BILL ANALYSIS                                                                                                                                                                                                    






                           SENATE JUDICIARY COMMITTEE
                        Senator Ellen M. Corbett, Chair
                           2007-2008 Regular Session


          AB 2279                                                A
          Assembly Member Leno                                   B
          As Amended April 21, 2008
          Hearing Date: June 24, 2008                            2
          Health and Safety Code                                 2
          GMO:jd                                                 7
                                                                 9

                                     SUBJECT
                                         
                  Medical Marijuana: Employment Discrimination

                                   DESCRIPTION  

          The bill would prohibit employment discrimination on the  
          basis of a person's status as a qualified patient (medical  
          marijuana user) or designated primary caregiver, or on the  
          basis of the person's positive drug test for marijuana,  
          provided the person is a qualified patient and the medical  
          use of marijuana does not occur at the place of employment  
          or during hours of employment.  An exception to the  
          prohibition would be when an employer hires a person in a  
          safety-sensitive position, as specified.

          The bill would create, for a person who has suffered  
          discrimination as described above, a civil action for  
          damages, injunctive relief, and any other appropriate  
          equitable relief to protect the peaceable exercise of the  
          right or rights secured.

          Finally, the bill contains a savings clause that states  
          nothing in the section shall  prohibit the employer from  
          terminating the employment, or taking other corrective  
          action against a person who is impaired on the property or  
          premises of the place of employment or during hours of  
          employment because of the medical use of marijuana.

                                    BACKGROUND  

          In 1996, California voters passed Proposition 215, the  
                                                                 
          (more)



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          Compassionate Use Act, "to ensure that seriously ill  
          Californians have the right to obtain and use marijuana for  
          medical purposes."  Following passage of the proposition,  
          several issues arose, including the establishment of a  
          qualified patient's right to use medical marijuana outside  
          the workplace.  SB 420 (Vasconcellos, Ch. 875, Stats. 2003)  
          was enacted to clearly prohibit the use of medical  
          marijuana by qualified patients on the property or premises  
          of any place of employment or during the hours of  
          employment. (Health & Safety Code  11362.785.)
           
          In September 2001, Gary Ross, a 45-year old disabled Air  
          Force veteran, was fired after failing an employer-mandated  
          drug test.  He was using medical marijuana on his doctor's  
          recommendation outside the workplace and had informed his  
          workplace of that fact.  He sued for unlawful  
          discrimination based on disability under the Fair  
          Employment and Housing Act (FEHA) and for wrongful  
          termination in violation of public policy.  The trial court  
          sustained a demurrer as to both causes of action.  The  
          court of appeal affirmed, and upon further appeal, on  
          January 24, 2008, the California Supreme Court ruled that:  
          (1) nothing in the text or history of the Compassionate Use  
          Act suggests the voters intended the measure to address the  
          respective rights and duties of employers and employees;  
          and (2) the FEHA does not protect the employment rights of  
          persons who test positive for illegal drugs (which  
          marijuana is under state and federal law). (Ross v.  
          Ragingwire Telecommunications, Inc. (2008) 42 Cal.4th 920,  
          January 12, 2008.)

          Americans for Safe Access, the sponsor of AB 2279, reports  
          that it receives more than 100 inquiries each year from  
          across the state covering medical marijuana related  
          pre-employment and employment discrimination issues.  They  
          come from employees in 25 of the state's 58 counties, and  
          from large well-known businesses such as Walmart, Safeway,  
          DirecTV, Kaiser Permanente, Costco Wholesale, UPS, Forster  
          Farms Dairy, etc.  The sponsor and author claim that  
          employment discrimination against medical marijuana  
          patients is a widespread problem facing Californians today.

          The author and proponents state that AB 2279 intends to  
          clarify the law on the employment rights of medical  
          marijuana users, in light of the Supreme Court's decision  
                                                                       




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          in Ross v. Ragingwire.

                             CHANGES TO EXISTING LAW
          
          Existing law  , Proposition 215 of 1996, the Compassionate  
          Use Act, confers on a person the right to obtain and use  
          marijuana for medical purposes where medical use is deemed  
          appropriate and has been recommended by a physician who has  
          determined that the person's health would benefit from the  
          use of marijuana in treatment of cancer, anorexia, AIDS,  
          chronic pain, spasticity, glaucoma, arthritis, migraine, or  
          any other illness for which marijuana provides relief.  
          (Health & Safety Code  11362.5(b)(1).  All references are  
          to the Health & Safety Code, unless otherwise indicated.)  

