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SUBSTANCE ABUSE
POLICY
FOR REGULATED SERVICE EMPLOYEES
(REVISED)
DECEMBER 10, 2019
EFFECTIVE JANUARY 1, 2020
T E R M I N A L R A I L R OA D
A S S O C I A T I O N
O F
S T. L O U I S
2
3
Terminal Railroad Association of St. Louis
Substance Abuse Policy
Table of Contents
Page
Policy Statement. ………………………………………………………………………... 3
Identifying Information…………………………………………………………………. 3
Scope……………………………………………………………………………………….. 5
Testing Programs…………………………………………………………………………. 6
Drug Testing Procedures………………………………………………………………… 9
Alcohol Testing Procedures……………………………………………………………… 11
Drug Testing Results…………………………………………………………………….. 11
Confidentiality…………………………………………………………………………….. 12
Regulated Service Personnel Training Program (49 CFR 219.11)………………… 13
Prescription Drugs (40 CFR 219.103)………………………………………………….. 13
Compliance With Testing Procedures………………………………………………….. 13
Positive Test Results…………………………………………………………………….... 14
Rehabilitation……………………………………………………………………………… 15
Appendix A………………………………………..………………………………………... 19
Appendix B…………………………………………………………………………………. 20
Appendix C…………………………………………………………………………………. 22
Appendix D…………………………………………………………………………………. 25
Alcohol and Drug Effects………………………………………………………………….. 27
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I. POLICY STATEMENT
The Terminal Railroad Association of St. Louis (TRRA) recognizes the problem of substance abuse in
today's society. This problem poses particular concerns to an employer who is subject to governmental
regulations and seeks to promote the safety of the General Public. This railroad has a concern for the
safety, health and well-being of its employees as well as an obligation to comply with the United States
Department of Transportation (DOT) and Federal Railroad Administration (FRA) regulations. This
railroad will comply with all statutes and regulations administered by the FRA in implementing the
required Part 219 Drug and Alcohol Program.
Programs have been established on this railroad which requires regulated service employees to
demonstrate their safety posture through:
1. Urine screens to detect the presence of marijuana, cocaine, opioids, phencyclidine and
amphetamines (See 49 CFR § 40.85 and 49 CFR § 40.87);
2. Breath alcohol tests to detect the unauthorized use of alcohol; and
3. Breath, urine, blood and tissue (fatality) testing after qualifying FRA post-accident events.
In accordance with the applicable Federal regulations, this railroad prohibits persons who perform
work regulated by the Federal Hours of Service Laws (see 49 U.S.C. §§ 21101-21108) and/or
performing duties as Maintenance-of-Way (MOW) workers as described in the definition of “Roadway
Worker” in § 214.7 from being under the influence and/or possession of illegal substances and/or
under the influence of alcohol while on duty or within four hours of reporting for regulated service.
Additionally, illegal substance use is prohibited on or off duty, except as allowed in 49 CFR §
219.103.
II. IDENTIFYING INFORMATION
Railroad
Name: Terminal Railroad Association of St. Louis
Address: 415 South 18th Street, Suite 200
St. Louis, Missouri 63103
Phone: 618-451-8430
Secure Fax: 314-621-3421
E-Mail: [email protected]
Designated Employer Representative
Name: Mr. Brad Ragland
Phone: 618-451-8430
Secure Fax: 314-621-3421
E-Mail: [email protected]
Alternate Designated Employer Representative
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Name: Mr. Adam Mahlandt
Phone: 618-451-8440
E-Mail: [email protected]
Medical Review Officer
Name: Dr. Stephen Kracht
Address: Pembrooke Occupational Health, Inc.
8140 Ward Parkway, Suite 275
Kansas City, KS 64114
Phone: 804-346-1010 Fax: 804-346-5050
Testing Laboratories
Name: LabCorp of America
Address: 1904 Alexander Drive
Research Triangle Park, NC 27709
Phone: 800-437-4986
Name: Alere Toxicology Services
Address: 1111 Newton St.
Gretna, LA 70053
Phone: 504-361-8989
Name: Alere Toxicology Services
Address: 450 Southlake Blvd.
Richmond, VA 23236
Phone: 804-378-9130
Collection Facility
Name: Gateway Regional Medical Center/Occupational Health
Address: 2044 Madison Avenue
Suite G-1
Granite City, Illinois 62040
Phone: 618-798-3376
Fax: 618-798-3379
24 Hour facility for Post-Accident Testing
Name: Guardian Medical Logistics
Address: 1868 Craigshire Road
St. Louis, MO 63146
Phone: (314) 576-7766
Name: Midwest Occupational Medicine
Address: 325 E. Madison (Hwy 143)
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Wood River, IL 62095
Phone: 618-251-5202
Substance Abuse Professional (SAP)
Name: Bob Turck, MSW, LCSW
Gateway Regional Medical Center
Address: 2100 Madison Avenue
Granite City, Illinois 62040
Phone: 24 hour Hotline: 618-798-3457
III. SCOPE
This policy applies to all railroad personnel (including contractors and volunteers) who perform
regulated duties subject to either the Federal Hours of Service Laws “Covered Service” and/or
performing Maintenance-of-Way (MOW) duties regulated by the definition of “Roadway Worker” in §
214.7. This includes Hostlers, Dispatchers, Signalmen, Trainmen, Engineers, Conductors, and
Roadway workers.
