Drug-Free Workplace: Support Core Business?

Editor’s Note: This is the second article in a 2-part series on workplace substance abuse. The series is adapted from work originally done by our founder, Dean Wisecarver. Those of you who remember him fondly may be interested to hear that he is now enjoying his well-earned retirement. To review Part 1 of the series, published in our Jul-Aug-Sep, 2009 issue, under the title "Drug Screening Programs: Benefit Or Bane?" just scroll to that article.

Try this quick "true or false" quiz.

Companies can comply with the Drug-Free Workplace Act of 1988 by implementing a drug screening/testing program.
Unfortunately, most of the time and money a company must spend to create and sustain a drug-free workplace program takes time and money away from operating its core business.
Besides an actual testing program, if you want to make a drug-free workplace program effective, your supervisors must know how to recognize the symptoms of substance abuse so that they can tell the difference between someone who just isn't performing well on the job and someone who has a real substance abuse problem.
If a company can afford it, the best way to implement a drug-free workplace program is to hire an outside testing company to come in and set it up.

All four statements are false. If you believe any of the statements above is true, you are not alone. I hope this article will give you and others a new perspective on how to establish an effective program that supports your core business. Let's review each statement to understand why it is false.

1- “Companies can comply with the Drug-Free Workplace Act of 1988 by implementing a drug screening/testing program.”

This statement is false because testing is not required under the Act. It is really just a matter of understanding what the Act does and does not require. If you are covered by the Drug Free Workplace Act of 1988 you are required to:

Certify that you will provide a drug-free workplace.
Publish a statement notifying your employees that the unlawful manufacture, distribution, dispensing, possession, or use of a controlled substance is prohibited in the workplace and what actions will be taken against your employees for violations.
Establish an ongoing, drug-free awareness program to inform your employees of the dangers of drug abuse, your drug-free workplace policy, the availability of any drug counseling programs, and the possible penalties for drug abuse violations occurring in the workplace.
Require each employee directly involved in work subject to the Drug Free Workplace Act to notify you of any criminal drug statute conviction for a violation occurring in the workplace.
Notify the Federal Government of such a violation.
Require the imposition of sanctions or remedial measures for an employee convicted of a drug abuse violation in the workplace.
Continue in good faith to comply with the above requirements.

The Drug-Free Workplace Act does not require you to:

Establish an employee assistance program
Implement a drug testing/screening program

Unfortunately, many company leaders believe that testing programs meet the requirements of the Act. What's worse, many of these companies effectively do not do many of the things that are required, especially that third requirement that deals with the "ongoing drug-free awareness training" for employees. Utilities in our program should particularly note that the Drug-Free Workplace Act of 1988 requires only some Federal contractors (and all Federal grantees) to agree that they will provide drug-free workplaces as a condition of receiving a contract or grant from a Federal agency. The Act does not apply to those who do not have, nor intend to apply for, contracts/grants from the Federal government. And, the Act also does not apply to subcontractors or subgrantees.

2- “Most of the time and money a company must spend to create and sustain a drug-free workplace program, unfortunately, takes time and money away from operating its core business.”

This statement is false because, as the real experts will tell you, the best way to create and sustain a drug-free workplace is by managing your company to attain excellence in all aspects of performance. In other words, hire good people, tell them clearly what doing a good job entails, tell them constantly when they are doing a good job, but don't ignore or avoid addressing performance problems, and teach your supervisors and managers how to do these things very, very well. That's the real essence of a drug-free workplace program. Of course, if you read that sentence outside the context of this article, it is also the essence of managing your core business.

It all starts with hiring good people, a subject we covered in a previously published article entitled Behavior Based Interviewing. Being an experienced user of this type of interviewing, I would go so far as to say that well conducted behavior-based interviews would successfully screen out more candidates who have substance abuse problems than expensive pre-placement testing could ever do, and at the same time the interview would be targeting other important job behavior traits that lead to good hiring decisions. Testing can't contribute anything to your hiring decision beyond the issue of drug use!)

