The Company recognizes the problem of drug and alcohol abuse in society, while also realizing that drug and alcohol dependency and abuse can be treated and controlled. The Company strives to provide for the safety and security of its employees. To this end, the purpose of this policy is to provide a work environment that is free of illegal drugs and alcohol abuse by offering programs concerned with awareness, intervention and rehabilitation.

    The Company has set requirements for the availability of employee assistance programs; has established restrictions on the use, sale and possession of illegal drugs and alcohol; and has identified circumstances for required substance testing. These are outlined below:

    In keeping with the Company’s objective to provide a safe and healthful work environment:

    1. The use, sale, consumption, possession or distribution of drugs, controlled substances or alcohol while on company property or company business is strictly prohibited and will result in discipline up to and including discharge.

    2. Drugs and alcohol may not be brought or consumed on any Company-owned or leased property (including vehicles) and job-sites. Any employee who is using prescription or over-the-counter drugs that may impair the employee’s ability to safely perform the job, or affect the safety or well-being of others, must notify a supervisor of such use immediately before starting or resuming work.

    3. Employees will not be permitted to work while under the influence of alcohol or with a detectable level of prohibited drugs in their systems. Prohibited drugs include both illegal substances and prescription drugs that have not been specifically prescribed by a registered physician for specific treatment purposes for the employee. While the Company has no intention of intruding into the private lives of its employees, we do require all employees to report to work in a condition that allows them to perform their duties. Individuals who appear to be unfit for work may be subject to a fitness-for-duty examination at a designated medical facility, shall be subject to random drug and alcohol testing and shall be subject to discipline up to and including discharge.

    4. Any employee who is involved with off-the-job illegal drug use may be considered in violation of this policy. In deciding what action to take, the Company will take into consideration the nature of the charges and employee’s assignment and record with the Company. In addition, the Company will consider any adverse effect the employee’s actions may have on its clients, other employees, the public, or the Company’s reputation and image.

    5. The Company does not intend to authorize indiscriminate searches of lockers, desks or personal effects on the Company’s property, but we do reserve the right to authorize searches for illegal drugs, alcohol, or contraband.

    6. Employees in jobs designated as “safety-sensitive” who are undergoing prescribed medical treatment with a controlled substance must report this fact to their supervisor. This information will be handled on a very confidential basis, but it is important for the Company to know treatment is occurring. A determination will be made if the employee’s assignment is temporarily affected; the employee’s job will not be jeopardized.

    The Company will encourage and reasonably accommodate employees with chemical dependencies (alcohol or drug) to seek treatment and/or rehabilitation. To this end, employees desiring such assistance should request a treatment or rehabilitation leave.

    The Company is not obligated, however, to continue to employ any person whose performance of essential job duties is impaired because of drug or alcohol use, nor is the Company obligated to re-employ any person who has participated in treatment and/or rehabilitation if that person’s job performance remains impaired as a result of dependency.  Employees who are allowed to continue to work for the Company following an incident of drug or alcohol abuse are required to bear the cost of their continued drug testing.  Additionally, employees who are given the opportunity to seek treatment and/or rehabilitation, but fail to successfully overcome their dependency or problem, will not automatically be given a second opportunity to seek treatment and/or rehabilitation.

    This policy on treatment and rehabilitation is not intended to affect the Company’s treatment of employees who violate the regulations described above. Rather, rehabilitation is an option for an employee who acknowledges a chemical dependency and voluntarily seeks treatment to end that dependency.

    To support the objective of a drug and alcohol free workplace, testing for chemical substances is required under the following circumstances:

    (1) Pre-employment drug testing as part of the employment process. Upon an offer of employment, a test will be required for all final candidates, and no applicant testing positive will be employed. This includes all employment and re-employment, whether for temporary, part-time or regular full-time positions.

    (2) After a work-related accident where judgement, coordination or physical or mental ability may have been impaired. Testing is required after a personal injury resulting in lost time or for an employee whose behavior raises a reasonable suspicion of drug or alcohol use. A test will also be required after a preventable vehicle accident as defined by the Company’s management.

    (3) Based on reasonable suspicion for conduct or appearances that suggest the use or abuse of controlled substances.

    (4) On an unannounced and random basis for employees in specific pre-designated safety-sensitive jobs. These are jobs where even a slight loss of judgement or motor skills could cause serious injury to employees, the public and the Company’s property. Examples of safety-sensitive jobs include such jobs as commercial drivers, heavy equipment operators, employees concerned with potentially explosive material or high voltage electrical systems, and machine operators controlling machines that affect the safety of other employees.

    Employees who are in safety-sensitive jobs will be notified of this designation, and the testing procedures required by this policy will be explained to them. Specific lists of safety-sensitive jobs will be developed and maintained by the Company’s management.

    The supervisor requesting the test shall escort the employee to the independent hospital, laboratory and/or clinic. (The hospital, laboratory and/or clinic will be mutually selected by the Employee and the Company.) At the time a specimen is collected, the employee shall be given a copy of the specimen collection procedures. The specimen must be immediately sealed, labeled and initialed by the employee to ensure that the specimen tested by the laboratory is that of the employee.

The required procedure is as follows:

    (1) Urine shall be in a wide-mouthed clinic specimen container which shall remain in full view of the employee until split, transferred to, sealed and initialed in two tamper-resistant urine bottles.

    (2) Immediately after the specimens are collected, the urine bottles shall, in the presence of the employee, be labeled and then initialed by the employee. If the sample must be collected at a site other than the drug and/or alcohol testing laboratory, the specimens shall then be placed in the transportation container. The container shall be sealed in the employee’s presence and the employee shall be asked to initial or sign the container. The container shall be sent to the designated testing laboratory on that day or the earliest business day by the fastest available method.

    (3) A chain of possession form shall be completed by the hospital, laboratory and/or clinic personnel during the specimen collection and attached to and mailed with the specimens.

    While we hope that the Company will never have to discuss alcohol abuse or drug problems with any employee, it is only fair that every employee understand the consequences of violating this policy. The illegal use, sale or possession of narcotics, drugs or controlled substances on the Company’s property or job sites will result in termination of employment. Working under the influence of illegal drugs or alcohol, as indicated by test results or other evidence, and violation of other provisions of this policy will result in administrative action, up to and including discharge – even for the first offense. In addition, refusal to participate in any part of the program can be considered an act of insubordination and may also lead to administrative action, up to and including discharge.