This railroad has a total of 102 regulated service employees (including volunteers and contractors)
who perform “Hours of Service” functions.
This railroad has a total of 65 regulated service employees (including volunteers and contractors)
who perform “Roadway Worker” functions.
The total number of all regulated employees (include both regulated service and roadway
workers) at the time of this submission is: 167.
See Appendix D for list of contractors.
Previous Employer Checks: This railroad is required to check on the drug and alcohol testing record of
employees it is intending to use to perform regulated duties. This railroad will, after obtaining an
employee’s written consent, request information from DOT-regulated employers who have employed the
employee during any period during the two years before the date of the employee’s application or transfer
into regulated service. See 49 CFR 40.25.
An employee must also be asked whether he or she tested positive (or refused to test) on any Federal pre-
employment drug or alcohol test administered by a DOT employer to which the employee applied for, but
did not obtain regulated service work during the past two years.
With respect to any employee who violated a DOT drug and alcohol regulation, documentation of the
employee’s successful completion of DOT return-to-duty requirements (including Federal follow-up tests)
must be provided to this railroad.
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IV. TESTING PROGRAMS
There are numerous situations when Federal drug and/or alcohol tests must be administered for the
railroad to comply with 49 CFR Part 219. Personnel performing functions listed in Section III of this
policy will be required to submit to a drug and/or alcohol test in the instances set forth as follows:
A. Pre-Employment Drug Testing - (49 CFR 219.501)
Alcohol pre-employment testing will be conducted in conjunction with 49 CFR 219.501.
Applicants will be informed that all individuals this company will use for regulated service
must be drug-free. Passing a Federal pre-employment drug test is a condition prior to
performing regulated service duties. If an applicant refuses to submit to the drug test, or
tests positive on the drug test, the applicant will not be considered qualified to perform
regulated service and will not be offered a position in regulated service.
B. Testing For Reasonable Suspicion - (49 CFR 219.301)
Regulated service personnel will be required to submit to a Federal drug and/or alcohol test
whenever a properly trained supervisory employee of this railroad has reasonable suspicion that a
regulated employee is currently under the influence of or impaired by a controlled substance or
alcohol. Reasonable suspicion must be based on specific, contemporaneous personal observations
the supervisor can articulate concerning the employee’s appearance, behavior, speech, body odor,
chronic effects or withdrawal effects.
Part 219.11(g) requires supervisory employees to have education and training on alcohol misuse
and controlled substance use. The training will cover the physical, behavioral, speech and
performance indicators of probable alcohol misuse and use of controlled substances. It will also
prepare the supervisors to make the decisions necessary in reasonable suspicion and FRA post-
accident situations (i.e., what is a qualifying event and who is to be tested).
The observation for alcohol must be made by at least one qualified supervisory employee who has
received proper training in the signs and symptoms of alcohol use per 219.11(g). Documentation of
this decision must be maintained, as required by Part 219 Subpart J.
The observation for drugs must be made by at least two qualified supervisory employees, one of
which has received proper training in the signs and symptoms of drug use per 219.11(g). One
qualified supervisory must be on-site, but the supervisor trained per 219.11(g), although preferred
does have to be the supervisor on-site. Documentation of this decision must be maintained, as
required by Part 219 Subpart J.
If operating on tracks of another railroad, this railroad will coordinate with the host railroad and
decide how the supervisor on the site will immediately communicate and coordinate decisions to
test and who will administer the necessary testing. In all reasonable suspicion cases, the supervisor
will ensure that the regulated service person is transported immediately to a collection site for a
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timely collection of a urine and/or breath specimen. If the regulated service person is deemed not fit
to return to work, the supervisor will arrange transportation for the person. This is not a Federal
requirement, but safety will be better assured if accomplished.
Supervisors must document their observations that led them to decide there was a “reasonable
suspicion” to have the regulated service person subjected to Federal drug and/or alcohol testing.
C. Testing for Reasonable Cause- (49 CFR 219.401)
The TRRA will not conduct Federal Reasonable Cause testing, described in 219.403.
All reasonable cause testing will be conducted in conjunction with the railroad’s non-DOT
reasonable cause testing policy.
If operating on tracks of another railroad, this railroad will coordinate with the host railroad
and decide how the supervisor on the site will immediately communicate and coordinate
decisions to test, and who will administer the necessary testing. In all reasonable cause cases,
the supervisor will ensure that the regulated service person is transported immediately to a
collection site for a timely collection of a urine and/or breath specimen. If the regulated service
person is deemed not fit to return to work, the supervisor will arrange transportation for the person.
This is not a Federal requirement, but safety will be better assured if accomplished.
D. FRA Post-accident Drug/Alcohol Testing - (49 CFR 219.201)
FRA regulations require blood and urine specimens from all surviving regulated service
personnel when they are directly involved in a qualifying accident or incident. Tissues are also
collected, in addition to urine and blood, from any fatality involving an on-duty railroad
employee (direct or “regulated service” contractual employee). Events requiring FRA post-
accident testing include (note regulatory exception will be followed):
1. Major Train Accident involving any rail equipment accident with reportable damages
in excess of the current calendar year reporting threshold under 49 CFR Part 225 and
one or more of the following:
a. A fatality (any fatality)
b. A release of hazardous materials from railroad "lading" that results in an evacuation
or reportable injury caused by the hazmat release.
c. Damage to railroad property of $1.5 Million or more.
