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| Drug and alcohol testing in the workplace |
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by Richard S. Schottenfeld
Drug and Alcohol Testing in the Workplace -- Objectives, Pitfalls, and Guidelines ABSTRACT This paper examines the historical development of drug testing, the motivations underlying proposals to implement workplace testing for drugs and alcohol, the types of programs currently in use, and the potential pitfalls of workplace testing. It also examines the basic principles involved in disputes about the legality of workplace testing. Finally, this paper discusses guidelines to ensure that workplace testing programs are fair and to minimize unwanted and harmful effects of testing. INTRODUCTION Proposals to test employees in the workplace for substance abuse have aroused considerable controversy. Workplace testing has been hailed by some as an essential weapon in the war against drug abuse and in efforts to restore economic productivity[1]. It has been criticized by others as unlikely to reduce drug-related impairments in the work force, as an unwarranted interference with the private lives of employees, and as fraught with technical limitations and potential harmful consequences[2-4]. Despite the controversy, there has been a rapid proliferation of workplace testing programs. Between 1982 and 1985, the percentage of Fortune 500 companies testing applicants or employees for drug use rose from 3 to almost 30% percent, and an additional 20% is expected to begin testing programs in the near future[5]. The percentage of smaller firms conducting workplace testing is unknown. Many of the ideas discussed in this paper were clarified during the deliberations of a Task Force on Drug and Alcohol Testing in the Workplace sponsored by the APT Foundation in New Haven, Connecticut, to address the difficult issues. The Task Force consisted of members with expertise in substance abuse treatment, laboratory medicine, occupational medicine, law, business, and labor[6].(*1) HISTORICAL DEVELOPMENT The technology to detect drugs of abuse in urine has been developed over the past 20 years to aid in the acute, emergency treatment of drug overdoses and to aid in the long-term treatment of drug abusers in drug rehabilitation programs. The technology was developed for specific medical uses. In rehabilitation programs, drug testing is invaluable as an aid in confronting denial. Testing is not problematic in treatment programs because patients come in more or less voluntarily, agree to testing as part of their treatment, and are tested for their own benefit. In treatment programs, patients give informed consent to testing and voluntarily disclose private information about themselves. Because the prevalence of use is high in treatment programs, positive tests are likely to be true positives (see discussion below regarding false positives). Patients are also given the opportunity to dispute the accuracy of test results, and clinicians do not rely solely on test results to confirm use. Used for medical purposes as part of treatment programs, urine toxicology screening is a valuable diagnostic test. Problems arise, however, when medical technology is applied to the workplace. In workplace testing, none of the factors listed above is necessarily operative. OBJECTIVES OF WORKPLACE TESTING Workplace testing programs to detect substance abuse have been advocated primarily as a way of preventing or curtailing drug- or alcohol-related impairment in the workplace and consequently of enhancing safety and productivity in the workplace. In addition to this primary objective, workplace testing programs have also been advocated as a way of achieving a number of closely related, secondary objectives. These secondary objectives include expediting identification and referral for treatment of impaired workers, fostering public trust in the business or industry using such programs, decreasing the likelihood that employees will engage in illegal activities (such as stealing from the employer or betraying company secrets) in order to support expensive drug habits or to avoid blackmail, and complying with federal regulations or orders requiring such testing. All of the primary and secondary objectives listed above are related to the employer's obvious responsibility for ensuring workplace safety and productivity. Although problems may result from using workplace testing to achieve these objectives, there is no doubt about the legitimacy of business' interest in pursuing these goals. In contrast to these objectives, an additional objective that often underlies proposals for workplace testing, viz., to detect and punish any drug use by an employee at any time, does not pertain directly to a business goal. In a simple cost-benefit analysis, workplace testing to achieve nonbusiness-related objectives may not be worth the costs of such programs or the costs of problems resulting from such programs. POTENTIAL PROBLEMS RESULTING FROM WORKPLACE TESTING Regardless of the motivations for instituting workplace testing, such testing is fraught with potential problems. Included among these are that workplace testing 1) may lead to the abandonment of more effective and less problematic approaches to substance abuse problems in the workplace, 2) may divert attention away from efforts to prevent alcohol abuse in the workplace, 3) may be used arbitrarily or maliciously to intimidate employees, 4) may lead to the mistaken identification as substance abusers of employees or applicants who do not have drug or alcohol problems, 5) may be used to detect medically approved prescription drug use and thereby lead to discrimination against employees with medical problems, 6) may result in the creation of a pool of unemployable individuals, and 7) may unnecessarily infringe on the private lives of employees and applicants. In the following sections, each of these potential problems is discussed and ways of mitigating or resolving them are suggested. 