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Interurban Transit Partnership (ITP) Drug-Free Workplace (DFWP) Policy Effective Date: April 1, 2008 Revised: January 17, 2016 Substance Abuse Program Administrators Big Responsibility…Smart Choice! 3625 Clyde Park SW Suite B Grand Rapids MI 49509

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Interurban Transit Partnership (ITP)

Drug-Free Workplace (DFWP) Policy

Effective Date: April 1, 2008 Revised: January 17, 2016

Substance Abuse Program Administrators Big Responsibility…Smart Choice! 3625 Clyde Park SW Suite B Grand Rapids MI 49509

Section 1

Company Policy

Section 2

Supervisor Information

Section 3

Forms

Section 4

Records & Reports

Section 5

Regulations

This page intentionally blank.

Section 1

Company Policy

Page 2 Contact Persons

Page 3-4 Company Policy: A. Introduction and General Requirements A-1 Employee Copy of Company Policy A-2 Notice to Employee Representatives A-3 Access to Substance Abuse Records

Page 4 B. Information and Materials Provided B-1 EAP Manager B-2 Covered Employees Subject to this Policy B-3 Required Compliance Periods

Page 4-6 B-4 Prohibited Conduct

Page 6-9 B-5 Tests Required: a. pre-employment/pre-duty b. post-accident c. random d. reasonable suspicion e. return-to-duty f. follow-up

Page 9-10 B-6 Testing Procedures: a. specimen collection and chain of custody b. initial and confirmation testing c. medical review of lab results d. reporting and recordkeeping

Page 11 B-7 Requirement to submit to testing B-8 Refusal to submit to testing B-9 Consequences of violating this policy B-10 An alcohol concentration of 0.02 - 0.04

Page 12 B-11 Effects of alcohol and controlled substances C Unenforceable provisions D Certificate of Receipt requirement

Appendix Page 13-15 A Definitions 16-21 B Effects and Consequences of Alcohol/Drugs 22 C Certificate of Receipt 23 D Request for Safety Determination

© 1998 Drug Screens Plus All Rights Reserved. 6 Ver DFWP 981204 for: ITP

Contact Persons Effective: October 2015

REGARDING: Contact: Nancy Groendal Drug/Alcohol Policy/Procedures

Substance Abuse Program Manager The SAPM is also the EAP (Employee Assistance Program) manager unless another person has been listed below

as the EAP manager.

Human Resources Manager Interurban Transit Partnership 300 Ellsworth SW Grand Rapids MI 49503 (616)-456-7514

Specimen Collection Site for Drug and

Breath Alcohol Testing. Other site listings available.

DRUG SCREENS PLUS 3625 Clyde Park SW Grand Rapids MI 49509 (616) 532-9034

Medical Review of Test Results

John Budnick, D.O., MRO DRUG SCREENS PLUS 3625 Clyde Park SW, Suite B Grand Rapids MI 49509 (616) 532-9299 ext 25 (800) 459-9012 ext 25

Substance Abuse Evaluation Substance Abuse Professional (SAP)

Appointments must be made by a Company official. This office can

coordinate SAP evaluations throughout the U.S..

Employee Assistance Center 1400 Leonard NE Grand Rapids, MI 49505 (616) 464-2944 EAC will make referral to appropriate SAP

Counseling/Treatment (Must be an entity other

than the above SAP)

Employee Assistance Center 1400 Leonard NE Grand Rapids, MI 49505 (616) 464-2944

DHHS Certified Laboratory

MedTox Laboratories Inc 354 West County Road D Saint Paul MN 55112 and/or Quest Toxicology Network (QTN) Quest Diagnostics 506 East State Parkway Schaumburg IL 60173

Crisis Hotlines: Alcoholics Anonymous

Cocaine Natl Institute on Drug Abuse

800-356-9996 800-COCAINE (262-2463) 800-662-HELP (622-2255)

© 1998 Drug Screens Plus All Rights Reserved. 7 Ver DFWP 981204 for: ITP

INTERURBAN TRANSIT PARTNERSHIP (The Company, or ITP) DRUG-FREE WORKPLACE POLICY

DFWA 5152 (a)(1)(B)(ii)

A INTRODUCTION AND GENERAL REQUIREMENTS It is ITP's policy to provide a work environment which is free (to the maximum extent possible) of the effects of substance abuse including both drugs and alcohol. ITP participates in the Drug Screens Plus (DS ) Drug-Free Workplace Program (The Program) and may, as a condition of employment, require your authorization to obtain information regarding your abuse of a controlled substance (or misuse of alcohol) or your refusal to submit to testing from one or more previous employers; and may release such information to other entities in accordance with the provisions in A-3 below. Margin notes refer to the Drug Free Workplace Act and are intended only to facilitate reference to that act by an appropriate contracting agency which may be required to review this policy with regard to ITP's receipt of a contract or grant covered by the Act. See Appendix A (Definitions) for DEFINITIONS of italicized terms used in this policy.

DFWA 5152 (a)(1)(C)

A-1 EMPLOYEE COPY OF COMPANY POLICY All Company employees and applicants for positions with ITP will be provided with a copy of this policy (i.e., Section 1 of the Program Manual) prior to being required to submit to its provisions.

A-2 NOTICE TO REPRESENTATIVES OF EMPLOYEE ORGANIZATIONS A copy of this policy and other related material will be provided to representatives of employee organizations (recognized by ITP) prior to implementation of this policy (and thereafter, upon request).

A-3 ACCESS TO SUBSTANCE ABUSE RECORDS a. Inquiries for substance abuse information regarding previous tests. ITP may, pursuant to written authorization from an employee or applicant, inquire about the following information regarding his/her previous tests or refusals to test for alcohol or controlled substances: i. Alcohol tests with a result equivalent to a Breath Alcohol Concentration (BAC) of 0.04 alcohol concentration or greater; ii. Verified positive controlled substances test results; and iii. Refusals to submit to testing. OR, iv. The results (including positive; negative; refusal/inability to provide, or suspect specimen; or canceled test) of any request for testing.

b. Release of substance abuse information upon request by the tested individual. Upon receipt by ITP or by a DS MRO Assistant of a written authorization signed by the tested individual (a form for this purpose is included in Section #3), ITP or the DS MRO Assistant will forward substance abuse information about that individual to him/her or to another person named on the authorization form. The request must include:

© 1998 Drug Screens Plus All Rights Reserved. 8 Ver DFWP 981204 for: ITP

i. The name and complete address of a specific individual who is authorized to receive the information. ii. The earliest date for which information is requested. This date must be no less than 90 days and no more that 2 years from the date of the request for information. iii. The type of information requested. Must be equivalent to either A-3(a)(i-iii) or A-3(a)(iv) above.

Information regarding a request limited to negative test results only will not be released if (during the time period for which information has been requested) the record also contains information about one or more positive test(s), refusal or inability to provide specimen(s), suspect specimen(s), or canceled test(s). The appropriate response to such a request is: "This request for information does not meet the requirements of the DS Drug Free Workplace Program."

