Working alongside someone who is impaired by drugs or alcohol on the job is not an experience any of us want to have. That is especially true for those who are employed in dangerous occupations like coal mining.

Let me be very clear: The United Mine Workers of America does not want anyone who is under the influence of drugs or alcohol working in America’s coal mines. Our members do not want to work next to an impaired individual, because lives are at stake.

That is why we have worked with many of the companies where we represent workers as they have implemented drug and alcohol testing programs, most recently with Foundation Coal and Consol Energy earlier this year. Those two companies joined the dozens of other coal companies that already have drug and alcohol testing programs in place, including many in West Virginia.

We took these steps because we remain committed to creating the safest and healthiest possible environments in America’s coal mines, and that can’t happen when workers are impaired.

The fact is, the vast majority of coal miners already are tested for drugs and alcohol. Most coal companies have already implemented testing programs, and more are on the way. By the federal Mine Safety and Health Administration’s own data, 80 percent of coal miners already have to pass pre-employment drug and alcohol screening tests. Seventy-five percent of miners are subject to random testing by their employers, and under current regulations all miners who are working in a section of a mine where a safety incident occurs can automatically be tested for drugs and alcohol.

One could argue that coal miners are already tested for drugs and alcohol at higher rates that any other group of industrial workers in America. Yet reading some of the commentary on this issue, one would think that drug and alcohol abuse in our nation’s coal mines is running rampant. The facts simply don’t support that suggestion.

Our concern with MSHA’s recent proposed rule for wide-scale drug and alcohol testing is not based on the safety aspects of the rule, but instead with the implication that this is such a big problem in the coal mines that thousands of hours of government employees’ time and millions of dollars of taxpayers’ money should be spent on developing and enforcing a nationwide regulation that is largely unneeded.

Indeed, in none of the recent major coal mine disasters — Sago, Aracoma, Darby and Crandall Canyon — was there any indication of drugs or alcohol being contributing factors to those tragedies. In each of those cases, the actions or inactions of mine management and MSHA itself were to blame. It’s interesting that in the wake of the devastating reports about MSHA’s actions in the Crandall Canyon tragedy, the agency’s distracting response has been to propose this drug testing rule.

There are clearly more pressing safety and health issues that should be drawing MSHA’s time and attention, but aren’t. For example, data published by the National Institute for Occupational Safety and Health show that the insidious and nearly always fatal black lung disease — caused by too much coal and silica dust in the mine atmosphere — is once again on the rise, afflicting thousands of miners, even younger miners who have been working in the industry only a short time.

The UMWA has been aggressively seeking action from MSHA to protect miners from respirable coal and silica dust for many years, yet nothing has happened. Action in this area would save far more lives in our industry and be a better use of government resources and taxpayer dollars than the proposed rule on drug and alcohol testing.

The UMWA supports actions that make coal miners safer and healthier on the job. Our concern is that government resources and money are being misplaced here, when far more critical issues remain unaddressed.

— Roberts is the international president of the United Mine Workers of America.