2. Impact Accident involving reportable damage in excess of the current threshold that
results in:
a. A reportable injury; or
b. Damage to railroad property of $150,000 or more.
3. Fatal Train Incident involving any on-duty railroad employee where damages do not
exceed the current reporting threshold.
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4. Passenger Train Accident with a reportable injury to any person in a train accident
involving damage in excess of the current reporting threshold that involves a passenger
train.
5. Human-Factor Highway-Rail Grade Crossing Accident/Incident meeting one of
the following criteria:
i. Regulated employee interfered with the normal functioning of a grade crossing
signal system, in testing or otherwise, without first providing for the safety of
highway traffic that depends on the normal functioning of such a system, as
prohibited by § 234.209, is subject to testing.
ii. Train crewmember who was, or who should have been, flagging highway traffic
to stop due to an activation failure of a grade crossing system, as provided §
234.105 (c)(3), is subject to testing.
iii. Regulated employee who was performing, or should have been performing, the
duties of an appropriately equipped flagger (as defined in § 234.5), but who
failed to do so, due to an activation failure, partial activation, or false activation
of the grade crossing signal system, as provided by § 234.105 (c)(1) and (2),
234.106, or 234.107 (c)(1)(i), is subject to testing.
iv. If there is a fatality of any regulated service employee regardless of fault.
(fatally injured regulated employee must be tested)
v. If regulated employee violates an FRA regulation or railroad operating rules
and whose actions may have played a role in the cause or severity of the
accident/incident, is subject to testing.
Testing Decision: For an accident that meets the criteria for a Major Train Accident, all
assigned crew members of all involved trains and on-track equipment must be tested.
Test any other regulated service employees that had a possible role in the cause or severity of
the accident.
For an Impact Accident, Fatal Train Incident, Passenger Train Accident or Human-Factor
Highway-Rail Grade Crossing Accident/Incident, Test any other regulated service employees that
had a possible role in the cause or severity of the accident. The railroad must exclude other
regulated service employee if the responding railroad representative can immediately determine,
on the basis of specific information, that the employee had no role in the cause(s) or severity of
the accident/incident (considering any such information immediately available at the time).
For a fatal train incident, the fatally injured employee cannot be excluded from being tested.
If there is a fatality of any regulated service employee as result of a Highway-Rail Grade Crossing
Accident/Incident, the fatally injured regulated employee must be tested regardless of fault.
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Exceptions from Testing: No test may be required in the case of a collision between railroad
rolling stock (including any on-track equipment) and a motor vehicle or other highway
conveyance at a rail/highway grade crossing, unless it meets the criteria set forth above in Item 5
(i-v).
No test may be required in the case of an accident/incident the cause and severity of which are
wholly attributable to a natural cause (e.g., flood, tornado, or other natural disaster) or to
vandalism or trespasser(s), as determined on the basis of objective and documented facts by the
railroad representative responding to the scene.
The railroad supervisor(s) on the scene will make timely determinations as to the event being a
qualifying event and which regulated service employees (if any) are required to be tested
according to the rule.
This railroad will identify the appropriate personnel who must be tested and then ensure that
specimens are collected and shipped.
D. Random Drug and Alcohol Testing Program - (49 CFR 219.601)
PROGRAM GUIDELINES
The Terminal Railroad is responsible for ensuring that the random program meets regulatory
requirements and is approved by the FRA.
The selection process will ensure that each regulated service person will have a substantially equal
statistical chance of being selected within a specified time frame.
The random plan shall ensure that testing is accomplished at the beginning and at the end of the
duty period for alcohol. The minimum annual random percentage of alcohol testing at either end of
the duty period is 10 percent over the course of the year.
The program will select for testing a sufficient number of employees so that the number of the tests
conducted will equal or exceed the percentage rate established annually by the FRA. The TRRA will
test at a 50% rate for both drugs and alcohol for all regulated employees.
Each employee shall perceive the possibility that a random test may be required on any day and time
that an employee is working.
Notice of the employee's selection will not be provided to the employee until they are working and as
close to collection as possible.
The employee shall be tested only while on duty. Only employees who perform regulated service for
the railroad shall be subject to the Federal Random Testing.
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The employee selected for testing will be informed that the selection was made on a random basis.
Non-compliance by an employee selected for participation in a random drug test shall be excused only
in the case of a documented medical or family emergency.
An employee, who upon being notified to provide a sample, refuses to provide a sample, shall be
immediately withdrawn from regulated service and shall be deemed disqualified for a period of nine
months.
SELECTION PROCESS
Selections for drugs and alcohol will be generated on a monthly basis (30 day window) by the Designated
Employee Representative via https://www.randomizer.org/#randomize or a similar website. The number of
selections will be made each month based on the Carrier’s fulfillment of annual requirements.
The TRRA will safeguard these selection records to ensure that information concerning collection dates
and selections are not disclosed until necessary to arrange for collection or provide notifications.
