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March 1, 2018
<br />SUBSTANCE ABUSE PROGRAM
<br />I. POLICY STATEMENT
<br />Walsh & Kelly, Inc. recognizes Ute importance of assuring properadministrative and
<br />operational decisions and actions in the asplish paving industry. We recognize the need
<br />to even those individuals who might endanger themselves through Ilia abuse of alcohol or
<br />controlled substances (drugs). In order to mitigate the risks, which result front, being
<br />under the influence of alcohol or drugs, the management of Walsh & Kelly, Inc. will
<br />enforce tmiform testing for determination of ability to work and disciplinary action as
<br />described in the following policy documenla€ion.
<br />Furthermore, Walsh & Kelly, Inc. does not allow, condone Ute consumption, or use of
<br />illegal controlled substances (drugs) during working hours or on company property. Any
<br />possession, consumption, or sale of contra€led substances on company property or
<br />worksdcs of Walsh & Kelly, Inc. is forbidden and "ill result in immediate termination.
<br />The consumption of alcohol is likewise prohibited, with the exception of social events
<br />sanctioned by senior management of Walsh & Kelly, Inc. where and when manufacturing
<br />stork is not taking place. Any consumption of alcohol on company property is strictly
<br />forbidden and will result in ternination.
<br />Management of Walsh & Kelly, Inc. also reserves the right to search all company
<br />properly, including, but not limited to, employee desks and lockers, company cars, tool
<br />boxes, elc. to prevent violations of this policy or for any other legitimate reasons. Entry
<br />onto company properly orjob site$ constitutes consent Wand recognition of Use right of
<br />Walsh & Kelly, Inc. company management to search the person, vehi(le, and other
<br />personal property orindividuals whi€o on company's pmporly. Such searches may be
<br />initiated by Walsh & Kelly, Inc. management without prior announcement and will he
<br />conducted at such limes and locations as deemed appropriate- Persons who refuse to
<br />cooperate with a search will not be allowed to remain on company property and will be
<br />subject to tetnunation_
<br />In order to consistently meet thestandmds of the Walsh and Kelly Substance Abuse
<br />Program and the requirements of the Indiana Department of Transportation (DOT)
<br />requirements, Walsh and Kelly, Inc. will use the Building & Construction Resource
<br />Center, Inc. (BCRC) and the Indiana Construction Association's (ICA) Substance Abuse
<br />Programs found in Appendixes 1, 2, and 3 of this document.
<br />The Walsh & Kelly, Inc. Substance Abuse Program applies to all Walsh & Kelly, Inc.
<br />employees, including employees under collective bargaining agreements.
<br />III, QT„HER TESTING REQUIREMENTS
<br />Post Accident Tc5lina— As pan of Walsh & Kelly, Inc. accident investigation program,
<br />employees who require medial allenllon as the result of any injury or illness occurring
<br />Pursuant to the federal Drug -Free Workplace Act of 1988, employees are required to
<br />notify the company of any conviction for criminal drug violations that may affect their
<br />abilky. w work legally. Abiding by these regulations and Walsh & Kelly, Inc. Substance
<br />Abuse Program is a condition of continued employment. Violation of this program will
<br />subject the employee to termination.
<br />while on duty, Hill receive a drug and alcohol screen as soon as medically reasonable and
<br />possible during the first visit to the clinic for medical treatment, Thefacililymannger,
<br />corporate management, or the corporate safely Manager may, as a result of an accident, a
<br />near -miss accident, or unsafe incident, require involved employee$ to be tested. Such
<br />tests shall be conducted in accordance with the Reasonable Cause procedures ss
<br />described in B above. -
<br />Pursuant to the U.S. DOT regulations, any CDL driver involved in an accident resulting
<br />in a fatality, bodily injury, one or more vehicles which most he towed, or a moving tragic
<br />violation resulting from the accident, most W alcohol and drug tested within two (2)
<br />hours. All deviations from the$e requirements must he reported to the Walsh & Kelly,
<br />Griffith office at 1-219-924-5900 within twenty four (24) hours.
<br />Pre•A(cess Testing — In some cases, cuilomer contracts require that the Company
<br />perform drug screens an company employees prior to gaining access to the customer's
<br />work site- The company will perform such pre -access drug screens on all employees who
<br />will be working at the customer's site as appropriate.
<br />IV. CHANGES OR MODIFICATIONS
<br />Walsh & Kelly, Inc. reserves the right to change the provisions of this policy, including
<br />the uniform testing procedure and disciplinary action at any future time.
<br />V, SUBSTANCE ABUSE PROGRAM COORDINATORS
<br />The coordinator for Walsh & Kelly, Inc.' Substance Abuse Program shall be Heritage
<br />Group Safely (HGS). HGS shall review the program periodically and serve as the
<br />recipient of the test results from the Medical Review Officer (MRO) for testing done in
<br />accordance with the DOT regulations or from The (lint¢ for non -DOT testing_
<br />The Medical Review Officer is the medical director or designate of the company -
<br />designated program conducting the substance abuse testing. 'Ilia MRO receives results
<br />from the NIDA - certified testing laboratory and/or Breath Alcohol Technician on
<br />substance abuse test results, determines Una basis for "positives", and communicates the
<br />results to the company.
<br />VI. EMPLOYEE INFORMATION AND TRAINING
<br />Employee infornnation and training sessions shall be conducted periodically. This
<br />training Hill provide informa€ion on program benefits, testing procedures and
<br />requirements, as well as answer any questions or concerns employees may hare about the
<br />program Training for supervisory personnel in recognition of die signs of alcohol and/or
<br />substance abuse and reasonable suspicion shall be provided. Polen€ial new employees
<br />shall be informed of the program and procedures prior to the pre -employment testing.
<br />Any questions nest be directed to the coordinator prior la the initial testing of the
<br />potential employee.
<br />Vff. CONVICI'IONSFOR DRUG VIOLATIONS
<br />SUBSTANCE ABUSE PROGRAM
<br />APPENDIX I
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