Substance Abuse Policy II-41 - The MetroHealth System

Subject: Substance Abuse
I. POLICY
The MetroHealth System
Policy: II-41
A. The MetroHealth System (MHS) is dedicated to the prevention of
substance abuse and/or alcohol abuse and supports rehabilitation where
appropriate. MHS maintains a Zero Tolerance Policy.
B. Evidence of alcohol and/or other drug abuse will be considered a
legitimate reason for rejecting a candidate for employment. Evidence that
an employee is under the influence of drugs or alcohol at work will result in
that employee being required to undergo a "for cause" drug/alcohol
screen. A positive drug/alcohol screen may result in the employee being
subjected to disciplinary action, up to and including discharge, or being
required to undergo a treatment program as a condition of continued
employment. MetroHealth encourages any employee who feels that
he/she may have a drug or alcohol problem to contact the Employee
Assistance Program (EAP).
C. Results of all drug tests are kept confidential. Any information regarding
test results will be disclosed on a strict ‘need to know’ basis only.
II. PURPOSE: To promote a drug-free work environment that will assist with
ensuring the safety of patients, visitors and employees.
III. SCOPE: All MHS employees.
IV. DEFINITIONS
A. Drug of Abuse: "Drug of Abuse" means any controlled substance as
defined in section 3719.01 of the Ohio Revised Code, any harmful
intoxicant as defined in section 2925.01 of the Ohio Revised Code, and
any dangerous drug as defined in section 4729.02 of the Ohio Revised
Code. A prescription drug will not be considered a Drug of Abuse so long
as it is legally obtained and is being used for prescribed purposes and in
prescribed amounts by the person for whom it is prescribed. A harmful
intoxicant will not be considered a Drug of Abuse unless it is being abused
as specified in section 2925.01 of the Ohio Revised Code. Alcohol will be
considered a Drug of Abuse if it is detected during the pre-employment
process for new candidates, or while on duty or on the premises.
B. Positive Drug Test: Detection of alcohol and/or another Drug of Abuse at
or above a threshold level.
C. Negative Drug Test: Failure to detect alcohol and/or another Drug of
Abuse at or above a threshold level.
V. PROHIBITIONS

Substance Abuse Policy: II-41 (2)
A. Consuming, using, possessing, selling, transferring or purchasing Alcohol
or a Drug of Abuse on the premises of or while on duty at MHS is
prohibited. Having a drug of abuse in the employee's system at or above
a detectable level as set forth by the National Institute of Drug Abuse
standards is also prohibited. Having a detectable blood alcohol level is
prohibited. Also, having alcohol on the breath while on duty is prohibited.
Further, possession of drug paraphernalia on Hospital premises is also
prohibited. For purposes of this policy, employees shall still be considered
to be "on duty" if they are on a rest or meal break on or off the premises.
In addition, employees shall be considered to be "on duty" when they are
on the premises for the purpose of reporting to work or after finishing work
(e.g., an employee in the locker room changing into, or out of, work
clothes).
B. Engaging in any of the activities described in paragraph A while off the
premises or off duty is also prohibited where such activity:
1. Constitutes a threat to the patients, visitors, employees or property
of MHS.
2. Otherwise affects the interests or mission of MHS.
C. Any employee in violation of paragraph A or B may be subject to
disciplinary action, up to and including discharge. In addition, such an
employee may be required, as a condition of continued employment, to
undergo a treatment program. MHS encourages all employees and
supervisors to voluntarily use the EAP and/or other Substance Abuse
Programs.
VI. DRUG TESTING REQUIREMENTS AND PROCEDURES
A. Testing Requirement: In order to detect the presence of Substances of
Abuse among persons not currently employed by MHS, the System’s
policy is to require candidates for employment to submit to a drug screen
as part of the pre-placement process. This policy applies to candidates for
full-time, part-time, temporary employment. All classifications are subject
to this policy, including the medical staff and the house staff.
1. MetroHealth will utilize only those temporary agencies who provide
written assurance that their employees have submitted to a preemployment
drug screen.
2. Drugs to be tested for are shown on the enclosed Drug Screen List
(see attachment B).
3. Candidates who test positive will be disqualified from employment
for one year. A second Positive Drug Test will forever exclude
them from consideration for employment.
B. Testing Procedures