1. Workplace Testing May Lead to the Abandonment of Effective and Less Problematic Approaches Substance abuse in the workplace is a complex problem with multiple causes. Testing is unlikely to be effective when used alone, and undue optimism about its effectiveness may cause abandonment of more comprehensive approaches that would ultimately be more effective. Consider, for example, the role of testing following an accident. Testing may be useful to verify whether substance abuse was a factor. Since some substance abuse may not be detected by urine testing, however, it is important to determine whether there is other evidence that impairment related to substance abuse played a part. Conversely, since a positive test for drugs or alcohol does not mean that the employee was impaired at the time of the accident or that the employee caused the accident, it is also necessary to investigate the accident thoroughly to determine whether other factors may have led to the accident. Regardless of whether or not the employee was impaired, safety hazards in the workplace may have contributed to the accident. Consequently, unless performed as part of a comprehensive incident review, drug and alcohol testing might lead to premature closure of the investigation and failure to detect the true cause or other causes of the accident. 2. Workplace Drug Testing Programs May Focus on Drug Abuse and Divert Attention from Alcohol Abuse Since alcohol is by far the most abused substance in the workforce and a major cause of impaired safety and performance, it is essential to include alcohol in discussions about workplace testing and about comprehensive substance abuse programs designed to improve safety and productivity. Workplace testing programs should not focus exclusively on drug abuse. 3. Workplace Testing May Be Used to Intimidate Employees In the absence of an objective, appropriate definition of what constitutes evidence of impairment or of the criteria used to decide whom to test and under what circumstances to test, workers may be tested arbitrarily or maliciously. Some workers have already complained that they were ordered to submit to urine testing because of their involvement in union organizing or in disclosing safety problems in the workplace. It is deplorable to use workplace testing for drugs or alcohol to single out perceived troublemakers or to intimidate employees and discourage them from organizing or engaging in other legitimate activities. In order to prevent workplace testing from being used arbitrarily or maliciously, written policies about testing should be promulgated prior to implementing testing programs, and policies should be applied uniformly and consistently to all employees. 4. Workplace Testing May Lead to the Mistaken Identification as Substance Abusers of Employees and Applicants Who Do Not Have Drug or Alcohol Problems False positive tests will by definition incorrectly identify as drug or alcohol users individuals who do not have drugs or alcohol in their urine. Additionally, correct detection of drugs or alcohol in urine does not necessarily indicate substance abuse or impairment. Consequently, testing must be accurate and positive tests must be interpreted carefully to avoid mistaken identification of individuals who do not have substance abuse problems. a) False positives. Because of the possibility of human error as well as the technical limitations of the testing methods, no workplace testing program can ensure completely accurate or 100% specific results. Human error can occur at each step along the chain of custody of the specimen, from the original labeling of the sample, to alterations of the label in transport, or to the mistaken transcription of names prior to or following testing. Errors may also result from equipment that is poorly maintained or from results that are misinterpreted. To guard against human error requires sustained vigilance and carefully designed procedures. Specific guidelines for reducing the possibility of human error are discussed below. Commonly used screening tests, such as thin layer chromatography (TLC) or immunoassays (including, for example, EMIT), are often very "sensitive," which means that they are likely to detect even very minute amounts of substances when the substance is present. Screening tests, however, are often not sufficiently "specific," which means that they may indicate the presence of a substance even when it is not present. Even when correctly performed, screening tests will yield a certain proportion of "false positives." For example, false positives may result in immunoassays from drugs that are not meant to be detected but that "look like" a drug of interest and cross-react or bind to the antibody used to detect the drug. Using another immunoassay to confirm the test could result in a repeated false positive[7, 8]. To guard against inaccuracies resulting from systematic errors, it is essential that all screening tests be confirmed by an independent test based upon a different analytical principle, and one that ideally is more accurate. Gas chromatography-mass spectrometry (GC-MS) is the ideal