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HomeMy WebLinkAbout01-22-2026 ARB Agenda Packet Administrative Review Board AGENDA Thursday, January 22, 2026, 4:00 p.m. Council Hearing Room, 990 Palm Street, San Luis Obispo SPECIAL MEETING OF THE ADMINISTRATIVE REVIEW BOARD The Administrative Review Board holds in-person meetings. Zoom participation will not be supported. Attendees of City Council or Advisory Body meetings are eligible to receive one hour of complimentary parking; restrictions apply, visit Parking for Public Meetings for more details. INSTRUCTIONS FOR PUBLIC COMMENT: Public Comment prior to the meeting (must be received 3 hours in advance of the meeting): Mail - Delivered by the U.S. Postal Service. Address letters to the City Clerk's Office at 990 Palm Street, San Luis Obispo, California, 93401. Email - Submit Public Comments via email to advisorybodies@slocity.org. In the body of your email, please include the date of the meeting and the item number (if applicable). Emails will not be read aloud during the meeting. Voicemail - Call (805) 781-7164 and leave a voicemail. Please state and spell your name, the agenda item number you are calling about, and leave your comment. Verbal comments must be limited to 3 minutes. All voicemails will be forwarded to the members and saved as Agenda Correspondence. Voicemails will not be played during the meeting. *All correspondence will be archived and distributed to members, however, submissions received after the deadline may not be processed until the following day. Public Comment during the meeting: Meetings are held in-person. To provide public comment during the meeting, you must be present at the meeting location. Electronic Visual Aid Presentation. To conform with the City's Network Access and Use Policy, Chapter 1.3.8 of the Council Policies & Procedures Manual, members of the public who desire to utilize electronic visual aids to supplement their oral presentation must provide display-ready material to the City Clerk by 12:00 p.m. on the day of the meeting. Contact the City Clerk's Office at cityclerk@slocity.org or (805) 781-7114. Pages 1.CALL TO ORDER Chair Karlin will call the Special Meeting of the Administrative Review Board to order. 2.OATH OF OFFICE City Clerk Teresa Purrington will administer the Oath of Office to Jim Gardiner, who was appointed to the Administrative Review Board on September 16, 2025. As the Board meets on an as-needed basis, a meeting has not been held since this term began. 3.CONSENT Matters appearing on the Consent Calendar are expected to be non- controversial and will be acted upon at one time. A member of the public may request the Administrative Review Board to pull an item for discussion. The public may comment on any and all items on the Consent Agenda within the three-minute time limit. 3.a CONSIDERATION OF MINUTES - May 29, 2025 ADMINISTRATIVE REVIEW BOARD MINUTES Consideration of the Administrative Review Board Minutes of May 29, 2025. Recommendation: Approve the Administrative Review Board Minutes of May 29, 2025. 4.BUSINESS ITEMS 4.a ORIENTATION AND TRAINING 5 The Administrative Review Board will have the opportunity to review the orientation and training materials, and to ask staff any related questions. Legal counsel to the Board will provide training to the Board. 5.APPEALS Any decision of the Administrative Review Board is final unless appealed to the Superior Court. Filing for de novo review must happen within 20 days of the Board's decision pursuant to California Government Code Section 53069.4. To challenge the decision by writ, please refer to California Code of Civil Procedure Section 1094.5 or consult an attorney. 6.ADJOURNMENT The next Special Meeting of the Administrative Review Board will be scheduled as needed. LISTENING ASSISTIVE DEVICES are available -- see the Clerk The City of San Luis Obispo wishes to make all of its public meetings accessible to the public. Upon request, this agenda will be made available in appropriate alternative formats to persons with disabilities. Any person with a disability who requires a modification or accommodation in order to participate in a meeting should direct such request to the City Clerk’s Office at (805) 781-7114 at least 48 hours before the meeting, if possible. Telecommunications Device for the Deaf (805) 781-7410. Agenda related writings or documents provided to the Administrative Review Board are available for public inspection on the City’s website: https://www.slocity.org/government/mayor-and-city-council/agendas-and- minutes. Meeting video recordings can be found on the City’s website: https://opengov.slocity.org/WebLink/Browse.aspx?id=61073 Page 4 of 55 Administrative Review Board Agenda Report For Agenda of: 1/22/2026 Item Number: 4 Estimated Time: 30 minutes FROM: Mark Amberg, Assistant City Attorney Prepared By: Sarah Zion, Legal Assistant SUBJECT: ORIENTATION AND TRAINING RECOMMENDATION Review and ask questions regarding the orientation and training materials. DISCUSSION Introductions. Assistant City Attorney and advisor to the Board Mark Amberg to speak to the Board regarding their role in the administrative citation review process, City policies on Anti-Discrimination and Harassment, Conflicts of Interest and Drug Free Workplace, and to answer any questions they may have about that process, or the materials distributed with this agenda item. ATTACHMENTS A – Policy against Discrimination, Harassment and Retaliation B – Citywide Drug and Alcohol-Free Workplace Policy C – Due Process Primer D – SLOMC1.24.130 ARB Decision Contents E – San Luis Obispo Municipal Code 2.36.380 Page 5 of 55 Page 6 of 55 Page 1 of 10 Policy Against Discrimination, Harassment, and Retaliation Contents I. PURPOSE ............................................................................................................................. 2 II. SCOPE .................................................................................................................................. 2 III. POLICY ................................................................................................................................. 2 IV. DEFINITIONS ....................................................................................................................... 2 V. COMPLAINT PROCEDURE ................................................................................................. 5 VI. RESPONSE TO COMPLAINTS ............................................................................................ 7 VII. ADDITIONAL ENFORCEMENT INFORMATION ................................................................. 9 VIII.TRAINING AND POLICY DISSEMINATION .......................................................................10 IX. APPROVAL AUTHORITY ..................................................................................................10 Docusign Envelope ID: F4CBC585-949A-4D23-9DAE-BC66BCCD4FC0 Page 7 of 55 City of San Luis Obispo – Policy Against Discrimination, Harassment, and Retaliation Page 2 of 10 Last Updated 10/02/25 I. PURPOSE The City of San Luis Obispo is committed to providing a work environment in which all individuals are treated with respect, courtesy and professionalism, and that is free from unlawful discrimination, harassment, and/or retaliation. In keeping with this commitment, the City maintains a strict policy prohibiting such conduct. All covered individuals are encouraged to report any conduct that is believed to violate this policy as soon as possible. The purpose of this policy is to define and forbid discriminatory, harassing, and/or retaliatory conduct, to prohibit the condoning or perpetuating of such conduct, and to provide an efficient means for reporting and resolving complaints of discrimination, harassment, and/or retaliation against any individual who reports discrimination, harassment, or retaliation, or who participates in an investigation of such reports. II. SCOPE This policy applies to all City employees, job applicants, advisory body members, elected officials, volunteers, and contractors (Covered Individuals) when they are on City property or performing City business. This includes all locations where City employees work or represent the City, including City worksites, City vehicles, customer and vendor premises, and City sponsored events and activities. To the extent permitted by law, this policy may apply to off-duty employee conduct, depending on the nexus to the job and the impact to the City. III. POLICY The City of San Luis Obispo maintains a policy prohibiting discrimination, harassment, and/or retaliation in the workplace. This policy expressly prohibits discrimination, harassment, and/or retaliation based upon an individual’s legally protected characteristics. Covered Individuals must not harass, discriminate, or retaliate against anyone because of a legally protected category or legally protected characteristic as defined herein and by federal and state law. This includes conduct which constitutes unacceptable behavior even if it is not considered unlawful. Conduct may violate State and/or Federal law but need not be a violation of law to violate this Policy and to be the basis for discipline up to and including termination. The City also will not tolerate discrimination, harassment, or retaliation against City employees or other Covered Individuals by vendors, customers, or members of the public and will take appropriate steps to address and stop such behavior if it occurs. IV. DEFINITIONS A. Adverse Action or Adverse Employment Action Examples of conduct that can constitute an adverse action or adverse employment action include, but are not limited to, the following: i. Disciplinary actions, unwarranted negative performance evaluations, undesirable transfers, undesirable change in work duties, unwarranted exclusion from meetings or events. ii. Threats or intimidation, negative comments, unwarranted criticism that may dissuade or prevent an individual from reporting alleged wrongdoing or because of protected activity. iii. Any negative action that is taken because of the employee’s complaint of or opposition to harassment, discrimination, or because of the employee’s Docusign Envelope ID: F4CBC585-949A-4D23-9DAE-BC66BCCD4FC0 Page 8 of 55 City of San Luis Obispo – Policy Against Discrimination, Harassment, and Retaliation Page 3 of 10 Last Updated 10/02/25 participation in an employment discrimination or harassment investigation, proceeding, or hearing. B. Adverse Conduct Includes, but is not limited to, taking sides because an individual has reported harassment, discrimination, and/or retaliation, spreading rumors about a complainant or investigation participant, shunning and avoiding an individual who reports harassment, discrimination, and/or retaliation; or real or implied threats of intimidation to prevent an individual from reporting harassment, discrimination, or retaliation. C. Covered Individuals City employees, job applicants, advisory body members, elected officials, volunteers, and contractors when they are on City property or performing City business. D. Discrimination An adverse action or conduct by which an individual is treated differently or less favorably than similarly situated individuals because they are a member of a legally protected category, associate with individual(s) in a legally protected category, or are perceived as being in a legally protected category. E. Discriminatory Harassment Verbal, visual, or physical conduct based on an employee’s membership or perceived membership in a protected category or association with an individual in a protected category that is sufficiently severe or pervasive to negatively affect an employee’s work performance or alter the conditions of employment so that a reasonable person would find it more difficult to do the job. Note that discriminatory harassment is not limited to conduct by employees. Under certain circumstances, discriminatory harassment can also include conduct by those who are not employees, such as persons providing services under contracts or even members of the public. Harassing conduct can take many forms and includes, but is not limited to, slurs, jokes, statements, negative stereotyping, threatening or hostile acts, gestures, and written or graphic material that demeans or denigrates an individual or group because of an employee’s legally protected characteristics. Harassment on the job is prohibited whether it involves co-worker harassment, harassment by a supervisor or manager, harassment by elected or appointed officials, or harassment by third parties doing business with or for the City. F. Legally Protected Category or Legally Protected Characteristic Race (including traits historically associated with race, including, but not limited to, hair texture and protective hairstyles), religious creed (including religious dress and grooming practices), color, national origin (including discrimination based on possessing a driver’s license indicating “this card is not acceptable for official federal purposes”), ancestry, physical disability, mental disability, reproductive health decision-making, medical condition, veteran status, sex (including pregnancy, childbirth, and breastfeeding, and related medical conditions), gender, sexual orientation, gender identity, gender expression, genetic Docusign Envelope ID: F4CBC585-949A-4D23-9DAE-BC66BCCD4FC0 Page 9 of 55 City of San Luis Obispo – Policy Against Discrimination, Harassment, and Retaliation Page 4 of 10 Last Updated 10/02/25 information, marital status, veteran or military status, age over 40 years, or any other basis protected by applicable federal, state, or local law, including association with individuals with these protected characteristics or perception that an individual has one or more of these protected characteristics. G. Sexual Harassment Sexual harassment is an unwelcome sexual advance, proposition, or request for sexual favors or dating, or any verbal, visual, or physical conduct of a sexual nature. Sexual harassment occurs where: 1. Submission to such conduct is made a term or condition of employment or relates to the conditional receipt of employment benefits, such as hiring, compensation, and advancement; 2. Submission to or rejection of such conduct is used as basis for making employment decisions affecting the individual; or 3. Such conduct is severe or pervasive to the extent that it has the purpose or effect of unreasonably interfering with an employee’s work performance or creates an intimidating, hostile, or offensive working environment. Sexual harassment can occur between members of the same or opposite sex. Sexual harassment need not be motivated by sexual desire. Sexual harassment is prohibited whether it is perpetrated by a co-worker, supervisor or manager, local City elected or appointed official, subordinate, or