B INFORMATION AND MATERIALS PROVIDED: DFWA 5152 (a)(1)(B)(iii)

B-1 EMPLOYEE ASSISTANCE PROGRAM (EAP) MANAGER See: Page 2 (Contacts) Substance Abuse Program Manager (SAPM)

B-2 COVERED EMPLOYEES SUBJECT TO THIS POLICY DFWA 5152 (a)(1)

The term Covered Employee includes full time and part-time employees who are either directly employed by or under lease to ITP or to its contractors or their sub-contractors at all tiers, including non-bargaining and bargaining unit employees. All employees are Covered Employees unless the individual has been notified in accordance with a written Company policy that he or she is not a covered employee. Notwithstanding the potential exemption cited above; if ITP is the recipient of a contract for the procurement of any property or services of a value of $25,000 or more from any Federal agency (or the recipient of a Federal grant); then, for the purposes of this policy, all employees are Covered Employees.

B-3 COMPLIANCE REQUIRED Covered employees are required to be in compliance with this policy at all times while on Company premises or Company time, and during any period in which they are performing or available to perform duties on behalf of ITP regardless of their location or duty status.

Equipment, lockers and/or personal belongings may be randomly inspected for drugs or alcohol and related paraphernalia and all other controlled or illegal items, and covered employees shall have no expectation of privacy concerning their use of such equipment, lockers or personal belongings while on Company premises or Company time.

DFWA 5152 (a)(1)(D) DFWA 5152 (a)(1)(E)

As a condition of employment, covered employees are required to abide by all terms and provisions of this policy and are required to notify ITP of any criminal drug statute conviction for a violation occurring in the workplace no later than 5 days after such conviction. If ITP is the recipient of a contract for the procurement of any property or services of a value of $25,000, within 10 days of receiving any such notice (or otherwise receiving actual notice of such conviction) ITP is required to notify the contracting agency.

© 1998 Drug Screens Plus All Rights Reserved. 9 Ver DFWP 981204 for: ITP

In addition, covered employees may not use alcohol within the 4-hour period prior to reporting for duty, nor within 8-hours following an accident (unless a post-accident alcohol test has been completed), and are subject to drug testing for 32 hours following an accident.

Other time periods or circumstances in which covered employees may be tested are explained below in section B-5 TESTS REQUIRED.

B-4 PROHIBITED CONDUCT DFWA 5152 (a)(1)(A) (a)(1)(B)(iv)

General. The unlawful manufacture, distribution, dispensation, possession, or use of a controlled substance is prohibited in the workplace. Any violation of this prohibition will subject the Covered Employee to disciplinary action up to and including discharge.

DFWA 5152 (a)(1)(B)(iv)

Refusal to take a required drug or alcohol test, or failure of such test(s) shall result in removal from performing duties and shall, as with any other prohibited conduct, subject the individual to disciplinary action up to and including discharge.

Use of Hemp Products. Hemp products may contain substances which can result in a positive test for THC (whether or not such ingredients are listed on the product label). The consumption of such products is prohibited. The use of products containing Hemp for any reason (including "medical", "nutritional", "cosmetic" or "clothing") will not be considered a legitimate explanation for a positive drug test.

a. Alcohol. (i.) Alcohol Concentration. Employees are prohibited from reporting

for duty or remaining on duty requiring the performance of duties while having an alcohol concentration equivalent to a BAC of 0.04 or greater. If a company representative has actual knowledge that an employee has an alcohol concentration of 0.04 or greater, the individual shall not be permitted to perform or continue to perform Company. [See B-10: Alcohol greater than 0.02 but less than 0.04.]

(ii) On-Duty Use. Employees are prohibited from using alcohol while performing Company duties or while on-duty. If a company representative has actual knowledge that an employee is using alcohol while performing Company duties, the individual shall not be permitted to perform or continue to perform Company duties.

(iii) Pre-Duty Use. Employees are prohibited from using alcohol within 4 hours prior to performing Company duties, or, if an individual is called to duty at any time, within the time period after the individual has been notified to report for duty. If ITP has actual knowledge of such use, the individual shall not be permitted to perform Company duties and is subject to disciplinary action up to and including discharge.

(iv) Use Following an Accident. Employees subject to post-accident alcohol testing are prohibited from using alcohol for eight hours following an accident, or until s/he undergoes a post-accident alcohol test, whichever occurs first.

(v) Being in possession of alcohol (including medications containing alcohol).

© 1998 Drug Screens Plus All Rights Reserved. 10 Ver DFWP 981204 for: ITP

b. Controlled Substance(s). (i) No employee (or other covered individual) shall report for duty or

remain on duty requiring the performance of Company functions when that person uses (or has in his/her possession) any controlled substance, except when the use is pursuant to the instructions of a

physician, who has informed ITP in writing that the substance will not adversely affect his/her ability to perform any functions s/he may be required to perform in the course of his/her duties. The term "uses" includes (but is not limited to) the meaning "having a detectable level in his/her urine."

Use of another person's (including family members) prescription is prohibited. Should such use result in a positive test result, the MRO shall report that test result to ITP as a "verified positive".

Prescription or other use of Marijuana or THC will not be accepted as an explanation for a positive test and is prohibited. The only allowable explanation for the presence of THC is notification of a valid prescription for Marinol (for a DEA-approved use) provided to ITP in writing prior to use.

(ii) ITP, when it has actual knowledge that an employee has used a controlled substance shall not permit the employee to perform or continue to perform a Company function, except when the use is pursuant to the instructions of a physician, who has informed ITP as required above.

(iii) No employee shall report for duty, remain on duty or perform a Company function, if the employee tests positive for controlled substances. ITP, when it has actual knowledge that an employee has tested positive for controlled substances, shall not permit the employee to perform or continue to perform Company functions.

DFWA 5152 (a)(1)(B)(iv)

c. Refusal to Submit to Testing. No employee shall refuse to submit to any drug or alcohol test required by ITP. ITP shall not permit an employee who refuses to submit to such tests to perform or continue to perform Company functions. Refusal to submit to testing will result in disciplinary action up to and including discharge. (See also: B-7, B-8)

DFWA 5152 (a)(1)(B)(iv)

d. Use of Adulterants, Dilutants, or Masking Agents. The use of any substance for the purpose of adulterating or diluting a specimen or for the purpose of masking the presence of any drug or drug metabolite in a specimen intended for drug testing is strictly prohibited. Specimen dilution, adulteration, or the use of masking agents (including but not limited to a determination by a specimen collector, laboratory or Medical Review Officer) will be considered a "Refusal to test" and will result in disciplinary action up to and including discharge.

e. Other Prohibited Conduct (i) Soliciting to buy or sell a controlled substance, whether or not there is an actual exchange of drugs and/or money. (ii) Failing to stay in contact with ITP or its Medical Review Officer while awaiting the results of a drug test. (iii) Violating any applicable federal and/or state requirement governing the use of alcohol or drugs.

© 1998 Drug Screens Plus All Rights Reserved. 11 Ver DFWP 981204 for: ITP

B-5 TESTS REQUIRED GENERAL. Covered employees are subject to testing for alcohol and controlled substances (including all substances listed on Schedules I through V of 21 CFR 1308 as they may be revised from time to time) including, but not limited to, urinalysis, blood, breath, saliva, or hair tests. At a minimum, covered employees will be tested for the following drugs and/or their metabolites: Marijuana, Cocaine, Opiates, Phencyclidine, and Amphetamines.

