Topic 690 Page 1 of 8 ALCOHOL/SUBSTANCE ABUSE Reviewed 02/01/2012

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1 Page 1 of 8 Policy It is the policy of Southern Research to maintain a Drug Free Workplace and Drug Free Work Force in compliance with the Federal Government Drug-Free Workplace Act of This policy applies to those employees working in sensitive positions on grants and/or contracts (a) funded by the U.S. Department of Defense (DOD) and its branch agencies and (b) that contain the provisions of the DOD Drug-Free Workforce Rule of These persons are subject not only to the Drug-Free Workplace Act of 1988, but also to the more stringent regulations of the DOD Drug-Free Workforce Rule of 2005 as described in the DFARS at Section and its associated contract clause, Southern Research does not tolerate alcohol and/or substance abuse. Southern Research will establish and maintain an alcohol and substance abuse program that will include: An Employee Assistance Program (EAP). Testing, procedures (pre-employment, post-accident, random and reasonable cause). A Drug Free Workplace Awareness Program. Some of our employees may be subject to contract specific drug testing requirements. Those will be identified on a case-by-case basis. Specified disciplinary action. Southern Research is committed to the highest standards of safety, integrity, and professionalism in its work and for this reason does not condone the abuse of any substance by employees. The nature of our work mandates behavior that inspires the highest degree of confidence by clients and the public. The use of illegal drugs and abuse of other controlled substances or alcohol is inconsistent with law-abiding behavior and is a threat to the safety of others and the efficiency of our operations. Individuals who engage in any conduct prohibited in these guidelines shall be subject to disciplinary action up to and including termination. Responsibilities Each employee is responsible for conducting their own actions within the expectations of a drug free workplace environment. Any employee who refuses to take a drug test as outlined by this policy will be subject to the provisions of this policy as if they had taken the test and tested positive. The overall responsibility for this policy lies within the Safety Oversight Committee. The Vice President of HR and Administrative Services will be responsible for ensuring regulatory compliance for all issues related to this policy. Other outlined responsibilities: Environmental Health, Safety and Security (EHS&S)/Human Resources (HR) are responsible for the review and appropriate updating of this document. Environmental Health, Safety and Security (EHS&S) will maintain all records and will manage the quarterly Random Drug Testing program, Post-accident Drug Testing and coordinating any Reasonable Cause Drug Testing with Human Resources. Human Resources (HR) is responsible for the administration of the Pre-employment Drug Testing, Drug Free Workplace Awareness program, the Employee Assistance Program, and for conducting the training of supervisors on this policy in order for them to identify substance abuse and/or policy violations among their staff.

2 Page 2 of 8 Contracts Administration (CA) is responsible for notifying EHS&S of any changes that may be necessary as a result of specific sponsor contract requirements. CA is also responsible for notifying the Government Contracting Officer in writing within 10 days after receiving notice of an employee who violates the drug and alcohol policy. The notice shall include the position title of the employee. Supervisors are responsible for enforcing this policy and ensuring employees are immediately released from work to be tested when they have been randomly selected, and carrying out any disciplinary actions coordinated through Human Resources as a result of violation of this policy. The Safety Oversight Committee will have responsibility for approving any disciplinary actions under this policy. If an employee fails a drug test, discipline will be recommended by the employee s supervisor, manager and/or director, in consultation with Human Resources. In this manner, Human Resources will ensure consistent implementation throughout the organization. In all cases, disciplinary recommendations will then be routed through the Safety Oversight Committee which will have final approval. Human Resources will handle all issues related to an accelerated random testing schedule for employees who are under disciplinary status. Employee Assistance and Drug Free Workplace Awareness Programs All Southern Research Institute employees and their dependents are eligible to receive one initial assessment and up to two counseling sessions free of charge, but only when provided through EAP provider, Behavioral Health Systems (BHS). (Refer to materials included in the Benefits section on SRInsider.) An employee Drug Free Workplace awareness program will consist of periodic reminders concerning the requirements of this policy and educational materials as available. The requirements identified in this policy will be reviewed and signed by all employees while in the new-hire orientation process. Communication with existing employees will be done via and through information posted on SRInsider. All employees must notify their supervisor in writing of a felony conviction of a drug statute no later than 5 days after such conviction. For those employees who have security clearances, Southern Research Institute will notify the Government Security Officer within 10 days after receiving notice about an employee s conviction for a criminal drug statute; this notice will include the position and title of the employee. Security clearances will be flagged until closure is reached regarding a conviction. Prohibited Substances The use, possession, concealment, transportation, promotion or sale of the following items or substances is strictly prohibited on Southern Research premises: Illegal drugs, controlled substances (including trace amounts), and look-alike or designer drugs. Drug paraphernalia.