The TRRA Single FRA pool will consist of trainmen, enginemen, utility men, flagmen, signal
maintainers, hostlers, dispatchers and roadway workers.
Selections will be made prior to the start of the month to be tested, based on job designation numbers.
Each regulated service job will be on a list, maintained by the Program Administrator, and assigned a
numeric designation (for example, 1 through 50). The Program Administrator will input into the
randomizer, the number of jobs required for testing in a given month. Based on this information, the
randomizer will select the required amount of numbers for that month’s testing. Those numbers are
associated directly with a regulated service job.
The Program Administrator will update the pools as required; however, at least on a monthly basis.
The selections will be reviewed by the Program Administrator who will then have the month in which
to schedule testing with the collector.
The Program Administrator will then notify the TRRA Officer no more than 24 hours in advance of the
specific job designation or individual to be tested and the time to be tested, i.e. beginning, middle or
end of shift. EXCEPTION – notification for weekend testing and Monday testing will be on the Friday
prior to the scheduled test.
The collector and Program Administrator will determine times and locations, not the TRRA Officer.
V. DRUG TESTING PROCEDURES
The designated collection agents will be qualified and follow the proper collection procedures as
described in 49 CFR Part 40.
a. The Medical Review Officer (MRO) will review drug test results
as required in 49 CFR Part 40. All test results will be reported
exclusively through the MRO.
b. A laboratory certified by the Department of Health and Human
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Services/Substance Abuse and Mental Health Service Administration
(DHHS/SAMHSA), under the Mandatory Guidelines for Federal
Workplace Drug Testing Programs, will perform all drug testing.
c. Test results will be reported from the laboratory only to the MRO
for review and action consistent with 49 CFR Part 40.
d. The name of the individual providing the specimen will remain
confidential and will not be provided to the laboratory
performing the test. The testing laboratory is only able to
identify the specimen by the specimen ID number printed on
the chain-of-custody form. The laboratory will only use a
specimen custody and control form consistent with the requirements of
49 CFR Part 40.
e. The designated laboratory will only test for the drugs listed in
49 CFR 40.85.
f. The MRO will verify the results and report (using procedures in
49 CFR Part 40) to the DER whether the test was positive or negative,
and the drugs for which there was a positive result.
VI. ALCOHOL TESTING PROCEDURES
Breath alcohol testing will be performed by fully trained and certified Breath Alcohol Technicians
(BAT) using the National Highway Traffic Safety Administration (NHTSA) approved testing devices.
The results will be documented on an approved Federal Breath Alcohol Testing Form and will be signed
by the employee and the BAT. At the time of the alcohol test, the employee will receive a copy of the
test result, with an identical copy being sent to the railroad's DER.
a. Negative Results. The DER will be mailed a copy of the negative test
results.
b. Positive Results. The BAT will immediately and directly notify the
railroad's DET if the test results are positive (0.02 percent or higher), who
will take appropriate action to remove the employee from regulated service
as required by Part 219.
VII. DRUG TEST RESULTS
Positive or Otherwise Non-Negative Results. If the laboratory reports the drug test result as POSITIVE
or otherwise non-negative, the following procedures will be followed:
a. The MRO will immediately inform the regulated service person of the
result and offer the person the opportunity for an interview to
discuss the test result. If the MRO has difficulty reaching the
employee, the procedures set forth in 49 CFR 40.131 will be
followed.
b. The MRO will complete and document the review as required by
49 CFR Part 40 Subpart G, determining if the external chain of
custody was intact, if the person has a legitimate medical
explanation for the presence of any controlled substance, and whether
there is any basis to question the scientific sufficiency of the test
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results. In the case of an opiate positive, the MRO will also make the
special determinations required by the regulation.
c. If the MRO verifies the test result as positive, the MRO will report the
result to the railroad's DER. If the MRO determines that the result
is non-negative and the non-negative result cannot be explained, the
appropriate regulatory action will be pursued. The chart at Appendix
D delineates the appropriate action. The MRO will report the verified test result in
accordance with 49 CFR § 40.163. The MRO will not provide the DER
with the quantitative test results unless the employee, as stipulated
in the regulation, disputes the test.
Negative Results: If the MRO has determined that the drug test is NEGATIVE, the MRO will
accomplish the required administrative review and report the negative results to this railroad's DER
in accordance with 49 CFR § 40.163.
Negative-dilute results: Unless the MRO directs a railroad to conduct a recollection under direct
observation (for a result with creatinine from 2 to 5 mg/dL), per 40.197, a negative-dilute is considered
a negative test, although a railroad may, but is not required to direct the employee to immediately take
another test. Such recollections must not be collected under direct observation unless there is another
basis to do so. A railroad must treat all regulated employees the same. For example, it must not retest
some employees and not others. A railroad may establish different policies for different types of tests
(e.g., conduct retests in pre-employment situations, but not in random test situations). This railroad’s
policy for negative-dilutes is as follows: If the MRO determines that the drug test result is negative
but dilute then an immediate second collection will take place. The donor will be tested within 24
hours of the result notification or the next day the donor reports in for duty. The reason for the test
will be the same as the first negative dilute test. The results of the second test will be the final result
the Company accepts. If the donor refuses to participate in the second collection will be considered a
refusal to test. NOTE: this second collection will be unobserved unless an observed collection is
requested by the MRO.