Alcohol testing will utilize breath specimens analyzed by an evidential breath testing device (EBT) except when, at the sole discretion of ITP, testing by other means (e.g., a Screening Test Device [STD]) may be more appropriate to the circumstances. Drug testing will utilize urine specimens except when, at the sole discretion of ITP, testing by other means (e.g., testing of hair specimens) may be more appropriate to the circumstances.

ITP will conduct drug and/or alcohol tests under the following conditions or times: pre-employment/pre-duty; reasonable suspicion; post-accident; random, return-to-duty; and, follow-up. ITP's policies, procedures, and requirements for each of these tests are as follows:

a. pre-employment/pre-duty: Required before a covered employee can be hired or transferred into a position which includes Company functions. Prior to testing, applicants will be provided notification of the required tests, and instructions to follow. Applicants may be required to

i. Execute a consent and release form for drug testing. ii. Pass a drug test. A positive test result or a refusal to test may disqualify the applicant from further consideration for the position. iii. Execute authorization for ITP to obtain all of the applicant's test results (including refusals to be tested) from each company for whom the applicant either worked, or took or refused to take a drug or alcohol test within the previous two years. At a minimum, any applicant who has had a positive test result or a refusal to test within the previous two years will be required (prior to any further consideration) to provide evidence of or undergo an evaluation by a substance abuse professional (SAP) and of their compliance with all recommendations or requirements of the SAP. In addition, such applicants will be subject to follow-up testing for alcohol and/or drugs for a period of up to 5 years following the most recent positive test result or refusal to test.

iv. Comply with any other conditions or requirements of which the applicant is advised in connection with the offer to hire or transfer.

b. post-accident: Required as soon as possible after the occurrence of any accident. Covered employees must always submit to post-accident drug and alcohol testing as soon as possible after an accident. They must (1) contact their immediate supervisor or other Company official as soon as possible following the accident and (2) remain readily available for testing. Failure

© 1998 Drug Screens Plus All Rights Reserved. 12 Ver DFWP 981204 for: ITP

to do so will be considered refusal to submit to testing unless the delay results from a need to arrange medical attention or to obtain assistance in responding to the accident (or other equaling compelling reason as may be determined by ITP with the advice of its MRO).

Covered employees who (in connection with an accident) submit to drug or alcohol testing at the direction of a law enforcement officer must contact their supervisor (or other Company official) immediately and provide ITP with the name, employing authority (e.g., MI State Police, Kent County Sheriff, etc.) badge number and telephone number of the officer who conducted the testing.

Covered employees who are required to submit to post-accident drug or alcohol testing may, at ITP's discretion, be assigned to other Company duties (see definitions), or placed on non-disciplinary suspension with pay, while awaiting the post-accident test results.

DFWA 5152 (a)(1)(B)(iv)

Covered employees who test positive for drugs or alcohol, refuse or fail to submit to post-accident drug and alcohol testing as required, or otherwise fail to comply with ITP's post-accident testing procedures, will be subject to disciplinary action up to and including a change of their disciplinary status from non-disciplinary suspension with pay to disciplinary suspension without pay and discharge from ITP.

c. random: ITP will test covered employees at random and without prior notice. Covered employees are subject to random selection and testing at any and all times throughout the year. Each covered employee will be subject to random selection during each selection period and, therefore, may be selected more than one time per year. Selections are made on a mathematically random basis by DS (an independent Substance Abuse Program Administrator) to ensure that employees cannot be singled out by name or by any other means. Upon notification, covered employees selected for random testing must report immediately to the specimen collection site.

Refusal to submit to any required drug or alcohol test shall be considered equivalent to a positive test result. A covered employee who fails or refuses to submit to random testing immediately following

DFWA 5152 (a)(1)(B)(iv)

notification (or, who tests positive) is unqualified to perform (or continue to perform) any Company function for ITP, and is subject to disciplinary action up to and including discharge.

d. reasonable suspicion: For the purpose of requiring drug or alcohol testing, reasonable suspicion will exist when a covered employee's appearance, behavior, speech, breath or body odors indicate drug or alcohol use, or chronic or withdrawal effects of drugs.

Such observations must be personally observed and documented by at least one Company official who has received training covering the physical, behavioral, speech, and performance indicators of probable drug and/or [depending on the test(s) that are being required] alcohol use. 3rd party observations indicative of substance abuse must be confirmed by a supervisor with the appropriate (drug and/or alcohol) training. Unless

© 1998 Drug Screens Plus All Rights Reserved. 13 Ver DFWP 981204 for: ITP

it is impracticable for any other individual to perform this function, the supervisor who initiates reasonable suspicion alcohol testing may not perform the alcohol specimen collection or testing.

If the covered employee who requires reasonable suspicion testing does not require immediate medical attention, the employee will be transported by an agent of ITP to the specimen collection site and be tested as directed (alcohol and/or drugs) as soon as possible. ITP will attempt to contact a person designated by the employee, or will make arrangements for other suitable transportation in order to transport the employee to his/her home following reasonable-suspicion testing.

Covered employees required to take reasonable suspicion tests are considered unqualified to work and placed on immediate suspension, without pay, pending the results of their test(s). If the test results are negative and if the tested employee has fully cooperated with the testing, reimbursement will be made for the time of the suspension.

If the test results are negative, and the factors which resulted in the determination of reasonable suspicion of impairment continue to be observed, ITP may require medical or other examinations in order to determine the cause of those factors.

DFWA 5152 (a)(1)(B)(iv)

A positive test result for either drugs or alcohol, a refusal of trans-portation or any other failure to cooperate when requested to provide specimens for reasonable-suspicion testing will be grounds for disciplinary action, up to and including discharge.

e. return-to-duty Prior to a return to duty in any position with ITP, every covered employee who has violated this policy (except an alcohol concentration of 0.02 or greater but less than 0.04) shall be required to undergo and pass a return-to-duty test for alcohol and/or controlled substances as required by ITP and is subject to follow-up testing for a period of up to 5 years from the date of violation. See also: B-9 CONSEQUENCES OF VIOLATING THIS POLICY

f. follow-up Following a positive test result, a refusal to test or a determination by a substance abuse professional (SAP) that a covered employee is in need of assistance in resolving problems associated with alcohol misuse and/or use of controlled substances, the employee is subject to a minimum of 6 unannounced follow-up tests over the 12 months following return-to-duty and subject to additional follow-up testing for a period of up to 5 years from the date of violation.

B-6 TESTING PROCEDURES GENERAL. To protect covered employees and the integrity of testing processes and to ensure the validity of the test results, ITP has adopted policies, standards, and procedures covering: specimen collection processes and the chain-of-custody; initial and confirmation tests; review of test results by a Medical Review Officer (MR0); and, reporting and recordkeeping.

© 1998 Drug Screens Plus All Rights Reserved. 14 Ver DFWP 981204 for: ITP

a. specimen collection and chain-of-custody General: For both alcohol and drug testing, custody and control (chain-of-custody) forms will be utilized. Specimen donors will receive a copy of the custody and control form(s) at the time specimens are provided. The collection site person is responsible for maintaining the integrity of the specimen collection and transfer process, ensuring the modesty and privacy of the specimen donor, and avoiding any conduct or remarks that might be construed as accusatorial or otherwise offensive or inappropriate. Unless it is impracticable for any other individual to perform this function, a direct supervisor of a covered employee shall not serve as the collection site person.