Substance Abuse Policy: II-41 (3)
1. Candidate will be informed of the drug testing policy and that an
offer of employment is contingent upon a Negative Drug Test.
2. A candidate will be scheduled for the drug test after an offer of
employment is made. The assigned Employment staff member will
do scheduling.
3. When positive test results are received from the lab, the Medical
Review Officer will review the report and, if necessary, may consult
with authorized management representatives of the Department of
Human Resources or designated staff in the Employee Health
Clinic. The Medical Review Officer will then complete the drug test
report for employment, noting that the candidate's test was positive
or negative. Any indication of adulteration of a specimen will be
treated, and reported, as a Positive Drug Test.
4. All lab reports will be filed in the candidate's medical folder
maintained in the Employee Health Clinic.
5. An authorized representative of the Department of Human
Resources will inform the candidate of a positive drug test. The
candidate will be told that they have the option to have the test
results confirmed at an alternate lab site, at his/her own expense.
The candidate must inform the Department of Human Resources of
his/her decision as soon as possible, and within no more than two
(2) workdays of being informed of the positive result. Candidates
who test positive shall not be given further consideration in the
employment process. However, candidates who test positive may
re-apply in 12 months. A second positive drug test will exclude
them from future consideration for employment with MHS.
6. The candidate will be provided with a copy of the test results, upon
written request presented to Human Resources.
7. The Employee Health Clinic will keep a log of all candidates who
test positive. The Employee Health Clinic will maintain this log and
positive test results, in order to maintain confidentiality.
C. For Cause
1. Testing Requirement: MHS may require an employee to submit to
a drug screen based upon a reasonable suspicion that the
employee has a detectable level of a drug of abuse in their system
or alcohol on their breath while on duty or while on the premises.
All employees are subject to this policy, including the medical staff
and house staff. Drugs to be tested for are shown on the enclosed
Drug Screen List (see attachment B).
2. A reasonable suspicion determination will be based on specific,
articulated observations, including, but not limited to the following:

Substance Abuse Policy: II-41 (4)
a) Walking (e.g. stumbling, staggering, falling, swaying,
unsteady, holding on, pace (faster or slower than normal)
b) Standing (e.g. swaying, rigid, unable to stand, feet wide
apart, staggering, sagging at knees)
c) Balance (e.g. falling, swaying, staggering, sagging knees)
d) Inappropriate behavior (e.g. wearing sunglasses indoors,
excessive time in lavatory without explanation, employee in
unusual and inappropriate areas such as storage room,
closet, etc.)
e) Speech (e.g. shouting, silent, whispering, slow, rambling,
repetitive, rapid, mute, slurred, slobbering, confused,
incoherent)
f) Demeanor (e.g. sleepy, crying, agitated, silent, talkative,
excited, sarcastic, fighting)
g) Actions (e.g. resisting communications, fighting, disoriented,
threatening, drowsy, profanity, hyperactive, hostile, pacing,
erratic)
h) Eyes (e.g. bloodshot, pinpoint pupils, watery, dilated,
wandering, glassy, droopy, closed)
i) Face (e.g. flushed, pale, sweaty)
j) Appearance (e.g. unruly, messy, dirty)
k) Breath (e.g. alcoholic odor, faint alcoholic odor, other odors
associated with use of drugs/alcohol)
l) Movements (e.g. fumbling, jerky, slow, nervous, hyperactive)
m) Awareness (e.g. confused, bewildered, sleepy)
n) Attendance (e.g. pattern of unexplained absence, absences
clustered around weekends or holidays, absences clustered
around paydays, instances of AWOL)
o) Tardiness (e.g. pattern of tardiness after holidays, weekends
or paydays)
p) Deterioration of work performance (e.g. pattern of
unexplained work errors, inability to meet reasonable
deadlines, other unexplained changes in quality of work)
q) Unexplained work-related accident or injury