third-party doing business with or for the City. Examples of conduct that can constitute unlawful harassment or sexual harassment include, but are not limited to, the following: a. Verbal harassment: Verbal sexual advances or propositions, jokes, epithets, derogatory comments or slurs, graphic commentaries about an individual’s body, or other suggestive or offensive comments made on the basis of a legally protected category. b. Physical harassment: Assault, unwanted touching, impeding or blocking movement, interference with normal work movement, massages, sitting on laps, or physical behavior of any type based upon a legally protected category. Please also see Workplace Violence Prevention Policy. c. Visual harassment: Leering, derogatory gestures, inappropriate or offensive posters, notices, bulletins, cartoons, drawings, e-mails, content displayed from a computer or cell phone, or other depictions related to a legally protected category. d. Sexual conduct: Unwelcome sexual advances or propositions, requests for sexual favors, unwelcome requests for dates, verbal abuse of a sexual nature, verbal commentary about an individual’s body, dress or appearance, sexually explicit jokes, sexually degrading language, suggestive or obscene communications, and other verbal, visual or physical conduct of a sexual nature. H. Retaliation Taking adverse employment action against an employee, or other adverse action against another Covered Individual (1) because of the individual’s good faith report of or opposition to a practice the individual believes to constitute employment discrimination, harassment, or retaliation, or (2) because of the individual’s participation in an employment discrimination, Docusign Envelope ID: F4CBC585-949A-4D23-9DAE-BC66BCCD4FC0 Page 10 of 55 City of San Luis Obispo – Policy Against Discrimination, Harassment, and Retaliation Page 5 of 10 Last Updated 10/02/25 harassment, and/or retaliation investigation, proceeding, or hearing (collectively “protected activity”). Protected activity or Protected participation may include, but is not limited to, any of the following: 1. Good faith opposition to or reporting of perceived or actual discrimination, harassment, and/or retaliation, including a complaint or protest made on behalf of another employee or made by the employee’s representative. Complaints or oppositions that are intentionally false and/or not made in good faith are not protected. 2. Filing a charge or complaint with the City or a federal or state enforcement or administrative agency. 3. Participating in, testifying as a party, witness or accused, in any internal or administrative investigation, proceeding or hearing regarding alleged unlawful activity or cooperating with a federal or state enforcement agency that is conducting an investigation of the City regarding alleged unlawful activity. 4. Filing a workers compensation claim. 5. Refusing to tolerate or engage in prohibited conduct, or threatening to file a complaint with any federal, state, or administrative agency or court. I. Supervisor An employee with the authority to hire, transfer, suspend, lay off, recall, promote, discharge, assign, reward, or discipline other employees, or the responsibility to direct them, or to adjust their grievances, or effectively to recommend that action, if, in connection with the foregoing, the exercise of that authority is not of a merely routine or clerical nature, but requires the use of independent judgment. Employees are strongly encouraged to contact their supervisor, the Director of Human Resources, or other supervisory employee with any questions regarding these definitions, or regarding any uncertainty about what constitutes discrimination, harassment, sexual harassment, retaliation, or prohibited conduct generally under the City’s policy. V. COMPLAINT PROCEDURE The City encourages all Covered Individuals to report all actual or perceived incidents of discrimination, harassment, and/or retaliation as soon as possible. Regardless of whether a formal complaint is submitted, the City will take a proactive approach to potential Policy violations and will conduct an investigation if its officers, supervisors, or managers become aware that harassment, discrimination, and/or retaliation may be occurring. A. Employee Reporting Employees who believe the conduct or actions of a Covered Individual are discriminatory, harassing, retaliatory, or otherwise in violation of this policy are encouraged, but not required, to inform the person who engaged in the conduct that they find it offensive and request that the person cease their behavior. Employees who do not wish to confront the person, or whose attempts to do so have failed, should file a complaint with the City following the procedures below. Deciding not to confront the person will not prevent the employee from filing a complaint, nor does it in any way exonerate the accused person(s). Docusign Envelope ID: F4CBC585-949A-4D23-9DAE-BC66BCCD4FC0 Page 11 of 55 City of San Luis Obispo – Policy Against Discrimination, Harassment, and Retaliation Page 6 of 10 Last Updated 10/02/25 The City’s management is readily available and receptive to complaints of discrimination, harassment, and/or retaliation. Employees who believe they are being discriminated or retaliated against or harassed by, another employee, volunteer, vendor, visitor, elected or appointed official, or other individual, should immediately report the facts of the incident and the names of the individuals involved to their immediate supervisor, or to any other supervisor or Department Head they feel comfortable speaking with, within or outside of their department. Employees who do not feel that the matter can be discussed with their immediate supervisor or another supervisor, should contact the Director of Human Resources and arrange for a meeting to discuss the complaint. Employees who are not comfortable discussing their complaint with the Director of Human Resources should contact the City Attorney. Complaints should be made as soon as possible following the incident and should include the following information: 1. The complaining employee’s name, department, and position title. 2. The name of the person or persons committing the discrimination, harassment, or retaliation, including their titles, if known. 3. The specific nature of the discrimination, harassment, or retaliation, how long it has gone on, any employment actions such as demotion, failure to promote, dismissal, refusal to hire, or transfer suffered as a result of the discrimination, harassment, or retaliation, and/or any other threats made against the target of the discrimination, harassment, or retaliation. 4. Witnesses to the discrimination, harassment, or retaliation, if any. 5. Whether the target of the discrimination, harassment, or retaliation has previously reported it, and, if so, when and to whom. The City cannot resolve discrimination, harassment, or retaliation problems unless it knows about them. Therefore, it is an employee’s responsibility to bring concerns to the attention of the City so that appropriate steps can be taken to address them. Employees will not be retaliated against for good faith opposition to or reporting of discrimination, sexual or other harassment, or retaliation. It is unlawful for an employer to retaliate against employees who, in good faith, report or oppose practices prohibited by state and federal law, file complaints, or otherwise participate in an investigation, proceeding, or hearing conducted by the California Civil Rights Department (CRD) or the Equal Employment Opportunity Commission (EEOC). Similarly, the City will not tolerate any interference with internal or administrative investigations and/or complaint procedures. All employees who observe or learn about the potential harassment of another employee, volunteer, or intern are encouraged to follow these reporting procedures, and employees who are supervisors are required to do so, as addressed further in Section (B) below. All employees should note that the failure to use the City’s complaint procedure may have an adverse effect on any legal claim under this policy. Docusign Envelope ID: F4CBC585-949A-4D23-9DAE-BC66BCCD4FC0 Page 12 of 55 City of San Luis Obispo – Policy Against Discrimination, Harassment, and Retaliation Page 7 of 10 Last Updated 10/02/25 B. Supervisor Reporting Obligations All supervisors should convey to their employees strong disapproval of discrimination, harassment, and retaliation and convey that any discrimination, harassment, or retaliation violates City policy and will not be tolerated. Any supervisor who receives a complaint of discrimination, harassment, and/or retaliation; who witnesses discrimination, harassment, and/or retaliation; or has any reason to believe that discrimination, harassment, and/or retaliation may have occurred in the workplace is required to report the conduct immediately to the Director of Human Resources, unless the Director of Human Resources is the subject of the complaint, in which case the supervisor should notify the City Manager or City Attorney immediately. The Director of Human Resources will notify the City Manager of receipt of all harassment or discrimination complaints. A supervisor will be subject to discipline for failing to report conduct that potentially constitutes discrimination, harassment, or retaliation if the supervisor knew or should have known of the conduct. C. Anonymous Complaints Anonymous complaints are more challenging to investigate and process, so the City encourages employees to identify themselves when reporting violations. However, any employee who wishes to make an anonymous complaint of discrimination, harassment, and/or retaliation without disclosing their identity may do so by following the complaint procedure above and requesting the complaint be filed anonymously. Employees should also be aware that should the City learn of the identity of an anonymous complainant, the City cannot guarantee that their identity will remain confidential if the City determines in its discretion that disclosure is necessary to complete the investigation or address sustained findings. Please also see section on Confidentiality, under Section (B) below. VI. RESPONSE TO COMPLAINTS A. Investigation of Complaints All incidents of discrimination, harassment, and/or retaliation that are reported will be timely investigated by qualified personnel. The City will immediately undertake or direct an effective, thorough, impartial, fair, and objective investigation of the discrimination, harassment, and/or retaliation allegations. The investigation will include obtaining information from the person accused and anyone who may have been a witness to the alleged misconduct. All parties to the investigation will be provided with a fair and appropriate process. If the complaint is incomplete or contains insufficient information to conduct an investigation, the Department of Human Resources will ask for more information from the claimant or find that the claim is unfounded. Docusign Envelope ID: F4CBC585-949A-4D23-9DAE-BC66BCCD4FC0 Page 13 of 55 City of San Luis Obispo – Policy Against Discrimination, Harassment, and Retaliation Page 8 of 10 Last Updated 10/02/25 Employees who have information they believe will assist the City in an investigation pertaining to a violation of this policy are encouraged to contact the Director of Human Resources or City Attorney. The City may take appropriate interim action(s) in response to allegations of discrimination, harassment, and/or retaliation, including but not limited to, placing employees on administrative leave until the conclusion of the investigation or as otherwise notified by the City, or attempting informal resolution of the complaint, if appropriate. The City will document each complaint and monitor each investigation to ensure reasonable progress, timely closure, and reasonable findings based on the evidence collected. B. Confidentiality Any investigation under this policy will be conducted with as much confidentiality as possible and with respect for the rights of all individuals involved. However, no investigation can be completely confidential, and information related to the investigation may be provided on a “need-to-know” basis. The City and/or its authorized investigator retains sole discretion to determine whether disclosure of information is necessary to conduct or complete the investigation. All employees involved in the investigation of discrimination, harassment, and/or retaliation complaints as either investigator(s), complainant(s), witness(es), or accused parties are required to keep all information related to the investigation confidential when directed to do so. If so directed, revealing such information is grounds for disciplinary action, up to and including termination, except where disclosure is expressly permitted by law, such as in discussion with a chosen labor or other designated employee representative, attorney, or any other individual with whom the employee has a legally recognized privilege. The City will not disclose a completed investigation report except as it deems necessary to support a disciplinary action, to take remedial action, to defend itself in adversarial proceedings, or to comply with the law or a court order. C. Cooperation with Investigation All employees involved in a workplace investigation into alleged discrimination, harassment, and/or retaliation are required to cooperate with the investigation fully and truthfully. Failure to cooperate with the investigation fully and truthfully is grounds for disciplinary action, up to and including termination. If after making the complaint, the complainant prefers not to participate further, the investigation will be completed but will be limited by the information available. Complainants will not be disciplined for choosing not to participate further in an investigation. It is a violation of this policy for any complaining party, responding party, or witness to discuss any prohibited details of an investigation with other employees or witnesses or to conduct independent investigations at any time on their own initiative. The City will not tolerate any interference with its internal investigations or internal complaint procedures. D. Determination and Corrective Action Following investigation, the City will determine whether the allegations in the complaint are Docusign Envelope ID: F4CBC585-949A-4D23-9DAE-BC66BCCD4FC0 Page 14 of 55 City of San Luis Obispo – Policy Against Discrimination, Harassment, and Retaliation Page 9 of 10 Last Updated 10/02/25 substantiated or unsubstantiated and communicate that determination to the complaining and accused parties. Parties are not entitled to copies of any notes or other written materials regarding the investigation, as the City considers those documents