Alcohol: The specimen shall be collected by a breath alcohol technician (BAT) or Screening Test Technician (STT) trained to proficiency in the operation of the evidential breath testing device (EBT) or screening test device (STD) on the Conforming Products List (CPL) approved by the NHTSA used for the test.

Drugs: The collection site person shall have successfully completed training for single specimen and split specimen collection procedures to carry out this function, or shall be a licensed medical professional or technician who is provided instruction and certifies completion of the collection process utilizing the method specified by ITP.

b. initial and confirmation testing Alcohol: Initial alcohol testing may use either an EBT device or STD. An initial alcohol test with result of 0.02 or greater will be followed by a confirmation test that provides quantitative data of alcohol concentration. Confirmation tests for alcohol will utilize an EBT device whenever possible.

When an EBT is not available within 20 minutes of the initial test, confirmation by two tests utilizing STDs will be considered as equivalent to confirmation by an EBT.

Drugs: Initial testing will utilize an immunoassay screen to eliminate "negative" urine specimens from further consideration. Specimens will also be screened for adulterants, dilutants and masking agents. An initial lab positive result will be followed by gas chromatography/mass spectrometry (GC/MS) to ensure reliability and accuracy of the lab result prior to review by the MRO.

c. medical review of lab results ITP's Medical Review Officer (MRO) will review all drug test results which have been confirmed positive by the lab. Prior to reporting such results to ITP, the covered employee has an opportunity to discuss the lab results with the MRO and to present any alternate explanations for any positive test result. If the employee fails to utilize that opportunity, the MRO will report the test as positive. The MRO has established procedures to review any appeal to such determinations.

Controlled substances for which the employee does not have a current valid prescription (and medications containing alcohol) will not be considered lawfully used when taken by a covered employee and subsequently detected by a test conducted under this policy.

© 1998 Drug Screens Plus All Rights Reserved. 15 Ver DFWP 981204 for: ITP

DFWA 5152 (a)(1)(B)(iv)

Once notified of a drug test required by ITP, employees must remain available for contact by the MRO and/or ITP on a daily basis. Failure to do so shall be cause for disciplinary action up to and including discharge.

Prescription or other use of Marijuana or THC will NOT be accepted as an explanation for a positive test. The use of products containing any form of Hemp or Marijuana will not be considered a legitimate explanation for a positive drug test. The only allowable explanation for the presence of THC is notification of a valid prescription for Marinol (for a DEA-approved use). The presence (as determined by the MRO) of adulterants, dilutants or masking agents in any specimen will be reported to ITP and will be considered a "Refusal to Test".

The covered employee is required to pay for any retest requested by him/her and must make arrangements with (and satisfactory to) ITP within the earlier of 72 hours of first being notified by ITP of a verified positive, or 14 days from the date of specimen collection. The split specimen (if a split specimen was collected) or an aliquot of the original specimen (if a single specimen was collected), will be sent from the testing laboratory to a second DHHS-certified laboratory.

d. reporting and recordkeeping The results of all alcohol and controlled substances tests will be considered confidential and will be maintained in a secure location with controlled access. Covered employees are entitled, upon written notice, to obtain copies of test results pertaining to their use of alcohol or controlled substances.

ITP may provide information about test results (and any refusal to submit to testing) to third parties upon written authorization by the person tested. The covered employee may be required (by a subsequent employer) to provide such authorization as a condition of employment.

B-7 REQUIREMENT TO SUBMIT TO TESTING Covered employees are required to submit to all drug and/or alcohol testing required by ITP pursuant to this policy.

DFWA 5152 (a)(1)(B)(iv)

B-8 REFUSAL TO SUBMIT TO TESTING Refusal to submit to testing will be considered equivalent to a positive test result and will be cause for discipline up to and including discharge.

Refusal to submit to testing includes the failure (without a valid medical explanation) to provide adequate (e.g., breath or urine) specimens for alcohol or drug testing after receiving notice of the requirement for testing, or engaging in conduct (including failure to cooperate) that clearly obstructs the testing process. Substitution or adulteration of a urine specimen are other examples of a refusal to submit a specimen.

DFWA 5152 (a)(1)(B)(iv) (a)(1)(F) DFWA 5154

B-9 CONSEQUENCES OF VIOLATING THIS POLICY A covered employee who violates any provision of this policy is subject to disciplinary action up to and including discharge. ITP is not obligated, and by the inclusion of this provision in this policy does not undertake or commit to any obligation under this policy, to reinstate, retain, or rehire any individual who violates any Company

© 1998 Drug Screens Plus All Rights Reserved. 16 Ver DFWP 981204 for: ITP

DFWA 5152 (a)(1)(B)(iii)

prohibition, provision, or requirement concerning drugs and/or alcohol. At a minimum, such employees are immediately suspended (without pay) from any position with ITP, and (unless the violation is limited to an alcohol concentration of 0.02 or greater but less than 0.04) at their own expense, such employees:

DFWA 5152 (a)(1)(F) DFWA 5154

a. must be evaluated by a substance abuse professional (SAP) (as defined in 49 CFR Part 40) who will determine what assistance (if any) the employee needs in resolving problems associated with alcohol misuse and controlled substances use, b. must comply with all recommendations or requirements of the SAP, c. must pass return-to-duty testing for alcohol and/or controlled substances, and d. are subject to unannounced follow-up testing for alcohol and/or drugs for a period of up to 5 years following return-to-duty.

An applicant who violates any provision of this policy will be considered ineligible for hire or transfer to a position with ITP until they s/he has satisfied requirements "a" and "b" above.

DFWA 5152 (a)(1)(B)(iv)

B-10 AN ALCOHOL CONCENTRATION OF 0.02 - 0.04 If the violation is limited to an alcohol concentration of 0.02 or greater but less than 0.04, the employee or applicant will not be permitted to perform any safety sensitive function for ITP until (1) testing below 0.02, or (2) until the start of the covered employee's next regular shift, but not less than 24 hours. No other disciplinary action will be taken solely on such test results.

DFWA 5152 (a)(1)(B)(i) DFWA 5152 (a)(1)(B)(iii)

B-11 EFFECTS OF ALCOHOL AND CONTROLLED SUBSTANCE USE The effects of alcohol and controlled substances use on health, work, and personal life are well known. See Appendix B1-B6 for a summary of drug and alcohol effects and consequences. Additional information is readily available from your public library and from the Crisis Hotlines listed on page 2 (Contact Persons) of this policy. Upon request, ITP's SAPM will provide additional information about employee assistance resources available to the employee or his/her dependents.

C UNENFORCEABLE PROVISIONS: At the time this policy was developed, each aspect of the policy was thought to be not prohibited by applicable statutes. However, different interpretations may occur and some provisions may be determined to be unenforceable. It is ITP's policy to provide a work environment which is free (to the maximum extent possible) of the effects of substance abuse. Therefore, any provisions of this policy which are not specifically prohibited by State or Federal statute shall be enforced.