VIII. CONFIDENTIALITY
Medical information a regulated person provides to the MRO during the verification process is treated
as confidential by the MRO and is not communicated to the railroad except as provided in Part 40.
Confidentiality of Federal drug or alcohol testing results will be maintained as required by the
regulations. For example:
1. The laboratory observes confidentiality requirements
as provided in the regulations. The TRRA does not
advise the laboratory of the identity of persons
submitting specimens. The laboratory performing
the testing must keep all records pertaining to the
drug test for a period of two years.
2. All test results will remain exclusively in the secure files
of the MRO. The MRO will observe strict confidentiality
in accordance with the regulations and professional
standards. The MRO will retain the reports of individual
test results as required in Part 219 Subpart J.
3. The DER will maintain all test results reported by the
MRO, both positive and negative, in secure storage.
The results will be retained as required in Part 219
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Subpart J. Other personnel will be informed of
individual test results only in the case of positive
tests and authorized only on a need-to-know basis.
IX. REGULATED SERVICE PERSONNEL TRAINING PROGRAM (49 CFR 219.11)
Supervisors will have the required three (or more) hours of education and training on alcohol misuse
and controlled substance use. The training will cover the physical, behavioral, speech and performance
indicators of probable alcohol misuse and use of controlled substances. It will also prepare the
supervisors to make the decisions necessary in reasonable suspicion and FRA post-accident situations
(i.e., what is a qualifying event and who is to be tested).
Each regulated service person will receive a copy of this policy and the other information requirements
in 49 CFR Part 219.23 (e) which clearly states the prohibitions required by the regulation. In addition,
each regulated service person will be given information concerning the problems caused by alcohol or
controlled substances and available methods of intervening when an alcohol or controlled substance
problem is suspected, including confrontation, referral to an employee assistance program, and/or
referral to management.
X. PRESCRIPTION DRUGS (40 CFR 219.103)
The use of controlled substances (on Schedules II through V of the controlled substance list) is not
prohibited as long as they are prescribed or authorized by a medical practitioner and used at the dosage
prescribed or authorized. Either one treating medical practitioner or a railroad-designated physician
should determine that use of the prescription(s) at the prescribed or authorized dosage is consistent
with the safe performance of the employee's duties. Regulated service employees should also seek the
advice of a medical professional whenever they are taking any over-the-counter drug that may
adversely effect the safe performance of duties. This includes use instructions and medication labeling
which could present a safety concern.
XI. COMPLIANCE WITH TESTING PROCEDURES
All regulated service personnel/applicants requested to undergo a Federal drug and/or alcohol test are
required to promptly comply with this request. The TRRA expects all prospective and current
regulated service personnel to exercise good faith and cooperation in complying with any procedures
required under this policy. Refusal to submit to a Federal drug or alcohol test required under FRA
Rules, engaging in any conduct which jeopardizes the integrity of the specimen or the reliability of the
test result, or any other violations of the prohibited conduct in 49 CFR 219.101 or 219.102 could subject
the person to disciplinary action (up to and including termination), independent and regardless of any
test result. This includes failure to show up on time for a drug/alcohol test, postponing or rescheduling
of specimen collections or failing to remain at the testing site until the testing process is complete, etc.
(see 40.191).
All DOT Federal return-to-duty and follow-up urine specimens must be collected under direct
observation (using the new direct observation procedures in 40.67 (i)) when the regulated service
employee has had a previous positive Federal drug test, or has previously refused to take a Federal
test (including adulteration or substitution). Note that a SAP may also require return-to-duty and
follow-up “drug” tests in addition to alcohol tests following an alcohol positive of 0.04 percent or greater.
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Direct Observation Urine Collection Procedures: The collector (or observer) must be the same gender
as the employee. If the collector is not the observer, the collector must instruct the observer about the
procedures for checking the employee for prosthetic or other devices designed to carry “clean” urine
and urine substitutes AND for watching the employee urinate into the collection container. The
observer will request the employee to raise his or her shirt, blouse or dress/skirt, as appropriate, above
the waist, just above the navel; and lower clothing and underpants to mid-thigh and show the observer,
by turning around, that the employee does not have such a device.
1) If the employee has a device, the observer immediately notifies the collector;
the collector stops the collection; and the collector thoroughly documents the
circumstances surrounding the event in the remarks section of the testing
form. The collector notifies the DER. This is a refusal to test.
2) If the employee does not have a device, the employee is permitted to return
his/her clothing to its proper position for the observed collection. The observer
must watch the urine go from the employee’s body into the collection container.
The observer must watch as the employee takes the specimen to the collector.
The collector then completes the collection process.
3) Failure of the employee to permit any part of the direct observation procedure
is a refusal to test.
As a minimum, a regulated service employee will be removed from FRA regulated service for a
minimum of nine months if there is a finding of "refusal to test".
XII. POSITIVE TEST RESULTS
Regulated service personnel should receive written notification of test results which are other than
negative. A Federal positive drug test or a Federal alcohol test result of 0.02 percent or greater or a
refusal to test will result in immediate removal from regulated service under FRA regulations. A
positive alcohol test of at least 0.02 percent but less than 0.04 percent will result in the removal of the
person from regulated service for at least eight hours.