confidential, except where disclosure is required by applicable law or where documents are required to support proposed discipline. If the City concludes that the accused party has violated City policies, appropriate corrective action will be taken in accordance with established City disciplinary or other applicable procedures, up to and including termination of employment or discharge. The severity of the discipline will be determined by the severity and/or frequency of the offense. The City may take whatever measures are appropriate to ensure its workplaces remain free of unlawful discrimination, harassment ,and/or retaliation. Further, as part of the City’s attempt to remedy the complaining party's concerns, the City’s notice to the complaining party will also advise generally that corrective action has been taken against the accused party, but will not provide detail, such as the level of discipline imposed. The City also reserves the right to take appropriate corrective action, up to and including termination of employment, when the City finds that an employee engaged in inappropriate conduct that does not rise to the standards set forth in this policy but violates other City policies or standards of conduct. For example, the City may take appropriate corrective action for inappropriate conduct that was not subjectively unwelcome or offensive, or does not meet the legal threshold of severe or pervasive under other City policies prohibiting unprofessional or discourteous treatment, or similar. For harassing, discriminatory, retaliatory, or other inappropriate conduct by vendors, customers, or members of the public, the City will take appropriate action to protect Covered Individuals, which may include, but is not limited to, ending a business relationship or restricting further interaction. E. Appeal Disciplinary action taken under this procedure may be appealed with or without representation subject to appeal or grievance procedures indicated in the applicable Memorandum of Understanding or Personnel Rules and Regulations. F. Bad Faith and Intentionally False Complaints While the City vigorously defends its employees’ right to work in an environment free of discrimination, harassment, and/or retaliation, it also recognizes that false accusations can have serious and damaging consequences. Any employee who is found, through the City’s investigation, to have deliberately, falsely accused another person of discrimination, harassment, and/or retaliation will be subject to appropriate disciplinary action, up to and including termination. VII. ADDITIONAL ENFORCEMENT INFORMATION Employees who believe they have been discriminated, harassed, or retaliated against may also file a complaint of discrimination with the Civil Rights Department (CRD) or the Equal Employment Opportunity Commission (EEOC). The CRD and/or EEOC may also investigate and process the complaint. Violators are subject to penalties and remedial measures that may include sanctions, fines, injunctions, reinstatement, back pay, and damages. Employees can Docusign Envelope ID: F4CBC585-949A-4D23-9DAE-BC66BCCD4FC0 Page 15 of 55 City of San Luis Obispo – Policy Against Discrimination, Harassment, and Retaliation Page 10 of 10 Last Updated 10/02/25 contact the local CRD or EEOC at: CRD– Bakersfield Regional Office 4800 Stockdale Highway, Suite 215 Bakersfield, CA 93309 Phone: (800) 884-1684 EEOC – Los Angeles District Office Roybal Federal Building 255 East Temple St., 4th Floor Los Angeles, CA 90012 Phone: 213-785-3090 VIII. TRAINING AND POLICY DISSEMINATION In accordance with Government Code Section 12950.1, the City requires all employees to be trained on preventing discrimination, sexual harassment and retaliation in the workplace every two years. In addition, all new employees or persons appointed or promoted to supervisory positions shall be trained within six months of their hire, appointment, or promotion. Supervisory training shall last for a minimum of two hours. Non-supervisory training shall last for a minimum of one hour. In accordance with Government Code Section 53237.1, the City requires members of the City Council and all paid members of Advisory Bodies be trained on preventing sexual harassment. The two-hour training must be completed within six months of taking office and every two years thereafter. A local City official who serves more than one local agency may satisfy the training requirements once every two years, without regard to the number of local agencies they serve. In addition, all employees, elected officials and paid advisory body members shall be given a copy of this policy as part of their initial orientation with the City and may be required to sign an acknowledgement of receipt, which will be maintained in the employee’s personnel file. Further, they shall receive a copy in conjunction with any discrimination, harassment and/or retaliation prevention training they attend. IX. APPROVAL AUTHORITY The City Manager has authority to approve administrative updates to this policy. Responsible Department: Human Resources Approved by: _____________________________ ____________ Whitney McDonald, City Manager Date Date Revised: 10/02/25 To ask questions regarding this policy or to discuss a particular situation, please contact the Human Resources Department at (805) 781-7250. Docusign Envelope ID: F4CBC585-949A-4D23-9DAE-BC66BCCD4FC0 10/13/2025 | 6:12 PM PDT Page 16 of 55 Page 1 of 25 Adopted 08/23/22 Drug and Alcohol-Free Workplace Policy City of San Luis Obispo Purpose The City of San Luis Obispo is committed to providing all its employees with a safe, healthful, and productive work environment, which includes maintaining a drug and alcohol-free workplace. This Policy is intended to provide guidance for employees who may have questions or concerns about the use of illegal or controlled substances including alcohol that could impair an employee’s ability to perform the functions of their job safely and effectively and/or threaten the safety of coworkers. This Policy applies to all City employees, regardless of their employment status (e.g., regular, supplemental, contract employees). Additionally, the City of San Luis Obispo complies with the Drug Free Workplace Act of 1988 and complies with the Omnibus Transportation Employee Testing Act of 1991 ("OTETA") with respect to covered employees under OTETA. For covered employees, as defined by the Department of Transportation (DOT) performing safety-sensitive work, or positions that would be particularly dangerous if performed under the influence of drugs and alcohol, The City of San Luis Obispo oversees random testing and reasonable suspicion testing to prevent accidents and injuries. These positions are listed in Attachment A. Policy Summary All City Employees are expected to be in the best possible mental and physical condition to perform their jobs and may not manufacture, distribute, dispense, possess, or use drugs or controlled substances including alcohol and marijuana any place where City work is performed, including a City building or site, in any City-owned vehicle, or off-site while conducting City business. The City will make a good faith effort to maintain a drug and alcohol-free workplace through implementation of this Policy. Exceptions. This Policy shall not prevent a Safety Employee of the City of San Luis Obispo Police Department from possessing drugs or alcohol as part of their official duties and when in furtherance of the mission of the Police Department. Members who are authorized to consume alcohol as part of a special assignment shall not do so to the extent of impairing on-duty performance. Employee Support Employees with concerns about personal use of alcohol or drugs are encouraged to seek help and will not have their job or promotional opportunities jeopardized if they do so. Employees with concerns about coworkers’ actions that may be related to drug or alcohol use should convey their observations to their supervisors. The City provides resources to foster productive workplace behaviors and healthy life choices including drug counseling, rehabilitation, and employee assistance programs. The City respects individuals’ rights to confidentiality and privacy; pertinent information and records of employees seeking assistance will be preserved in the same manner as other confidential records and will not become part of the employee’s personnel file. Page 17 of 55 Page 2 of 25 Adopted 08/23/22 Violation of Policy While the City will be supportive of those who seek help voluntarily, the City will be equally firm in identifying and disciplining those who endanger their health, safety, and general wellbeing and of others because of their use of substances or who violate a federal, state or City law and/or drug policies. Discipline may include not being hired, mandatory participation in a treatment program, or termination. Employees will notify the Director of Human Resources within five (5) days of any criminal drug statute conviction for which s/he receive a violation occurring in the workplace. As required by law, the City shall notify the appropriate federal granting agency of any criminal convictions of an employee for illegal drug activity in the workplace within ten (10) days of the City’s notification of such conviction. Prescription Drugs Employees may take over-the-counter drugs that are not marked “Do Not Drive,” or “Do not operate heavy equipment,” or include some other precaution. Otherwise, employees must provide their supervisor with a written statement from the prescribing physician that medications with listed precautions will not impair the employee’s ability to perform his or her duties. If the prescribing physician determines use of the medication will impair the employee’s functioning on the job, the supervisor can modify work assignments, or recommend paid leave or industrial leave as appropriate. Implementation of this Policy will not require or result in any special regulations, privileges, or exemptions from the standard administrative practices applicable to job performance requirements. All employees should be fully informed of this Policy and have access to information concerning the impact of the use of alcohol and drugs on job performance. All newly hired employees will sign this Policy, and a copy will be kept in their Personnel File. I, __________________________________ have read, understand, and will abide by the City of San Luis Obispo's Drug and Alcohol-Free Workplace Policy. ______________________________________________________________________ Signature Date The following are among the drug counseling, rehabilitation and/or other agency assistance programs available locally: • City of San Luis Obispo Employee Assistance Program (EAP) (800) 342-8111 • San Luis Obispo County Drug Program (805) 781-4753 • San Luis Obispo County Alcohol Services (805) 781-4275 • Narcotics Anonymous (805) 549-7730 • Alcoholics Anonymous (805) 541-3211 Page 18 of 55 Page 3 of 25 Adopted 08/23/22 Who is Subject to Drug and Alcohol Testing? Group 1: DOT Classifications Covered employees include individuals who are required to operate a vehicle with a gross weight of at least 26,001 pounds; with a gross combination weight of at least 26,001 pounds inclusive of a towed unit with a gross vehicle weight rating of more than 10,000 pounds; designed to transport 16 or more passengers, including the driver; or used to transport hazardous materials found in the Hazardous Materials Transportation Act. If an employee does not perform safety-sensitive functions, the Director of Human Resources may provide a written exemption from this Policy and can also provide a list of specific positions that are covered under the Omnibus Transportation Employee Testing Act of 1991. A list of DOT classifications are defined in Attachment A. Applicants for safety-sensitive jobs. Those applying for safety-sensitive jobs are required to take a drug and alcohol test after receiving a conditional job offer. Those who refuse to submit to testing or attempt to tamper with or alter a test sample will be considered to have refused to participate in the testing process and will not be hired or considered for employment for the positions listed above for one year from the job applicant’s refusal to participate in the testing process. All applicants who transfer from classifications which are not covered to classifications which are covered will be required to submit to pre-employment/pre-duty drug testing. Applicants will not be assigned to classifications which are covered by this Policy if they do not pass the test. An applicant who tests positive for drugs and/or alcohol or unauthorized prescription drugs will not be hired or reconsidered for employment for a year from the last positive test. Certain supplemental employees. Supplemental employees whose job duties are the same as those listed as covered employees and who are required to hold a California class A or B license, will be part of the random drug and alcohol testing. Group 2: All classifications represented by the San Luis Obispo City Firefighters’ Association, Local 3523 Group 2a: Sworn Classifications Group 2b: Non-Sworn Classifications A list of Local 3523 classifications are defined in Attachment A. Group 3: All classifications represented by the San Luis Obispo Police Officers’ Association (POA) and the San Luis Obispo Police Staff Officers’ Association (SLOPSOA) Group 3a: Sworn Classifications Group 3b: Non-Sworn Classifications A list of POA and SLOPSOA classifications are defined in Attachment A. Note: These employees are also covered by Policy 1011 of the San Luis Obispo Police Department Policy Manual. Group 4: All other classifications, including: - All classifications represented by the San Luis Obispo City Employees Association (SLOCEA), as defined in Attachment A. Page 19 of 55 Page 4 of 25 Adopted 08/23/22 - All Unrepresented Management and Confidential Employees - All Supplemental employees. Types of Testing No drug and/or alcohol test may be administered, sample obtained, or drug and/or alcohol test be conducted on any sample without the written acknowledgment of the applicant or employee being tested (Attachment D). Pre-employment testing: Group 1, 2a, and 3a Employees Those applying for Group 1 jobs that possess a Commercial Driver’s License (CDL) and those applying for Group 2a or Group 3a jobs are required to take and pass drug and alcohol tests as part of their pre-employment physical after receiving a conditional job offer and prior to employment. Applies only to initial probationary employees. Random Testing: Group 1 Employees • A random alcohol and/or drug test will be administered just prior to the employee performing a safety-sensitive function (e.g. driving), while the employee is performing a safety-sensitive function, or just after the employee has