DFWA 5152 (a)(1)(B)(iv)

D CERTIFICATE OF RECEIPT: Each covered employee is required to sign a certificate of receipt certifying that he or she has received a copy of the materials described in this section. Do not sign for materials, informa-tion, or training which you have not received. Failure or refusal to sign the certificate of receipt is grounds for disciplinary action up to and including discharge. You are entitled to receive a signed copy of the certificate.

© 1998 Drug Screens Plus All Rights Reserved. 17 Ver DFWP 981204 for: ITP

Company Policy Appendix - A Definitions:

accident

An incident involving loss of human life; or medical treatment away from scene, or property damage requiring repair or replacement and a recordable safety infraction.

alcohol

The intoxicating agent in beverage alcohol, ethyl alcohol or other low molecular weight alcohol including methyl or isopropyl alcohol.

alcohol concentration

The alcohol in a volume of breath expressed in terms of grams of alcohol per 210 liters of breath as indicated by a breath test.

alcohol test

An analytic procedure to determine whether an individual has (confirmation test) or may have (screening test) a prohibited concentration of alcohol in a body specimen.

alcohol use

The consumption of any beverage, mixture or preparation, including any medication, containing alcohol.

applicants

Individuals hired or transferred into positions which include Company functions.

collection site

A place designated by the employer where individuals present themselves for the purpose of providing a specimen to be analyzed for the presence of drugs or alcohol.

collection site person

A person who instructs and assists individuals at a collection site and who receives and makes a screening examination of the specimen provided by those individuals.

confirmation (or confirmatory) test

In drug testing, a second analytical procedure to identify the presence of a specific drug or metabolite that is independent of the screening test. GC/MS is ITP’s authorized confirmation method for controlled substances testing. In alcohol testing, a second test, following a screening test with a result of 0.02 or greater, that provides quantitative data of alcohol concentration.

conforming products list (CPL)

NHTSA's Conforming Products List of Evidential Breath Measurement Devices (CPL).

consent and release form(s)

May be used for an employee consenting to drug/alcohol testing, SAP evaluation or other action, and for release of results and/or information to company officials and others.

consortium

An entity providing alcohol or drug testing services on behalf of ITP.

controlled substance

Includes all substances listed on Schedules I through V of 21 CFR 1308. At a minimum, covered employees will be tested for the following drugs and/or their metabolites: Marijuana, Cocaine, Opiates, Phencyclidine, and Amphetamines.

covered employee

Any individual on-duty during any period in which the individual is performing or available to perform any duties on behalf of ITP unless their position has been previously identified in writing as containing no Company requirements.

© 1998 Drug Screens Plus All Rights Reserved. 18 Ver DFWP 981204 for: ITP

detectable level

of a controlled substance: the lowest level deemed by the testing laboratory to be scientifically sufficient to determine that the controlled substance is present.

drugs see: controlled substance

drug test

An analytic procedure to determine whether an individual has (confirmation test) or may have (screening test) a prohibited controlled substance in a body specimen.

evidential breath testing device (EBT)

A device approved by the National Highway Traffic Safety Administration (NHTSA) for the evidential testing of breath and placed on NHTSA's "Conforming Products List of Evidential Breath Measurement Devices: (CPL).

failure to provide a specimen

Failure to report to the designated specimen collection site immediately following notification of a request for testing. Failure to provide a minimum of 45 ml of urine within 3 hours of arrival at the collection site, or failure to provide an adequate breath specimen, without a medical explanation satisfactory to ITP's MRO.

follow-up testing

Drug/alcohol testing of an employee determined to be in need of assistance in resolving problems with drugs/alcohol.

immediately

with respect to random testing: as soon as possible consistent with safety considerations.

MRO: Medical Review Officer

A licensed physician (Medical Doctor or Doctor of Osteopathy) responsible for receiving laboratory results generated by an employer’s drug testing program who has knowledge of substance abuse disorders and has appropriate medical training to interpret and evaluate an individual’s confirmed positive test result together with his or her medical history and any other relevant biomedical information.

NHTSA National Highway Traffic Safety Administration

positive result (alcohol)

Refusal to submit a specimen OR an alcohol concentration of 0.02 or greater on a test performed by a Breath Alcohol Techni-cian on Evidential Breath Testing equipment or by other means.

positive result (drugs)

Refusal to submit a specimen OR the presence of a drug or drug metabolite in a urine sample at or above the following test levels: Substance Levels(ng/ml): Screening Test Confirmatory Test Marijuana 50 15 Cocaine 300 150 Opiates Morphine 2000 2000 Codeine 2000 2000 Phencyclidine (PCP) 25 25 Amphetamines 1000 Amphetamine 500 Methamphetamine 500

© 1998 Drug Screens Plus All Rights Reserved. 19 Ver DFWP 981204 for: ITP

refusal to submit

Refusal by an employee to complete and sign any forms that are required for drug and/or alcohol testing, refusal to provide an adequate specimen, other refusal to cooperate that prevents completion of the test as scheduled, or failure to provide a specimen within the required time. (See: failure to provide..)

Company duties/functions

Any on-duty functions in which the individual is performing, ready to perform, or available to perform any duties on behalf of ITP if any such duty could directly or indirectly result in or have the potential to result in (1) Injury to the individual or other person(s), or (2) Damage to property not belonging to the individual, or (3) A recordable safety infraction or citation, or (4) (For the purposes of this policy) duties or functions which may affect not only physical safety, but also security, privileged information, Company image, financial security, or other equally significant issues as determined by ITP.

(For controlled substance testing)

A minimum of 45 ml of the tested employee's freshly voided urine as determined by the collection site person.

split sample method A drug testing specimen collection procedure which involves dividing the collected specimen into two separate containers.

substance abuse Illicit use of a controlled substance or misuse of alcohol.

substance abuse professional (SAP)

A licensed physician (Medical Doctor or Doctor of Osteopathy); or a licensed or certified psychologist, social worker, or employee assistance professional; or an addiction counselor (certified by the National Association of Alcoholism and Drug Abuse Counselors Certification Commission or by the International Certification Reciprocity Consortium/Alcohol & Other Drug Abuse). All must have knowledge of and clinical experience in the diagnosis and treatment of alcohol-and controlled substances-related disorders.

Substance abuse program manager (SAPM)

The designated Company official who has primary responsibility for administering ITP's substance abuse program. (Look under "Contact Persons" in the index to Section 1 of ITP's substance abuse policy".)

© 1998 Drug Screens Plus All Rights Reserved. 20 Ver DFWP 981204 for: ITP

DFWA 5152(a)(1)(B)(i) Appendix B1 - Effects and Consequences Alcohol Alcohol is the most widely abused of all drugs and belongs to the class of drugs known as depressants.

Depressants affect the central nervous system; slowing down mental functions, depressing the pulse rate, blood pressure, respiration and other bodily functions. 60% of all automobile accident fatalities involve alcohol.

Alcoholism is a progressive disease which typically passes through 5 stages: social drinking, increased tolerance, behavioral changes, concealment of drinking, complete dependency. In addition to the direct effects, even small amounts of alcohol can have a serious effect on an unborn child. Two-thirds of all Americans will be involved in an alcohol-related vehicle accident during their lifetimes. The rate of separation and divorce in families with alcohol dependency problems is 7 times the average. From 1982 through 1993, deaths from drunken driving accidents have dropped by nearly one third. This drop is attributed (by the CDC) to improved law enforcement, state’s raising their drinking ages to 21 and lowering their legal limits for intoxication. Fewer people are drinking. There has been an increase in social pressure against driving drunk and heightened public awareness as a result of groups such as MADD.

