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The first and most important
step in a drug-or alcohol-free workplace program is to develop a
policy that makes your position about drug and alcohol use in the
workplace very clear. You have clear guidelines on attendance, performance,
conduct, and even smoking in the workplace; why shouldn’t you
also have a policy that tells employees not to be present at work
with drugs or alcohol in their systems?
Such a policy should also
have reasonable business objectives. You should provide notice of
the violations that will result in disciplinary action. The policy
should be written, acknowledged in writing by all employees, and
prominently displayed for a reasonable period before instituting
it.
At a minimum, the following
elements need to be addressed in the policy statement:
• Your overall position
on drug and alcohol abuse (e.g., drug and/or alcohol abuse is a
medical problem, often a legal problem, but always unacceptable
in the workplace);
• Your position on the
consequences for an employee using, selling, or possessing drugs
or alcohol in the workplace (discipline, termination, due process,
etc.);
• Your position on job
performance as it relates to drug and alcohol use;
• Your position on safety
of the public, your clients, and the abuser’s co-workers as
it relates to drug and alcohol use;
• Your position on treatment
and rehabilitation services available to employees who have drug
and/or alcohol problems, including who will be responsible for paying
for such treatment;
• The responsibility
of the employee to seek treatment;
• The need for strict
confidentiality for employees who are in treatment, and procedures
for dealing with any violation of confidentiality;
• How you will enforce
the policy? For example, will supervisors be trained to conduct
interventions? Will employees be subject to searches? Will drug
and/or alcohol testing be included in the program? If testing is
to be included, what types of testing will be conducted: random,
post-accident, reasonable cause, post-rehabilitation, etc.?
The policy should define
key terms such as “illegal drugs” and “post-accident
testing.” The policy should prohibit employees from “being
at work with any detectable trace amount of drugs or alcohol in
their system.” The policy should refrain from prohibitions
such as “being under the influence” or “impairment”
since drug tests cannot establish either of these situations. A
drug test can only detect the “presence” of a drug metabolite
or the “presence” of alcohol.
Avoid mixing policy with
procedures. Your policy should rarely change, but procedures can
and probably will change periodically. Procedural issues should
be defined in a separate document, not the policy.
If you plan to conduct drug
and/or alcohol testing of employees and job applicants, that should
be disclosed in your policy.
If you have an EAP, workers
should be informed in the policy about the program and be encouraged
to use it. However, the initiation of discipline following a drug
or alcohol infraction should not be postponed pending the employee’s
involvement in such a program.
Once a policy is adopted,
all employees should know what is expected of them by the employer
and what they can expect from the employer.
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