stopped performing a safety- sensitive function. • A random alcohol test will be administered to at least 10% of the total number of covered employees per year and selected by the company contracted by the City. • A random drug test will be administered to at least 50% of the total number of covered employees per year and selected by the company contracted by the City. • Some employees may be tested more than once in a year, while others may not be tested at all, depending on the random selection by the company contracted by the City. • Group 3 Employees: See Policy 1011 of the San Luis Obispo Police Department Policy Manual. Reasonable Suspicion Testing: Group 1, 2, 3, and 4 Employees Alcohol and/or drug testing may be warranted under the following circumstances: • The supervisor reasonably believes, based upon objective facts, that the employee is under the influence of alcohol or drugs that are impairing his/her ability to perform duties safely and efficiently. o Attachment C provides a reasonable suspicion assessment form for the trained supervisor to complete and provide to the Human Resources Department prior to sending the employee for reasonable suspicion testing. The supervisor shall consult with the Human Resources Director or designee, such as the Risk Manager or Safety Officer, prior to sending employee for testing. The observation must be based on short term indicators, such as blurry eyes, slurring or alcohol on the breath. The supervisor may not rely on long-term signs, such as absenteeism or tardiness, to support the need for immediate action. Page 20 of 55 Page 5 of 25 Adopted 08/23/22 o The employee has a right to consult with their representative, if any. If the representative an employee requests is unavailable, the employee may request alternate representation; however, the City is not obliged to postpone the reasonable suspicion testing. • During the performance of his/her duties, the employee drives a motor vehicle and becomes involved in an incident that results in bodily injury to him/herself or another person, or substantial damage to property and there is a reasonable suspicion based on objective facts that the employee is under the influence of alcohol or drugs. • Group 3a Employees Only: The employee discharges a firearm, other than by accident, in the performance of his/her duties, and, there is a reasonable suspicion based on objective facts that the employee is under the influence of alcohol or drugs. See Attachment C. An alcohol test will be administered within two hours of a documented observation. If not, the employer must provide a written explanation why the test was not promptly conducted. No test may be administered after eight hours following the observation. To ensure that supervisors are trained to assess observations and make determinations for immediate action, supervisors vested with the authority to require drug and alcohol tests will attend at least 1.5 hours of training on alcohol and controlled substance misuse within six months of hire. Additionally, supervisors shall attend 1.5 additional hours of training on alcohol and controlled substance misuse every two years. The training will cover the physical, behavioral, speech, and performance indicators of probable alcohol misuse and use of controlled substances. Employees tested based upon reasonable suspicion of drug and/or alcohol use in accordance with this Policy will remain on paid administrative leave and not be allowed to return to work until the results of the test are received that verify that the employee is not under the influence or until a qualified medical professional releases the employee for duty. Post-Accident Testing: Group 1 Employees Testing is undertaken when an on-duty employee has been involved in a vehicle-related incident and a State or local enforcement authority issues a citation to the covered employee driver for a moving violation. If the accident involved the loss of human life and no citation is issued, each surviving driver will be tested. Post-accident alcohol tests shall be administered on covered employees within two hours following an accident and no test may be administered after eight hours. A post-accident drug test shall be conducted within 32 hours following the accident. Post-Treatment Testing: Group 1, 2, 3 and 4 Employees Follow-up testing is required for employees who have returned to work following a positive test and their participation in a drug and/or alcohol rehabilitation program. (See Return to Duty section) Testing Protocols Administration. The Director of Human Resources or his/her designee is the Designated Employer Representative (DER) and shall be responsible for overseeing implementation of the Policy and the testing procedures listed below. The DER will be responsible for reviewing all Page 21 of 55 Page 6 of 25 Adopted 08/23/22 disciplinary actions resulting from violations of this Policy to ensure actions are consistent with this Policy and applicable laws. The DER also shall be responsible for communicating directly with the Medical Review Officer (MRO) and/or Substance Abuse Professional (SAP) and Substance Abuse and Mental Health Services Administration (SAMHSA) regarding any drug and/or alcohol tests, and for providing training to supervisors and employees. The drug testing program is administered by Addiction Medicine Consultants, Inc (AMC) and testing is done by Star Drug Testing, 1223 Higuera Street, San Luis Obispo during regular business hours. The employer shall pay for all costs involving drug and alcohol testing as well as the expenses involved of the MRO. Mandatory Reporting. Any employee who has reason to believe that another employee may be in violation of this Policy shall immediately notify his or her immediate supervisor. The supervisor should take whatever action is deemed prudent to ensure the safety of the public and employees. Should the supervisor believe, based on specific and documented facts and observations (Attachment C), that the employee may be under the influence of drugs and/or alcohol, immediate coordination with Human Resources should occur. This will include immediately removing the employee from the workplace placing them on paid administrative leave until such time as testing results confirm or refute the presence of drugs and/or alcohol. Alcohol Testing. Alcohol testing will be conducted by using an evidential breath test device (EBT) approved by the National Highway Traffic Safety Administration. Non-EBT devices may be used for initial screening tests. A screening test will be conducted first. If the result is an alcohol concentration of less than 0.02, the test is considered a negative test. If the alcohol concentration level is 0.02 or more, a second confirmation test will be conducted. Drug Testing. Drug testing will be conducted in compliance with DOT Regulations (CFR49Part40) and pursuant to these procedures: • The urine specimen will be split into two bottles labeled as “primary” and “split” specimen. Both bottles will be sent to the lab. • If the urinalysis of the primary specimen tests positive for the presence of illegal, controlled substance, the employee has 72 hours to request that the split specimen be analyzed by a different certified lab. • The urine sample will be tested for marijuana, cocaine, opioids, amphetamines, and phencyclidine (See Attachment E). • If the test is positive for one or more of these drugs, a confirmation test will be performed using gas chromatography/mass spectrometry analysis. • All drug tests will be reviewed and interpreted by a physician before they are reported to the employee and then to the City. • With all positive drug tests, the MRO will first contact the employee to determine if there is an alternative medical explanation for the positive test result. If documentation is provided and the MRO determines that there was a legitimate medical use for the prohibited drug, the test result may be reported to the City as “negative.” Refusal to Test Refusal to test is defined as any of the following: Page 22 of 55 Page 7 of 25 Adopted 08/23/22 • Refusal to complete and sign the breath alcohol testing form, or otherwise to cooperate with the testing process in a way that prevents the completion of the test. • Tampering with a specimen or collection process. • Tardiness to reporting collation site after time allocated for applicant or employee to report without a valid explanation. • A refusal to provide a urine sample for a drug test. • Inability to provide a urine sample without a valid medical explanation. • Inability to provide breath or to provide an adequate amount of breath without a valid medical explanation. • Not reporting to the collection site in time allotted by the supervisor or manager who directs the employee to be tested. • Leaving the scene of an accident without a valid reason as to why authorization was not obtained from a supervisor or manager who shall determine whether to send the employee for a post-accident drug and/or alcohol test. Applicants who refuse to submit to testing as required by this Policy will not be hired or considered for employment for the positions considered to be covered by this document. An applicant who tests positive for drugs, alcohol and/or unauthorized prescription drugs will not be hired or reconsidered for employment for a year from the last positive test. A covered employee who refuses to submit to any required drug/alcohol testing will be treated in the same manner as an employee who tested 0.02 or greater on an alcohol test or tested positively on a controlled substances test. Additionally, the employee will be subject to the Personnel Actions described. Rehabilitation Voluntary Disclosure. The City has established an Employee Assistance Program (EAP) to help employees who voluntarily seek assistance with their use of alcohol and controlled substances. If an employee needs help, s/he should call Aetna Resources for Living at (800) 342-8111 and inform them that s/he is an employee of the City of San Luis Obispo and request an appointment. At the supervisor’s discretion, an employee requesting this assistance may be transferred, given work restrictions, or placed on leave while receiving treatment until the employee is drug and/or alcohol free. An employee’s voluntary disclosure of substance or alcohol abuse will not terminate any investigation, criminal or administrative action initiated prior to the disclosure. Each employee is responsible for seeking assistance before the employee’s drug and/or alcohol problem leads to a violation of this Policy or before the employee is asked to submit to drug and/or alcohol testing. Leave Time. Employees must use available paid time off including sick, vacation, floating holiday, holiday leave, compensatory time off, administrative leave etc. or request an unpaid leave of absence if time off from work is necessary for any treatment or rehabilitation program. The costs of long-term rehabilitation or treatment services are the ultimate responsibility of the employee whether covered by the employee’s medical plan. Return to Duty/Follow-up Testing Page 23 of 55 Page 8 of 25 Adopted 08/23/22 A covered employee who has violated any of the Prohibitions of this Policy must submit to a return-to-duty test before s/he may be returned to his/her position. The test result must indicate an alcohol concentration of less than 0.02 or a verified negative result on a controlled substance test. The employee will be subject to at least six additional unannounced drug/alcohol tests during the first year back to their position following the violation because studies have shown that the relapse rate is highest during the first year of recovery. Any covered employee who engages in any action prohibited by this Policy will: • Be removed from performing any safety-sensitive functions. • Submit to an examination by a substance abuse professional. Upon a determination by the substance abuse professional, the employee may be required to undergo treatment for his/her alcohol or drug abuse. The City is not required to pay for this treatment. • Not be reassigned to safety-sensitive duties until the employee is evaluated by a substance abuse professional; participates in a rehabilitation program if directed by the professional who has determined the employee has properly followed the rehabilitation program; submits to a return-to-duty controlled substance and/or alcohol test (depending on which test the employee failed) which indicates an alcohol concentration level of less than 0.02 or a negative result on a controlled substance test. • Be subject to unannounced follow-up testing after returning to his/her position. Prohibited Conduct The following conduct is prohibited by OTETA and in violation of the City Personnel Rules and Regulations: • Reporting for duty or remaining on duty requiring the performance of safety-sensitive functions with an alcohol concentration level of 0.02 or greater. • Performing a safety-sensitive function within four hours of using alcohol. • Being on duty or operating a vehicle while possessing alcohol. • Reporting for duty or remaining on duty requiring the performance of safety-sensitive functions after use of any controlled substances, except if the use is pursuant to the instructions of a physician who has advised the employee that the substance does not adversely affect the employee's ability to safely operate a vehicle. • Reporting for duty or remaining on duty requiring the performance of safety-sensitive functions if the employee tests positive for controlled substances. • Refusing to submit to any alcohol or controlled substances test required by this Policy. A covered employee who refuses to submit to a required drug/alcohol test will be treated in the same manner as an employee who tested 0.02 or greater on an alcohol test or tested positively on a controlled substances test (see Refusal to Test section). • Consuming alcohol during the eight hours immediately following an accident, or until the employee undergoes the post-accident alcohol test, whichever occurs first. • Refusing or being unable to provide, within twenty-four (24) hours of request, a current valid prescription for any drug or medication identified when a drug screen/analysis is positive. The prescription must be in the employee's name. Page 24 of 55 Page 9 of 25 Adopted 08/23/22 Any covered employee who engages in any action prohibited by this Policy will be removed from performing any safety-sensitive functions and not reassigned until a substance abuse professional has determined that s/he has followed recommended rehabilitation measures and passed drug and/or alcohol tests as described in this document. All are subject to the provisions of this Policy, which complies with applicable Federal, State, and City laws, including the Drug Free Workplace Act of 1988 and the