Signs and Symptoms:

Typical Sources: Beer, wine, hard liquors. Physical Symptoms: Odor on breath; slurred speech; very bloodshot/ watery eyes; poor balance/ coordination; sleepy or stuporous condition; gaze nystagmus (spasmodic movement of eyes); possibly constricted pupils; greatly impaired driving ability; impaired judgment; inability to divide attention; lowered inhibitions; changes in sleep patterns. Behavioral Symptoms: excessive use of mouthwash or mints to cover odor of alcohol; focus on alcohol- related activities; hidden drinking, morning drinking, drinking before attending an activity that includes drinking; drinking instead of eating; chronic, unjustifiable problems with family, employer, other drivers; excessive irritability and impatience; extreme changes in personality.

Personal Health, Safety, and the Work Environment: The annual alcohol-related death toll includes: 35,000 auto accident deaths; 15,000 in non-highway accidents; 40,000 deaths due to liver and brain disease or suicide; 125,000 in other alcohol-related conditions/accidents. Two-thirds of all homicides are committed by people who drink prior to the crime. Two to three percent of the drivers on the highway are legally drunk on a typical week-day, and four to six percent on nights and weekends.

General Health Effects: Reduced coordination and reflex action Impaired vision and judgment depressed genital reflexes and increased sexual dysfunction/impotency (in spite of reduced inhibitions) vitamin/mineral deficiencies resulting from improper diet increased risk of miscarriage/premature birth/birth defects ruptured veins high blood pressure damage to stomach, pancreas, brain cells, esophagus, liver increased danger of auto/boating accidents, slips/trips/falls, fire, drowning, or becoming a victim of violence, crime, murder.

Safety and the Work Environment: Impairment in coordination and judgment can be objectively measured with as little as two drinks in the body (increasing with each additional drink) and resulting in an accident rate of up to 6 times the rate for an unimpaired individual. It takes an average person (150 pounds) about an hour to process one serving of an alcoholic beverage from the body. Over 40 percent of falls are alcohol-related.

Overdose Effects: Unconsciousness Amnesia/Blackouts Impotency Coma Death

Withdrawal Syndrome: Alcohol withdrawal can be fatal. Symptoms can include Sleep disturbance Anxiety attacks Decreased appetite/nausea/vomiting/cramps Hallucinations Sweating and tremors Convulsions Coma Heart failure. The alcoholic requires professional medical attention during withdrawal.

© 1998 Drug Screens Plus All Rights Reserved. 21 Ver DFWP 981204 for: ITP

Appendix B2 - Effects and Consequences Marijuana Marijuana use is very common; about one-third of all adult Americans have tried the drug. In the 1985

National Household Survey on Drug Abuse (NIDA, 1986b), about 10 percent of Americans over the age of 12 reported that they had used the drug within the month prior to their interviews. Among those young adults who have tried marijuana, 39 percent of males and 24 percent of females report using it more than 100 times. Regardless of any state or local statutes permitting the use of Marijuana or THC, such use (including a prescription by a licensed physician) violates Federal statutes.

Passive inhalation of marijuana smoke does occur and can result in detectable levels of THC in blood and urine. Clinical studies have shown, however, that it is highly unlikely that a nonsmoking individual could un-knowingly inhale sufficient smoke by passive inhalation to result in a high enough drug 22 in urine for detection at the cutoff level currently used in the Federal program.

Signs and Symptoms:

Evidence of Presence: plastic bags (commonly used to sell marijuana); smoking papers; roach clip holder; small pipes of bone, brass, or glass; smoking bongs; distinctive odor (like burning rope). Physical Symptoms: reddened eyes (often masked by eye drops); stained fingertips from holding "joints" particularly for non-smokers; chronic fatigue; irritating cough, chronic sore throat; accelerated heart beat; slowed speech; impaired motor coordination; altered perception; increased appetite. Behavioral Symptoms: impaired memory; time-space distortions; feeling of euphoria; panic reactions; paranoia; "I don't care" attitude; false sense of power.

Personal Health, Safety, and the Work Environment: Marijuana produces a pleasant euphoria or "high," commonly followed by drowsiness. Intoxication temporarily impairs concentration, learning, and perceptual-motor skills. Thus, for at least 4-6 hours after a dose of mari-juana, drivers probably function with reduced abilities. Preliminary studies suggest that performance is impaired long after the acute subjective effects have ended. Experienced pilots in a flight simulator were im-paired for at least 24 hours after a dose, long after the subjective "high" had disappeared. Functional impair-ments are less well understood in cases of prolonged, heavy marijuana use, because although THC accumu-lates in the body, behavioral and physiological tolerance also develop.

General Health Effects: Chronic marijuana smoking causes emphysema-like conditions. One "joint" is the cancer-causing equivalent of 1/2 to a full pack of tobacco cigarettes. Marijuana is commonly contaminated with the fungus Aspergillis, which can cause serious respiratory tract and sinus infections. Chronic marijuana smoking causes changes in brain cells and brain waves. Long-term brain damage is likely to occur. The active chemical, THC, and 60 other chemicals in marijuana tend to concentrate in the ovaries and testes. Chronic smoking of marijuana in males causes a decrease in the male sex hormone and an increase in the female sex hormone, which can lead to female sex characteristics including breast development. Chronic smoking of marijuana in females causes a decrease in fertility and an increase in male sex hormones. THC has been linked with: malformations of the brain, spinal cord, forelimbs, liver, and spine, and visual/ophthalmic problems.

Safety and the Work Environment: Regular use can cause: delayed decision making diminished concentration impaired short-term memory impaired signal detection (ability to detect a brief flash of light) impaired tracking (the ability to follow moving objects with the eyes) and visual distance measurements The mental impairments resulting from the use of marijuana produce reactions that can lead to unsafe and erratic driving behavior. Distortions in visual perceptions, impaired signal detection, and altered reality can make driving a vehicle (or other Company work) very dangerous.

Overdose Effects: Aggressive urges Anxiety Confusion Fearfulness Hallucinations Heavy sedation Immobility Mental dependency Panic Paranoia Unpleasant/distorted body image.

Withdrawal Syndrome: Sleep disturbance Hyperactivity Decreased appetite Irritability Gastrointestinal distress Salivation, sweating and tremors.

© 1998 Drug Screens Plus All Rights Reserved. 22 Ver DFWP 981204 for: ITP

Appendix B3 - Effects and Consequences Cocaine Cocaine is an alkaloid (organic base) derived from the coca plant. In its more common form, cocaine

hydrochloride ("snorting coke") is a white to creamy granular or lumpy powder (chopped fine before use). Cocaine base, rock, or crack is a crystalline rock about the size of a small pebble. Cocaine hydrochloride is snorted into the nose, rubbed on the gums, or injected into the veins. Cocaine base is heated in a glass pipe and the vapor is inhaled. It is estimated that 5.8 million Americans use cocaine in any given month, and 5 percent of employed persons 20 to 40 years old reported using cocaine in the month prior to the NIDA survey. Cocaine first produces psychomotor and autonomic stimulation, with a euphoric subjective "high." Larger doses may induce mental confusion or paranoid delusions, and serious overdoses cause seizures, respiratory depression, cardiac arrhythmias, and death. Cocaine abusers, even if they do not use at work, often report vocational impairment due to exhaustion; they use the drug until late at night. Among chronic users, exhaustion, lethargy, and mental depression appear, and the stimulant effect may seem progressively weaker. But the drug is highly reinforcing; repeated experiences with it tend to drive further episodes of self-administration. Many patients say that although the drug no longer produces much "high," they are unable to abstain.

