From the NATCA VOICE, a publication of the National Air Traffic Controller's Assn.(Feb.'99)

Fit For Duty...Or Is It? by Gene Tinelli, MD, addiction psychiatrist, with Lee Hamlett, Syracuse Tower NATCA Local president, and Mike Smithson, Syracuse Tower NATCA Local legislative rep.

It is an uncomfortable event that each air traffic control facility experiences about once a year. Management informs the union that the people with the official looking white coats are here to collect a urine sample from a "randomly" selected list of people and make those randomly selected people prove they are innocent of any illegal substance use.

First of all, there is nothing really random about the selection process. If you happen to have a day shift, you will probably be tested. If you work mostly evenings or midnight shifts, there is a good chance you may never have to prove your innocence.

The drug testing process puts a reverse spin on innocent until proven guilty. When the white coats visit, everyone selected is instructed to provide a urine specimen. Tampering with the specimen or obstructing the collection process can result in termination of employment. Resistance is futile. One feels like they are being viewed at as guilty and the hope is the urine specimen accurately proves "innocence", if not competence.

But is drug testing's primary goal to insure the flying public's safety? From the employee's point of view, it appears to be a way for a not so benevolent employer to humiliate, insult and possibly persecute their own employees. If the employer were most concerned about insuring the flying public's safety, they would not have a drug testing system in place that allowed employees tested to continue working for days to weeks until the results are known. Potentially, anyone legitimately testing positive will have been allowed to work a minimum of 2-3 shifts before being prevented from working airplanes. Those that test negative unfortunately are not told by management for 2-3 weeks. This can result in increased anxiety on the part of the employee waiting for the results and does nothing to enhance employee morale or competence. Not only would it be appropriate to be informed immediately about negative results, but an apology for an undignified invasion of privacy would also be in order.

The FAA, for some reason, doesn't realize that their 'get the controller' attitude makes it more difficult for those few that may have a substance use problem from coming forward and getting real help for their situation, instead of hiding it until it possibly gets out of control. Anyone that does have a problem has to get help without the benefit of insurance or employer support. So how did we get into this mess?

Due to the Drug Free Workplace Act of 1986, there have been dramatic increases in the use of pre-employment and random testing of American workers for illicit drugs such as heroin, cocaine, amphetamines and marijuana. Whereas in 1987, only 21.5% of the respondents surveyed by the American Management Association reported that they conducted some form of drug testing, 87.3 % indicated that they tested in 1994. The rationale for this testing is to assure a drug free work force, to increase safety by lowering accidents, mistakes or errors in judgment, and to enhance worker productivity. However, given testing's cost, intrusiveness and dislike among the work force, it is reasonable to ask whether it works.

In 1994, the National Academy of Sciences issued a report which was a comprehensive analysis of all available data regarding the effect of drug use upon employers, including discussions of the relationship between drug use and safety and productivity. With regard to drug testing lowering drug use, they concluded ³despite beliefs to the contrary, the preventative effects of drug testing programs have never been adequately demonstrated². The studies they reviewed suffered ³from serious methodological problems that preclude any scientific assessment of the impact . . . on work force productivity². Recreational drug users were found to be no less productive than their co-workers and the report concluded that most recreational drug users, like most social drinkers, do not become drug dependent and do not use drugs on the job. The Academy also found no relationship between drug test results and safety. Employees who used illegal drugs off-the-job were no more likely to be involved in workplace accidents that other employees.

The National Institute of Drug Abuse has also published results of companies with drug testing programs. For example, Georgia Power and Light conducted an extensive analysis of their testing program and examined rates of promotion, demotion, and absenteeism to see if there were differences in the performance of employees who tested positive and negative for off-duty drug use. They found no significant differences between those who tested positive and those who tested negative.

A recent study by the Le Moyne College Institute of Industrial Relations took a novel approach to drug testing and compared productivity between 63 firms within the computer and communications equipment industries. They found that pre-employment and random drug testing did not succeed in improving productivity and, surprisingly, companies adopting drug testing programs were found to exhibit lower levels of productivity than their counterparts that did not. There are possible explanations for these findings.

Drug testing may not lower drug use. Although proponents of drug testing presume it will discourage drug use, those current employees most deterred by the prospect of workplace testing are likely the most casual offers users who abstain from their at-home use in order to avoid potential embarrassment and job loss. Because people who have alcohol and other drug dependencies have less control over their drug intake, testing may not so easily deter their substance abuse, which has greater potential for personal and organizational harm. Some members of this group may thwart detectors by altering their own urine or even substituting drug-free urine samples and testing cannot prevent employee drug use in the workplace. Thus, applicant screening may not keep both serious and casual users from gaining employment in the first place.