A regulated service employee with a positive breath alcohol test of at least 0.02 percent but less than
0.04 percent will be required to undergo an evaluation conducted by the Carrier’s Employee Assistance
Program (EAP) to determine the need for treatment and/or education. The employee will be required
to participate and comply with the EAP recommended treatment and any after care or follow-up
treatment that may be recommended or required at their own expense.
After successful treatment, for a positive Federal alcohol test of at least 0.02 percent but less than 0.04
percent, per the EAP’s requirements, the person must provide a Non-DOT return-to-duty alcohol test
(which is negative) prior to being allowed to return to regulated service. In addition, the person will
be subject to additional unannounced Non-DOT follow-up testing, as determined by the EAP, for a
maximum period of 60 months, with a minimum of six tests being performed in the first twelve months.
Failure to comply with these provisions and remain alcohol free will result in subsequent removal from
regulated service and could result in disciplinary action, up to and including termination.
A regulated service person with a MRO verified positive drug test or a breath alcohol test result of 0.04
percent or greater (or a refusal) will be immediately removed from regulated service. The employee
will be required to undergo an evaluation by a qualified Substance Abuse Professional (SAP) that is
railroad approved to determine the need for treatment and/or education. The employee will be required
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to participate and comply with the SAP-recommended treatment and any after-care or follow-up
treatment that may be recommended or required at their own expense.
After successful treatment, for a Federal positive drug test (or alcohol test result of 0.04 percent or
greater), per the SAP’s requirements, the person must provide a Federal return-to-duty urine specimen
and/or breath specimen for testing (which is negative) prior to being allowed to return to regulated
service. In addition, the person will be subject to additional unannounced Federal follow-up testing,
as determined by the SAP, for a maximum period of 60 months, with a minimum of six tests being
performed in the first twelve months (engineers and conductors - 6 drug tests and 6 alcohol tests in the
first 12 months). Failure to comply with these provisions and remain alcohol and/or drug free will
result in subsequent removal from regulated service and could result in disciplinary action, up to and
including termination.
Note: Federal regulation does not guarantee the employee will maintain an employment relationship.
This is determined via employer and employee negotiations. These Federal return-to-duty and follow-
up drug tests must be collected under direct observation.
If an employee has a Federal alcohol test result of at least 0.02 percent or greater or a Federal positive
drug test the employee will be removed from service and a formal Company Investigation will be
scheduled to determine if TRRA Company Policy or GCOR 1.5 has been violated.
XIII. REHABILITATION
The TRRA has employed the services of Gateway Regional Medical Center for Employee Assistance
(EAP), Drug and Alcohol Counselor (DAC) and Substance Abuse Professional (SAP) services to help
employees and their dependent family members who may have various personal problems, in addition
to drug and alcohol addictions. There is no cost to the employee or his eligible family members for the
Employee Assistance Program services. The EAP Counselor will provide you with information about
the benefits that are available to employees.
Employee Assistance Program Administrator
Contact Person: Bob Turck, MSW, LCSW
Gateway Regional Medical Center
2100 Madison Avenue
Granite City, Illinois 62040
24 hour Hotline: 618-798-3457
In conjunction with Federal Railroad Administration Regulations prohibiting alcohol and drug use in
railroad operations, and in compliance with 49 CFR part 219.1001 and 49 CFR Part 219.1003, the
TRRA adopted the following policies designed to encourage and facilitate the identification of
employees who abuse alcohol or drugs and insure that such employees are provided the opportunity to
obtain counseling or treatment.
A. VOLUNTARY REFERRAL POLICY: Any employee who is affected by an alcohol or drug use
problem may maintain an employment relationship with the Carrier if, prior to being charged
with conduct deemed to be sufficient to warrant dismissal, the employee seeks assistance
through the Carrier's Employee Assistance Program. Such assistance may be requested by the
employee or through referral by another employee or Union Representative. In order to invoke
the benefits of this policy, the employee must contact the Director of Labor Relations:
(1) during non-duty, or
17
(2) while unimpaired and otherwise in compliance with the Carrier's GCOR 1.5, consistent
with 219.1005 (d).
The Company will treat all referrals and subsequent handling, individual counseling and treatment
as confidential. Confidentiality will be waived, however, if:
(1) The employee at any time refuses to cooperate in a recommended
course of counseling or treatment and/or
(2) The employee is later determined, after investigation, to have an
alcohol or drug related disciplinary offense growing out of subsequent
conduct.
(3) With respect to a certified locomotive engineer, conductor or a candidate
for certification, the policy of confidentiality is waived (to the extent
that the railroad shall receive from the EAP Counselor or DAC official notice
of the substance abuse disorder and shall suspend or revoke the
certification as appropriate) if the person at any time refuses to
cooperate in a recommended course of counseling or treatment.
Any drug and/or alcohol test conducted pursuant to this railroad's voluntary referral policy is
non-Federal testing because a violation of Federal regulations has not occurred.