Omnibus Transportation Employee Testing Act of 1991 ("OTETA"), and as defined in this Policy (Attachment B). Personnel Actions Any employee violations of this program may constitute misconduct under the City’s Personnel Rules and Regulations. Consistent with the City’s practices, disciplinary action shall be considered on an individual basis, considering the nature of the offense, the employee’s previous work and conduct record, the length of the service of the employee concerned and any other pertinent information. In appropriate circumstances and solely within its discretion, the City may consider the employee’s commitment to recovery and/or the employee’s agreement to enter into a Last Chance agreement as mitigating factors in assessing the appropriate disciplinary action. The City may also take action to terminate employment as it deems appropriate. Any Group 1 employee who engages in any of the prohibited activities violates federal law and could be subject to federal penalties. Enforcement Managers and supervisors are responsible for consistent enforcement of this Policy. Any supervisor who knowingly permits a violation of this Policy by employees under his/her direct supervision may be subject to disciplinary action. Questions Employees should contact the Director of Human Resources if they have any questions about their rights and obligations under this Policy. Page 25 of 55 Page 10 of 25 Adopted 08/23/22 Attachment A - Classifications Covered by Drug and Alcohol Testing Group 1 DOT • Fire Vehicle Mechanic • Mechanic Helper • Ranger Maintenance Worker I and II • Streets Maintenance Operator • Streets Crew Coordinator • Sweeper Operator • Urban Forester • Urban Forester Supervisor City Arborist • Underground Utilities Locator • Wastewater Collection System Operator • Wastewater Collection System Supervisor • Water Distribution Chief Operator • Water Distribution System Operator • Water Distribution System Supervisor Group 2 Group 2a: Sworn Fire • Fire Battalion Chief • Fire Captain • Fire Engineer • Firefighter Group 2b: Non-Sworn Fire • Fire Inspector I, II and III • Fire Vehicle Mechanic 1 • Hazardous Materials Coordinator Group 3 Group 3a: Sworn POA • Police Officer Group 3b: Non-Sworn POA • Communications Technician • Lead Police Records Clerk • Property and Evidence Technician • Lead Property & Evidence Technician • Police Cadet • Police Field Service Technician • Police Records Clerk I and II Group 3a: Sworn SLOPSOA • Police Sergeant • Police Lieutenant • Police Captain Group 3b: Non-Sworn SLOPSOA • Police Records Supervisor • Communications Supervisor • Communications Manager Group 4 • Please see the current regular and contract salary schedule at www.slocity.org for a complete list of SLOCEA, unrepresented management and confidential Classifications, listed under Bargaining Units CEA, MME, DPH and CNF. Some classifications are also included under Group 1. 1 Fire Vehicle Mechanic is also included under Group 1. Page 26 of 55 Page 11 of 25 Adopted 08/23/22 • Please see the current supplemental employee salary schedule at www.slocity.org for a list of supplemental classifications. Attachment B - Definitions Accident shall mean when an individual dies or when a State or local law enforcement authority issues a citation to a covered employee for a moving violation arising from the accident as a result of an occurrence involving a vehicle. Alcohol shall mean the intoxicating agent in beverage alcohol, ethyl alcohol or other low molecular weight alcohol including methyl or isopropyl alcohol. Chain of Custody shall mean procedures to account for the integrity of each specimen by tracking its handling and storage from point of collection to final disposition of specimen at a certified laboratory. City Equipment shall mean all property and equipment, machinery and vehicles owned, leased, rented or used by the City. Collection Site shall mean a designated clinic/facility where applicants or Employees may present themselves for the purpose of providing a specimen to be analyzed. The City will select a Collection Site and require that the Collection Site comply with all the methods of collection and Chain of Custody and provide documentation of compliance to the City. Covered Employee(s) under Group 1 is a person who operates (i.e., drives) a Commercial Motor Vehicle (CMV) with a gross vehicle weight rating (GVWR) of 26,001 or more pounds; or is designed to transport 16 or more occupants (to include the driver); or is of any size and is used in the transport of hazardous materials that require the vehicle to be placarded. (FMCSA 49 CFR Part 382) Designed Employer Representative (DER) shall mean the Director of Human Resources or designee. Drug or Drugs shall mean any controlled substance that is not legally obtainable under State or Federal law, or a prescription drug obtained or used without benefit of a prescription by a licensed physician. Medical Review Officer (MRO) shall mean a licensed physician with knowledge of drug abuse disorders as well as appropriate training to interpret and evaluate an employee’s positive test results together with an employee’s medical history and any other biomedical information. MRO reviews all negative and positive test results and interviews individuals who tested positive to verify the laboratory report before the employer is notified. The City shall select an MRO who is a licensed physician. Prescription Drug shall mean any substance that an awfully be obtained or possessed pursuant to a prescription by a licensed physician. Page 27 of 55 Page 12 of 25 Adopted 08/23/22 Positive Test shall mean to have the presence of a drug or a drug metabolite and/or alcohol in a person’s system that is equal to or greater than the levels allowed by this Policy in the confirmation test as determined by appropriate testing of breath, urine, or blood specimen and which is determined by the MRO to be the result of the use of drugs and/or alcohol. Testing Laboratory shall mean Substance Abuse and Mental Health Services Administration (SAMHSA) certified testing laboratory. Safety Sensitive Positions. While the DOT leaves it to the individual agencies to determine which positions are safety-sensitive, it also describes these as positions are jobs in which an employee is responsible for his or her own or other people’s safety and that would be particularly dangerous if performed under the influence of drugs or alcohol. Safety-Sensitive Functions - The following are safety-sensitive functions: a) All time at a carrier or shipper plant, terminal, facility or other property, or on any public property, waiting to be dispatched, unless the driver has been relieved from duty by the employer. This includes employees who are “eligible” at work to drive a commercial motor vehicle at anytime. b) All time inspecting equipment as required by the Federal Motor Carrier Safety Regulations (FMCSRs), or otherwise inspecting, servicing or conditioning any commercial motor vehicle at any time. c) All driving time, which is any time spent at the driving controls of a commercial motor vehicle in operation. d) All time, other than driving time,in or upon any commercial motor vehicle, except time spent resting in the sleeper berth. e) All time loading or unloading a commercial motor vehicle, supervising, or assisting in the loading or unloading, attending a vehicle being loaded or unloaded, remaining ready to operate the vehicle, or in giving or receiving receipts for shipments loaded or unloaded. f) All time repairing, obtaining assistance for, or remaining with a disabled vehicle. Substance Abuse Professional (SAP) shall mean a licensed physician, social worker, psychologist, Employee Assistance Program (EAP) or certified National Association of Alcohol and Drug Abuse Counselors (NAADAC) with knowledge of and clinical experience in diagnosis and treatment of alcohol and controlled substance disorders. SAP determines whether an employee is “Fit for Duty” following an employee’s refusal to test or failed alcohol or drug test, refers employee for a return to duty test and schedules unannounced follow up testing for a period of up to 36 months from the date the employee tested positive. Page 28 of 55 Page 13 of 25 Adopted 08/23/22 Attachment C - Reasonable Suspicion Assessment Form Employee Name: ______________________________________________________________________ Observation Date(s) and Time(s): ______________________________________________________________________ Location of Employee: ______________________________________________________________________ Location of Supervisor(s): ______________________________________________________________________ Other present during activities or observations: ______________________________________________________________________ Incident(s) observed which give cause for concern. May include behaviors such as taking needless risks, accident(s), disregard for others’ safety, unusual/distinct pattern of absenteeism/tardiness, increased high/low periods of productivity, lapses of concentration or judgment, etc.) __________________________________________________________________________ __________________________________________________________________________ ______________________________________________________________ 1. Presence of alcohol, alcohol containers, drugs, and/or drug paraphernalia (specify): ________________________________________________________________________ ________________________________________________________________________ _________________________________________________________ 2. Appearance:  Flushed  Bloodshot/Glassy/Watery Eyes  Dilated/ Constricted Pupils  Inappropriate Behavior  Dry-mouth symptoms  Puncture Marks  Tremors  Inappropriate wearing of Sunglasses  Runny Nose/Sores  Disheveled Profuse Sweating  Smell of Alcohol or Marijuana  Other Other (specify if selected) ______________________________________________ 3. Behavior/Speech:  Incoherent  Confused  Agitated  Slurred Page 29 of 55 Page 14 of 25 Adopted 08/23/22  Slowed  Sleeping on the job  Unconscious  Hostile/Confrontational  Other Other (specify if selected) _____________________________________________ 4. Awareness:  Confused  Lethargic  Lack of Coordination  Mood Swings  Paranoid  Euphoric  Disoriented  Other Other (specify if selected) _____________________________________________ 5. Motor skills/Balance:  Unsteady  Staggering  Arms Raised for balance  Swaying  Stumbling  Falling  Reaching for Support  Other Other (specify if selected) _____________________________________________ 6. Other observed actions or behaviors: ________________________________________________________________________ ________________________________________________________________________ ______________________________________________________ Supervisor’s Comments: __________________________________________________________________________ __________________________________________________________________________ __________________________________________________________________________ ______________________________________________________ Supervisor’s Name: ____________________________________________________ Signature: ___________________________________ Date: ___________________ Witness’ Name: _______________________________ Date: ___________________ Page 30 of 55 Page 15 of 25 Adopted 08/23/22 Attachment D – Acknowledgement of Submission to Drug and/or Alcohol Testing CITY OF SAN LUIS OBISPO ACKNOWLEDGEMENT OF SUBMISSION TO DRUG AND/OR ALCOHOL TESTING I, ______________________________________ (PRINT NAME), understand and acknowledge that I have reviewed a copy of the City of San Luis Obispo Drug and Alcohol Testing Policy (Policy). I hereby acknowledge that I am required to submit to drug and/or alcohol testing pursuant to the Policy. I understand and acknowledge that information regarding the test results will be released to the City of San Luis Obispo and that such information may be used as grounds for disciplinary action up to and including discharge. I further understand and acknowledge that: - The City of San Luis Obispo will pay the cost of all drug and/or alcohol tests required or requested by the City. - I may request in writing a copy of the results of any such test. - I may request that a split sample test be sent to a certified Testing Laboratory of my choice, consistent with the procedures outline in the City of San Luis Obispo Drug and Alcohol testing Policy, and that I will bear all of the costs associated with the split sample testing. - By signing this form, I hereby acknowledge that the split sample test results will be released to the City of San Luis Obispo. - I have the right to refuse to submit to such testing; however, refusal by me to submit to or cooperate at any stage of the testing shall be considered equivalent to a confirmed “positive” test for purposes of disqualification from Employment and/or disciplinary action, up to and including discharge from employment with the City of San Luis Obispo. - I may also be required to execute forms at the Collection Site of Testing Laboratory. With full understanding and knowledge of the foregoing, I hereby acknowledge my obligation to submit to drug and/or alcohol testing conducted by the clinic and/or Testing Laboratory selection by the City of San Luis Obispo. I have read the above acknowledgement and certify that I have signed this document with full knowledge and understanding of its contents. Signature ____________________ Date_________ City & State _______________ Witness Signature_________________________ Date__________ Page 31 of 55 Page 16 of 25 Adopted 08/23/22 Attachment E - Fact Sheets Alcohol Alcohol is a socially acceptable drug that has been consumed throughout the world for centuries. It is considered a recreational beverage when consumed in moderation for enjoyment and relaxation during social gatherings. However, when consumed primarily for its physical and mood-altering effects, it is a substance of abuse. As a depressant, it slows down physical responses and progressively impairs mental functions. Signs and Symptoms of Use • Dulled mental processes • Lack of coordination • Odor of alcohol on breath • Possible constricted pupils • Sleepy or stuporous condition • Slow reaction rate • Slurred speech (Note: Except for the order, these are general signs and symptoms of any depressant substance.) Health Effects The chronic consumption of alcohol (average of three (3) servings per day of beer [12 ounces], whiskey [1 ounce], or wine [6-ounce glass] over time, may result in the following health hazards: • Decreased sexual functioning • Dependency (up to 10 percent of those who drink alcohol become physically and or mentally dependent on alcohol and can be termed “alcoholic”) • Fatal liver diseases • Increased cancers of the mouth, tongue, pharynx, esophagus, rectum, breast, and