           Existing law  removes the criminal penalties for cultivation  
          and possession of marijuana by qualified patients, who are  
          persons with a physician's written or oral recommendation  
          or approval to use marijuana for medical use, or by their  
          primary caregivers, and protects physicians from punishment  
          for recommending marijuana to a patient for medical  
          purposes. ( 11362.5(b), (c) and (d).)

           Existing law  provides that employment having no specified  
          term may be  terminated at the will of either party on  
          notice to the other. (Labor Code  2922.)

           Existing law  provides that it shall be an unlawful  
          employment practice to discriminate based on race,  
          religious creed, color, national origin, ancestry, physical  
          disability, mental disability, medical condition, marital  
          status, sex, age, or sexual orientation.  (Fair Employment  
          and Housing Act (FEHA), Government Code  12940 et seq.)   
          The FEHA requires employers in their hiring decisions to  
          take into account the feasibility of making reasonable  
          accommodations to a person with a disability or medical  
          condition. (Gov. Code  12940(a)(2).)

           This bill  would make it unlawful for an employer to  
          discriminate against a person in hiring, termination, or  
          any term of employment or otherwise penalize a person,  
          based on (1) the person's status as a qualified patient or  
          a designated primary caregiver, or (2) the qualified  
          patient's positive drug test where the medical use of  
          marijuana does not occur on the property or premises of the  
                                                                       




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          employer or during the hours of employment. 

           This bill  would establish a civil cause of action by a  
          qualified patient or primary caregiver who suffered  
          discrimination for damages and injunctive relief, and other  
          equitable relief to protect the peaceable exercise of the  
          right or rights secured. 

           This bill  would not apply when the employer employs a  
          person in a safety-sensitive position, as defined. 

          Finally,  this bill  would expressly provide that the bill  
          would not prohibit an employer from terminating the  
          employment of or taking corrective action against a person  
          who is impaired on the workplace premises or who is  
          impaired during working hours.

                                     COMMENT
           
          1.    Need for the bill  

            The author writes:

              On January 24, 2008 the California Supreme court  
              ruled in Ross v. Ragingwire Telecommunications that  
              an employee using medical marijuana with a doctor's  
              recommendation as permitted by California law may be  
              fired solely because of their status as a medical  
              cannabis patient.  AB 2279 would make it unlawful to  
              discriminate in employment practices based on an  
              employee's legal use of medical marijuana outside the  
              work place and not during work hours.

              In its ruling the California Supreme Court ignored  
              the will of the voters and the legislature by  
              invalidating the rights of over 250,000 patients to  
              be free from discrimination in employment.  Most  
              concerning was the fact that Gary Ross was not  
              employed in a safety-sensitive position, did not use  
              medical marijuana at the workplace, and was not under  
              the influence of marijuana at work.  In essence, the  
              Court said that Ross could be fired simply because of  
              his status as a patient using doctor recommended  
              medication. 

                                                                       




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              In denying Ross certain protections from employment  
              discrimination, the High Court did invite the  
              Legislature to clarify its intent with respect to the  
              employment rights of medical cannabis patients.

              AB 2279 will provide the clarification requested by  
              the Court and reverse a decision that puts every  
              medical cannabis patient in jeopardy of losing their  
              job without due cause. ?AB 2279 clearly establishes  
              that medical marijuana patients have a right to work.  
               This bill does not require an employer to  
              accommodate marijuana impairment or use in the  
              workplace, and does not require the employer to  
              violate any state or federal law. ?

              The policy of this state should be to encourage  
              gainful employment by those patients who are able to  
              work.  In addition to being an issue for basic human  
              fairness, medical marijuana patients who lose their  
              jobs could become an additional burden for state  
              general assistance, MediCal, and other social  
              services programs that are already stressed by  
              chronic funding shortages.  AB 2279 is a reasonable  
              solution that protects patients, employers, and  
              public safety.

