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EEOC publishes new guidance on employee opioid addiction

September 2020 employment law letter
Authors: 
Colin Hargreaves, Felhaber Larson

Opioid addiction continues to be a serious problem in the United States. As with many other prescription medications, opioids present significant challenges to employers, who must address issues relating to both the lawful use of the medication as well as the impact of its abuse.

The Equal Employment Opportunity Commission (EEOC) recently issued a guidance document entitled “Use of Codeine, Oxycodone, and Other Opioids: Information for Employees.” While not breaking any new legal ground, the guidance is a powerful reminder to employers that opioid addiction often constitutes a disability entitling the individual to the rights and protections of the Americans with Disabilities Act (ADA), including the right to reasonable accommodation.

Legal background

The ADA considers a person addicted to alcohol or drugs to be disabled and therefore entitled to legal protection if she:

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