malignant melanoma • Kidney disease • Pancreatitis • Spontaneous abortion and neonatal mortality • Ulcers • Birth defects (up to 54 percent of all birth defects are alcohol related) Social Issues • Two-thirds of all homicides are committed by people who drink prior to the crime. • Two to three percent of the driving population is legally drunk at any one time. This rate is doubled at night and on weekends. • Two-thirds of all Americans will be involved in an alcohol-related vehicle accident during their lifetimes. • The rate of separation and divorce in families with alcohol dependency problems is seven times the average. • Forty percent of family court cases are alcohol problem related. Page 32 of 55 Page 17 of 25 Adopted 08/23/22 • Alcoholics are fifteen times more likely to commit suicide than are other segments of the population. • More than sixty percent of burns, forty percent of falls, sixty-nine percent of boating accidents and seventy-six percent of private aircraft accidents are alcohol related. The Annual Toll • 24,000 people will die on the highway due to the legally impaired driver. • 12,000 more will die on the highway due to the alcohol-affected driver. • 15,800 will die in non-highway accidents. • 30,000 will die due to alcohol-caused liver disease. • 10,000 will die due to alcohol-induced brain disease or suicide. • Up to another 125,000 will die due to alcohol-related conditions or accidents. Workplace Issues • It takes one hour for the average person (150 pounds) to process one serving of an alcoholic beverage from the body. • Impairment in coordination and judgment can be objectively measured with as little as two drinks in the body. • A person who is legally intoxicated is six time more likely to have an accident than a sober person. Page 33 of 55 Page 18 of 25 Adopted 08/23/22 Amphetamine Amphetamines are central nervous system stimulants that speed up the mind and body. The physical sense of energy at lower doses and the mental exhilaration at higher doses are the reasons for their abuse. Although widely prescribed at one time for weight reduction and mood elevation, the legal use of amphetamines is now limited to a very narrow range of medical conditions. Most amphetamines that are abused are illegally manufactured in foreign countries and smuggled into the U.S. or clandestinely manufactured in crude laboratories. Description • Amphetamine is sold in counterfeit capsules or as white, flat, double-scored “minibennies.” It is usually taken by mouth. • Methamphetamine is often sold as a creamy white granular powder or in lumps and is packaged in aluminum foil wraps or sealable plastic bags. Methamphetamine may be taken orally, injected, or snorted into the nose. • Trade/street names include Biphetamine, Delcobese, Desotyn, Detedrine, Chetrol, Ritaline, Speed, Meth, Crank, Monster, Black Beauties, and Rits. Signs and Symptoms of Use • Hyperexcitability, restlessness • Dilated pupils • Increased heart rate and blood pressure • Heart palpitations and irregular beats • Profuse sweating • Rapid respiration • Confusion • Panic • Talkativeness • Inability to concentrate • Heightened aggressive behavior Health Effects • Regular use produces strong psychological dependence and increasing tolerance to drug. • High doses may cause toxic psychosis resembling schizophrenia. • Intoxication may induce a heart attack or stroke due to spiking of blood pressure. • Chronic use may cause heart and brain damage due to severe constriction of capillary blood vessels. • The euphoric stimulation increases impulsive and risk-taking behaviors, including bizarre and violent acts. • Withdrawal from the drug may result in severe physical and mental depression. Workplace Issues • Since amphetamines alleviate the sensation of fatigue, they may be abused to increase alertness because of unusual overtime demands or failure to get rest. • Low-dose amphetamine use will cause a short-term improvement in mental and physical functioning. With greater use or increasing fatigue, the effect reverses and has an impairing effect. Hangover effect is characterized by physical fatigue depression, which may make operation of equipment or vehicles dangerous. Page 34 of 55 Page 19 of 25 Adopted 08/23/22 Cocaine Cocaine is used medically as a local anesthetic. It is abused as a powerful physical and mental stimulant. The entire central nervous system is energized. Muscles are more tense, the heart beats faster and stronger, and the body burns more energy. The brain experiences an exhilaration caused by a large release of neurohormone associated with mood elevation. Description • The source of cocaine is the coca bush, grown almost exclusively in the mountainous regions of northern South America. • Cocaine Hydrochloride – “snorting coke” is a white to creamy granular or lumpy powder before use. It is snorted into the nose, rubbed on the gums, or injected in veins. The effect is felt within minutes and lasts forty to fifty minutes per “line” (about sixty to ninety milligrams). Common paraphernalia include a single-edged razor blade and a small mirror or piece of smooth metal, a half straw or metal tube, and a small screw-cap vial or folded paper packet containing the cocaine. • Cocaine Base – a small crystalline rock about the size of a small pebble. It boils at a low temperature, is not soluble in water, and is up to ninety percent pure. It is heated in a glass pipe and the vapor is inhaled. The effect is felt within seven seconds. Common paraphernalia include a “crack pipe” (a small glass smoking device for vaporizing the crack crystal) and a lighter, alcohol lamp, or small butane torch for heating. • Trade/street names include Coke, Rock, Crack, Free Base, Flake, Snow, Smoke, and Blow. Signs and Symptoms of Use • Financial problems • Frequent and extended absence from meetings or work assignment • Increased physical activity and fatigue • Isolation and withdrawal from friends and normal activities • Secretive behaviors, frequent non- business visitors, delivered packages, phone calls • Unusual defensiveness, anxiety, agitation • Wide mood swings • Runny or irritated nose • Difficulty in concentration • Dilated pupils and visual impairment • Restlessness • Formication (sensation of bugs crawling on skin) • High blood pressure, heart palpitations, and irregular rhythm • Hallucinations • Hyperexcitability and overreaction to stimulus • Insomnia • Paranoia and hallucinations • Profuse sweating and dry mouth • Talkativeness Page 35 of 55 Page 20 of 25 Adopted 08/23/22 Health Effects • Research suggests that regular cocaine use may upset the chemical balance of the brain. As a result, it may speed up the aging process by causing irreparable damage to critical nerve cells. The onset of nervous system illnesses, such as Parkinson’s disease, could also occur. • Cocaine use causes the heart to beat faster and harder and rapidly increases blood pressure. In addition, cocaine causes spasms of blood vessels in the brain and heart. Both effects lead to ruptured vessels causing strokes or heart attacks. • Strong psychological dependency occurs within days (crack) or within several months (snorting coke). Cocaine causes the strongest mental dependency of any known drug. • Treatment success rates are lower than for other chemical dependencies. • Cocaine is extremely dangerous when taken with depressant drugs. Death due to overdose is rapid. The fatal effects of an overdose are not usually reversible by medical intervention. The number of cocaine overdose deaths had tripled in the last four years. • Cocaine overdose was the second most common drug emergency in 1986 – up from 11th place in 1980. Workplace Issues • Extreme mood and energy swings create instability. Sudden noises can cause a violent reaction. • Lapses in attention and ignoring warning signals greatly increase the potential for accidents. • The high cost of cocaine frequently leads to workplace theft and/or dealing. • A developing paranoia and withdrawal create unpredictable and sometimes violent behavior. • Work performance is characterized by forgetfulness, absenteeism, tardiness, and missed assignments. Page 36 of 55 City of San Luis Obispo, Title, Subtitle Page 21 of 25 Adopted 08/23/22 Cannabinoids (Marijuana) Marijuana is one of the most misunderstood and underestimated drugs of abuse. People use marijuana for the mildly tranquilizing and mood- and perception-altering effect it produces. Description • Usually sold in plastic sandwich bags, leaf marijuana will range in color from green to light tan. The leaves are usually dry and broken into small pieces. The seeds are oval with one slightly pointed end. Less prevalent, hashish is a compressed, sometimes tar-like substance ranging in color from pale yellow to black. It is usually sold in small chunks wrapped in aluminum foil. It may also be sold as an oily liquid. • Marijuana has a distinctly pungent aroma resembling a combination of sweet alfalfa and incense. • Cigarette papers, roach clip holders, and small pipes made of bone, brass, or glass are commonly found. Smoking “bongs” (large bore pipes for inhaling large volumes of smoke) can easily be made from soft drink cans and toilet paper rolls. • Trade/street names include Marinol, THC, Pot, Grass, Joint, Reefer, Acapulco Gold, Sinsemilla, Thai Sticks, Hash, and Hash Oil. Signs and Symptoms of Use • Reddened eyes (often masked by eye drops) • Slowed speech • Distinctive odor on clothing • Lackadaisical “I don’t care” attitude • Chronic fatigue and lack of motivation • Irritating cough, chronic sore throat Health Effects General • When marijuana is smoked, it is irritating to the lungs. Chronic smoking causes emphysema-like conditions. • One joint causes the heart to race and be overworked. People with undiagnosed heart conditions are at risk. • Marijuana is commonly contaminated with the fungus Aspergillus, which can cause serious respiratory tract and sinus infections. • Marijuana smoking lowers the body’s immune system response, making users more susceptible to infection. The U. S. government is actively researching a possible connection between marijuana smoking and activation of AIDS in positive human immunodeficiency virus (HIV) carriers. Pregnancy Problems and Birth Defects • The active chemical, tetrahydrocannabinol (THC), and 60 other related chemicals in marijuana concentrate in the ovaries and testes. Page 37 of 55 City of San Luis Obispo, Title, Subtitle Page 22 of 25 Adopted 08/23/22 • Chronic smoking of marijuana in males causes a decrease in the male sex hormone, testosterone, and an increase in estrogen, the female sex hormone. The result is a decrease in sperm count, which can lead to temporary sterility. Occasionally, the onset of female sex characteristics, including breast development occurs in heavy users. • Chronic smoking of marijuana in females causes a decrease in fertility and an increase in testosterone. • Pregnant women who are chronic marijuana smokers have a higher than normal incidence of stillborn births, early termination of pregnancy, and higher infant mortality rate during the first few days of life. • In test animals, THC causes birth defects, including malformation of the brain, spinal cord, forelimbs, and liver, and water on the brain and spine. • Offspring of test animals who were exposed to marijuana have fewer chromosomes than normal, causing gross birth defects or death of the fetus. Pediatricians and surgeons are concluding that the use of marijuana by either or both parents, especially during pregnancy, leads to specific birth defects of the infant’s feet and hands. • One of the most common effects of prenatal cannabinoid exposure is underweight newborn babies. • Fetal exposure may decrease visual functioning and causes other ophthalmic problems. Mental Function • Delayed decision-making • Diminished concentration • Impaired short-term memory, interfering with learning • Impaired signal detection (ability to detect a brief flash of light), a risk for users who are operating machinery. • Impaired tracking (the ability to follow a moving object with the eyes) and visual distance measurements • Erratic cognitive function • Distortions in time estimation • Long-term negative effects on mental function known as “acute brain syndrome,” which is characterized by disorders in memory, cognitive function, sleep patterns, and physical condition. Acute Effects • Aggressive urges • Anxiety • Confusion • Fearfulness • Hallucination • Heavy sedation • Immobility • Mental dependency • Panic Page 38 of 55 City of San Luis Obispo, Title, Subtitle Page 23 of 25 Adopted 08/23/22 • Paranoid reaction • Unpleasant distortions in the body image Workplace Issues • The active chemical, THC, stores in body fat and slowly releases over time. Marijuana smoking has a long-term effect on performance. • A 500 to 800 percent increase in THC concentration in the past several years makes smoking three to five joints a week today equivalent to 15 to 40 joints a week in 1978. • Combining alcohol or other depressant drugs and marijuana can produce a multiplied effect, increasing the impairing effect of both the depressant and marijuana. Page 39 of 55 City of San Luis Obispo, Title, Subtitle Page 24 of 25 Adopted 08/23/22 Opioids Opioids (also called narcotics) are drugs that alleviate pain, depress body function and reactions, and, when taken in large doses, cause a strong euphoric feeling. Description • Natural and natural derivatives – opium, morphine, codeine, and heroin • Synthetics – meperidine (Demerol), oxymorphone (Numorphan), hydrocodone, and oxycodone (Percodan) • May be taken in pill form, smoked, or injected, depending upon the type of narcotic used • Trade/street names include Smack, Horse, Emma, Big D, Dollies, Juice, Syrup, and China White Signs and Symptoms of Use • Mood changes • Impaired mental functioning/alertness • Constricted pupils • Depression and apathy • Impaired coordination • Physical fatigue and drowsiness • Nausea, vomiting, and constipation • Impaired respiration Health Effects • IV needle users have a high risk for contracting hepatitis and AIDS due to the sharing of needles. • Narcotics increase pain tolerance. As a result, people could more severely injure themselves or fail to seek medical attention after an accident due to the lack of pain. • Narcotics’ effects are multiplied when used in combination with other depressant drugs and alcohol, causing increased risk for an overdose. Social Issues • There are over 500,000 heroin addicts in the U.S., most of whom are IV needle users. • An even greater number of medicinal narcotic-dependent persons obtain their narcotics through prescriptions. • Because of tolerance, there is an ever-increasing need for more narcotic to produce the same effect. • Strong mental and physical dependency occurs. • The combination of tolerance and dependency creates an increasing