ML20137Z680

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Mgt & Supervision Guide to Drug & Alcohol Policy
ML20137Z680
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 01/01/1986
From:
TOLEDO EDISON CO.
To:
Shared Package
ML20137Z657 List:
References
PROC-860101, NUDOCS 8603130094
Download: ML20137Z680 (23)
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{{#Wiki_filter:_ _ _ _ _ . MANAGEMENT AND SUPERVISION GUIDE TO THE DRUG AND ALCOHOL POLICY i TOLEDO EDISON I n P 888 P n 888 6 PDR h hh gn .h

) CONTENTS

1. PRESIDENT'S LETTER II. THE TOLEDO EDISON COMPANY'S POLICY ON THE USE OF DRUGS AND ALCOHOL III. CONTROLLED SUBSTANCES: USE, ABUSE AND EFFECTS IV. ADMINISTRATION OF THE DRUG AND ALCOHOL POLICY V. EMPLOYEE ASSISTANCE PROCPAM VI. EXAMPLES OF COMPANY FORMS:

EMPI.0YEE ASSISTANCE PROGRAM FORM EMPl.0YEE CONSENT / SUPERVISOR REFERRAL FORM l

Memorandum To: All Employees

Subject:

Corporate Drug and Alcohol Abuse Policy i Our Company has long maintained a strong commitment to operate its facilities in the safest manner possible. This is in the best interest of our employees, our customers, our stockholders, and the general public. To assist us in ensuring that this commitment is made even stronger, a Corporate Drug and Alcohol Abuse Policy has been developed to clearly communicate the Company's position as it relates to the use of alcohol and illegal drugs. The utilization of either alcohol or drugs in any manner that would impact on an employee's performance or the safety of any employee in the workplace is not acceptable. Although Toledo Edison respects the privacy of employees' activities outside the Company, if those activities impact on a safe and productive work environment, we have an obligation to intercede. This booklet contains many facts about drugs and alcohol to help show you what many of the harmful physical and psychological effects may be. You are encouraged to review it carefully and if you believe that you are suffering from any of these difficulties, cur Employee Assistance Program is available, at no charge, to help employees through difficult situctions. Our supervisors have received training in identifying the symptoms associated with the abuse of alcohol and drugs and will be instrumental in ensuring that employees are fit for duty. Those employees who are unable to abide by our policy and do not respond to counseling risk loss of their jobs with the company. We owe it to ourselves, our fellow employees and our families to do all that is reasonably required to ennure a safe work environment free from the dangers inherent with alcohol abuse and illegal drug usage. You are urged to cooperate in fulfilling this chligation. Pau M. . mart President PMS.tr

TOLEDO EDISON COMPANY POLICY ON THE USE OF DRUGS AND ALCOHOL PURPOSE The purpose of this policy is to outline the Company's guidelines and expectations concerning the use of illegal drugs and/or alcohol by our employees. OBJECTIVE To ensure the highest standard of health and safety for all employees, customers, vendors, contractors, and the general public and to provide for the efficient and effective operation of the Company. SCOPE This policy applies to all employees and to any person (s) who has access to any Company facility or equipment, or who may perform work in conjunction with the Company's operation. POLICY

1. The use, sale, or possession of controlled substances (defined as any narcotic, drug or drug-like substance for which the sale, use, or possession is either unlawful or is being utilized outside of a prescribed medical treatment) during working hours, on assignment, or on Company property is a dischargable offense.

Any controlled substances will be turned over to the appropriate law enforcement agency and may result in criminal prosecution. The use or presence of such controlled substances in an employee's physical system (s) will result in disciplinary action up to and including discharge. *

2. Off-the-job use of controlled substances which could adversely affect an employee's job performance or which could jeopardize the safety of other employees, the public, or Company equipment is proper cause for disciplinary action up to and including discharge.
3. Employees who are arrested for off-the-job activity relating to any controlled substance may be considered to be in violation'of this policy. In deciding what action to take, management will take into consideration the nature of the charges. the employee's present job assignment, the employee's record with the Company and other factors relative to the impact upon the conduct of Company business.
4. Employees undergoing prescribed medical treatment with a legally controlled drug should report thin treatment to the Health Center. The prescribed use of legally controlled drugs as part of a medical treatment program is naturally not grounds for disciplinary action, although it is important for the Company to know such use is occurring. Failure to provide such notice to the Company in a timely manner may result in disciplinary action.

Effective 1/1/86

e TOLEDO EDISON COMPANY POLICY ON THE USE OF DRUGS AND ALCOHOL Page'2 s d s

5. The Company is a public utility and the actions of our employees in their use of alcoholic beverages will directly impact our .

public image, customer relations, and our safe working conditions. Employees are expected to exercise common ser.co in their use of alcoholic beverages and no nicoholic beversges are to be brought ' on Company property at any time without the prior approval of the mission head. Alcoholic beverages should not be consumed between the beginning and ending times'of the regularly scheduled work day, during otler work assignments, or inmediately prior to reporting for work. 'Ench Mission Head may develop more specific guidelines on their employees' use of alcoholic beverages. Any violations of either this section or the mission guidelines will result in disciplinary action up to and including discharge.

6. If off-the-job use of alcohol leads to unsatisfactory job performance, excessive absenteeism, a poor safety record, or misconduct, then the Company is directly concerned and will act accordingly. In deciding what action to take, management will ,

take into consideration the employee's present job assignment, his/her record with the Compary and other pertinent factors.