            In 2006, the author and other legislators filed an amicus  
            brief in Ross v. Ragingwire, indicating to the appellate  
            court the Legislature's intent in SB 420 (Vasconcellos,  
            Ch. 875, Stats. 2003) to permit the use of medical  
            marijuana outside the workplace setting and to make FEHA  
            applicable so that "accommodation of medical cannabis use  
            by disabled persons with medical conditions" are required  
            of employers.  The appellate court rejected the argument,  
            thus inviting further clarification by the Legislature.   
            This bill was introduced to do just that, after the  
            Supreme Court affirmed the lower court decisions.




          2.    The Compassionate Use Act and federal law remain in  
          conflict
             
            California voters enacted the Compassionate Use Act in  
                                                                       




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            1996 in order to permit the use of marijuana for medical  
            purposes by persons deemed qualified by their physicians.  
             Marijuana was then, and still is, an illegal drug both  
            under federal and state law, and its use, possession,  
            distribution, cultivation, or sale carries significant  
            penalties.  Under federal law, possession of marijuana,  
            even by medical users, continues to be a crime: the  
            Controlled Substances Act provides that except as  
            provided by the Act, it is unlawful for any person  
            knowingly or intentionally?to manufacture, distribute, or  
            dispense, or possess with intent to manufacture,  
            distribute, or dispense a controlled substance. (21  
            U.S.C.  841(a).)  The only exception provided in the Act  
            for marijuana, a Schedule 1 drug, is for its use in  
            government-controlled research projects.

            Lawsuits filed by the United States against "medical  
            cannabis dispensaries" have resulted in the complete  
            rebuke of efforts by supporters of medical marijuana use  
            to create a "medical necessity" exception to the  
            Controlled Substances Act's prohibition on manufacturing  
            and distributing marijuana.  (United States v. Oakland  
            Cannabis Buyers' Cooperative et al.(2001) 532 U.S. 483,  
            491-485.)  This conflict remains to this day.

            Proponents of this bill, however, contend that federal  
            law does not stand as an obstacle to AB 2279, as further  
            discussed in Comment 4b.

          3.    Ross v. Ragingwire Telecommunications, Inc: FEHA does  
            not provide protection to medical marijuana users at work  

            In Ross v. Ragingwire Telecommunications the Supreme  
            Court revisited the ballot arguments proferred by  
            supporters of Proposition 215 (the initiative that  
            enacted the Compassionate Use Act) and declared that  
            "[n]othing in the act's text or history indicates the  
            voters intended to articulate any policy concerning  
            marijuana in the employment context, let alone a  
            fundamental public policy requiring employers to  
            accommodate marijuana use by employees." Further, the  
            court said, an examination of the ballot arguments did  
            not put defendant employer (and other employers) on  
            notice that employers would thereafter be required under  
            the FEHA to accommodate the use of marijuana.
                                                                       




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            Gary Ross also contended that the Legislature's passage  
            of SB 420, that enacted  11362.785 evidences the  
            legislative intent of the Compassionate Use Act to  
            require employers to accommodate employees' use of  
            medical marijuana at home.  That section provides:

               (a) Nothing in this article shall require any  
               accommodation of any medical use of marijuana on the  
               property or premises of any place of employment or  
               during the hours of employment or on the property or  
               premises of any jail, correctional facility, or other  
               type of penal institution in which prisoners reside or  
               persons under arrest are detained.

            Answering plaintiff's argument that  11362.785 at least  
            inferred a requirement of accommodation under FEHA, the  
            court said, "[e]ven without inferring a requirement of  
            accommodation, the statute can be given literal effect as  
            negating any expectation that the immunity to criminal  
            liability for possessing marijuana granted in the  
            Compassionate Use Act gives medical users a civilly  
            enforceable right to possess the drug at work or in  
            custody?In any event, ?we do not believe that Health and  
            Safety Code section 11362.785, subdivision (a), can  
            reasonably be understood as adopting such a requirement  
            silently and without debate."

          4.    AB 2279 would prohibit discrimination in employment  
            based on status as a medical marijuana user

             Under existing law, the Compassionate Use Act does not  
            require any accommodation of any medical use of marijuana  
            on the property or premises of any place of employment or  
            during the hours of employment, or on the property or  
            premises of any jail, correctional facility, or other  
            type of penal institution in which prisoners reside or  
            persons under arrest are detained. ( 11362.785.)   
            Proponents read this provision as current law prohibiting  
            use of medical marijuana by qualified patients at the  
            workplace or during working hours.