confirmatory test, allowing conclusive identification of a drug[7-9]. Even very accurate testing may lead to a high proportion of false positive results during pre-employment or random testing of individuals who do not appear to be under the influence. The following example shows why. Assume that quality control efforts are excellent, that the test procedures are extremely accurate, that testing identifies all positive samples as positive and correctly identifies as negative 999 out of 1000 truly negative samples (i.e., it misidentifies only 1 out of 1000 truly negative samples as positive). Assume that only 1 out of 1000 individuals is a user (which is higher than the prevalence of opiate abuse in the population). We would then expect there to be one true positive result and one false positive result out of every thousand individuals tested. Consequently, half of all workers identified as being positive for the substance will be false positives. Because of this problem, it is imperative that all of the safeguards ensuring the accuracy of test results be followed in every workplace testing program. Anything less than 100% specificity is bound to result in a high percentage of positive tests being false positives. b) Incorrect interpretation of a positive test. In the absence of independent evidence of impairment, even an accurate positive test is not informative about the recency of use, whether the person tested was impaired at the time of testing or whether the person has substance abuse problems. Consider the situation of an applicant or employee who is not impaired but whose urine tests positive for alcohol or for benzodiazepines. The unlucky person in this example may have taken several drinks or a sleeping pill to assure adequate relaxation or sleep the night before being tested. Poorly designed testing programs would also victimize individuals suffering from colds who took cough medicines containing codeine or individuals who ate large quantities of poppy seed cake, which contains opiates[10]. These problems can be avoided by limiting testing to situations where there is independent evidence suggesting impairment, allowing individuals who test positive an opportunity to explain or dispute positive tests, and informing applicants in advance about testing. Advance notice of testing, including information about substances that will be detected and warning that some substances are detected for prolonged periods after use, provides a safeguard for applicants who do not have substance abuse problems, while detecting applicants who are dependent on alcohol or drugs or are unable to refrain from use. 5. Workplace Testing May Detect Medically Prescribed Drug Use Unrelated to an Employee's Job Performance and Thereby May Lead to Discrimination Against Employees with Medical Problems Although the technology exists to detect in urine those medications used to treat diabetes, heart disease, depression, anxiety, and a large number of other medical conditions, the use of workplace testing to detect medical problems is problematic. In our society, medical conditions and medical treatment are considered private matters. Doctors are forbidden by law from disclosing confidential information about patients. Without assurance of confidentiality, many people would be so embarrassed or so afraid of being stigmatized that they would not seek medical treatment. From a societal perspective, workplace testing to detect medical conditions or medically approved prescription drug use is particularly objectionable. It is in society's interests to encourage people to receive appropriate medical care rather than to deter them from medical treatment in order to avoid disclosure. Workplace testing can avoid detecting prescription drugs that are used to treat medical conditions by imposing limitations on the types of substances that will show up in testing methodologies. Laboratories should be instructed to test only for alcohol and specified drugs. An alternative measure is to require that the results of testing are reported only to an independent physician. It would be the responsibility of the physician to discuss positive tests with the individual tested and to determine whether use of a drug was prescribed by a physician for a medical condition and whether drug usage or the medical condition could interfere with the ability of the individual to perform the job safely. Only after making such a determination would the physician notify the employer that the individual did or did not meet the medical standards for the job (in the case of applicants) or was or was not likely to have been impaired by the detected substance (in the case of employee testing). 6. Workplace Testing Programs May Result in the Creation of a Pool of Unemployable Individuals Although facilitating treatment of impaired individuals is a major motivation of workplace testing programs, workplace testing may lead to loss of employment or rejection of applicants rather than treatment. If individuals who test positive do not receive treatment or if their early failure to pass the urine test creates a record that prevents subsequent employment, one positive test may lead to permanent unemployment. In order to prevent this unwanted consequence, employers who decide to use workplace testing have an obligation to inform employees or applicants who test positive about the existence of treatment facilities in the community. Test results should be treated with the utmost confidentiality, and disclosure of test results to individuals outside the testing business should be avoided. Finally, in order to avoid making individuals who have tested positive on the occasion permanent outcasts, employers should allow these individuals to return to work or reapply without prejudice after a defined period of time or after the completion of treatment. 