3 Page 3 of 8 Unauthorized prescription drugs. Employees found using, possessing, concealing, transporting, or promoting the sale of these items on Southern Research premises will be subject to discipline up to and including discharge. The use of alcoholic beverages is strictly prohibited during working hours (including lunch) by all employees. All employees must report to their supervisor if they are taking any medications that may impair their ability to do their job in a safe and competent manner. This is especially true for those employees who will be operating machinery, motorized equipment or working in any laboratory or shop area. Employees may not enter the A/BSL-3 if they are on any medications that may impair their judgment, coordination, or ability to work in a safe manner. Please contact EHS&S if there are any questions about which medications would fall into this category. All employees may be subject to alcohol testing if there is a reasonable suspicion the employee may be impaired. Definition of Terms "Alcohol" means the intoxicating agent in beverage alcohol, ethyl alcohol or other low molecular weight alcohol, including methyl or isopropyl alcohol. "Controlled substance" means a controlled substance in Schedules I through V of section 202 of the Controlled Substances Act (21 U.S.C. 812) and as further defined in regulation at 21 CFR "Conviction" means a finding of guilt (including a plea of nolo contendere) or imposition of sentence, or both, by any judicial body charged with the responsibility to determine violations of the Federal or State criminal drug statutes. "Criminal drug statute" means a Federal or non-federal criminal statute involving the manufacture, distribution, dispensing, possession, or use of any controlled substance. "Drug-free workplace" means the site(s) for the performance of work done by the employee. Employees working at these locations are prohibited from engaging in the unlawful manufacture,, distribution, dispensing, possession, or use of any controlled substance. These locations may include but not limited to all Southern Research properties and any other location where the employee may be assigned to perform work. "Employee" means an individual on the payroll of Southern Research, directly engaged in the performance of work. Employee in a sensitive position means an employee who has been granted access to the BSL-3 laboratory or who has access to classified information, or who is working on contracts where the client requires the employee to be in a random drug testing program. This may also include employees in positions that may be involved with national security, health and safety or other positions that require a high degree of trust and confidence. Types of Testing

4 Page 4 of 8 Post Offer Pre-placement Testing All individuals selected for employment with Southern Research shall satisfactorily complete a ten-panel urine drug test. Reasonable Cause Any individual suspected of being impaired by drugs or alcohol will be subject to drug and/or alcohol testing. Reasonable cause is a belief based on objective and articulable facts sufficient to lead a prudent person to suspect that an individual is using drugs, reporting to work while legally impaired (0.020 % blood alcohol), or using alcohol while on-the-job. Post-Accident Any individual involved in an on-the-job lost time accident will be subject to drug and/or alcohol testing. Some employees may be tested after any OSHA reportable accident if required as a result of contract requirements. These employees will be identified by EHS&S. The safety and well being of the employee will be addressed before any testing is conducted. Random Southern Research Institute will establish and maintain a random drug testing program. Employees who work in the following areas and positions will be automatically enrolled in the program: the CEO, the senior staff of the CEO, all EHS&S employees, all employees who work at the ERC facility, all employees who work at our Frederick facility, all employees who have select agent clearance, all employees who have access to controlled substances, all employees who are assigned master A keys and all employees who are assigned to work on projects requiring government clearances or who work at customer facilities which require a contractor safety and drug testing program for all of its contractors. A minimum of twenty five percent (25%) of these employees will be tested annually. Follow-Up - If an employee, during the course of employment, enters an Employee Assistance Program (EAP) for drug or alcohol related problems or an alcohol and drug rehabilitation program or the employee is removed from performing his or her job for violation of this policy, the employee may be required to submit to unannounced testing as a follow-up for a period of 12 months. In addition, employees of third-party staffing contractors will be required to satisfactorily complete a preplacement, ten panel urine drug screen through their employer before being assigned to perform work at the direction of Southern Research. Disciplinary Actions Employees will be subject to discipline, up to and including discharge, for: Use of alcohol on premises. The on-premises use, manufacture, distribution, sale, trade, or possession of illegal drugs. The on-premises abuse, distribution, or sale of prescription drugs. Being under the influence of any unauthorized controlled substance, illegal drug, or alcohol on any Southern Research premises during work hours. The on-premises storage (including in a locker, desk, vehicle, or other repository on Southern Research property) of any illegal drug, drug paraphernalia, any controlled substance (unless authorized), or any alcohol. The failure to report to management within five days any conviction (including guilty or nolo contendere plea) for a criminal drug offense. The conviction (including guilty or nolo contendere plea) of any criminal drug offense in the workplace. The failure or refusal to cooperate with any aspect of a drug treatment program. The failure or refusal to sign forms consenting to drug/alcohol testing or refusal to consent to or cooperate with any requested drug/alcohol test.