Signs and Symptoms:

Evidence of Presence: small folded envelopes, plastic bags, or vials used to store cocaine; razor blades; cut-off drinking straws or rolled bills for snorting; small spoons; heating apparatus.

Physical Symptoms: dilated pupils; runny or irritated nose; profuse sweating; dry mouth; tremors; needle tracks; loss of appetite; hyperexcitability; restlessness; high blood pressure; heart palpitations; insomnia; talkativeness; formication (sensation of bugs crawling on skin).

Behavioral Symptoms: increased physical activity; depression; isolation and secretive behavior; unusual defensiveness; frequent absences; wide mood swings; difficulty in concentration; paranoia; hallucinations; confusion; false sense of power and control.

Personal Health, Safety, and the Work Environment: General Health Effects: may upset chemical balance of the brain...speed up the aging process...cause irreparable damage to critical nerve cells causes heart to beat faster and harder and rapidly increases blood pressure causes spasms of blood vessels in the brain and heart...leading to strokes and heart attacks Cocaine causes the strongest mental dependency of any known drug. Treatment success rates are lower than those of other chemical dependencies. Cocaine is extremely dangerous when taken with depressant drugs. Medical intervention for overdoses in such cases usually proves ineffective.

Safety and the Work Environment: Regular use can cause the following effects: Paranoia and hallucinations Hyperexcitability and overreaction to stimulus Difficulty in concentration Wide mood swings Withdrawal leads to depression and disorientation Cocaine use results in an artificial sense of power and control which leads to a sense of invincibility. Lapses in attention and the ignoring of warning signals greatly increase potential for accidents. Paranoia, hallucinations, and extreme mood swings make for erratic and unpredictable reaction. The cost of maintaining cocaine dependency frequently leads to workplace theft and/or dealing. Forgetfulness, absenteeism, tardiness, and missed assignments can translate into lost business.

Overdose Effects: Agitation Increase in body temperature Hallucinations Convulsions Death

Withdrawal Syndrome: Apathy Long periods of sleep Irritability Depression Disorientation

© 1998 Drug Screens Plus All Rights Reserved. 23 Ver DFWP 981204 for: ITP

Appendix B4 - Effects and Consequences Amphetamine/Methamphetamine In their pure form, amphetamines are yellowish crystals. They are manufactured in a variety

of forms including pill, capsule, tablet (ingested), powder (snorted), and liquid (injected). Amphetamine ("speed") is sold in counterfeit capsules or as white, flat, double scored "mini bennies." Methamphetamine is often sold as a creamy white, granular powder or in lumps wrapped in aluminum foil or plastic bags. These synthetic drugs are much less widely abused than cocaine or marijuana. About 4% of young adults 18-25 and less than 1% of adults over 25 years of age report nonmedical use of a stimulant in the month before their interviews. The stimulant effects of amphetamine and methamphetamine are similar to those of cocaine, but last longer. A single therapeutic dose enhances attention and performance, but performance deteriorates as the effects wear off, or with repeated dosing. These stimulant drugs are useful in treating narcolepsy and attention-deficit disorder, and are sometimes prescribed for depression which has not responded to other treatments. The drugs cause anorexia, but tolerance quickly develops, limiting their merit for treating obesity. Because of the abuse risk, medical boards in several jurisdictions have formally determined that it is inappropriate to treat obesity with these drugs for more than a few weeks. However, a tested individual producing a confirmed positive should be carefully queried about prescribed medications.

Signs and Symptoms:

Evidence of Presence: Most frequently - pills, capsules, tablets; envelopes, bags, vials for storing; Less frequently - syringes, needles, tourniquets.

Physical Symptoms: dilated pupils; sweating; increased blood pressure; palpitations; rapid heartbeat; dizziness; decreased appetite; dry mouth, headaches; blurred vision; insomnia; high fever (depending on the level of the dose).

Behavioral Symptoms: confusion; panic; talkativeness; hallucinations; restlessness; anxiety; moodiness; false sense of confidence and power; "amphetamine psychosis" which might result from extended use.

Personal Health, Safety, and the Work Environment: General Health Effects: "Amphetamine psychosis" - Resembling schizophrenia, users may see, hear, and feel things that do not exist (hallucinations), have irrational thoughts or beliefs (delusions), and feel as though people are out to get them (paranoia). Regular use produces strong psychological dependence and increasing tolerance to the drug. The euphoria increases impulsive and risk taking behavior, such as bizarre and violent acts. Intoxication may induce a heart attack or stroke due to spiking of blood pressure. Chronic use may cause heart and brain damage due to severe constriction of capillary blood vessels. Lack of sleep, weight loss, and depression also result from regular use. Users who inject drugs can get serious and life-threatening infections, lung or heart disease, and/or kidney damage).

Safety and the Work Environment: Regular use can cause: Restlessness Anxiety Moodiness False sense of power. Extended use can result in: Hallucinations Delusions Paranoia Brain damage. A false sense of alertness can result in risky driving behavior and increased accidents. Drivers who fail to get sufficient rest may use the drug to increase alertness and become dependent. While limited doses cause short-term mental/physical improvement, greater use impairs functioning. Amphetamine hangover effects (fatigue/depression) are a danger in Company positions.

Overdose Effects: Agitation Increase in body temperature Hallucinations Convulsions Death

Withdrawal Syndrome: Apathy Long periods of sleep Irritability Depression Disorientation

© 1998 Drug Screens Plus All Rights Reserved. 24 Ver DFWP 981204 for: ITP

Appendix B5 - Effects and Consequences Opiates: Morphine/Codeine/Heroin/Others Natural and natural derivatives include: opium; morphine; codeine; and heroin (semi-synthetic).

Synthetics include: meperidine (Demorol); oxymorphone (Numorphan); and oxycodone (Percodan). Opiates may be taken in pill form, smoked, or injected, depending on the type of narcotic used. Because of the variety of compounds and forms, opiates are more difficult to clearly describe in terms of form, color, odor, and other physical characteristics. Opium and its derivatives can range from dark brown chunks to white crystals or powders. Fortunately, opioid abuse overall is relatively uncommon...fewer than 1/2% of respondents report heroin use in the month preceding their interviews. Agencies employing many health care professionals may find occasional unexplained urine samples containing non-heroin opioids...such as meperidine, fentanyl, hydromorphone, oxycodone, or pentazocine. Since the body metabolizes codeine to morphine, both substances may occur in urine following the use of codeine. Poppy seeds contain trace amounts of morphine and codeine, so an driver who consumes poppy seed rolls may produce urine positives for morphine (with or without codeine). Thus, MROs must find that a urine containing morphine, or morphine and codeine, does not demonstrate drug abuse unless other signs also are present: needle tracks or signs of intoxication or withdrawal...moderate, nonlethal, "flu"-like abstinence syndrome with nausea, diarrhea, coryza, occasional vomiting, weakness, malaise, "gooseflesh," and mydriasis. However, the metabolite 6-monoacetylmorphine in the urine comes only from heroin; this compound confirms illicit drug use.