7. Employees who voluntarily request assistance in, dealing with a personal problem involving controlled substances may participate in the Employee Assistaace Program without jeopardizing their continued employment with the Company, provided they stop any and all involvement with controlled substances. The Employee Assistance Program will also continue to be available to any employees who feel that they may have a substance abuse problem. In either case, the Company Employee s Assistance Coordinator will refer employees to an appropriate [

treatment resource. Volunteering to participate in the Fmployet i Assistance Program, in and of itself, will neither cause nor prevent disciplinary acti)n for a prior violation of any Company' policy which has already Occurred or a subsequent violation that. ' may occur after the emplojee completen the program or returns to work. ADMINISTRATION [ Each employee is responsible for ensuring Th at, thin policy in observed. Management personnel will enforce.this policy by either i promptly transporting employees who are obnerved as potentially being under the influence of alcohol or drugs to a designated facility for a " fitness for duty examination" or removing the employee from the Company premises. Such employees who are referred for a " fitness for duty examination" will be required to sign an " Employee Connent i Form". Failure to comply with either the signing of the consent fo rm or submitting to the examination will result in the employe?'s; immediate suspennion for gross insubordination and will be'tonsidered grounds for discharge. i Effecti,ve 1/1/86 

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                                                . s ,

b ._ -

l '- U.S. Departme t cf Justice Drug Enforcement Administration Controlled Substances : Use, Abuse and Effects Commonly misused drugs, their uses, abuses, effects, and the symptoms they produce. DEFINITIONS Drug: A substance which by its chemical nature alters the making accurate diagnoses. Therefore it is important not to structure or function of the living orgamsm. (For the purpose act on your own for it could lead to falsely accusing an inno. of this bulletin, a drug is any chemical substance that alters cent person. Seek professional advice and help from the mood, perception, or consciousness, and is misused to the ap- experts, such as various agencies specializing in drug problems, parent injury orthe individual or society.) and physicians. Tolerance: A state in which the body's tissue eells adjust to it should also be remembered that a per.on may have a the presence of a drug. The term " Tolerance" refers to a state legitimate reason for possessmg a syrmge and needle the may in which the body becomes used to the presence of a drugin be a diabette)or havmg tablets and capsules (they may be pre-given amounts and eventually fads to respond to ordmanly senbed by a doctor). Itaving the sniftles and running eyes may effeettve dosages. Hence, increasingly larger doses are nec- be due to a head cold or an allergy. Unusual or odd behavior essaiy to produce desired effects, may not be connected in any way with drug use. Habituation (psychological dependence): The result of re- Drugs other than narcotics can become addicting. Some peated consumption of a drug which produces psychological people have acquired an addiction to sedatives and certam but no physical dependence. The psychological dependence tranquilizers. Stimulants in very large doses are addict.ve. produces a desire (not a compulsion) to continue talung drugs NOTE: Never ta:te an unknown substance. for the sense ofimproved well being. Physical Dependence (addictioni: This occurs when a CO%f 3f 0N SIGNS OF DRUG SilSUSE person cannot function normally without the repeated use of a

1. Changes in attendance at work or school.

drug. If the drug is withdrawn, the person has severe physteal

2. Change f rom normal capabilities (work habits.efileiency.

and psychic disturbance. 

                                                                                       '8-Harmful Drugs: Are all drugs harmful? Every drug is narm-
3. Poor phy swal appearance,ineluding inattention to dress ful when taken in eteess.e g., even aspirin and, of course, and personal higiene.

alcohol. Some drugs can also be harmfulif taken in dangerous eombinations or by hyper sensitive people in ordmary amounts. # *"" 8 5"" $ '5 l 5 ' " 5 ' '" 'IY 3 8 '"3PP' P"8" ' * (i"" doors or at night, for instance)not only to hide ddated or constricted puptis but also to compensate for the eye's inabdity IDENTIFYING Tile DRUG USER to adjust to sunkght. Manjuana causes blood shot eyes. A drug user will do every thing posuble to conceal his habit. 5. Unusualeffort made to cover arms in order to hide So it is important to be able to recognize the outward ugns needle marks. and symptoms of drug misuse. One should be alert to these 6. Asocist,on with known drug users. symptoms, but it is important to reahze that the drug preblem 7. Steahng items which can be readdy sold for cash tto is to comples that even experts sometimes have dif ticulty support a drug habiti iContinued on back page.)

[.:} i lt.: Drugs P. NTROI Schedule I Trade or Other Names FD AllR! Medical Uses Physical ' Depen. dance 

                                                                                                                                                 9 "#'

Op.um 11, it1. V N,*,NioY"' Analgesic, antidiarrheal High Morphine 41, lll Morphine. Pectoral Syruo Analgesic, antitussive Codeine n. in. v e Wnme9mfAc*==IC r,d Anaige c. anticusme uod-ate 

                                                                                 ~

Heroin i Diacervimorphine, Horse, Smack Under investigation Hydromorphone Dilaudid Anaigesic 

                                                                       ^ '                                                                                                                           High M Meoeridine (Pethidine >         E       n      E o'rnerol. Pethados                 l        An sige ,ic             E Dobonine, Methadone,                    Analgesic, heroin                        NM Methadone                                 Methadese                              substitute LAAM, Leritine, Levo-Drom-g U     "I-    oran, Percodan, Tussiones,           Analgesic, anti-Fentanyl. Darvon *.

H Other Narcotics IV,V diarrheat, antitustive Taiwin* Lomotel IV Noctec, Somnos Hy pnotic j ( Chloral Hydrate l l Moderate Amobarb.tal, Phenobarbital, Anesthetic. High-Barbiturates ll, Ill, IV Butisol, Phenonbarbital, anticonvulsant, Modvate Secobarbital. Tuinal sedative, hy pnotic E k_ W"*'" Glutethimide E 111 E Doridea Optimil, Parest, Quaalude, E Sedative, hypnotic High Methaoualone u Somnaf ac, Socor e 

                                                                   -         "M                                               Ativan. Atene, Cionopin, Dal-        Ante an xiety, ante IV          mane, Diazepam, Librium. Serax,      convulsan t, sedative,             Low
                         - "Ti                               '

Benrodiazepines Trannene Valium, Verstrasi hypnotic 

                                                                                                                                               "      "*          ^"            n Moderate
                                                                              ' Other Depressants               ill, tV       pi/e$',,$mid Q
                                                                                                                                                 '                hv$'"igery, o              sedative,
                                                                                                                   !!         Coke, Flake, Snow                       Local anesthetic Cocainet Biohetamine, Delcobese.

