performance, the legality of the substance should be irrelevant to the testing decision. To the extent that employers are basing their testing decision on the legality of the substance, they are, in essence, assuming the role of law enforcement agencies. Setting aside


the question of whether it is appropriate for an employer to assume this role, there remains the question of whether employers have a responsibility to accord due process protections similar to those that exist for criminal prosecution. Thus, probable cause would precede search and seizure and the accused would have a right to counsel and a fair hearing.

However, if the concern of employers is truly job performance and related productivity losses, employers should be aware that there are potential costs from testing as well. Implementing drug testing policies can have costs aside from productivity losses. Studies in this symposium indicate that there is a significant group of employees and applicants who believe testing for drugs is inappropriate (Garland, Giacobbe, & French, 1989, this issue). Some find this invasion of privacy so abhor- rent that they are unwilling to join organizations that do test for drugs (Karren, 1989, this issue).

A number of employers recognize that the problems of invasion of privacy, the inaccuracy, costs, and interpretation of the tests are important factors and therefore choose not to test; others believe that health, safety, and productivity costs associ- ated with drug use justify the decision to test. (See Karren, 1989, this issue, for a further discussion of these factors.) Certainly, workplace safety is a significant concern. Employees whose job performance is impaired by drugs can cause accidents injuring fellow employees or members of the general public. Some states, limiting employers' rights to test for drugs, have recognized this and have exempted employees in safety-related positions from these limitations. (See discussion in Greenfield, 1989, this issue.)

Employers who choose to test have other job-related concerns in addition to safety. A human resource director at a financial services company states, "We can't af- ford to risk what results from that casual [drug] use, whether it affects the job or a person's financial integrity. Security in an industry dealing with billions of dollars demands that." On the other hand, the director of an engineering company replies that good employee relations and a testing program are " . . . inimical. Ours is based on a relationship that doesn't just come from a paycheck. When you say to an employee, 'You're doing a great job; just the same I want you to pee in this jar, and I'm sending someone to watch you,' you've undermined that trust" (Waldholz, 1986).

If the employer does decide to test and the test results are positive for drug usage, should the employer fire the employee or should the employer give the employee the opportunity to enter a rehabilitation program, as was the case with Jane Doe? What implications does the choice between rehabilitation and punishment have for both good employee relations and public policy?

Many employers have employee assistance programs (EAPs) that serve employees with problems of alcohol abuse. Certainly the same mechanisms can be used to serve employees with drug abuse problems (Sonnenstuhl, Trice, Staudenmeir, & Steele, 1987). Several problems may arise, however, when a rehabilitation program is cou- pled with a drug testing program. A director of an employee assistance program oper- ated by the AFL-CIO states that a drug testing program could be harmful to the EAP, because the employees will see the testing program "as a detecton and discipline device, and thereby destroy Employees' trust that the employer is trying to help t h e m - a critical element to EAP success" (BNA, 1986, p. 44). Another problem is that workers may be improperly placed into a rehabilitation program for two reasons: first, on

8 Greenfield et al.

the basis of an erroneous test result; and, second, they are classified as addicts when they are only occasional recreational drug users. This creates problems not only for the individual who is unfairly stigmatized, but also for the integrity of the program, which is then put in the position of spending time, money, and resources attempting to rehabilitate individuals who do not require rehabilitation.

We noted above that the decision to test for drugs can be used to effectuate broader societal policies of keeping the workplace drug free. The decision whether to punish or rehabilitate can also have significant societal consequences. To test and then discharge an employee with a serious drug problem provides no incentive to rehabilitate, and takes away from a person with a serious drug problem his or her ability to earn a livelihood. On the other hand, to rehabilitate with the assurance of a job at the end of the rehabilitation period may be a powerful incentive for an employee with a serious drug problem to take steps to cure that problem.

WORKPLACE RESPONSIBILITIES A N D SUPERVISION

Societal norms dictate that each employee has a responsibility to perform "an honest day's work for an honest day's pay." If there is a relationship between drug usage and performance, the first visible effect of drug abuse should be apparent in the employee's job performance. Furthermore, despite the erosion of the employment- at-will doctrine, the employer has substantial rights in discharging an employee for poor performance, regardless of whether it is caused by drugs, alcohol, personal problems, or bad karma.

It is generally the responsibility of employers to identify poor performers. Su- pervisors generally have the responsibility of appraising the performance of their subordinates, differentiating between acceptable and unacceptable performers. One danger of drug testing is that it can become a proxy for reasonable supervision (Denen- berg & Denenberg, 1987). As one arbitrator pointed out, drug testing, particularly random testing with no probable cause or reasonable suspicion, "allows supervisors to shift their assigned responsibility to someone else, while it is they who are required to perform their personnel functions" (Oil Transport Company, 1986).

