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10 Steps for Addressing Workplace Impairment

6/25/19  |  Liz Rossiter, Rexel Technical Consultant

Workplace impairment threatens the safety of employees, customers, and the public. Though impaired workers don’t set out to harm themselves or others, that’s exactly what they run the risk of doing—and that risk shouldn’t be taken lightly. Considering the effect it can have, it’s helpful to understand what can cause impairment and how to recognize it.

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Causes of Impairment

IIt can be difficult to pinpoint workplace impairment because it can take many forms. Traditionally, when we hear “impairment,” we think of drug and alcohol abuse. And for good reason:

        - One in 13 working adults has an alcohol problem
        - $74 billion is lost each year due to productivity loss related to alcoholism
        - 18% of people over 12 admit to using illicit drugs

But there are often other causes of impairment. Prescription and over-the-counter medications are contributing to the problem. It’s important to remember that workplace impairment can be caused by any condition that inhibits an individual’s ability to perform an assigned function safely.

Impairment and Compliance

OSHA’s Occupational Safety and Health Act of 1970 (OSH Act) states:

        - Employers must “… furnish employees a place of employment free from recognized hazards likely to cause death or serious physical harm”
        - Employees “… shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act”

Though workplace impairment falls under these regulations, the act doesn’t provide hard guidelines for dealing with it. However, the lack of strict federal guidelines does not mean that issues that threaten safety can go unaddressed. By extension, it means you need to do more to ensure your company is providing the safe workplace mandated in the OSH Act.

To avoid violating health and safety standards, you can start by recognizing impairment and its possible symptoms.

Symptoms of Workplace Impairment

Depending on how and why an employee may be impaired, there are a variety of signs and combinations of symptoms that may present themselves. The Society for Human Resources Management (SHRM) provides some excellent guidance on what to look out for. The symptoms of workplace impairment include:

        - Odors: Scents like alcohol and marijuana are strong indicators, but the smell of body odor or urine can also be telling
        - Movements: Impaired employees may be uncharacteristically unsteady, fidgety, twitchy, or dizzy
        - Eyes: The pupils may be dilated or constricted, eyes may be watery, and eye movements may be erratic or involuntary
        - Face: You may notice flushing, pallor, and/or sweating as well as a confused or blank look.
        - Speech: Depending on the substance ingested, speech may be slow and slurred or even rapid and scattered. The employee may also be distracted mid-thought and/or unable to
          verbalize thoughts
        - Emotions: Look for changes in attitude including an individual becoming uncharacteristically argumentative, agitated, irritable, or drowsy
        - Demeanor: Impaired employees may be sleeping, unconscious, or show no reaction to questions

New patterns like those mentioned above can point towards possible impairment, especially when a combination of symptoms are present.

Establishing a Protocol

Recognizing workplace impairment is just the beginning. Organizations should not only have a mechanism for employees to voice their concerns, but they should also have a structured process for dealing with it. SHRM provides some guidelines for documenting reasonable suspicion. Here is a high-level process for developing a protocol for recognizing and handling impairment in your workplace.

        - Step 1: Accurately Record Complaints – You need to capture more than concerns. Ask employees specific questions about what behavior they observed, when they saw it, and
          how often they’ve witnessed impaired behaviors.
        - Step 2: Formally Observe the Employee – Immediately following complaints, two members of management should observe the employee’s behavior firsthand. That way, the
          concerns can be verified by multiple parties.
        - Step 3: Immediately Address Safety Concerns – Any employee showing signs of impairment should be immediately removed from working with machinery or heavy equipment.
        - Step 4: Document Each Independent Observation – Be as specific as possible when capturing abnormal behaviors and physical symptoms without attempting to diagnose the
        - Step 5: Compare Observations – Assess the situation by comparing the documented observation to determine if all witnesses agree. If there is a dispute, bring in a third party.

Dealing with Workplace Impairment

The remaining steps in SHRM’s guide to documenting reasonable suspicion are heavily dependent on your company’s policies. Most notably, they assume that your organization has a written drug and alcohol policy and requires consent to drug testing as a condition of employment. Both should be considerations when developing a comprehensive safety program.

Here are steps six through ten.

        - Step 6: Hold a Meeting with the Employee – Clearly explain the situation and review the documented observations with the employee. Explain that they are suspected of violating
          the company’s drug and alcohol policies. And then inform the individual that they will have to take a drug test.
        - Step 7: Provide Safe Transportation – If you suspect an employee is impaired, do not allow them to drive to the test site. Provide and/or pay for transportation. Additionally,
          employers should ensure that the employee can get home safely.
        - Step 8: Arrange for Employee Testing – Once you have secured safe transport to the testing site, notify the location, and send the employee on their way.

        - Step 9: Keep the Employee Away from Work Pending Test Results – Employees should not return to work until the test results are in. Whether or not you pay employees for any
          missed time depends on your organization’s policies and the Fair Labor Standards Act.
        - Step 10: Respond Appropriately to Test Results –

o  Negative: Employers should return workers to their positions as quickly as possible. Many companies also pay employees for any missed time.
o  Positive: How positive test results are handled will differ depending on the policies in place. Employers may consider consulting legal counsel. Whether or not employment continues, it’s a good idea to provide the employee information about any employee assistance program (EPA) in place.

Ready for a Safer Workplace?

Workplace impairment is just one piece of the safety puzzle. We can help you develop a comprehensive, compliant safety program. Our Safety Specialists are your experts, providing in-depth assessments and recommendations as well as OSHA-certified training. Contact us today!