Amphetamims y, ni Desouvn. Deredrine, Mediatrie 

                                                 $lhl                     1         Phenmetrarine          E              E Preiudia                           E      Hvoorkinesis.

narcolepsy, Possible Methylphenidate Ritalin Adipe x, Bacarate, Cylert, De-Other Stimulants Ill, iV dy,",-{" nam,in, 

                                                                                                                                            ,, n ge'a"ti. Pro-Tepanil, Voranil LSD                                       Acid, Microdot None None Mescahne and Peyote                   E Mesc, Buttons Cactus              l 2       A.P M ^                                                      Unknown Amphetamine Variants                                   A       '008-Phencyclidine                   11        PCP, Angel Dust. Hog                Veterinery anesthetic            o,gr,,

Phencyclidine Analogs PCE, PCPy TCP unknown Buf tenine, gaim, DM, gon, Other Hallucinogens DET, Psilocybin. Psilocyn I Pot. Acaoutco Gold. Grass. ' Marihuana Reefer, Sansemilla, Thai Sticks f nwe,tigation Degio Tetrahydrocannabinol i THC E unknown Hashish Hash l Hashish Oil  % Hash Oil  %

Psychological CFR:USES & EFFECTS Tol- 0 

                               ,,uNec"ts           Usual Methods
                                                                         '                              Elfects of      M Withdrawal erance                                                   Poss.ble Effects Dependence                  (in hours)          of Administration                                    Overdose               Syndrome Oral, smoked High Watery eye ,

l Oral. insected smoked l Slow and Moderate I 36 E Oral, injected Euphoria, dr E iniected. inifred. imoked E ,e,owsiness,

  • allow tseathing, ciammy yawning, losset appetite.

oi,atory irritability, deoression, ik'". Con, tre ws, High Yes constricted vulsions, Dac, chills pupils, coma. poss ble ating. 12-24 Oral. insected nausea nausea High Low Variable l Moderate l Possible 5-8 l Oral High- Shallow Moderate I*10 Slurred respiration. An xie ty, speecn, cold and insomnia. clammy skin, tremors. I disorientation, High drunken behavio, dilated delirium, Yes Oral. injected ,,thout pupils, weak convulsions. odor of andrapd possible 4,g alcohol pu'se. coma, death Low possible death Moderate E Possible E 12 .E Snitted. iniected E Increased alert- Agitation, in. Apathy, ness excitation. crease in body long Oral. injected euphoria. in- temperature, periods of creased puise hallucinations, sleep, l I2,4 High Yes rate and blood convulsions. imtability, pressure, possable depression, Oral 'nsomnia. loss death disorientation of appetite 8 12 l Oral l ogree unknown E ,, ton ,e,, mo,e Yes Up to days 

                                                                                                      'ntense " trip **        Withdrawal h lu ina ions.

poor perception . episodH. syndrome not reported psychosis. Smoked, oral, infected of time and posuble deatn l g ,, I distance E po,,,b,e E E Orai.iniected.imoied. . E E E mif fed Euonoria, re- p ,jgy,, ,"c ,,;,y, Smoked, oral ' ' t 0"S. I Moderate paranoia, and decreased Ifes I24 tite, disoriented psyChosas oCCasiorVlly reported

  • Not designated a narcotic under the CSA t Designated a narcotic under the CSA l

m INDICATIONS OF POSSIBLE MISUSE DEPRESSANTS e.g., Quaalude, Doriden (Barbiturates / OTHER HALLUCINOGENS A. Behavior like that of alcoholintoxication, but without

  • A. Behavior and mood vary widely, he user may sit or the odor of alcohol on breath. recline quietly in a trance-like state or may appear fearful or B. Staggering, stumbling, or apparent drunkenness without even terrified.

odor or use of alcohol. B. In some cases, dilated pupt!s. C Falling asleep while at work. C. Increase in blood pressure, heart rate, and blood sugar. D. Slurred speech. D.May experience nausea, chills, dushes, irregular breathing, E. Pupils dilated. sweating and trembling of hands. F. Difficulty concentrating. E. There may be changes in sense of sight, hearing, touch, smell, and time. STIMULANTS / Amphetamines / It is unlikely that a person who uses LSD, for instance. A. He user may be excessively active,irntable, argumenta- would do so at work, since a controlled environment, often in-tive, or nervous. volving a friend to provide care and supervision of the user is B. Excitation, euphoria, and talkativeness. generally desired. C. Pupils dilated. D. tong periods without eating or sleeping. E. Increased blood pressure or pulse rates. GLUE OR HYDROCARBON (Casoline/ SNIFFING A. Odor of substance mhaled on breath and clothes. B. Excessive nasal secretion and watering of the eyes. NARCOTICS A. Sears (" tracks") on the arms or on the backs of hands, 