            Based on the Court's holding in Ross v. Ragingwire that   
            11362.785 does not infer an accommodation under FEHA is  
            required, this bill would create a standalone statute  
                                                                       




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            prohibiting discrimination in employment based on status  
            as a qualified medical marijuana user or on the basis of  
            a positive marijuana drug test when use of marijuana  
            occurred outside the employment workplace or during  
            non-working hours.

            a.    Discrimination on the basis of status
             
               AB 2279 would prohibit an employer from discriminating  
               against a person in hiring, termination, or in any  
               term or condition of employment, or otherwise  
               penalizing a person on the basis of that person's  
               status as a qualified patient (medical marijuana user)  
               or a designated primary caregiver.  

               Gary Ross and other medical marijuana users are  
               protected under the Compassionate Use Act because the  
               voters decided, in passing Proposition 215, to  
               disagree with Congress' assessment that marijuana has  
               a "high potential for abuse," that it lacks any  
               "currently accepted medical use in treatment in the  
               United States," and that it lacks "accepted safety for  
               use?under medical supervision." (Id., citing 21 U.S.C.  
                812(b)(1) and Gonzales v. Raich (2005) 545 U.S. 1,  
               14.)  Instead, the voters viewed the possibility of  
               beneficial medical use of marijuana as sufficient  
               basis for exempting from criminal liability under  
               state law patients whose physicians recommend the  
               drug.  This logic, however, said the court in Ross,  
               did not compel the voters to take the additional step  
               of requiring employers to accommodate marijuana use by  
               their employees.

               Proponents contend that it doesn't make sense to allow  
               a person to use medical marijuana to control pain, for  
               example, and be immune from criminal liability, just  
               to be deprived of the opportunity to work and be  
               self-supporting because the Compassionate Use Act did  
               not mention employment law in the findings and  
               declarations that precede the Act's operative  
               provisions.  And since it was the Supreme Court's view  
               that the follow up legislation, SB 420, did not  
               clearly state legislative intent to protect the  
               employment rights of medical marijuana users, AB 2799  
               is the author's and proponents' response to the call  
                                                                       




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               for clarity.

               While there may be justification for the prohibition  
               against discrimination in employment decisions on the  
               basis of status as a medical marijuana user or  
               qualified patient, no justification has been made to  
               include designated primary caregivers in the protected  
               class in the voluminous material provided by  
               proponents.

               SHOULD PROTECTION AGAINST DISCRIMINATION IN EMPLOYMENT  
               FOR A DESIGNATED PRIMARY CAREGIVER BE REMOVED FROM THE  
               BILL?

            b.    Discrimination on the basis of positive marijuana  
            drug test  

               Under AB 2279, an employer also may not discriminate  
               against a qualified patient with a positive test for  
               marijuana, as long as the medical use of marijuana  
               does not occur on the premises of the place of  
               employment or during the hours of employment.

               FEHA does not require employers to accommodate the use  
               of illegal drugs. (Ross v. Ragingwire, supra, citing  
               Loder v. City of Glendale (1997) 14 Cal.4th 846).  In  
               Loder the high court concluded that an employer can  
               require prospective employees to undergo testing for  
               illegal drugs and alcohol and an employer can have  
               access to test results, without violating California's  
               Confidentiality of Medical Information Act (Civil Code  
                56 et seq.)  Thus, the Court declared in Loder that  
               employers may deny employment to persons who test  
               positive for illegal drugs and confirmed in Ross that  
               the FEHA was unavailable as a source of protection for  
               the employment rights of medical marijuana users.

               Proponents contend, however, that except for the  
               federal 1991 Omnibus Transportation Employee Testing  
               Act that requires employers to test all workers who  
               apply for or currently hold "safety sensitive"  
               positions in the transportation industry, there are no  
               state or federal laws that require private businesses  
               to have drug testing programs.  Even the 1988 Drug  
               Free Workplace Act that requires companies with  
                                                                       




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               federal contracts in excess of $25,000 to show they  
               have made appropriate efforts to maintain a drug-free  
               workplace does not require drug testing of job  
               applicants or current employees.  In fact, a report by  
               the American Civil Liberties Union, "Drug Testing: A  
               Bad Investment" (September 1999) states that while no  
               court has held an employer legally liable for not  
               having a drug testing program, employers have incurred  
               substantial legal costs defending their drug testing  
               programs against workers' claims of wrongful  
               dismissal.

