Cases2408757/2023

Claimant v Costco Wholesale UK Ltd

14 March 2025Before Employment Judge HolmesManchesterremote video

Outcome

Claimant fails

Individual claims

Unfair Dismissalfailed

The tribunal found the dismissal was for conduct (attending work under the influence of alcohol) which was a potentially fair reason. The respondent carried out a reasonable investigation using a third-party testing provider, followed a fair procedure including disciplinary meetings with right to accompaniment, and dismissal fell within the band of reasonable responses given the zero-tolerance policy and health and safety implications in a warehouse environment.

Direct Discrimination(race)withdrawn

Claim was withdrawn by the claimant and subsequently dismissed by the tribunal.

Facts

The claimant, employed by Costco since 2002, was dismissed for reporting to work under the influence of alcohol on 18 April 2023. Colleagues reported concerns about her demeanour and smell of alcohol. She underwent four breath tests by third-party provider Synlab showing readings between 0.44 and 1.31. She challenged the reliability of the testing equipment and procedures. Following disciplinary meetings in April and May 2023, she was dismissed on 17 May 2023. A review of the dismissal was conducted in response to a late appeal request.

Decision

The tribunal found the dismissal fair. The respondent had a potentially fair reason (conduct), carried out a reasonable investigation by using an independent testing service and properly investigating the claimant's challenges to the results, followed a fair procedure including properly conducted disciplinary meetings and a review on appeal, and dismissal was within the band of reasonable responses given the zero-tolerance policy and safety-critical environment.

Practical note

An employer can reasonably rely on third-party professional alcohol testing results where it properly investigates and responds to challenges raised by the employee, and dismissal for breach of a zero-tolerance drug and alcohol policy in a safety-critical warehouse environment will ordinarily fall within the band of reasonable responses.

Legal authorities cited

Polkey v A E Dayton Services Ltd [1988] ICR 142RSPCA v Cruden [1986] IRLR 83Iceland Frozen Foods v Jones [1983] ICR 17Foley v Post Office [2000] ICR 1283BHS v Burchell [1978] IRLR 379Taylor v OCS Group Ltd [2006] IRLR 613

Statutes

ERA 1996 s.98ERA 1996 s.123(6)

Case details

Case number
2408757/2023
Decision date
14 March 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
retail
Represented
Yes
Rep type
barrister

Employment details

Role
Marketing Membership Clerk
Service
21 years

Claimant representation

Represented
Yes
Rep type
lay rep