                                                                                             """"' *' # " ""' I 8 8'"" 8 I *#"    "N""'"

f exposure. caused by injecting drugs. D. Drowsiness or unconsciousness, B. Pupils constricted and fixed:possibly dilated during E. Presence of plastic or paper bags or rags contaming dry withdrawal. plastic cement. C. Scratches self frequently. D. toss of appetite. Frequently eats candy, cookies, and uned sPd G. Bad breath. drinhs sweet liquids. E. May have snif0es, red, watering eyes and a cough which disappears when he gets a "fix" During withdrawal the Phencyclidine (PCP) addict may be nauseated and vomiting. Flushed skin, Phencyclidine, developed in the 1950's,is now licitly manu. frequent yawning, and muscular twitching are common. These factured as a vetennary anesthette under the trade name symptoms a'so disappear when the addict gets a "fix" Semylan. Since 1967 it has also been produced in clandestine F. Users often leave synnges, bent spoons, cotton, needles, laboratories, frequently in dangerously contammated forms. metal bottle' caps, medicine droppers, and glassine bags in De prevailing patterns of street. level abuse are by oral locker or desk drawers, ingestion of tablets or capsules, containing the drug in powder . . G. The user is lethargic, drowsy, and may go on the " nod" form both alone and in combination with other drugs, and by (i.e.. an attemating cycle of dozing and awakenmg.) smoking the drug after it has been spnnkled on parsley, mari. H. Anyone dissolvmg tablets for mjection runs a great nsk huana, or some form of tobacco. It is sometimes sold to un-and danger oflung impairment due to deposits of talcum suspecting consumers as LSD, THC, or mescalme. Peported (part of the tablet) obstructing or occluding the lung through experiences under the influence of phencyclidine are mainly the blood stream. nondescript or unpleasant. In low doses the expenence usually proceeds in three succesnve stages: changes in body MARIJUANA image, sometimes accompanied by feelmgs of depersonaliza-A. In the early stages of manjuana usage, the person may tion; perceptual distortions, infrequently evidenced as visual i appear animated with rapid, loud talking and bursts oflaugh. or auditory hallucinations;and feelings of apathy or estrange-l ter. In later stages,he may be sleepy. ment. The experience often meludes drowsmess, inability to B. Pupils may be dilated and the eyes bloodshot. verbalize, and feelings of emptiness or " nothingness." Reports . C. May have distortions of perception and ha!!uem:tions, of difficulty in thinking, poor concentration, and preoccupa. The marijuana user is difficult to recognize unless he is tion with death are common. Many users have reacted to its actually under the influence of the drug, and even then, he may use with an acute psychotic episode. Common signs of be able to work reasonably well. The drug may distort his phencyclidine use include flushing and profuse sweatmg. depth and time perception, making dnving or the operation of Analgesia, involuntary eye movements, muscular incoordina-machinery hazardous. Long continued use of marijuana has tion, double vision, dizziness, nausea, and vomiting may also been associated with mental deterioration. be present.

u. ~ rmm n:v :n :rt::t ne: nt.u. -

f s

l ADMINISTRATION OF THE DRUG AND ALCOHOL POLICY Introduction The following personnel procedure and guideline is designed to assist the foremen, supervisors, and all management members in the administration of the drug and alcohol policy. This procedure is to be utilized in conjunction with the Drug and Alcohol Policy and is intended to ensure that it is enforced. 

 .I. THE " FITNESS FOR DUTY EXAM" (FDE)
1. Testing Levels Fitness for duty exams will be tailored to the individual situation and may range from urine sample / blood serum screening to a complete physical examination.

The FDE will reveal the presence of any alcohol, cocaine, opiates, amphetamines, barbituates, methadone, PCP, and benzodiapines. The test will also show the presence of marijuana in excess of 20 nan /ml.

2. Type of Test The Company will use an initial test and a confirmation test.

The initial test will be administered "in-house" at the health centers or designated location, and will require the employee to sign a consent form. This test will utilize a urine sample and/or a blood serum screen. An initially positive test result will be submitted to an outside laboratory for a confirming test. This confirmation test will take approximately 48 hours.

3. Who will receive " Fitness for Duty Exam" A. For Controlled Substances:

There are seven ways in which persons may routinely receive a fitness for duty examination for controlled substances. These are: (1) New Job Applicants; (2) innual Physical Examination for Nuclear Security Officers and Nuclear Operators;

ADMINISTRATION OF THE DRUG AND ALCOHOL POLICY , Page 2 l

3. Who will receive " Fitness for Duty Exam" (Continued)

A. For Controlled Substances (3) Any employee absent from work for thirty (30) continuous l days or more and/or any employee who is "off due to sickness" for thirty (30) days, continuous or not, in I a calendar year. Employees who are off due to major l surgery or clearly identified physical ailments may not l be subject to receiving this exam. 1 (4) Employees arrested for "off-work" drug activity. (5) Employees who have completed the Employee Assistance Program, for drug and/or alcohol abuse, and have returned to the work piece will routinely receive a fitness for duty examination four (4) times, unannounced. within their first year of returning to work. l (6) Employees who are transferring to Davis-Besse and require plant access may receive an exam. l (7) Random testing at Davis-Besse. There are two ways in which an employee may be referred.by a supervisor for a " fitness for duty" examination (Note enclosed example of " Employee Consent / Supervisor Referral" Form) . These are: . 

                *(8)   Behavioral observation - If an employee is observed to potentially be under the influence of controlled substances.

(9) Post Accident - If an employee has an industrial accident and the reasons for its cause are either unclear and/or the supervisor believes it should not have occurred and the Safety Department agrees. B. For Alcohol All testing for the presence of alcohol, for the purpose of either removing the employee from the work place or taking disciplinary action will be performed under three (3) conditions via a supervisor referral (Note enclosed example of Employee Consent / Supervisor Referral" Form) . These three (3) ways are: 

                 *(l)   Behavioral observation - If an employee is observed to potentially be under the influence of alcohol.

(2) Confirmation of Fitness for Duty - The supervisor has legitimate reason to question the employee (s) freedom from the effects of alcoholic beverages. Such reasons may include the following examples of having observed the employee drinking alcoholic beverages at lunch or the odor of alcohol on the employee.

  • Refer to Section II, Supervisor Guidelines

ADMINISTRATION OF THE DRUG AND ALCOHOL POLICY Page 3 B. For Alcohol (Continued) (3) Post accident - If an employee has an industrial accident and the reasons for its cause are either unclear and/or the supervisor believes it should not have occurred and the Safety Department agrees. l

4. Treatment of Employee (s) During The Examination Employees referred for a fitness for duty examination will normally continue to be paid their normal work code during such testing subject to Item 5 below.
5. Test Results I A. Negative - Controlled Substances and Alcohol If the results of the test are
  • negative, then the employee will normally be considered fit for duty.