financial burden for the user. Costs for heroin can reach hundreds of dollars a day. Workplace Issues • Unwanted side effects such as nausea, vomiting, dizziness, mental clouding, and drowsiness place the legitimate user and abuser at higher risk for an accident. • Narcotics have a legitimate use in alleviating pain. Workplace use may cause impairment of physical and mental functions. Page 40 of 55 City of San Luis Obispo, Title, Subtitle Page 25 of 25 Adopted 08/23/22 Phencyclidine (PCP) Phencyclidine (PCP) was originally developed as an anesthetic, but the adverse side effects prevented its use except as a large animal tranquilizer. Phencyclidine acts as both a depressant and a hallucinogen, and sometimes as a stimulant. It is abused primarily for its variety of mood- altering effects. Low doses produce sedation and euphoric mood changes. Larger doses may produce a coma-like condition with muscle rigidity and a blank stare with the eye lids half closed. Sudden noises or physical shocks may cause a “freak out” in which the person has abnormal strength, extremely violent behavior, and an inability to speak or comprehend communication. Description • PCP is sold as a creamy, granular powder and is often packaged in one-inch square aluminum foil or folded paper “packets.” • It may be mixed with marijuana or tobacco and smoked. It is sometimes combined with procaine, a local anesthetic, and sold as imitation cocaine. • Trade/street names include Angel Dust, Dust, and Hog. Signs and Symptoms of Use • Impaired Coordination • Severe confusion and agitation • Extreme mood shifts • Muscle rigidity • Nystagmus (jerky eye movements) • Dilated pupils • Profuse sweating • Rapid heartbeat • Dizziness Health Effects • The potential for accidents and overdose emergencies is high due to the extreme mental effects combined with the anesthetic effect on the body. • PCP is potentiated by other depressant drugs, including alcohol, increasing the likelihood of an overdose reaction. • Misdiagnosing the hallucinations as LSD induced, and then treating with thorazine, can cause a fatal reaction. • Use can cause irreversible memory loss, personality changes, and thought disorders. • There are four phases to PCP abuse. The first phase is acute toxicity. It can last up to three days and can include combativeness, catatonia, convulsions, and coma. Distortions of size, shape, and distance perception are common. The second phase, which does not always follow the first, is a toxic psychosis. Users may experience visual and auditory delusions, paranoia, and agitation. The third phase is a drug-induced schizophrenia that may last a month or longer. The fourth phase is PCP-induced depression. Suicidal tendencies and mental dysfunction can last for months. Workplace Issues • PCP abuse is less common today than in recent years. It is also not generally used in a workplace setting because of the severe disorientation that occurs. Page 41 of 55 Page 42 of 55 1 A DUE PROCESS PRIMER I. DUE PROCESS A. Basic Procedural Due Process Requirement: Due process under both the federal and state constitutions requires that, before a person can be deprived of a property or liberty interest, he or she must be notified of the charges and have an opportunity for a fair hearing before an impartial decision maker, where he or she can respond to the charges at a meaningful time and in a meaningful manner. B. What Legal Authority Mandates Procedural Due Process: 1. Federal - The 14th amendment of the U.S. Constitution [“ nor shall any state deprive any person of life, liberty, or property, without due process of law”] as interpreted by federal court decisions. 2. State - Article I, Section 7(a) of the California Constitution [“A person may not be deprived of life, liberty, or property without due process of law....”] as interpreted by California Court decisions. C. When Is Procedural Due Process Required? 1. A property or liberty interest must be threatened before procedural due process protections are triggered. For administrative citations, a liberty interest is not normally implicated. (A liberty interest includes all interests recognized as protected by the due process clauses of state and federal constitutions. In addition to protection against unlawful incarceration, there are constitutional protections of numerous other liberty interests, such as right to contract, acquire useful information, pursue a particular occupation, protect good name, reputation, honor or integrity; protection against situations where harm by governmental action may deprive person of a future opportunity.) 2. Property Interest: any type of right to specific property whether it is personal or real property, tangible or intangible, or any quantifiable benefit derived from an action includes payment of fines). 3. Due Process is required in administrative proceedings. II. MINIMUM DUE PROCESS REQUIREMENTS BEFORE DEPRIVATION OF A PROPERTY OR LIBERTY INTEREST A. Notice Of The Allegations Must Be Given 1. The administrative citation must notify the person of the code violation alleged against him or her, i.e., the municipal code sections violated, when and where the violations occurred. 2. The person must be notified of the consequences if the violation is upheld, including a range of consequences if applicable. 3. The person should be notified of any right to appeal. Page 43 of 55 2 4. If the person chooses to appeal the administrative citation, he or she must be provided with the date, time and location of the hearing and the identity of the decision maker(s), if known. 5. Copies of all written statements, reports, photographs and records, etc., as well as names of witnesses, on which the City is relying to prove the alleged violation should be provided to the appellant as soon as possible after the request for appeal is received, if not previously provided. B. Appellant Must Have Opportunity To Respond To The Charges Before Deprivation Of Protected Interest Occurs 1. After notice of the charges against a person, due process requires that a person have a meaningful opportunity to respond to the charges before a final decision imposing consequences is made. This means that both the decision maker must be fair, (i.e., unbiased, impartial and having no financial or personal involvement or conflict of interest in the decision) and the hearing must be conducted in a fair manner. 2. Due process is an elastic concept. The extent of the procedure required depends on the nature and magnitude of the interest affected and may require a balancing act. III. FAIR DECISION MAKER A. Decision Maker Must Be Impartial And Unbiased 1. A decision maker cannot be picked and paid by one party if future employment/remuneration may depend on favorable decisions. 2. The due process requirement for impartiality applies equally to decision makers as to judicial officers. 3. Decision maker cannot have any bias against any party or class to which a party belongs that could adversely impact impartiality: a) Statutorily Protected classes (heightened scrutiny): race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, familial status, marital status, disability, genetic information, national origin, source of income or ancestry, including a perception that a person has any of those characteristics or that the person is associated with a person who has, or is perceived to have, any of those characteristics. b) Even where there is no protected class involved, decisions driven by implicit or explicit bias based on a variety of factors can give rise to claims that an individual was deprived of a fair hearing. Thus, a decision maker should make decisions based only on facts and applicable law, not on assumptions based on a group or class the appellant or witness belongs to or appears to belong to, i.e., student, landlord, tenant, teenager, elderly, etc. B. Decision Maker Can Have No Financial Or Conflicting Interest In Decision 1. City Code of Ethics for employees applies to advisory bodies and those acting as representatives of the City, including hearing officers, and generally requires ethical behavior consistent with the following: Page 44 of 55 3 a) No direct or indirect interest that may conflict with official duties, including any obligation (real or perceived) which may impair independent judgment in the discharge of official duties, or give rise to the appearance of wrongdoing. b) Impartiality and dedication to best interests of City, avoiding actions and statements that may create a public perception of preferential service or lack of neutrality. c) No acceptance of money or other consideration, gifts, gratuities, including meals, or favors of any kind, from appellant or related entities or persons or anyone testifying before decision maker either before, during, or after hearing d) No disclosure of any confidential information acquired or made available to the decision maker or use of any information, City’s facilities, equipment or supplies for personal gain. e) No use, or attempt to use, position to secure privileges or exemptions, personally or for others. f) No involvement in any City contract or sale in which the decision maker or a member of their family may have a financial interest. g) No expectation of priority use of City facilities and programs. h) Perform duties in good faith and in manner that the decision maker believes to be in best interest of City of San Luis Obispo. i) Be aware of potential conflicts of interest arising from serving on another board if there is a clash of duties between the two positions, i.e. when one board exercises supervisory, auditory or removal powers over the other or where City policy prohibits dual service. j) Comply with all applicable City policies, including but not limited to Anti- Discrimination and Unlawful Harassment Policy and Drug Free Workplace Policy. 2. State laws also apply. These include: a) Political Reform Act – Government Code Section 81000 et seq. and Fair Political Practice Commission (“FPPC”) Regulations, 2 Cal. Code of Regs., section 18700 et seq. prohibit any public official from making, participating in making or attempting to influence in any way, the government decision in which he or she has a material financial interest. Hearing officers and board members are public officials subject to these laws according to an FPPC opinion the City received. These laws require disclosure (filing of a statement of economic interest) and disqualification when there is a conflict of interest. See Appendix A. b) Government Code Section 1090 prohibits a city official from having a financial interest in any contract entered into by him or her in his or her official capacity, or by any board or body of which he or she is a member. Page 45 of 55 4 C. Decision Maker Should Have No Personal Interest In The Decision Or In Any Participant 1. A decision maker is generally not impartial if he or she, or someone the decision maker has a close relationship with, is involved in the matter. Even if the decision maker believes they could be impartial, there may be an appearance of partiality, which may subject the hearing process to challenge. 2. Public decision makers shall disqualify themselves from hearing a matter if they are personally involved in the matter, or a family member, in-law, friend or business associate is involved. They also should strongly consider disqualification or, at a minimum, publicly disclose facts and explain impartiality conclusions, where they: a) Have a personal relationship with appellant or witness, the nature of which would cause a reasonable person to doubt impartiality; or b) Are personally involved in a similar code enforcement matter pending before the City as a complainant, witness, or appellant; or c) Have personal knowledge about the matter obtained outside the hearing, which will influence the decision, unless the knowledge is disclosed to the appellant and the appellant has the opportunity to counter such information. D. Avoiding The Appearance Of Bias Or Conflict Of Interest Is As Important As Avoiding Actual Conflict Of Interest 1. Treat all participants in a similar manner and with respect; avoid words or actions that might appear overly friendly or partisan or that suggest you are advocating for one side. 2. Do not commit to an outcome or create an impression that you have done so in ex parte (outside the hearing itself) communications with anyone. Disclose the facts and substance of any communications about the subject matter of the hearing that you have had outside of the hearing, so that such information is part of the record and can be addressed by the appellant. 3. Keep an open mind and don’t form conclusions prior to hearing all evidence. 4. Do not make comments tending to favor or disfavor a group to which appellant or a witness belongs, or appears to belong. IV. FAIR HEARING The conduct of the hearing must be fair and impartial. The hearing procedure must provide a meaningful opportunity for the appellant to respond to the charges. However, application of due process principles is flexible, depending on the nature of the competing interests and no specific procedure is required for all matters. At a minimum: 1. The hearing procedure must be explained to the appellant. 2. The appellant must have an opportunity to present his or her side. Page 46 of 55 5 3. The greater the possible loss to the appellant, the greater the degree of procedural due process must be afforded. For an administrative citation that imposes a fine, the loss in most cases is not considered substantial. Therefore a hearing before an impartial decision maker that allows the appellant to present his or her side and to refute the City’s documents or position before the decision is made, should be sufficient. However, for an administrative citation(s) that imposes significant on going fines, such as hourly or daily fines until a violation is corrected, or requires the appellant to expend significant amounts of money to correct a violation to avoid repeated citations, or where the appellant risks loss of a business or investment, or demolition of all or portion of a building, the degree of procedural due process required may be greater. A. Before Hearing Begins 1. Reasonable notice to appellant of date, time and place of the hearing. 2. Reasonable time for the appellant to respond or prepare an adequate defense. The amount of time needed may depend on the nature and complexity of the violation. 3. Notice of right to reasonable accommodation for disability, if needed. 4. Notice of right to bring interpreter, if needed. 