DRUG AND ALCOHOL ABUSE POLICY

GOAL
Employees have the basic right to work in an environment that is free of drugs and alcohol, and to rely on the fact that co-workers are not impaired by substance abuse. The hospital is committed to strictly enforce its drug and alcohol abuse policy and to comply with the requirements of the Drug-Free Workplace Act of 1988.

POLICY
Cottage Health System (CHS) is committed to maintaining the health and safety of its employees and patients, and will not tolerate any drug or alcohol use, which endangers the health and well being of its employees or patients. To this end, CHS employees and supervisors will be educated on:

1. CHS's Drug and Alcohol Abuse Policy
2. The dangers of abusing drugs or alcohol in the workplace
3. The medical treatment available for persons seeking treatment and counseling
4. The action CHS will take when employees violate the alcohol and Drug Abuse Policy.
   

Policy Violations
CHS specifically prohibits the following and will discipline an employee, up to and including discharge, for any of the following:

1. Use, possession, manufacture, distribution, or sale of illegal drugs, unauthorized controlled substances, or alcohol on hospital premises or during working hours.
2. Storing in a locker, desk, automobile or other repository on CHS premises any illegal drug, drug paraphernalia, any controlled substance that is unauthorized, or any alcohol.
3. Being under the influence of an unauthorized controlled substance, illegal drug or alcohol on CHS premises or during working hours. The term “being under the influence” of alcohol is defined as a blood alcohol level of 0.04. The definition of “being under the influence” of unauthorized controlled substances or illegal drugs is testing positiveat a specific mg/dl level.
4. Refusing to consent to testing or to submit a breath, urine or blood sample for testing when requested by management.
5. Refusing to sign a statement to comply with CHS's drug and alcohol abuse policy.
   

PROCEDURE

I. Training
CHS is committed to early identification and referral for professional medical treatment of substance abuse. However, its commitment to employee assistance does not waive CHS's right to impose appropriate disciplinary measures if CHS policies have been violated, particularly when the employee does not first come forward voluntarily with his/her substance abuse problem.

Management/Supervisors are to:

• Identify signs of on-the-job use or impairment by drugs or alcohol;
• Identify and report violations of this policy;
• In partnership with Human Resources, determine the need for testing employees who are suspected of drug or alcohol impairment on the job;
• Encourage referrals to the Employee Assistance Program.

II. Authorized Use of Prescribed Medicine
When employees are taking a medically prescribed drug that can alter behavior, physical ability or mental function in such a way that the employee's ability to safely perform his or her job may be impacted, the employee must report the use of this drug to their manager who will review with Employee Health and Safety Department to determine whether temporary job reassignment/ medical leave is warranted until the treatment is finished. Employees must keep all prescribed medications in the original container, which identifies the drug, dosage, date of prescription and prescribing physician.

III. Arrest or Conviction Under Criminal Drug Statute
Employees must notify the Director of Human Resources in writing within five days of any conviction of a criminal drug statute. This requirement is set forth to comply with the federal Drug-Free Workplace Act.

IV. Condition of Employment
Compliance with the CHS's Drug and Alcohol Abuse policy is a condition of employment. Employees who violate any aspect of the policy are subject to disciplinary action, up to and including termination. Employees who voluntarily come forward before any disciplinary action or investigation occurs and request a Leave of Absence in order to participate in a substance abuse treatment program will be reasonably accommodated. Upon successful completion of the program, employees will be reinstated to their former or similar position whenever possible. Upon reinstatement, the employee will be required to consent to random testing for a minimum period of twelve months, or as otherwise stipulated in the rehabilitation program's aftercare instructions.

CHS will notify the appropriate licensing board in those cases where there is evidence of impairment, substance abuse, or drug diversion.

V. Drug Screening
If an employee is required to participate in a drug test, the procedure will be as follows:

1. The employee will be asked to list all drugs consumed during the past 30 days, and will have the opportunity to explain the use of each one.
2. The employee will complete consent for alcohol or drug testing. Unwillingness to consent is a violation of this policy and may be treated as a presumption of impairment.
3. Test results will be returned to the Employee Health and Safety Department for review with the employee, and a copy of the test results will be placed in the employee's health file. All positive results will be verified by a second test.
4. If an employee tests positive on the verification test, he/she will be disciplined, up to and including termination. The termination of an employee or use of the Employee Assistance program will be a decision of management in consultation with Human Resources, depending upon the circumstances in the judgment of management.

VI. Procedure to be Followed for Reasonable Suspicion Testing
1. CHS maintains the right at all times to evaluate the need for and conduct testing for drugs, alcohol or controlled substances.

2. If an employee “appears” to be under the influence of alcohol, drugs, including controlled substances and prescriptions, or both, the supervisor/manager notifies the Human Resources Consultant, or Director of Human Resources to assist in the behavioral/situation analysis. If the incident occurs outside of normal business hours, the supervisor/manager notifies Human Resources the following business day to insure timely finalization of investigation and appropriate progressive discipline.

3. The supervisor/manager conducts a behavioral/situation analysis in a private office to determine if the employee is impaired. Human Resources or another supervisor/manager must be present in this process. The forms (Word documents) to be used are:

• Observation Check Sheet
• Questions for Suspected alcohol or Substance users
• Opinion Based Upon Observations

4. If the behavioral/situation analysis results in a strong opinion that the employee is impaired, the manager/supervisor places the employee on investigatory suspension.

If the behavioral/situation analysis results in an opinion that it is questionable whether or not the employee is impaired, the supervisor contacts Employee Health and Safety to coordinate the drug screening. If this occurs outside of normal business hours, the manager/supervisor pages Employee Health and Safety to request a “For Cause Drug Screening”. The attached form is completed and Human Resources is notified immediately on the next business day to conduct appropriate follow up. The manager/supervisor places the employee on investigatory suspension.

If there is insufficient basis to find “reasonable suspicion” that the employee is under the influence of alcohol or drugs, including controlled substances and prescription drugs, and he/she is able to perform his/her work duties, the employee is allowed to return to his/ her work.

5. The Employee Assistance Program (EAP) is available to provide education, counseling and referral for substance abuse and other personal problems. Human Resources coordinates with EAP as appropriate pending outcome of testing and performance management plan.