               Proponents insist that the federal Drug-Free Workplace  
               Act does not place any general obligation on employers  
               to drug test their employees, much less to fire them  
               for a positive drug test for marijuana (citing Parker  
               v. Atlanta Gas Light Co. (S.D. Ga. 1993) 818 F.Supp.  
               345, 347), but acknowledge that under the Omnibus  
               Transportation Employee Testing Act, regulations of  
               the federal Department of Transportation do require  
               employers to drug test employees in safety sensitive  
               positions and to remove them from such positions if  
               they test positive for the illegal use of drugs.

               AB 2279 would provide that no employer may  
               discriminate against a qualified patient who tests  
               positive for marijuana use, so long as the medical use  
               of marijuana occurs outside the property or premises  
               of work or during non-working hours.  In other words,  
               a worker who is a medical marijuana user may use it  
               anyplace but work and anytime but working hours.  The  
               only question left would be whether the use of medical  
               marijuana impairs the ability of the employee who is a  
               qualified patient to perform his or her work.  That  
               question is resolved below.

             c.    No protection from employment discrimination if  
               employee is impaired because of medical use of  
               marijuana
              
               The bill contains a savings clause that states nothing  
               in the section shall  prohibit an employer from  
               terminating the employment of, or taking other  
               corrective action against, a person who is impaired on  
               the property or premises of the place of employment or  
                                                                       




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               during hours of employment because of the medical use  
               of marijuana.

               In this the author and proponents are cognizant of the  
               possible effects of marijuana on the performance of an  
               employee, and thus provide employers with the right to  
               exercise their business judgment in taking corrective  
               action when that employee is impaired and cannot  
               function at an acceptable level. "This means that when  
               safety is in question employees can be terminated for  
               a positive drug test [for marijuana] in order to  
               protect employers from liability and to ensure public  
               safety," states the author.

               It should be noted that the employer's prerogative to  
               drug test for illicit drugs to determine whether an  
               employee is impaired due to drug use is applicable to  
               all employees, not just to those who are impaired due  
               to medical marijuana use, and that the employer's  
               right to exercise business judgment in taking  
               corrective action, including termination, applies to  
               all employees.

               Suggested technical amendment: 

               On page 4, line 12, strike out "a person" and insert:   
                an employee

             d.    No prohibition against discrimination on the basis  
               of a positive drug test for marijuana where employment  
               is for a safety sensitive position  

               The protection established by AB 2279 for a person who  
               tests positive for marijuana where the medical use of  
               the drug occurs outside of the employment premises or  
               during nonworking hours would not be available in  
               "safety sensitive" jobs.  Lifted from the Omnibus  
               Transportation Employee Testing Act, these safety  
               sensitive jobs  originally were those associated with  
               aviation, railroad, and mass transportation employees.

               Under this bill a "safety-sensitive" position means a  
               position in which medical cannabis-affected  
               performance could clearly endanger the health and  
               safety of others, and shall have the following general  
                                                                       




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               characteristics:

                           Its duties involve a greater than normal  
                    level of trust, responsibility for, or impact on  
                    the health and safety of others.
                           Errors in judgment, inattentiveness, or  
                    diminished coordination, dexterity, or composure  
                    while performing its duties could clearly result  
                    in mistakes that would endanger the health and  
                    safety of others.
                           An employee in a position of this nature  
                    works independently, or performs tasks of a  
                    nature that it cannot safely be assumed that  
                    mistakes like those described above could be  
                    prevented by a supervisor or another employee.

               A "safety-sensitive" position also includes a position  
               that involves the performance of a "safety-sensitive  
               function," which are specified:

               (1) as described in Section 655.4 of Title 49 of the  
                 Code of Federal Regulations:
                               Operating a revenue service vehicle;
                               Operating a nonrevenue service  
                      vehicle, when required to be operated by a  
                      holder of a commercial driver's license;
                               Controlling dispatch or movement of a  
                      revenue service vehicle;
                               Maintaining (including repairs,  
                      overhaul, and rebuilding) a revenue service  
                      vehicle or equipment used in revenue service,  
                      with exception for specified employers; and
                               Carrying a firearm for security  
                      purposes.