The Company will, to the extent necessary for treatment and rehabilitation, grant a leave of absence
for the period necessary to complete primary treatment and establish control over the employee's
alcohol or drug problem. The minimum leave of absence will be designated by the DAC for the purpose
of meeting initial treatment needs. Employees will be returned to service within five (5) days of the
DAC ’s notification to the railroad that the employee is fit to return to regulated service and the receipt
of a follow-up testing plan as per Part 219.1003(h)(2) and upon successful completion of a return-to-
work physical examination, which will include a drug and/or alcohol test.
This Voluntary Referral Policy does not apply to an employee who has previously been assisted by the
Company under this Policy or who has previously elected to waive investigation under the Co-Worker
Report Policy outlined in Paragraph (B) of this notice.
B. CO-WORKER REPORT POLICY: Any employee may maintain an employment relationship
with the Company following an alleged first offense under the Company's GCOR 1.5, provided the
alleged violation comes to the Company's attention as a result of a report by a co-worker that the
employee was apparently unsafe to work with, or was, or appeared to be, in violation of GCOR 1.5.
If a TRRA representative can confirm that the employee is in violation, that employee will
immediately be removed from service in accordance with existing policies and procedures. The
railroad must allow the employee the opportunity to accept the co-worker referral. If rejected, the
railroad may proceed to reasonable suspicion testing based on signs and symptoms of prohibited
alcohol or drug use as determined by a trained supervisor.
The employee will be notified of the GCOR 1.5 violation charge in accordance with applicable
Collective Bargaining Agreement rules where required. Along with the Notice of Investigation the
employee will be furnished an option form on which he/she can select one of the following options:
18
(1.) Will attend the investigation on GCOR 1.5 violation charge; or (in which the CO-
WORKER REPORT POLICY does not apply.)
(2.) Will contact the Charging Officer within five (5) days of the date
of the Notice of Investigation and waive their Investigation. They
must agree to enroll in and participate in an approved rehabilitation
program with the understanding that:
(i) The GCOR 1.5 charge Investigation will be held in abeyance.
(ii) The employee will continue to remain out of service, and
(iii) The employee will be carried on the Company's records
as being off due to illness.
(3.) The Director of Labor Relations will refer the employee to the Drug and Alcohol
Counselor, who will schedule interviews with the employee and complete an evaluation
within ten (10) calendar days of the date on which contacted by the employee for
evaluation under the policy, unless it becomes necessary to refer the employee for
further evaluation. In each case, all necessary evaluation will be completed within ten
(10) working days of the date on which the employee contacts the DAC. If more than
one evaluation is required, the evaluations must be completed within twenty (20)
working days.
The employee must cooperate with the DAC in the recommended course of counseling
or treatment. Locomotive engineers and conductors that do not cooperate with the
DAC will be considered to have active substance abuse disorders as per 49 CFR Part
240.119 and 49 CFR Part 242.115 and would have their confidentiality waived.
No follow up treatment, care, or testing shall exceed twenty-four (24) months from
their initial removal from service unless it involved a part 219 violation.
If the DAC determines that the employee is affected by psychological or chemical dependency on alcohol
or drugs or by another identifiable and treatable mental or physical disorder involving the abuse of
alcohol or drugs as a primary manifestation, the Company will:
(i) Grant the employee a leave of absence for the period necessary to complete
primary treatment and establish control over the alcohol or drug problem.
(ii) The employee will be expected to undertake and successfully complete
a course of treatment deemed acceptable by the DAC.
(iii) Employees will be returned to service within five (5) days of the DAC ’s notification
to the railroad that the employee is fit to return to regulated service and the receipt
of a follow-up testing plan as per Part 219.1003(h)(2) and upon successful completion
of a return-to-work physical examination, which will include a Federal drug and/or
alcohol test.
As a further condition of withholding of discipline, the employee, following return to service, may, as
necessary, be required to participate in a program of follow-up treatment, which will include periodic
19
Federal random drug and/or alcohol test(s) for regulated service employees. Furthermore, all
employees may be subject to periodic follow-up test(s) per the DAC recommendation for a period of up
to twenty-four (24) months from the date the employee was originally withdrawn from service.
If the DAC determines that an employee is not affected by an identifiable and treatable mental or
physical disorder:
(i) The railroad must return the employee to service within 5 days after completion of
the minimum education requirements.
(ii) During or following the out-of-service period, the railroad will require the employee
to participate in a program of education and training concerning the effects of alcohol
and drugs on occupational or transportation safety.
If there has been a violation of Federal regulations (219.101 or 219.102), the railroad must conduct
Federal return-to-service and follow-up tests (as described in 219.104) of an employee who waives
investigation and is determined to be ready to return to service under 219.405.
An employee, who elected option (2) of Section (b) and fails to enroll in the recommended rehabilitation
program within the prescribed period or, after enrolling, fails to continue participation in the program,
will be considered as having elected option (1) of Section (b). Under such circumstances, any provision
of any applicable Agreement Rule providing a time limit from the date of incident in which the
investigation must be held will be considered waived.
Upon being notified by the Employee Assistance Counselor of such fact, the Carrier will reschedule the
Investigation to be held within the time specified in the person's Union Contract.
C. NON-PEER REFERRAL: The TRRA will accept non-peer referrals from family members and
friends (non-employee) that contact the railroad.
A railroad representative will meet with the employee in person regarding the information
and determine whether to the employee is unsafe to work with or in violation of 49 CFR Part
219. If the railroad representative determines that employee is unsafe, the employee may
either accept or reject the referral.