Drug testing may not capture impairment on the job. Workers may switch from drugs that persist in the urine for long periods of time to other drugs that are either detectable for much shorter periods of time or not check for at all. For example, when the U. S. military started their mandatory urine screenings in Feb. 1981, marijuana use went down but use of alcohol, which may be the drug most associated with work productivity losses, went up. Tests can also produce false positives and negatives and workers can alter their urine to lower the detection rate.

Drug testing may lower productivity. First, testing could undermine worker morale and motivation. Surveys have shown that workers have negative attitudes toward testing, believing it is unreasonable search and seizure and an unnecessary and intrusive invasion of privacy. Second, drug testing is a large cost to an organization. When Texas Instruments, one of America's largest electronics manufacturing companies, evaluated their urine testing program, they found that it cost $1 million to test 1000 employees. Others have viewed costs in terms of dollars-per-positive test. American Management Association data suggests that the average cost of a confirmed positive test is in excess of $10,000. The average cost of a confirmed 'positive' in federal testing programs is in excess of $77,000! Drug testing as we do it now does not directly affect safety as it cannot detect drug use in time to prevent it from causing harm. Testing can only distinguish between someone who has used or been exposed to a drug and someone who has not; it cannot tell when the former took the drug, how much was taken, how frequently this person has taken this drug, or the effect of the drug on the user. By the time an employee's test result has been interpreted as positive, any drug-impaired behavior would already have taken its toll. On the other hand, the metabolites in a person's urine that produce a positive test result does not necessarily mean the person cannot work, as any effects of the drug could have long worn off by the time the test was administered. Furthermore, research finds that most on-the-job accidents result from stress, fatigue and illness rather than from drug use. The one drug test that is correlated with actual real-time impairment, analysis of the breath for alcohol, is the one least frequently used. Ironically, it is also one of the cheapest.

Drug tests don't prevent accidents because they don't address the root problems that lead to substance abuse. But good management and counseling can. Three methods are generic. Good reference checking can more effectively screen out poor employees, especially if the checking involves personally speaking with the applicantıs last direct supervisor. Also, retaining outside professionals to do reference checks is very effective. Improved supervisory training, especially of first line supervisors, can detect impairment early and supervisors can be trained on how to intervene. Finally, employee assistance programs (EAPs) help people facing emotional, health, financial or substance abuse problems that can affect job performance. EAP counselors decide what type of help is needed: staff support, inpatient treatment, AA meetings, and the like. In this context, the goal is rehabilitation and wellness ­ not punishment. These methods also show that impairment results more commonly from domestic problems, poor management of human resources, and, when alcohol or other drugs are involved, drug dependency rather than drug use.

However, our war on drugs (actually, a war on users of certain politically incorrect drugs) obscures our vision in a more fundamental manner. In our myopic focus on chemicals in the body, we lose sight of the actual goal, fitness for duty. The fundamental question is: Does the employee know their job description and can they do it on a daily basis? Fitness for duty is what occupational competency and safety are all about and drug testing only gives the illusion of capturing it.

What is needed and what should ultimately concern managers is an alternative to biological testing that is better suited to identifying the substandard work -- before it occurs -- while preserving employees' rights: actual performance-based fitness-for-duty testing. Computer-assisted performance tests, which measure hand-eye coordination and response time, Is a better way of detecting whether employees are up to the job. NASA, for example, has long used task-performance tests to determine whether astronauts and pilots are fit or unfit for work ­ whether the cause is substance abuse, fatigue, or physical illness.

The technology of performance testing was developed 30 years ago, but it has been applied commercially only since the late 1980s. According to accounts in the popular press, the computer-based critical tracking test, a sort of 'video game' in which employees engage in the same psychomotor skills their jobs require, is less intrusive and more valid than urine testing for determining impairment that may or may not stem from drug use. Test-takers use a control knob to try to keep a constantly and randomly veering cursor centered on their video screen. Employees' scores at a given trial, based on speed and accuracy, are compared to their average previous performance. Although test-takers' baseline performance may eventually improve, a complex algorithm precludes mastery and the test has been designed so that an employee cannot trick the computer into establishing a low baseline (so as to pass the test later while impaired), because an unusual lack of progress on baseline-setting trials is recognizable.

Fitness-for-duty testing has been faulted for not ascertaining if an employee who fails an impairment test is using drugs. As discussed, however, a major asset of behaviorally-based tests is that they protect employee rights by not disclosing to employers the cause of impairment. Rather, unlike biochemical tests, they are designed to determine whether or not the employee is impaired. If the goal is to identify impaired workers and either refer them to treatment or to prevent them from performing a task that may endanger themselves or others, then behavioral indicators provide a more direct means than drug tests of identifying employees unable to perform at required levels. To minimize hazardous behavior and other performance problems, behavioral indicators may be a better means than chemical tests.

Again, the real issue should not be whether an individual has been engaging in certain behavior (that is, ingesting a particular quantity of a drug) that could compromise some individuals' performance, but whether this individual's performance has, in fact, been impaired. A valid fitness-for-duty test, unlike a biochemical test, can more accurately assess an employee's actual readiness for work.