7. Workplace Testing Programs May Unnecessarily Infringe on the Private Lives of Employees Workplace testing programs have been advocated by some as a way to decrease the use of illicit drugs in society at large by attaching severe financial penalties in the form of loss of employment. Testing that is not based on individualized, reasonable suspicion of impairment, such as preemployment testing of applicants and random testing of employees, in particular, subjects employees' and applicants' off-the-job behavior to the scrutiny of the employer. While the goal of reducing substance abuse in society at large is laudatory, the use of drug testing in the workplace to achieve this goal and the consequent invasion of employees' privacy raise serious objections. Implementing drug testing in the workplace to detect and punish off-the-job illegal activity by employees turns employers into policemen. Not only is this role inappropriate for employers, but also, when employers act as policemen, they are likely to make mistakes. Unlike policemen, private individuals, such as employers, are not subject to the constraints of the United States Constitution, which are designed to protect individuals' rights. Although the Constitution guarantees individuals the right to be free from unreasonable searches, employers may require employees to undergo drug tests, which are a type of search, without having to establish a reason for the test. In addition, in order to prevent the innocent from being punished, the Constitution guarantees individuals the right to trial by jury, to cross-examine adverse witnesses, to rebut evidence, and to place on the accuser the burden of proving wrongdoing "beyond a reasonable doubt." Since employers are not bound by the constraints imposed by the Constitution, however, they may summarily take punitive action against employees without adequately protecting their rights. Although the economic sanction of losing a job for drug use is not as severe as the criminal sanction of going to jail, it is nevertheless a sanction with serious and possibly long-lasting consequences. A policy that subverts the cherished protections granted individuals under the Constitution by encouraging private parties to assume the state's role of criminal law enforcement thus has far-reaching implications for our society. Using private drug testing programs to detect and punish lawbreakers is an illegitimate and harmful rationale for workplace drug testing. LEGAL AND ETHICAL ISSUES RAISED BY WORKPLACE TESTING Workplace testing has led to legal challenges in federal and state courts and to the adoption of state statutes regulating workplace testing in at least five states[11-13]. Specific legal issues raised by workplace testing and the rights of employees and employers differ from state to state and according to employment sector (public sector or government, regulated industries, and private sector). Employees of federal, state, and municipal governments, for example, have greater rights in some respects than employees in the private sector because their employer, a governmental entity, is constrained by the federal Constitution or a state constitution. Government employees are protected against "unreasonable searches and seizures" by the Fourth Amendment in the Bill of Rights and by the due process clause of the Fourteenth Amendment. These constitutional rights may also apply in the context of private sector testing that is mandated by governmental regulations. In the private sector, however, federal constitutional protections do not constrain employers because their actions do not involve "state action." Private sector employees, however, may be protected by state constitutional provisions, federal or state statutes prohibiting discrimination against the handicapped, state statutes limiting workplace testing, or common law considerations, such as defamation of character, invasion of privacy, or breach of contract. In cases involving challenges to workplace testing programs arising under the Constitution, common law, or statutes, courts have tended, implicitly or explicitly, to weigh the employer's interest in testing against the employee's right and expectation of privacy. The more compelling the interests that lead employers to implement workplace testing and the less invasive of employee's privacy, the more likely courts are to view the program favorably. An employee's privacy interests are affected by the manner in which a test is administered (urinating in privacy or under surveillance) and by the extent to which private information gained from the test is disclosed to others. In order for an employee or applicant to waive the right to privacy and validly to consent to the administration of a workplace test, he or she must be informed in advance of the nature of the test, the potential consequences of an affirmative finding, and the audience to whom results may be revealed. GUIDELINES A number of guidelines were proposed by the APT Foundation Task Force to ensure that workplace testing programs are fair and to minimize unwanted and harmful effects of testing[6]. General guidelines include the following: 1. Workplace testing programs are most likely to succeed when they are used as part of a comprehensive approach to preventing and treating substance abuse in the workplace. Used alone, workplace testing is not likely to be effective. 