Substance Abuse Policy: II-41 (5)
r) The use of a drug of abuse while on duty either on or off the
premises
s) Suspicion of theft/or diversion of drugs.
3. Testing Procedure (see attachments A-F): A supervisor who has a
reasonable suspicion that an employee has a detectable level of a
drug of abuse in their system while on duty or while on the
premises or a reasonable suspicion that an employee has alcohol
on their breath while on duty shall take the following action:
a) Confirm the observed suspicious behavior with another
witness (preferably a management witness).
b) Interview the employee in private to determine if there is a
reasonable (non drug-related) explanation for the behavior.
Bargaining unit employees must have union representation
present at this time. Union representation will be present at
all stages of the For Cause process. The interview should
be conducted in an investigatory, rather than an accusatory,
manner. A second management witness must be present
during the interview and should document it.
c) Between 8:00 a.m. and 5:00 p.m. the Manager of
Employee/Labor Relations will inform the employee of the
Hospital's drug testing policy, and the employee will be
asked to submit to a drug test. The employee will be asked
to sign the Employee Drug Test Consent Form (see
attachment A) at this time. If the employee refuses to sign
the consent form or refuses to submit to a drug test, the
employee will be informed that such refusal will be
considered as insubordination and will result in disciplinary
action, up to and including termination. If the employee still
refuses, he/she is to be sent home on administrative leave
without pay until a determination is made regarding the level
of discipline the employee should receive in collaboration
with the Labor Relations section of Human Resources.
Otherwise, the Manager of Employee/Labor Relations will
contact the Employee Health Clinic to arrange for a drug
test. The employee will be escorted to the Employee Health
Clinic to submit urine and blood samples for analysis.
d) Before any test is administered, an employee must present a
signed Employee Drug Test Consent Form (attachment A) to
the test administrator. A copy of the signed Employee Drug
Test Consent Form will be provided to the union
representative.

Substance Abuse Policy: II-41 (6)
D. General
e) At the conclusion of this procedure the employee will be
placed off duty, on administrative leave status without pay,
pending the results of the drug test.
f) MetroHealth shall arrange for transportation to the
employee's home.
g) When the test results are received from the lab, the
Employee Health Clinic will review the report. The Medical
Review Officer will then complete the drug test report for
cause, noting that the employee's test was positive or
negative. The Medical Review Officer may consult with
authorized representatives of Human Resources or
Employee Health before completing the report. Any
indication of adulteration of a specimen will be reported to
the Manager of Employee/Labor Relations.
h) The Medical Review Officer and the Manager of
Employee/Labor Relations will inform the employee of the
results of the drug test. Bargaining Unit employees will be
offered union representation at this time. The employee will
be told that he/she has the option to have the test results
confirmed at an alternate lab site, at his/her own expense.
The employee must inform the Office of Human Resources
of his/her decision as soon as possible, and within no more
than two (2) workdays of being informed of the positive
result.
i) The employee will be provided with a copy of the lab test
results, upon written request. The Hospital must have
written authorization from the employee prior to releasing
this information to the union.
j) The Employee Health Clinic will keep a log of all employees
who test positive.
k) An employee who tests positive is subject to disciplinary
action, up to and including discharge.
l) Confidentiality of test results is of paramount importance.
1. Medical procedures for drug testing have been established. These
procedures are maintained in the Employee Health Clinic and must
be followed for every drug test.
2. Standards have been established for collection sites. A facility
must meet these standards to be approved as a collection site.
These standards are maintained in the Employee Health Clinic.

Substance Abuse Policy: II-41 (7)
VII. EMPLOYEE ASSISTANCE PROGRAM: Available to all MHS employees as an
option to coordinate substance abuse treatment.
VIII. EXCEPTIONS: Notwithstanding any other provision of this policy or any other
System policy, the President and Chief Executive Officer, or any Executive Vice
President, may make an exception to the prohibition on possession and
consumption of alcohol on the premises of the System for special events that
benefit MHS.
IX. CROSS-REFERENCES
A. Policy II-7 Drug-Free Workplace
B. Policy II-11 Employee Assistance Program (EAP)
C. Policy II-36 Corrective Action
X. ATTACHMENTS
A. Employee Drug Test Consent Form
B. Drug Screen List
C. Management Protocol: “For Cause Testing”
D. After Hours Protocol
E. For Cause Testing – Fitness For Duty Report
F. Employee Identification Form
XI. DATES
A. Initiated: April 1993
B. Reviewed/Revised:
1. April 1996
2. March 1997
3. January 2000
4. June 2000
5. January 2002
6. February 2004
7. September 2007

Substance Abuse Policy: II-41 (8)
XII. APPROVED
8. June 2008
Mark J. Moran
Interim President and Chief Executive Officer