5 Page 5 of 8 The attempt to alter, falsify or interfere with a drug/alcohol test or; A confirmed positive test for alcohol or unauthorized drugs. Employees with substance abuse problems are encouraged to seek assistance before disciplinary action is required. Human Resources will provide information, in confidence, to employees who request it. Additionally, an employee seeking voluntary assistance, like any other employee, must comply with all policies, and may be disciplined or discharged for noncompliance with the terms of their EAP plan. Employees must understand that testing is not a necessary prerequisite to discipline or discharge if the supervisor otherwise determines that the policy has been violated. Testing Procedures Employment Candidates: Post Offer Pre-Placement This testing will be coordinated by the Human Resources department and will be completed under Southern Research agreement with a drug testing provider. Applicants who receive an initial positive urine test result will discuss the test with the Medical Review Officer (MRO). If the retest of the initial sample is positive, the individual is to be excluded from employment. An adverse action letter will be sent to the candidate by Human Resources stating that the result of the drug screen precludes employment at Southern Research.

6 Page 6 of 8 Active Employees: The following steps will apply for Random, Post Accident and Reasonable Suspicion testing: In the situation of reasonable suspicion, the supervisor will contact EHS&S and/or Human Resources. For post accident and random, EHS&S will contact the employee. EHS&S or HR will advise the employee as to why it is necessary to be tested. EHS&S will send the employee immediately to our occupational health physicians or to one of our drug testing provider facilities to provide a specimen. Southern Research will utilize an observed testing procedure. Any refusal for testing or tampering or adulteration of a specimen or leaving the testing facility without Southern Research approval will be considered the same as a positive drug test result. Employees who receive an initial positive result will discuss the test with the Medical Review Officer (MRO). Failure to provide a specimen in a two-hour time frame, without a plausible explanation, will be considered the same as a refusal. Reasonable Cause Should an immediate supervisor deem it necessary to request an employee be tested for Reasonable Cause, the supervisor will request EHS&S or HR to perform a drug test. Post Accident As a matter of policy, all accidents resulting in lost time will require a drug test. Additionally, if there is reasonable suspicion the employee is impaired and the accident did not result in lost time a drug test will be administered. Some employees may be tested after any OSHA reportable accident if required as a result of contract requirements. These employees will be identified by EHS&S. Random Employees enrolled in the random drug testing program will be selected by our Random Testing contractor on a periodic basis. At a minimum 25% of the employees enrolled in the program will be tested annually. On-site testing conducted by the drug testing provider will be the preferred location of testing. However, if the employee cannot be tested onsite they may be tested at any contract testing laboratory approved by EHS&S.

7 Page 7 of 8 Urine Testing Tolerance Level Southern Research will utilize a ten panel test. The cut-off levels for drugs tested are as follows: Analyte Initial Test Cutoff (ng/ml) Confirmation Cutoff (ng/ml) Amphetamine Barbiturates Benzodiazepines Cannabinoids Cocaine Opiates Phencyclidine Methadone Propoxyphene MDMA (Ecstasy) Alcohol Testing: % blood alcohol content is considered negative, and above is considered positive. The identified cut-off levels may be revised at the sole discretion of Southern Research. Searches Southern Research may conduct searches for illegal drugs or alcohol on Southern Research's premises when management, at its sole discretion, determines there is a reasonable suspicion to believe that illegal drugs or alcohol are present. Searches may include an employee's personal property, including, but not limited to, the employee's vehicle, clothing, lunch box, cooler, purse, parcels and similar items. Disciplinary Procedures for Positive Drug Test The following disciplinary procedures will apply: If the Blood Alcohol concentration is or above, the Southern Research employee will be required to enroll in the EAP and successfully complete all substance abuse program requirements. A second positive test at any time will result in disciplinary action up to and including termination of employment. If a positive response is found for any one of the ten drugs in the panel, the employee will be required to enroll in the EAP and successfully complete all substance abuse program requirements. A second positive test at any time will result in disciplinary action up to and including termination of employment. Some contracts require removal of employees who test positive for alcohol or drugs from working on these contracts until they successfully complete the EAP program requirements. All disciplinary actions will be controlled through the Safety Oversight Committee.

8 Page 8 of 8 Rights of Southern Research Southern Research shall have full rights to all test results. Southern Research shall have the exclusive right to waive the requirements for drug and alcohol testing in extenuating circumstances. Southern Research shall have the exclusive right at any time to require a change in the methodology of drug and/or alcohol testing utilized to stay current with industry testing standards and for such other purposes as Southern Research deems appropriate. Audits, both announced and unannounced, of Contractor s program may be performed by Southern Research. Southern Research shall have the right to revise and administer this and all policies and procedures at its sole discretion. Customer Notification This policy shall govern Southern Research employees at all Southern Research locations. Related Topic Employee Assistance Program External Hires Safety Positive Discipline Government Security