Signs and Symptoms:

Evidence of Presence: Needles; syringe caps; eyedroppers; bent spoons; bottle caps; and rubber tubing (used in the preparation for and injection of the drug). Foil, glassine envelopes, or paper "bindles" (packets for holding drugs); balloons or prophylactics used to hold heroin; bloody tissues used to wipe the injection site; and a pile of burned matches used to heat the drug prior to injection.

Physical Symptoms: constricted pupils; sweating; nausea and vomiting; diarrhea; needle marks or "tracks"; wearing long sleeves to cover "tracks"; loss of appetite; slurred speech; slowed reflexes; depressed breathing and heartbeat; and drowsiness and fatigue.

Behavioral Symptoms: mood swings; impaired coordination; depression; apathy; stupor; and euphoria.

Personal Health, Safety, and the Work Environment: General Health Effects: Intravenous (IV) needle users have a high risk for contracting hepatitis and AIDS due to sharing of needles. Because opiates increase tolerance to pain, individuals may under-estimate the extent of injuries, leading to failure to seek medical attention after an accident. Because the effects of opiates are multiplied when used in combination with other depressant drugs and alcohol, overdoses are more likely.

Safety and the Work Environment: Regular use can cause the following effects: Depression Apathy Wide mood swings Slowed movement Slower reflexes High physical/psychological dependence The apathy caused by opiates results in an "I don't really care" attitude towards performance. Physical effects, depression, fatigue, and slowed reflexes raise the potential for accidents.

Overdose Effects: Slow/shallow breathing Clammy skin Convulsions Coma Death

Withdrawal Syndrome: Watery eyes Runny nose Yawning Loss of appetite Irritability Tremors Panic Cramps Nausea Chills Sweating

© 1998 Drug Screens Plus All Rights Reserved. 25 Ver DFWP 981204 for: ITP

Appendix B6 - Effects and Consequences PCP (Phencyclidine) PCP is not used in medicine and does not occur in nature. PCP's use as a human anesthetic was

discontinued because it produced psychotic reactions, and its more prolonged use as a veterinary tranquilizing agent also has stopped. Thus, the drug now has no therapeutic role; its use is strictly illegal. It is commonly sold as a creamy, granular powder (brown or white) and often packaged in one-inch-square aluminum foil or folded paper packets. Occasionally, it is sold in capsule, tablet or liquid form. It is sometime smoked in marijuana, tobacco, or other leafy materials. Since monkeys repeatedly self-administer PCP intravenously, resulting in gross intoxication, the drug is said to reinforce self-administration behavior in animals. Some human beings also repeatedly and chronically self-administer PCP. This behavioral reinforcement is striking, considering the drug's pronounced adverse effects. The psychosis which sometimes develops with intoxication may be long-lasting, and there are suggestions of personality and cognitive changes persisting for months after chronic use. Its toxicity has given it a bad reputation even among drug users, who often are not very discriminating in these matters. It remains a popular drug of abuse in some cities, notably Washington, DC, Los Angeles, CA, and Baltimore, MD.

Signs and Symptoms:

Evidence of Presence: foil or paper packets; stamps (off which PCP is licked); injection paraphernalia (needles, syringes, and tourniquets); leafy herbs (for smoking).

Physical Symptoms: dilated or floating pupils; blurred vision; nystagmus (jerky eye movement); drooling; muscle rigidity; profuse sweating; decreased sensitivity to pain; dizziness; drowsiness; impaired coordination (e.g., drunken-like walk, staggering); severe disorientation; rapid heartbeat.

Behavioral Symptoms: anxiety; panic/fear/terror; aggressive/violent behavior; distorted perception; severe confusion and agitation; disorganization; mood swings; poor perception of time and distance; poor judgment; auditory hallucinations.

Personal Health, Safety, and the Work Environment: General Health Effects: There are 4 phases to PCP abuse. Phase 1/Acute toxicity: can last up to three days and can include combativeness, catatonia, convulsions, and coma. Distortions of size, shape, and distance perceptions are common. Phase 2/Toxic psychosis: while this phase does not always follow the first, users may experience visual and auditory delusions, paranoia, and agitation. Phase 3/Drug-induced schizophrenia: may last a month or longer. Phase 4/Drug-induced depression: suicidal tendencies and mental dysfunction can last for months.

Safety and the Work Environment: Regular use can cause the following effects: Irreversible memory loss Personality changes Thought disorders Hallucinations Extreme mental/anesthetic effects create high potential for accidents and for overdose emergencies. Because the effects are aggravated by other depressant drugs such as alcohol, overdose potential is high. PCP-induced hallucinations may be misdiagnosed as LSD-induced. The standard treatment for LSD- induced hallucinations is Thorazine, which when administered with PCP can be fatal. Distortions in perception, and potential visual and auditory delusions make performance unpredictable and dangerous in Company positions. PCP use can cause drowsiness, convulsions, paranoia, agitation, or coma, all obviously dangerous in any Company position.

Overdose Effects: Longer, more intense "trip" episodes Psychosis Coma Death

Withdrawal Syndrome: None reported

© 1998 Drug Screens Plus All Rights Reserved. 26 Ver DFWP 981204 for: ITP

Appendix - C Certificate of Receipt for Interurban Transit Partnership Company Policy Each covered employee is required to sign a statement certifying that he/she has

received a copy of the materials described in this section.

READ BEFORE YOU SIGN:

It is Company policy to provide covered employees (and representatives of employee organizations) with educational/training materials to explain Company policies regarding drug/alcohol use and abuse, and other information concerning the effects of alcohol and controlled substances use. ITP requires all covered employees (and representatives of employee organizations) to certify receipt of these materials. Refusal to sign this form upon receipt of the materials will be grounds for discharge. By signing this receipt you agree that you have received and read and are responsible to understand Company policies regarding alcohol and drug use testing, and any Company training materials included with or referenced in this material. Any questions you have regarding the above materials or this certification form may be addressed to

___________________________________________ SAPM (or other Company official).

By signing this receipt, you are agreeing that your questions have been answered to your satisfaction. The original of this form will be retained by ITP in a separate file along with other Company drug and alcohol testing program records. You are entitled to receive a copy of this receipt and one will be provided upon request. CERTIFICATION: The undersigned hereby certifies that he/she has received a copy of the ITP Substance Abuse Policy. Furthermore, I agree that I am responsible for reading, understanding and obeying all current Company policies regarding alcohol and drug use and testing and all future changes in or additions to those policies as they are adopted by ITP. I further understand and agree that I may be subject to disciplinary action up to and including discharge for violating Company policies. Prior to signing this Receipt, I read it carefully and any questions I had regarding the above materials and/or this form have been answered to my satisfaction. Employee Signature ___________________________________ Date: ___/___/___ Print Name ___________________________________ Witness Signature ___________________________________ Date: ___/___/___ Print Name ___________________________________