However, even though such tests are negative, no employee should be allowed to continue working, for any reason, if they do not appear capable of performing their job in a safe manner. Such employees should be dealt with on a case-by-case basis as discussed between the supervisor and either Union Relations or Management Compensation and Development and, if appropriate, the Company's Employee Assistance Coordinator. Employees with drug or alcohol related problems are encouraged to refer themselves to the Employee Assistance Program. Such employees, if they have not otherwise violated the policy, will not be discharged or subject to discipline. They will, however, be subject to four (4) fitness for duty examinations, unannounced within the first year of completing the program. B. Positive Controlled Substance Any employee found to have a positive test result to a controlled substance, including marijuana, will be subject to discharge. If unusual er extenuating circumstances exist, then a complete review of the facts, the employees work record, and/or other pertinent data will be conducted. Upon the results of this review, if circumstances warrant, some action other than discharge may be found appropriate. 

  *To be defined hereafter.

ADMINISTRATION OF THE DRUG AND ALCOHOL POLICY Page 4

5. Test Results (Continued)

C. Positive Alcohol (1) Blood Alcohol Content (BAC) of .09% or below: The employee will receive a written reprimand and be allowed to return to work if the supervisor believes he/she can work safely. If the supervisor believes the employee cannot work safely, then the employee will be released from work (Code 84). (2) Blood Alcohol Content (BAC) of .10% or above: The employee will be removed from the work place (Code

84) and receive a one (1) day unpaid disciplinary suspension. The employee should also be referred to the Employee Assistance Program.
6. Future Violations:

A. Controlled Substances Any employee who is not discharged for the first violation will be discharged upon any second occurrence regardless of the length of time between incidents. B. Alcohol Progressive discipline will be utilized for any future violations on the following basis: OCCURRENCE BAC ACTION First .09 or under Written Reprimand Second .09 or under 1-Day Unpaid Suspension Third .09 or under 3-Day Unpaid Suspension Fourth .09 or under Discharge First .10 or above 1-day Unpaid Suspension Second .10 or above 3-day Unpaid Suspension' Third .10 or above Discharge Combirations of previous disciplinary actions for varying blood alcohol levels may occur. However, upon the fourth occurrence of any BAC, the action taken should be discharge.

7. Other Policy Violations A. Sale or possession of controlled substances on Company property or during work assignment.

Normally, any employee who is found to either be conducting the sale of, or have controlled substances in their possession, for either their personal use or for sale, shall be subject to immediate discharge.

l ADMINISTRATION OF THE DRUG AND ALCOHOL POLICY f Page 5 a

7. Other Policy Violations (Continued)

B. Possession of Alcoholic Beverages on Company Property , l or During Working Hours. i l Employees who bring, utilize, or maintain alcoholic beverages on the Company premises without the expressed permission of their mission head, or consume such beverages during working hours, will be subject to a # 3-day unpaid disciplinary suspension. C. Employees Arrested for Off-The-Job Activity Involving Controlled Substances. Due to the impact of this type of publicity and the varying factors which must be taken into consideration, it is impossible to state a general rule which will be followed in the event of such an occurrence. The supervisor should contact either Union Relations or Management Compensation and Development, Industrial Security and the Legal Department to discuss what is the best possible approach of dealing with this situation. D. Other Violation of the Policy Which are net Covered in this Procedure. The Corporate Drug and Alcohol Policy is a dynamic document. As previously stated, its intent is to provide a safe work place for all the employees, the public, and our customers. If you believe that other violations of the Policy have occurred which are not specifically referenced herein, please contact the Union Relations Department. 

                                                                                                                             ~

II. SUPERVISORY CUIDELINES FOR ADMINISTERING THE POLICY These guidelines are for use by supervisors at all levels throughout the Company. They are intended to provide assistance in the administration of the Company's drug and alcohol abuse policy.

1. All supervisors have a responsibility to assure themselves that employees under their supervision are at all times fit to perform their duties safely and are free from the influence of ,

, alcohol and/or controlled substances. ,

2. Employees who have a drug and/or alcohol problem and who ask for help should be referred irmediately to the Company's Employee 4 Assistance Program (example of form enclosed). This request for assistance will not excuse employees from possible disciplinary '

action for violation of Company policy.

ADMINISTRATION OF THE DRUG AND ALCOHOL POLICY Page 6

3. Each supervisor is responsible for taking appropriate action whenever an employee's demonstrated judgment or performance appears to be impaired by the possible use of drugs and/or alcohol.

When a supervisor suspects that an employee is " unfit for duty", the supervisor should arrange, if practical, for at least one l other supervisor to observe and evaluate the employee's behavior. The employee's supervisor should ask the employee to explain why he/she appears unable to perform the job. Should the employee fail to explain the condition to the supervisor's satisfaction, and it is still the supervisor's determination that the amployee may not be fit for duty (controlled substances and/or alcohol may be involved), the supervisor should accompany the employee or arrange for him/her to be taken by an-other u3nagement employee to the designated facility, normally the Health Center, for examination. If the employee refuses to go, he/she should be advised that a refusal will be considered in any disciplinary proceeding and the employee should be withheld from service pending further investigation. Depending upon his/her condition, arrangements should be made for the employee to be taken home.