Behavioral performance testing could also detect system problems and assist management with its scheduling practices. Imagine, for example, if everyone on a 'quick-turn' schedule scored lower consistently over a long period. The problem might not be drug use but rather a work recovery time that is too short. Or, what about a controller who is bothered by a domestic problem at home, or financial difficulties, or a family illness. A manager aware of his or her employees may suspect something is amiss, and, with the assistance of performance testing as a tool, may be better able to determine a problem. A concerned, caring manager could then initiate a private conversation, informing the employee of the manager's observations, including the employee's performance scores are erratic and ask if there is there anything they'd wish to discuss. This approach would be an entirely different scenario than the one currently in place that is known all too well: no trust by management of it's employees, total disregard of the fourth amendment to the Constitution (illegal search and seizure), and the big-brother attitude that says, "'If we don't test you all the time, then illicit drug use would be rampant."

Drug testing could still remain a part of the process. If performance scores are erratic and an employee asserts that a problem doesn't exist, a voluntary physical examination, including drug screening could be very useful. These tests, not meant as a condemnation of activity, may identify other problems, like a low blood sugar level, or other ailment. A case can be made of the collateral benefits from performance testing.

There are a number of concerns of performance based fitness-for-duty testing. Can they predict actual job performance? Can employees cheat or override impairment to pass a fitness-for-duty test? What are the costs of these tests and what kinds of policies have organizations devised to administer these tests and address test failures? How do employees view fitness-for-duty testing?

Unfortunately, the answers to these questions are mixed or the data is not yet available. The best and most recent review (Comar, 1995) stated ³performance-based fitness-for-duty testing would seem to be a promising tool to prevent substandard work and unsafe behavior. The popular press has sung the virtues of fitness-for-duty tests, and laboratory research has supplied evidence that they are psychometrically solid. But what has been conspicuously absent from the literature is a systematic investigation of fitness-for-duty testing programs in organizations². Her study reviewed archival data from two commercial test manufacturers, interview data with managers of former and current clients of fitness-for-duty tests, and questionnaires completed by employees who take fitness-for-duty tests. The results suggest that fitness-for-duty testing loses something in the translation from theory to practice. These tests emerge valid and reliable in laboratory investigations; yet current test-takers and managers of former test-takers assert that fit individuals fail while obviously impaired individuals pass, and employees claim they can pass or fail their performance tests at will. Further, introducing and administering a fitness-for-duty testing program require an ongoing commitment, which, apparently, has left most organizations no time to monitor whether fitness-for-duty testing actually enhances organizational safety and productivity. Could the FAA and NATCA be willing to 'join hands' on this project and determine it's validity?

So, where does that leave us in the workplace? "Random" substance abuse testing is wrong, although the Supreme Court disagrees. Random drug testing appears to be a violation of: 1) our right to not be required to testify against ourselves (5th Amendment) and 2) an illegal search and seizure without probable cause. (4th Amendment). Again, if our employer really cared about safety and the well being of its employees, they would use a different process for determining an employee's fitness-for-duty and eliminate any punishment for an employee that voluntarily sought help for an alcohol or drug problem. Even going to EAP for relationship or financial problems could conceivably result in the EAP counselor determining that the root of the problem is alcohol or drug related. Urine drug screening is ineffective, disliked and may be counterproductive. The future for this type of testing is hair analysis, which can detect most politically incorrect drug use (except alcohol) for months in the past but, like urine screening, cannot tell us about real-time competency. Performance based fitness-for-duty testing is a much more rational approach but obviously needs more workplace evaluation to determine its effectiveness and acceptability.

NATCA could be more proactive on these issues by:

1. Calling for a moratorium on current workplace testing.
2. Sponsoring and conducting research on performance based fitness-for-duty testing in the workplace.
3. Devising acceptable organizational policies if research indicates that fitness-for-duty testing is useful.
4. Encouraging the use of known methods of ensuring productivity - better reference checking, improved supervisory training, and enhanced employee assistance plans.

Whether or not fitness for duty testing is the answer is yet to be seen. It offers an interesting alternative to the distrustful environment in place now. NATCA, while continuing to protect the rights of bargaining unit members before, during and after alcohol and substance testing, could become proactive in looking for alternatives to our current process.

However, maybe the answer is right in front of us. Good supervision is, after all, nothing more than paying attention. If management does it's job and properly and consistently observes the operation of its employees and the system, that should be enough of a skills check for anyone. 

Written by Gene Tinelli, MD, addiction psychiatrist, with Lee Hamlett, Syracuse Tower NATCA Local president, and Mike Smithson, Syracuse Tower NATCA Local legislative rep. All three are members of ReconsiDer: Forum on Drug Policy. (http://www.reconsider.org)