2. Ideally, programs should also be developed through the cooperation of employers and employees, based on a shared recognition of the harmful effects of substance abuse and of the need to refer impaired employees to appropriate treatment. Since coworkers are more likely than supervisors or company medical personnel to know about impairment of a worker, programs that maximize the likelihood of reporting from this source are likely to be most effective. Implemented unilaterally in a way that increases tension in the workplace, workplace testing may be counterproductive. 3. Because alcohol is by far the most abused substance in the work force and a major cause of impaired safety and performance, a comprehensive approach to substance abuse needs to include alcohol in all discussions about workplace testing and in all programs to improve safety and productivity. 4. Some types of drug testing policies in the workplace are undesirable. Testing that is designed primarily to detect and punish any illegal drug use, without reference to its effect on the workplace, raises serious civil liberties concerns. It creates the spectre of employers acting as policemen and assuming the role of the state in criminal law enforcement. Individuals in a free society are entitled to maintain private lives that are free from unwarranted intrusions. Employers ought not have a right to demand private information from employees that is irrelevant to their on-the-job performance or concern for public safety. 5. With the exception of carefully defined high risk or safety sensitive positions, testing of employees should only be conducted based on individualized, reasonable suspicion of impairment. Random or universal drug testing is appropriate for employees who are in positions in which the lives of the worker, coworkers, or the general public would be regularly endangered by the impairment of the worker. In these positions, the possibility of being subjected to drug or alcohol testing at random and at any time while on the job may provide an additional incentive for the employee to remain substance free. Individuals who choose to work in such positions of responsibility must be willing to accept as a condition of their employment extremely close and careful scrutiny of their behavior on the job and of their fitness for duty. Because of the importance of ensuring that employees in these positions are free from substance abuse problems, it is particularly important that comprehensive programs designed to prevent substance abuse be developed for these positions. Employee Assistance Programs (EAP's) should be available, and use of EAP's should be encourage by guaranteeing that self-referral or referral by coworkers to such programs does not result in disciplinary action being taken against the employee. Work conditions that promote health and deter substance abuse should also be maintained. In addition to these general guidelines for workplace testing programs, the Task Force made the following specific recommendations: 1. Employers should notify applicants and employees of policies regarding the use of drugs and alcohol, the existence of an EAP (where one exists) or other suitable treatment, and workplace testing. The policies should specify under what circumstances testing will be conducted (preemployment testing of applicants, testing of impaired employees, testing following accidents or adverse incidents, or random testing). The policies should also specify the consequences of a positive test (e.g., refusal to hire and possibility of reapplying for applicants, referral to treatment or disciplinary action for employees) and to whom test results may be disclosed. 2. Individuals tested should give informed, written consent to testing prior to testing. The consent should include specific mention of the substances that can be detected and specify to whom results may be disclosed. The consent should also specify understanding of the company's policy regarding applicants or employees who test positive. 3. Testing should be conducted with the minimum of embarrassment to the person tested. Optimally, the person should be afforded the dignity of privacy in providing a specimen, and, in consideration thereof, the person should certify that they present an untampered specimen of urine. Employers should then test the temperature and specific gravity of the specimen to ensure its validity. Since sophisticated substance abusers may be able to subvert this procedure, some employers may prefer to insist on direct observation of the individual when the specimen is obtained. Whichever policy is adopted must be applied to all individuals tested. 4. Testing should be conducted in a manner that ensures the accuracy of test results. Procedures should ensure chain of custody of test specimens and the accuracy of reports. Testing should be performed only by certified, qualified laboratories, and blind proficiency testing of certified laboratories should be performed on a regular basis.(*2) Proper quality control procedures should be followed by the laboratory. Quality control procedures include, but are not limited to, repeating screening tests and running known positives and negatives with every batch. Repeat positive tests should be confirmed using gas chromatography and mass spectrometry. No test results should be disclosed outside of the laboratory prior to confirmation. 