4. When a supervisor observes the use, sale or possession of controlled substances by employees on the job, the supervisor should take the following steos:

A. Immediately confiscate, if possible, all drugs and/or paraphernalia. Contact another supervisor and the Industrial Security Department to direct any further investigation necessary. B. Separate the employees involved and take them to a location where they can be questioned individually by the Security Department about the incident. C. The incident should be reported to your superior as well as the Industrial Security Department. It may also be necessary to take action if the employee appears to be under the influence of the controlled substance the employee was observed with. In this case, refer to Item II-3 in these guidelines. D. Turn any confiscated drugs and/or paraphernalia over to the Industrial Security Department, which can be reached during work hours at (419) 249-5281. During other than work hours, call the TED Operator at 249-5000 and request her to utilize the Security Control List. E. If the employee has not been removed from Company property by law enforcerent personnel, send him/her or take him/her home, depending on the employee's condition. Remove the employee from service. Make no commitment regarding whether the employee will be paid or what discipline will follow.

ADMINISTRATION OF THE DRUG AND ALCOHOL POLICY Page 7

5. Following any incident that might fall under these guidelines, it is essential that the supervisor immediately make a detailed record for management of all actions, observations, statements and other pertinent facts, to include date, time, location, and l witnesses to the incident.

l l 6. When a supervisor learns that an employee has been arrested for I a drug-related of fense of f duty, that supervisor should immediately contact Union Relations if its a union member, or Management Compensation and Development if not a union member, and Industrial Security Department. A determination will be made by either Union Relations or Management Compensation and Development as to whether the employee shall be withheld from I service pending further investigation.

7. If drugs or drug paraphernalia are found on Company property and it is not obvious who the owner is, the first step should be to report the incident to your superior and the Industrial Security Department. An effort will be made by the Industrial Security Department to determine the owner of the item by questioning supervisors or employees who may have been in the immediate area. The Industrial Security Department may contact the appropriate law enforcement authorities and all drugs and/or illegal drug paraphernalia turned over to them. A signed receipt will be obtained from the law enforcement authorities.
8. If a supervisor receives a report that an employee has violated Company policy' the supervisor should obtain as much detailed information as possible from the person reporting the violation.

The supervisor's superior and the Industrial Security Department should then be notified. Unproved allegations of drug and alcohol policy violations shall be kept highly confidential and shall only be discussed with appropriate management-level individuals who have~a need to know by virtue of their position of responsibility. [ Supervisor should also refer to the Question and Answer information below.] . III. QUESTIONS AND ANSWERS FOR SUPERVISORS Q. How can I tell wher an employee is "not in a condition" to perform his work? A. An employee's physical appearance, unusual behavior, slurred speech, incoherent manner, lack of coordination, etc. may indicate that he is "not in a condition" to perform his work. Observation of job performance should be indicative. Is he drowsy, careless, inattentive? For specific signs of possible drug and alcohol use, a supervisor should refer to the training and printed material that has been provided Q. Is it possible for a supervisor to determine whether an employee is actually under the influence of alcohol or drugs?

ADMINISTRATION OF THE DRUG AND ALCOHOL POLICY Page 8 A. A chemical analysis is a definit e method to determine the concentration of drugs and alcotol in an individual. Supervisors can make a judgment whether an employee appears to be fit for duty. If a " fitness-for-duty" exam is taken, specific conclusions will be reported. When an exam is not administered, the supervisor (with the aid of another supervisor's opinion [when available]) can reach a determination that would be valid for purposes of safety and discipline. Q. What should I do if an employee comes in smelling of an alcoholic beverage? A. The presence of an alcoholic. beverage odor alone is not a fool-proof indication that 2n employee is under the influence. It is, however, a strong ir.dicator and should be investigated. The employee should be taken to a place with privacy where it can be determined if the odor is being emitted in the breath. An interview and " fitness for duty exam" should be conducted to determine if an alcoholic beverage was consumed and, if so, what, how much, when and where. The employee should be closely observed for any other indications of possible alcohol influence. Results of the interview, observation and " fitness for duty exam" will assist in determining action to be taken, if any. Q. How should I handle borderline cases where I think the employee may be " unfit for duty" but 1 am not sure? A. No guidelines can be so specific as to cover every situation. Two factors should be kept in mind, however. First, safety is always our primary consideration, and if any doubt exists about an employee's fitness to perform a specific task, take the employee off the job. Second, referral of an employee to the Employee Assistance Program or for a fitness-for-duty exam is not a form of discipline. If the lab reports back that the employee had no foreign substances in his system, the employee is simply paid for the time he was withheld from service. Do not be afraid to use the procedure when doubt exists, though use should not be so frequent that employees feel harassed. Q. Why is it important for a member of supervision to accompany an employee to a fitness-for-duty exam? A. Three reasons: (1) in most cases, when an employee is unfit to do his job, he is also unfit to drive to the Health Center or other desingated location; (2) it is important that a fitness-for-duty exam be administered as soon as possible to get an accurate indication of the employee's condition when he was on the job (some chemical substances are undetectable within just a few hours of their being taken); (3) supervision should be present and in control of the situation to ensure that appropriate action is taken.

ADMINISTRATION OF THE DRUG AND ALCOHOL POLICY Page 9 , Q. What should a supervisor do if an employee will not allow anyone to I drive him home? l A. Supervision should take all reasonable steps to ensure that someone l unfit for duty and possibly under the influence of drugs or alcohol l does not drive. If the employee will not ride with a supervisor, try to get a family member to pick up the employee. If necessary, advance the appropriate funds for whatever transportation arrange-ments must be made. If the employee will not accept any of these arrangements and insists on driving himself, the local police should be advised of the circumstances and a record made of what transpired. Q. How long does it take to get the results back from a fitness-for-duty exam? A. It may take up to 48 hours for a confirmation test. If other tests or exams are needed, it may take three to five days. When the medical resource takes the samples, it may also be sent to a laboratory for analysis. During this time, the employee should be withheld from service. The health center staff will notify the employee's immediate supervisor and/or the designated Company representative of the results of the exam. Q. What should I do if I see a number of employees using drugs and the possibility exists th at they may become hostile if confronted? A. Get help. Contact the Industrial Security Department and other supervisors. Supervisors should not allow illegal activity on Company property to go unchallenged. They should not, however, subject themselves to unnecessary risk. O. What should I do if an employee refuses to surrender a suspicious subste.nce when so instructed? A. Request that the employee accompany you to your. office or work Station while observing that he does not dispose of the subs tat:ce . Repeat your instruction in the presence of another supervisor, if possible, warning the employee thet continued refusal could result in discipline up to and including discharge. If the employee still refuses, contact the Industrial Security Department. Be sure to consult with your superior and with Union Relations of Management Compensation and Development. Q. How important is it to have another supervisor present when 1 question an employee?