Of course, in all aspects of performance, once you hire people you need to tell them what's expected of them on the job. This involves being able to clearly state your expectations, usually in the form of a policy. The experts* outline the steps to an effective program as follows:

Five Steps to a Workplace Substance Abuse Program

Step One: Writing a Clear and Comprehensive Policy

Step Two: Training Your Supervisors

Step Three: Educating Your Employees

Step Four: Providing Employee Assistance

Step Five: Starting A Drug Testing Program

*Working Partners for an Alcohol- and Drug-Free Workplace

These five steps are quoted from an excellent collection of material published by the Department Of Labor, specifically from the publications of the "Working Partners" program. (Click Here to access their site.) If you look closely at these steps, you'll notice the first three are simply good management practices for any aspect of performance. Collectively, they say "Tell them what you expect." The fourth step is a logical extension that says "We'll try to help you do what it takes because it's to both of our advantages." Thus, the first 4 steps are an integral part of managing all aspects of your business and do not represent a drain on resources you might otherwise spend on your company's real business. The fifth and last step is the one item that clearly costs money and time without directly supporting your core business - drug testing. Interestingly, here's what the experts from Working Partners say about that last step:

Before You Start Planning A Drug Testing Program:

A drug testing program is the LAST step of a comprehensive program. You should have in place a program which includes all the previous steps described in this pamphlet: a written policy statement, a supervisory training program, an employee education and awareness program, and an employee assistance program.

It goes on to outline all the issues you should consider before establishing a testing program, and there are many to consider. We covered part of these issues in a previous article (mentioned above) entitled Drug Screening Programs: Benefit or Bane? The conclusion is, if you envision a drug-free workplace program as primarily a testing/screening program, you probably see such a program as a drain on your efforts to manage your core business. Frankly, if testing is all you do, you're right. But let's look at the next statement...

3- ”Besides an actual testing program, if you want to make a drug-free workplace program effective, your supervisors must know how to recognize the symptoms of substance abuse so that they can tell the difference between someone who just isn't performing well on the job and someone who has a real substance abuse problem.”

Unless your core business is alcohol and drug abuse counseling, this statement is definitely false! The experts on alcohol and drug abuse are very clear on this point - supervisors and managers should deal with job performance issues. They should not try to diagnose substance abuse problems. (Interestingly, the requirements of the FMCA rules on CDL supervisors is in direct conflict with this!)

What your supervisors and managers should be trained in is how to be effective supervisors and managers – how to teach and coach workers to perform error free; how to reinforce good performance with lots of positive feedback; and how to address performance problems quickly and properly as performance problems, not character flaws, social problems, or substance abuse problems. Certainly, they should know that some performance problems may have their roots in substance abuse, but it is not their job to accuse someone who exhibits a performance problem of having a substance abuse problem. They should also know that substance abuse problems almost always manifest themselves in poor or unusual on-the-job behavior long before they become obvious as substance abuse problems. Therefore, if you teach your supervisors how to address job performance problems quickly, soundly and effectively, you can improve all aspects of your core business and know that, in the course of doing so, you also greatly increase your chances to identify, help, or otherwise ferret out, those workers who really do have substance abuse problems.

The conclusion is, good supervision and good management are good for your core business and, at the same time, contribute more than anything else you could do to maintaining a drug-free workplace.

4- ”If a company can afford it, the best way to implement a drug-free workplace program is to hire an outside testing company to come in and set it up.”

If you are still reading to this point, it should be abundantly clear why this last statement is false.

I am sure there are excellent companies that consult with employers on how to establish sensible, effective drug-free workplace programs. Unfortunately, I have seen too many companies who claim to be able to help you establish an effective drug-free workplace program but whose real business is selling drug screening services. The more testing samples taken, the more money they make. Thus, their "advice" on establishing a drug-free workplace program is very much oriented to testing and screening, the last and least important aspect of a good program. It's a hard truth that such companies thrive in the marketplace by exploiting their clients' lack of expertise.

If you are considering implementing a drug-free workplace program or if you are evaluating an existing one, please take a little time to do some research on the subject. This brief article gives you some beginning points, such as the link to the Working Partners program (where you will find links to several other expert resources on the subject) and some opinions we have formed based on our observations of many companies with which we have worked. I hope you will take a few minutes to read through these other resources. If you do, you will see why hiring an outside company to set up and administer a drug-free workplace program for you may cause you to miss out on all the real benefits of doing it yourself. Outsiders can surely help but only you and your people can make it work.

Ultimately, most of the process of developing and sustaining a drug-free workplace involves developing and sustaining good people management skills, setting and communicating expectations for a job well done, and striving to do well all the things that directly support your core business. That's pretty good news, isn't it?