               (2) as described in Section 13951(d) of the Government  
                 Code, the following law enforcement personnel: every  
                 district attorney, municipal police department,  
                 sheriff's department, district attorney's office,  
                 county probation department, and social services  
                 agency, the Department of Justice, the Department of  
                 Corrections, the Department of the Youth Authority,  
                 the Department of the California Highway Patrol, the  
                 police department of any campus of the University of  
                 California, California State University, or  
                                                                       




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                 community college, and every agency of the State of  
                 California expressly authorized by statute to  
                 investigate or prosecute law violators.

            In short, employers hiring for all of the above jobs may  
            not only require drug testing but also refuse to hire or  
            take adverse employment action against a person who tests  
            positive for marijuana, even if the person is a qualified  
            medical marijuana user whose use of medical marijuana  
            occurs any place but the work location or any time but  
            working hours.

            However, under this bill an employer would still be  
            prohibited from discriminating against the above "safety  
            sensitive" employees or potential employees on the basis  
            of the person's status as a qualified patient, i.e., a  
            medical marijuana user.




          5.    New civil action for damages based on discrimination  
            for qualified patient or designated primary caregiver

             Under the state's employment discrimination laws, an  
            employee may file a complaint of unlawful employment  
            practice with the Department of Fair Employment and  
            Housing (DFEH) or seek relief directly in superior court  
            for wrongful termination or adverse employment action.   
            Filing a complaint with the DFEH has the advantage of a  
            state agency investigating allegations of discriminatory  
            action by the employer and getting the benefit of the  
            state agency's findings before going to court pursuant to  
            a right to sue letter issued by the agency. 

            This bill would establish a new civil action for a person  
            who suffered discrimination prohibited by the bill, i.e.,  
            for a qualified patient (a medical marijuana user) or a  
            designated primary caregiver (assuming the caregiver is  
            kept in the bill, see Comment 4a), to seek damages,  
            injunctive relief, and "any other appropriate equitable  
            relief to protect the peaceable exercise of the right or  
            rights secured."  

            Generally, a civil action involving employment seeks  
                                                                       




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            reinstatement to a job or position, with backpay, actual  
            damages, recoupment of nonpecuniary losses, perhaps a  
            change in policy at the place of employment, and  
            reasonable attorney's fees and costs.  An award of  
            reasonable attorney's fees and costs is generally granted  
            by a court only if authorized by statute or by  
            contractual agreement of the parties.  It is not clear  
            whether any or all of the above items of relief are  
            intended to be recovered by a plaintiff under this bill.

            SHOULD THESE BE CLARIFIED?

          6.    Opponents' concerns

             Opposition to AB 2279 comes from different viewpoints.   
            The National Federation of Independent Business -  
            California (NFIB), for example, contends that AB 2279  
            "puts an employer in an untenable position with regard to  
            state-mandated workplace safety laws.  This bill does not  
            allow employers to carry out their duty to:
                     "furnish employment and a place of employment  
                 that is safe and healthful for the employees  
                 therein." Labor Code sec. 6400(a)
                     "Adopt and use methods and processes reasonably  
                 adequate to render the employment and place of  
                 employment safe" Labor Code Sec. 6403(b)
                     To do every other thing reasonably necessary to  
                 protect life, safety, and health of employees" Labor  
                 Code Sec. 6403(c)."

            Further, the NFIB states that while they understand that  
            AB 2279 does allow employers to exercise their right to  
            take corrective action against impaired employees, "this  
            bill cannot account for the possibility that accidents  
            and death may occur prior to any realization that an  
            employee's use of medicinal marijuana has caused  
            impairment.  This places employers in danger of costly  
            workplace safety citations and higher workers'  
            compensation premiums due to this bill."(Letter dated  
            June 10, 2008.)

            Another view is expressed by the Association of  
            California Health Care Districts (ACHD): "[w]hile ACHD is  
            sympathetic to the needs of patients who use medical  
            marijuana, our primary concern is for the safety of  
                                                                       




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            patients who rightly expect that their care givers will  
            have met certain employment criteria, one of which is  
            being drug free.  Although AB 2279 excludes individuals  
            employed in a 'safety sensitive position,' that term is  
            not sufficiently defined.  Many positions in a hospital  
            are clearly 'safety-sensitive'; however, the definition  
            could be construed to exclude them." (Letter dated June  
            10, 2008.)