I 1 ADMINISTRATION OF THE DRUG AND ALCOHOL POLICY Page 10 A. It is very helpful, especially if the employee chooses to challenge your action later on. It is also helpful for supervisors to have the benefit of a second management opinion. Q. Is it lawful for supervision or Company security personnel to inspect lockers, desks, or work stations? A. Yes, however, there should be a common sense, reasonable basis for such an inspection, ranging from implementation of a periodic inspection policy to specific reports of possible policy violation by an individual employee. Caution must be taken, however, to avoid any searches that are discriminatory or harassing in nature. If it's a union member, it is a good idea to have another member of management and a union representative t.s witnesses. The results of such inspections may provide a basis for disciplinary action. If the purpose of the search is criminal prosecution, the Industrial Security Department and possibly local law enforcement should be involved. Q. What should I do with any drugs that I find? A. Each Company operating area vill not always have a member of the Industrial Security Department on site. Contact the Industrial Security Department and call your superior. Keep the suspicious substance under your direct custody to avoid it being tampered with, and turn it over to Industrial Security as quickly as possible. Q. What if an employee is arrested off Company property for suspected drug activity? A. Call Union Relations if it's a union member or Management Compensation and Development if not a union member. We have a right to determine if an employee's off-the-job actions represent a violation of Company policy. If the facts indicate violation of Company policy, the Company has a right to take disciplinary action regardless of the outcome of any court action. Each situation will be judged on the circumstances of the arrest, and the impact the arrest may have on Company operations. Q. What if an employee says he has been drinking when he is called to come to work on a stand-by or emergency basis?

ADMINISTRATION OF THE DRUG AND ALCOHOL POLICY Page 11 A. The supervisor must respect the need for fitness for duty. Get someone else to do the job. Remember Company policy prohibits working when "under the influence." The employee involved should be advised that the job does require him/her to be available to work on an on-call basis. If an employee is regularly unavailable to respond when on call or on an emergency response status, disciplinary action is appropriate. When an employee is not required to protect his service on an off day and is then called to work, and he states that he is under the influence of drugs and/or alcohol, he will not be called to duty. If this situation persistently reoccurs, the employee should be referred to the Employee Assistance Program. Q. Who do I contact for a fitness-for-duty exam? A. Each Company operating area should contact the nearest available Health Center (refer to Page 12). The urine test procedures and consent form will have been provided to such locations. A supervisor should accompany the empicyee to the location for testing and the employee shall be withheld from service pending results of the test. The health center staff will notify the employee's immediate supervisor and/or the designated Company representative of the results of the exam. Q. If I see someone using what I suspect may be alcoholic beverages and/or drugs on the job, what should I do? A. Take immediate steps to intervene so that such activity is terminated. Even if the individual does not report to you, as a supervisor, you should intervene or take steps to see that immediate attention and intervention by management takes place. As a supervisor, it is your obligation to support Company policy. Company policy prohibits possession or use of alcohol or drugs while on the job. Determine as best you can exactly what was taking place, document exactly what you have observed. Confiscate any containers or contraband found and r take administrative action, including relieving the employee (s) from duty as appropriate. Q. What should I do if I hear about the use or buying / selling of illicit drugs either at work or away from the worksite? A. If you hear rumors of drug use, even though you have not actually seen anyone using illicit drugs, consult with your own superior about what you have heard. If you have reason to believe an employee is involved in criminal activity such as selling drugs or stealing to support a drug habit, report the facts to your supervisor and the Industrial Security Department and direction will be provided.

ADMINISTRATION OF THE DRUG AND ALCOHOL POLICY Page 12 Q. What level of alcohol or other drugs does the Company consider to be "over the limit"? A. The issue is not just the level of alcohol or other drugs but the use of these substances. The use of any of these substances may impact an employee's judgement and ability to work safely. Q. Does the Company plan to have searches for illegal drugs conducted on Toledo Edison property; and what is the position of the Company with respect to use of dogs to find drugs? A. Company management reserves the right to authorize inspections for illegal drugs or contraband. Such actions may involve an individual employee or groups of employees. The Company does not intend to search indiscriminately lockers or personal vehicles on Company property, but will-do so in order to protect the safety of the work location and to investigate possible violations of the law and Company rules. The use of dogs to search work locations has taken place and the Industrial Security Department will decide if and when such action is needed. IV. ADDITIONAL INFORMATION:

1. Health Center and other designated locations for Assignments; the following health center assignments are made for the referral / escort of employees by supervisors.

Davis-Besse - Davis-Besse Health Center Acme and Bay Shore - Bay Shore Health Center Holland and Delaware - Plaza Health Center Lakewood - Bay Shore Health Center Eastern District - Davis-Besse Health Center Defiance District - Defiance Hospital - Emergency Room Western District - Fulton County Hospital - Energency Room During hours when the health centers are not normally open, arrangements have been made with the following energency room facilities to accept urine and blood serum specimens and employees may be referred / escorted to these locations:

ADMINISTRATION OF THE DRUG AND ALCOHOL POLICY Page 13 Toledo - St. Charles Hospital St. Vincents Hospital Port Clinton - Magruder Hospital Defiance District - Defiance Hospital Western District - Fulton County Hospital When using these facilities ALL appropriate authorization and consent forms must be completed and submitted to the hospital staf f person assisting you. The hospitals will not have a supply of these forms.