Finally, there are some jobs where it would be dangerous to wait for, and sub- sequently address, poor performance. The consequences of an error in certain occupations (e.g., pilots, air traffic controllers, nuclear plant operators) can be tragic and irreversible. Without a doubt, there is an overwhelming public interest in assuring that employees in these occupations are fit for work. Drug tests may be warranted for such occupations, if the tests become sophisticated enough to differentiate cur-, rent impairment from benign chemical residue. A drug test would not necessarily certify that an employee was fit for work, but could be considered along with other information on mental, emotional, and physical health.

CONCLUSION

Clearly there are valid arguments on both sides of the drug testing debate. One of the strongest arguments for drug testing is the employer's obligation to ensure a


safe workplace and to ensure that employees do not endanger the public, co-workers, or themselves. In addition, many employers would argue that they have the right to conduct such testing as an inherent part of their managerial rights, particularly private employers who have few legal constraints. As Rothstein (1984) notes in his book on the medical screening of workers, employers can discriminate based on a range of criteria, including appearance, political affiliation, or sexual preference. Why, then, should an employer not screen all workers for drugs?

There are a number of strong arguments against drug testing, some based on economic concerns, most of them based on legal and societal concepts of fairness and employee rights. First, drug testing, particularly random drug testing, "requires the vast majority of employees to prove their innocence when there's no reason to suspect they've done anything wrong," a presumption contrary to our society's value of innocent until proven guilty (Maltby, 1987, p. 152). Second, urinalysis, particularly with an observer present, is at best intrusive and at worst humiliating. Third, it is clear the test does not measure workplace behavior or impairment; it elicits information concerning the employee's private life, an area where courts, arbitrators, and a number of employers believe is "beyond the employer's legitimate sphere of con- trol" (Maltby, 1987). Fourth, research indicates that the less expensive and more popular test has a high frequency of false positives; these errors lead to the unfair dismissal or unnecessary rehabilitation of certain employees. These arguments for and against drug testing reflect the complexities of the testing issue and the significant impact testing has on employee rights, particularly the right to privacy.

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Bureau of National Affairs (1987a, June 30). AMA calls for limitations on job drug testing programs. Daily Labor Report No. 124. Washington, DC: BNA.

Bureau of National Affairs (1987b, August 31). Corporations meet to consider drug-free workplace coalition. Daily Labor Report No. 167. Washington, DC: BNA.

Capua v. City o f Plainfield, 643 F. Supp. 1507 (D.N.J. 1986). Denenberg, T. S., & Denenberg, R. V. (1987). Drug testing from the arbitrator's perspective. Nova

Law Review, 11, 371-413. Dentzer, S., Cohn, B., Raine, G., Carroll, G., & Quade, V. (1986, May 5). Can you pass the job

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dary smoke, VDT's. Alexandria, VA: The ASPA Foundation. Maltby, L. L. (1987, June). Why drug testing is a bad idea. Inc., pp. 152-153. National Treasury Employees Union v. Von Raab, 816 F.2d 170 (5th Cir. 1987). Oil Transport Co., unpublished opinion, FMCS Case No. 86 K/17811 p. 13, Koenig Arb. (1986). O'Keefe, A. M. (1987). The case against drug testing. Psychology Today, 21(6), 34-38. Roth, J. D. (1987). An introduction to drug screening tests. The Labor Law Exchange: Drug Testing in

the Workplace. Washington, D.C.: AFL-CIO Lawyers Coordinating Committee. Rothstein, M. (1984). Medical screening of workers. Washington, DC: Bureau of National Affairs.

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Seeber, R., & Lehman, M. (1989). The union response to employer initiated drug testing programs. This issue, Employee Responsibilities and Rights Journal, 2(1), 38-48.

Sonnenstuhl, W. J., Trice, H. M., Stoudenmeir, W. J. Jr., & Steele, P. (1987). Employee assistance and drug testing: Fairness and injustice in the workplace. Nova Law Review, 11, 709-731.

Uniform Guidelines on Employee Selection Procedures (1978). Federal Register, 43, 38290-38315. Waldholz, M. (1986, November 11). Drug testing in the workplace: Whose rights take precedence? Wall

Street Journal, p. 37. Wisotsky, S. (1987). The ideology of drug testing. Nova Law Review, 11, 763-778.

drug testing in the workplace: an overview of legal and philosophical issues

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