            While persons involved in the delivery of health care do  
            not belong in the statutorily-specified categories, they  
            may in fact fall within the more general definition of  
            safety-sensitive positions excluded from the scope of AB  
            2279.  This does not, however, mollify concerns of the  
            California Hospital Association (CHA).  "While CHA is  
            sympathetic to the needs of patients who use medical  
            marijuana, hospitals are in a very different role when  
            faced with an applicant who has tested positive for  
            marijuana use.  Patients, health care workers and our  
            communities expect hospitals to screen out applicants who  
            may appear for work in an impaired state.  Requiring  
            hospitals to hire individuals who have tested positive  
            for marijuana use undermines their ability to ensure the  
            highest quality of care. ? The question of whether an  
            employee is 'impaired' is fact specific and the law  
            requires employers to have probable cause before seeking  
            a drug test." (Letter dated June 10, 2008.)

            The California Narcotics Officers Association, California  
            Peace Officers' Association, and the California Police  
            Chiefs Association have also stated their fierce  
            opposition to the bill.  "Proposition 215, which enacted  
            California's so-called medical marijuana law, not only  
            violates federal law, but is so loosely structured that  
            someone who simply wants to smoke marijuana 'legally'  
            need only contrive a medical condition and find a  
            compliant physician, who, for a fee, will 'recommend'  
            that marijuana is appropriate for that person."  Citing  
            the "60 Minutes" television series on medical marijuana  
            use in California, these groups express their belief that  
            a significant number of "medical marijuana"  
            recommendations are "simply bogus.  Given that reality,  
            it is inappropriate to use Proposition 215 - an overly  
            broad, poorly worded law - to prevent employers from  
            attempting to protect their workplace." (Letter dated  
                                                                       




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            June 11, 2008.)
            All of these opposition comments seem to focus on the  
            practice of drug-testing in the workplace.  While this  
            bill is focused on prohibiting employment discrimination  
            based on status as a qualified medical marijuana user,  
            the contentious issue centers around drug testing by  
            employers. There is really no other way for an employer  
            to find out whether an employee is a medical marijuana  
            user unless the employee discloses the fact prior to or  
            during the employment, or through drug testing in the  
            workplace.  As contended by the proponents in Comment 3,  
            drug testing is not required of employers under state or  
            federal law, and it is proving to be more costly to  
            businesses because of substantial costs in defending the  
            practice from challenges made by employees.


          Support:        American Federation of State, County, and  
                    Municipal Employees (AFSCME), AFL-CIO; AIDS  
                    Healthcare Foundation; Americans for Safe Access;  
                    California Labor Federation; SEIU; National  
                    Lawyers Guild; West Hollywood Chamber of  
                    Commerce; San Francisco AIDS Foundation; The AIDS  
                    Institute; National Association of People with  
                    AIDS; Drug Policy Alliance; California NORML;  
                    HIVictorious, Inc.; Lambda Letters Project; AIDS  
                    Project Los Angeles; Berkeley Chamber of  
                    Commerce;  South Carolina Campaign to End AIDS  
                    (SC-C2EA); American Civil Liberties Union (ACLU)

          Opposition:   Californians For Drug-Free Schools;  
                    Association of California Healthcare Districts  
                    (ACHD); California Narcotic Officers Association;  
                    California Peace Officers' Association;  
                    California Police Chiefs Association; California  
                    Hospital Association (CHA); California Chamber of  
                    Commerce; ALPHA Fund; California Association of  
                    Health Facilities (CAHF); California Association  
                    of Joint Powers Authorities (CAJPA); CSAC Excess  
                    Insurance Authority; National Federation of  
                    Independent Business (NFIB); California  
                    Employment Law Council (CELC); California  
                    Manufacturers and Technology Association (CMTA);  
                    City of Modesto; Western Electrical Contractors  
                    Association (WECA-IEC); Capitol Resource Family  
                                                                       




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                    Impact; Health Advocated Rejecting Marijuana  
                    (HARM)

                                     HISTORY
           
          Source:  Americans for Safe Access (Sponsor)

          Related Pending Legislation: None Known

          Prior Legislation: SB 420 (Vasconcellos, Ch. 875 Stats.  
          2003) See Comment 1.

          Prior Vote:Assembly Judiciary Committee (Ayes 6, Noes 3)
                    Assembly Labor & Employment Committee (Ayes 6,  
          Noes 2)
                    Assembly Floor (Ayes 41, Noes 35)
          
                                 **************