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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 <br />