A study in 2004 by the Independent Inquiry into Drug Testing at Work found that attempts by employers to force employees to take drug tests could potentially be challenged as a violation of privacy under the Human Rights Act 1998 and Article 8 of the European Convention of Human Rights. However, this does not apply to industries where drug testing is a matter of personal and public safety or security rather than productivity. In consultation with Dr. Carlton Turner, President Ronald Reagan issued Executive Order 12564. In doing so, he instituted mandatory drug-testing for all safety-sensitive executive-level and civil-service Federal employees. This was challenged in the courts by the National Treasury Employees Union. In 1988, this challenge was considered by the US Supreme Court. A similar challenge resulted in the Court extending the drug-free workplace concept to the private sector. These decisions were then incorporated into the White House Drug Control Strategy directive issued by President George H.W. Bush in 1989. All defendants serving on federal probation or federal supervised release are required to submit to at least three drug tests. Failing a drug test can be construed as possession of a controlled substance, resulting in mandatory revocation and imprisonment. There have been inconsistent evaluation results as to whether continued pretrial drug testing has beneficial effects. Testing positive can lead to bail not being granted, or if bail has already been granted, to bail revocation or other sanctions. Arizona also adopted a law in 1987 authorizing mandatory drug testing of felony arrestees for the purpose of informing the pretrial release decision, and the District of Columbia has had a similar law since the 1970s. It has been argued that one of the problems with such testing is that there is often not enough time between the arrest and the bail decision to confirm positive results using GC/MS technology. It has also been argued that such testing potentially implicates the Fifth Amendment privilege against self-incrimination, the right to due process (including the prohibition against gathering evidence in a manner that shocks the conscience or constitutes outrageous government conduct), and the prohibition against unreasonable searches and seizures contained in the Fourth Amendment. According to Henriksson, the anti-drug appeals of the Reagan administration "created an environment in which many employers felt compelled to implement drug testing programs because failure to do so might be perceived as condoning drug use. This fear was easily exploited by aggressive marketing and sales forces, who often overstated the value of testing and painted a bleak picture of the consequences of failing to use the drug testing product or service being offered." On March 10, 1986, the Commission on Organized Crime asked all U.S. companies to test employees for drug use.