5. Testing procedures should be limited to detect only alcohol and drugs, such as heroin, PCP, and cocaine, for which there are no or only limited prescribed medical uses. Alternatively, employers may test for other drugs if they follow procedures that protect applicants or employees with medical conditions. These procedures would include insisting that test results are reported to an independent physician who would determine whether drug usage was prescribed by a physician for a medical condition and whether such drug usage could impair the individual's ability to perform the job. The physician would notify the employer only that the individual did or did not meet the medical standards for the job (in the case of applicants) or was or was not impaired at the time of testing (in the case of employees). 6. Employers should inform individuals who test positive of the positive results. Disclosure of positive results to the individual tested allows an opportunity to offer an explanation or defend against an incorrect presumption of substance abuse. 7. Test results should be kept confidential and disclosed only to the company medical advisor and/or the company's Director of Personnel. Test results should not be disclosed to anyone outside the workplace. In addition to these guidelines, which should be mandatory for all testing, in preemployment testing, optimally, rejected applicants should be given the opportunity to reapply after a defined period or after they have completed treatment. CONCLUSION The principal motivations for workplace programs to detect substance abuse are exemplary: to promote health, safety, and productivity in the workplace or to refer impaired employees into treatment. To accomplish these goals, testing needs to be performed fairly, accurately, confidentially, and with a minimum of embarrassment to the individual tested, and results of testing should be used to facilitate treatment, not punishment. Problems may arise when workplace testing programs are implemented unilaterally and without the cooperation of employees and management, when workplace testing is not implemented as part of a broader program to combat substance abuse in the workplace, when workplace testing focuses on illegal drug use and not on impairment caused by alcohol and drugs, and when workplace testing is used to detect and punish any drug use rather than to refer impaired employees into treatment. Historically, alcohol problems have been the focus of workplace substance abuse programs. Many of the programs and policies developed to combat alcohol abuse in the workplace have proven successful and could be adapted to combat other substance abuse problems. The central tenets of most successful programs have been education of employees about the effects of alcohol use on performance and safety, development of Employee Assistance Programs (EAP's), and implementation of policies to facilitate constructive confrontation and referral to EAP's of impaired employees. These principles should continue to be the basis for comprehensive programs aimed at preventing or curtailing impairment resulting from drug and alcohol abuse. (*1)Members of the Task Force included Esther Armmand; Richard H. Bowerman; Robert E. Brubaker, MD; Mark Cullen, MD; Ralph Gregory Elliot; Daniel J. Freed; Peter Jatlow, MD; Herbert D. Kleber, MD; David F. Musto, MD; Richard S. Schottenfeld, MD; Barry R. Williams; Susan Carle; and Tanina Rostain. (*2)As of this writing, there are no certification procedures for laboratories. The federal government is moving rapidly to establish a certification process. REFERENCES [1]Dupont, R. L., Substance Abuse in the Construction Industry: The Problem and Its Identification, Presented at the National Conference on Substance Abuse in Construction, Minneapolis, Minnesota, July 17, 1986. [2]Bickerton, R. L., Urinalysis: Dilemma of the 80's, EAP Dig. pp. 27-35 (September/October 1986). [3]Weber, E. M., Counterpoint, U.S. Journal p. 10 (February 1986). [4]Abrams, R. I., Wishful thinking and public policy, Nova Law Rev. 11(2):291-294 (Winter 1987). [5]M. Levin-Epstein and S. Sola (eds.), Alcohol and Drugs in the Workplace: Costs, Controls and Controversies, Bureau of National Affairs, Washington, D.C., 1986. [6]The APT Foundation Task Force Report on Drug and Alcohol Testing in the Workplace, New Haven, Connecticut, 1988. [7]Council on Scientific Affairs, Scientific issues in drug testing, J. Am. Med. Assoc. 257(22):3110-3114 (June 12, 1987). [8]R. L. Hawks and C. N. Chiang (eds.), Urine Testing for Drugs of Abuse (NIDA Research Monograph 73 Rockville, Maryland, 1986. [9]Hoyt, D. W., Finnigan, R. E., Nee, T., Shultz, T. F., and Butler, T. J., Drug testing in the workplace--Are methods legally defensible? A survey of experts, arbitrators, and testing laboratories, J. Am. Med. Assoc. 258(4):504-509 (July 24/31, 1987). [10]Pettitt, B. C., Jr., Oysz, S. M., and Hood, L. V. S., Opiates in poppy seed: Effect on urinalysis results after consumption of poppy seed cake-filling, Clin. Chem. 33(7):1251-1252 (1987). [11]Legal Action Center, Urine testing: Cases flooding the courts, Of Substance pp. 1-2 (January/February 1986). [12]Dogoloff, L. I., and Angarola, R. T., Urine Testing in the Workplace (S. Price, ed.), The American Council for Drug Education, Rockville, Maryland, 1985. [13]Bookspan, P. T., Behind open doors: Constitutional implications of government employee drug testing, Nova Law Rev. 11(2):307-370 (Winter 1987). Richard S. Schottenfeld, MD Yale University School of Medicine Substance Abuse Treatment Unit Connecticut Mental Health Center New Haven, Connecticut 06519 |
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