5. Describe procedure to be followed. B. During Hearing 1. Recording of hearing: a) Audio recording and minutes are required by Municipal Code for Construction Board of Appeals and Administrative Review Board hearings. Appellant may, at their own expense, hire a court reporter or videotape the hearing, as long as there is no interference with the hearing. b) Recording and minutes not required for hearing officer hearings, but appellant may record. c) City makes and pays for required audio recording and minutes. d) Appellant pays for any other record desired. e) Either party shall provide a copy of the record it prepared to the other party upon the other’s request and payment of reasonable copying costs. 2. City’s documents are prima facie evidence of violation: The administrative citation and any reports, photos, or other records accompanying the administrative citation are admitted without the necessity for the City to appear. California Government Code Section 53069.4) 3. Type of procedure: a) Informal b) Rules of evidence do not apply Page 47 of 55 6 c) Open to public 4. No subpoena power: Hearing officers, Administrative Review Board and Construction Board of Appeals do not have the power to issue subpoenas (the City Council does have such power and may be requested to issue administrative subpoenas in appropriate circumstances). a) Witnesses cannot be compelled to attend the appeal hearing. b) Persons having custody of physical evidence or records cannot be compelled to provide the evidence to the hearing officer or board. 5. Appellants’ rights at hearing: a) Right to be represented by an attorney. b) Right to be present at the hearing. c) Right to challenge or refute City’s documents, by oral, written or physical evidence. d) Right to present oral, written or physical evidence supporting appellant’s position. 6. Admissible Evidence: a) Any relevant evidence, if it is the type of evidence on which responsible persons rely in the conduct of serious affairs. b) Need not be admissible in court (i.e., hearsay may be considered if deemed relevant and reliable in the context of the entire evidentiary record by the decision maker, but may not be the sole basis of a finding of fact or conclusion). 7. Inadmissible evidence or evidence not to be considered in making a decision: a) Not presented at hearing. b) Irrelevant or unduly duplicative. c) Illegible or unintelligible. d) Independent investigation by hearing officer or board is not permitted (site visits to familiarize decision maker with physical or geographic location at issue are permissible, but should be disclosed as part of the record). 8. Standard of Proof: Preponderance of evidence. Evidence supports finding that it was more likely than not that violation occurred/person was responsible. 9. Burden of proof: a) City to prove violation occurred by prima facie evidence permitted by Government Code Section 53069.4 and any additional testimony or evidence presented. Page 48 of 55 7 b) Appellant to prove any defense or mitigation through any testimony or evidence presented. V. DECISION AFTER HEARING After the hearing, the hearing officer or board shall issue a written decision with factual findings based only on information presented at hearing or in allowed site visit. The extent of the written decision depends on the degree of potential loss. A. Appeal To Hearing Officer Generally, for most administrative citations punishable by fine only, a decision letter by a hearing officer is sufficient. See also SLOMC 1.24.120(A). However, if significant fines have been imposed (collectively greater than $2,000) a more detailed decision, as set forth in the section on appeals to a board in the immediately following section, and SLOMC 1.24.130(A), should be prepared. The decision letter should state: 1. Whether the hearing officer finds that the specified violation(s) either did or did not occur; 2. Whether the appellant timely submitted any written evidence; 3. Whether the appellant was present at the hearing or failed to appear; 4. If the appellant failed to appear, what written evidence the hearing officer considered to be credible or not credible; and 5. If the appellant failed to appear and did not timely submit any written evidence, the appeal should so state, the appeal should be dismissed, and the violation and fine upheld. If the decision is that the violation did occur, the fine must be upheld. The hearing officer does not have the power to reduce the amount of the fine. The decision shall also advise the appellant of the right to appeal to the superior court for a trial de novo and the deadline to file such an appeal. If the decision is that the violation did not occur, the citation and fine are revoked and rescinded. B. Appeal To Administrative Review Board Or Construction Board Of Appeals Or Appeal Of Citation That Imposes Significant Fines 1. For an administrative citation that imposes significant on going fines (such as hourly or daily fines until a violation is corrected, that collectively exceed $2000, or requires the appellant to expend significant amounts of money to correct a violation to avoid repeated citations, or where the appellant risks loss of a business or investment, or demolition of all or a portion of a building) in addition to the information required in a hearing officer decision, a more detailed written decision may be required. The minimum requirements are set forth in municipal code section 1.24.130. Page 49 of 55 8 2. A decision must be approved by a majority of the applicable board. A member shall not vote if he or she did not hear all the evidence or listen to or read the entire hearing record before voting. SLOMC 1.24.130(A). 3. In addition to the requirements of SLOMC 1.24.130, it may be appropriate to determine which witnesses are credible; physical evidence reliable; if there are any mitigating circumstances or applicable defenses; the type, severity, frequency and duration of violation(s). 4. The decision must contain findings of fact supported by specified evidence presented at the hearing. 5. If the board upholds the citation, the board does not have the ability to reduce the fine. 6. The decision should also advise the appellant of the right to appeal to the superior court for a trial de novo, and/or of the right to file a petition for writ with the superior court, and the deadlines to do so. Page 50 of 55 9 APPENDIX A STATUTORY CONFLICT OF INTEREST POLITICAL REFORM ACT AND FPPC REGULATIONS Must comply with the California Political Reform Act (Government Code Sections 81000 et seq) and Fair Political Practices Commission Regulations (2 Cal. Code of Regs Sections 18700 et seq). What follows is a VERY brief summary of the conflict of interest requirements. A. File Form 700, Statement of Economic Interest when assuming office, then annually thereafter and when leaving position. B. Disclose financial interest and disqualify self from hearing matter if matter may materially affect personal finances and/or those of any member of immediate family. C. Four step analysis to determine if a conflict of interest exists: 1. Is it reasonably foreseeable that the government decision will have a financial effect on any financial interest? (Reg 18701). If no, no conflict. If yes, proceed to (2). Financial interests generally include: a) Investments. Business entity in which decision maker has direct or indirect investment worth at least $2,000 (Govt. Code 87103(a)) or in which they are a director, officer, partner, trustee, employee, or hold any position of management (Govt. Code 87103(d). For a “parent, subsidiary or otherwise related business entity”, see Reg. 18700.2. b) Real property. Property in which decision maker has a direct or indirect interest of at least 2,000 (Reg 87103(b). If property is within 500 feet of decision maker’s property, automatic disqualification. If decision can affect market value of property (up or down), distance may be greater. Other factors dependent on nature of matter and effect on decision maker’s property. c) Any source of income. This includes, but is not limited to, commissions, (ie. as real estate, insurance or travel agent or stock broker for any parties or properties involved) and incentive income, salary, income from a business entity, of at least $500, provided, promised to or received within 12 months before the decision is made(Government code 87103(c). d) Gift(s) amounting to at least $460 provided to, received by, or promised to, within 12 months before the decision is made. e) Loans 2. Will the reasonably foreseeable financial effect be material? (Reg. 18702)? If no, no conflict. If yes, proceed to (3). 3. Can decision maker demonstrate that the material financial effect on their financial interest is indistinguishable from its effect on the public generally? (Reg 18703). If yes, no conflict. If no, proceed to (4). 4. If after the 3 steps above the decision maker has a conflict of interest, absent an exception, he or she may not make, participate in making or in any way attempt to use his or her official positon to influence the government decision. THE DECISION MAKER MUST DECLINE TO HEAR MATTER IF CONFLICT OF INTEREST EXISTS. WHEN IN DOUBT, DECLINE TO HEAR MATTER. ONLY WRITTEN ADVICE LETTER FROM FPPC PROTECTS AGAINST PROSECUTION FOR VIOLATION Page 51 of 55 Page 52 of 55 San Luis Obispo Municipal Code 1.24.130 Decision by administrative review board or construction board of appeals. A.Decision by Board. After considering all the evidence and testimony submitted at an appeal hearing, the administrative review board or construction board of appeals, as applicable, shall issue a decision, as further described in the administrative citation and appeals guidelines, within thirty calendar days to either uphold or revoke the administrative citation based upon a conclusion of whether the violation occurred. A decision must be supported by a majority of the applicable board. A member shall not vote if he or she did not hear all the evidence or listen to or read the entire hearing record. If an administrative citation charges two or more code violations, the applicable board may uphold all violations, or uphold some violations but not all violations, or dismiss some or all violations. The written decision shall also summarize the evidence, and shall be supported by written findings of fact. The administrative review board and the construction board of appeals do not have the authority to reduce or modify a fine of a violation that is upheld on appeal. If a violation is not upheld, the administrative citation shall be revoked. The notice of decision shall be mailed by first class and certified mail, postage prepaid, return receipt requested, to the appellant or their designated representative. The failure by the appellant to appear at the appeal hearing shall be noted on the notice of decision. The decision of the administrative review board or construction board of appeals shall be final. The written decision may be, but is not required to be, adopted by resolution and shall contain, at a minimum, the following: 1.Name of appellant; 2.Date of administrative citation, municipal code violations charged, location of subject property (if applicable); 3.Date, time, and place of appeal hearing, and the identity of board members; 4.The names of all people participating in the hearing and their capacity, either as appellant, representative of appellant, witness for or against appellant, city staff or otherwise; 5.A statement that the hearing was recorded, the method of recordation, and that recording is in the custody of the city clerk; 6.A statement whether the appellant or designated representative was present or failed to appear; 7.If no one appeared on behalf of appellant, a statement whether appellant submitted any written or other evidence; 8.A statement that the board received the administrative citation and supporting information as prima facie evidence; 9.A brief summary of all credible relevant testimony and the identity of the witness giving it; 10.A list of all physical evidence, including, but not limited to photographs, maps, drawings, and documents; 11.A statement whether the board upholds, revokes or modifies the administrative citation(s), as to each municipal code violation charged; Page 53 of 55 12.A statement as to which oral or physical evidence the board found credible in support of the decision; 13.If the decision upholds the administrative citation, in whole or in part, the decision shall specify the due date for payment of the fine, which shall not be less than ten days nor more than thirty days after the date the decision is mailed; 14. The names and votes of members of the board, showing that a majority of the members of the board supported the decision; 15. The signature of the chairman of the board or his or her designee, and the date of signature. Page 54 of 55 The San Luis Obispo Municipal Code is current through Ordinance 1731, passed December 5, 2023. Disclaimer: The City Clerk's Office has the official version of the San Luis Obispo Municipal Code. Users should contact the City Clerk's Office for ordinances passed subsequent to the ordinance cited above. City Website: www.slocity.org City Telephone: (805) 781-7100 Hosted by Code Publishing Company, A General Code Company. 2.36.380 Employee responsibilities benefits—Code of ethics. A. An official or employee of the city shall not engage in conduct which would tend to discredit or dishonor his/ her position with the city. Such elected or appointed officials and employees must avoid conflicts of private interests with public duties and responsibilities and shall not do indirectly what may not be done directly. B. Disciplinary action generally does not follow an occasional error in judgment which occurs in good faith and is unintentional. However, misconduct, dishonesty and fraud shall be the basis for severe disciplinary action, including removal for cause. C. Officials and employees occupying designated positions are required to file an annual statement of financial interests with the city clerk as prescribed by the Conflict of Interest Code as adopted by the city. D. Each new employee must be informed of the obligation to submit a statement of financial interests if he/she falls within the listed designated position categories. E. Any employee whose job performance is adversely affected by the taking of alcohol, drugs, or other stimulants shall be subject to disciplinary action. F. Each employee is required to be familiar with city standards and statutory provisions relating to ethical and other standards of conduct. Each employee is expected to secure the advice of his/her superior or the personnel director or other appropriate officials, when in doubt about the meaning or application of any conduct requirement applying to his/her particular situation. G. The political activities of city employees shall conform to pertinent provisions of state and federal laws. (Prior code § 2708.1) Ch. 2.36 Personnel Rules and Regulations | San Luis Obispo Municipal Code Page 1 of 1 The San Luis Obispo Municipal Code is current through Ordinance 1731, passed December 5, 2023. Page 55 of 55