2. Information received regarding an employee who is taking legally prescribed drugs which may impact his ability to perform work in the work place will be closely monitored by the Company and kept confidential.

If it is determined that an employee cannot safely perform his duties due to his being under the influence of a legally prescribed drug, the Company will accommodate him/her through job re-assignment (where possible). If not possible, the employee should be informed that there is no work available which can safely be performed and the time should be recorded as off work due to illness.

3. It is strongly suggested that supervisors, in dealing with employees, make certain that the Employee Assistance Program is well communicated. This may be done by referring to the Employee Information Booklet which contains information on the back page on the Employee Assistance
            ?rogram.
4. If at any time a supervisor or manager has either a question or problem they would like to discuss in greater detail, it is imperative that they either contact the Union Relations Department or Management Compensation and Development. It is understood that these guidelines will not cover every situation and that some prudent decision making must occur to effectively police the Drug and Alcohol Policy.

EMPLOYEE ASSISTANCE PROGRAM The Employee Assistance Program is designed to assist Toledo Fdison Employees and their dependents in dealing with various personal problems such as alcohol or drug dependence, emotional stress, marital difficulties or severe financial situations. Any of the listed problems can have a negative effect on the job performance of the employee. The EAP counselor helps employees assess their problems and make referrals to other outside resources for treatment or assistance. Employees who are referred to outside resources such as doctors or psychologists, will be responsible for professional fees. The Company's medical plan does cover medical treatment and psychological counselling services. Consult the employee handbook or call the Employee 3enefits and Health Services Department for details. There are two ways in which an individual may become involved in the Employee Assistance Program. The first and preferred way is for the employee to seek confidential help volun-tarily; that is to realize the existence of a problem and to contact the Company EAP Coordinator, or Family Services or Northwest Ohio directly. The second method of employee involvement is through a Toledo Edison Supervisor on a Company referral. If an employee's job performance continues to deteriorate, despite corrective actions initiated by the Supervisor, a recommendation of referral to the Employee Assistance Program may follow. Please remember that employees are strongly encouraged to contact the EAP Counselor before drug or alcohol problems lead to disciplinary action. At that point, volun-teering to participate in the EAP will not lessen or prevent disciplinary action. EAP COUNSELORS: Tony Donisi, Manager Rosemarie Siebert-Earbeau, Counselor Wendy Seymour, Counselor TOLEDO 244-5511 PORT CLINTON 732-3569 BOWLING GREEN 352-4624 CENOA 855-3906

EMPLOYEE ASS 1 STANCE PROGRAM REEERRAL RECOMMENDAT10N TORM Name of Employee Being Recotmnended for Referral Department Date oi Employment Month Year Job Title Length of Time in Current Position Month Year Name of Supervisor Making Referral Ti tle Date Form Received by Coordinator initial (For each of the job performance problems listed below, circle the number which best de-cribes this employee's present performance.) JOB PERFORMANCE PROBLEMS EXTENT 07 THE PROBLEM No Minor Needs Serious Major Problem Problem Attention Problem Problem

1) Repeated unscheduled absences 1 2 3 4 5
2) Missing deadlines 1 2 3 4 5
3) Alternating periods of high/ low , g 3 3 4 productivity
4) Making poor decisions /judgements 1 2 3 4 5
5) Excessive tardiness 1 2 3 4 5
6) Inability to get along with , , y 4 5 co-workers
7) Wasting meterials used on the job 1 2 3 4 5
8) Overreacts to criticism 1 2 3 4 5
9) Work requires more time / effort , , 3 4 $

than usual

10) Excessive use of sick time 1 2 3 4 5
11) Leaving work early for a variety , , 3 4 5 of reasons
12) Di fficul t y remembering /following , , 3 4 $

directions

13) increase in the number of job y 4 g
                                                  ,                          3 related accidents
14) 2nability to accept supervision 1 2 3 4 5
15) Difficulty in dealing with complex , , 4 3 5 tasks
16) Deterioration of personal appearance 1 2 3 4 5
17) Making more mistakes than usual 1 2 3 4 5
18) Other (specify] 1 2 3 4 5

~

19) 1 2 3 4 5
20) 1 2 3 4 5 (over Please)

Employee Assistance Program Referral Recommendation Form Pags 2 Tar Any Circled " Serious Problem" or " Major Problem", Please Provide Specific Comments 8210ws Problem 2 Duration Comments Problem i Duration Cottwnent s Problem i Duration Consnents Problem R Duration Comments Problem E Duration Ccannen ts Additional Conenents This form is to be cornpleted and forwarded to the Employee Ass t stance Program Coord2 na tor in a CONFIDENTIAL MANNER.

I TOLEDO EDISON EMPLOYEE CONSENT FOR DRUG / ALCOHOL ANALYSIS' ED 7594 1, , Social Security No. do hereby give my consent to the Toledo Edison Company, its designated agent, and the laboratory to perform the necessary tests or examinations on me for drugs and'or alcohol.1 further give my permission to said designated agent and the laboratory to release the results of the tests or examinations to Toledo Edison. If a contract employee, authorization is hereby given for Toledo Edison to release said results to my employer. I have taken or am taking the following medications within the past 30 days: PRESCRIBING 4 NAME OF DRUG CONDmON FOR WHICH TAKEN PHYSICIAN oVER THE COUNTER COMMENTS NAME OF RE FERRING SUPERVISOR EX TENslON SPECIMEN No. DATE TAKEN SIGNATURE OF EMPLOYEE BEING TESTED DATE X W11 Ness DATE X 

       ' Failure to comply with either the signing of the consent form or submitting to the necessary tests or examinations will result in the employee's immediate suspension and will be considered grounds for discharge in accordance with the drug and alcohol abuse policy.
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