If rejected, a railroad representative trained in signs and symptoms would perform a GCOR
1.5 observation on the employee in question. If signs and symptoms are present, then the
railroad representative would order reasonable suspicion testing of the on-duty employee.
If a TRRA representative can confirm that the employee is in violation, that employee will
immediately be removed from service in accordance with existing policies and procedures. All
guidelines contained within Section B(1), B(2), and B(3) of this section will apply.
APPENDIX A
Once the FRA has approved a Random drug and alcohol testing plan, the railroad will receive an approval
letter, which includes these conditions.
20
STANDARD APPROVAL CONDITIONS FOR RANDOM TESTING PROGRAMS
1. This approval is effective upon receipt with respect to all matters within its scope. FRA reserves
administration jurisdiction over all approvals and may reopen review based upon experience gained
during implementation (audits).
2. Approval of the subject random testing program does not constitute or imply the granting of a
waiver or exemption from any provision of Federal law or regulation. Compliance with all
applicable provisions of 49 CFR Parts 219 and 40 is required. All random program plans must be
applied in accordance with the criteria listed in this Appendix A and Appendix B.
3. Approval is contingent upon the railroad making appropriate amendments to the program to
conform to any pertinent regulatory amendments that may be issued hereafter. Any such program
amendments that may be required shall be submitted to the Associate Administrator for Safety at
FRA by the effective date of the subject regulatory amendments or by the expiration of 30 days
from publication of the regulatory amendments in the Federal Register, whichever is later.
4. Amendments to the program shall be submitted as required by 49 CFR 219.601(a) and 49 CFR
219.607 (a) and shall not be implemented prior to approval. The following guidance is provided
with respect to when a program is deemed to have been amended.
A. Any change in the selection methodology, the criteria for scheduling collections, non-
availability criteria, or other structural element is a program amendment. Any change in the
organizational level at which a function is carried out is a program amendment.
B. Substitution of incumbents performing the same function at the same organizational level
(persons or contractors/volunteers) is not deemed to amend the program. Notification of these
changes would be appreciated to assist FRA in maintaining liaison, but is not required.
C. Any change in a program that is occasioned by an amendment of an applicable DOT/FRA
regulation and that involves the exercise of discretion to choose between or among one or more
courses of action is a program amendment required to be filed under item 3 above. Any non-
discretionary change in a program that is required by amendment of an applicable DOT/FRA
regulation is not considered a program amendment requiring approval; however, the Office of
Safety, FRA, would appreciate receipt of an informational copy of the revised program
document showing current compliance.
D. Any case not addressed above may be resolved by contacting the Office of Safety,
Administrator for Safety or that individual’s delegate.
21
APPENDIX B
CRITERIA FOR ASSESSING DEPARTMENT OF TRANSPORTATION (DOT)
RANDOM DRUG AND ALCOHOL TESTING PROGRAMS
Section I. Random Testing Pools
A. Random pool(s) must accurately and completely include all regulated service personnel.
Whoever is performing the safety-sensitive “regulated service”, regardless of job title or status,
is subject to 49 CFR Part 219 requirements (supervisors, volunteers, contractors, etc.). Pool
lists must be retained for a minimum of two years.
B. An employer may not mix regulated service and non-regulated service personnel in the same
pool.
C. Multiple pools for an employer are acceptable.
D. Employees do not need to be placed in separate pools for drug and alcohol testing selection.
E. Employees from different DOT operating administrations can be included in the same pool. It
is strongly recommended, however, that employers not mix groups of personnel subject to
different drug or different alcohol testing rates (i.e., having some employees subject to a 50%
rate for drugs and other employees subject to a 25% rate in the same pool). If they do, they
must test the entire pool at the highest selection rate for any of the groups with personnel in the
pool.
F. Pools may not be diluted with regulated service personnel who rarely perform regulated service
duties (i.e., less than once per quarter).
G. Pools must be routinely updated (i.e., at least monthly for employers with either a changing
workforce or seasonal employees; and quarterly for employers with a generally stable
workforce).
H. Besides individual employees, specific jobs (i.e., third shift main dispatcher at XYZ location) or
operational units (i.e., trains) may also be pool entries. However, there may not be a significant
difference in the size of the entries in the pool.
I. Pool entries may not be constructed in a way which could result in a manager/supervisor having
discretion as to who would be actually provide a sample (e.g., a specific job cannot be selected
with multiple people working in it at the same time, but with only one to be tested).
Section II. Random Selections
A. Everyone in a pool must have an equal chance of selection in each selection period.
1. No individual, job, or operational unit may be removed from the pool if it is still actively
performing regulated service. However, employees doing de minimus regulated service
may be eliminated from the pool (see Section I.-F).
2. There may be no selections without replacement (i.e., an individual cannot be removed from
the pool because he or she was previously tested).
3. No selection weightings are allowed which would increase or decrease the chance of any
individual being selected.
B. The following selection options are acceptable. Note that manual selection using names or
social security numbers drawn out of a hat (or equivalent) is no longer an acceptable practice:
1. Computer programs which randomly select entries from an employee list without
apparent bias. The specific selection criteria used by the computer must be extensively
detailed in writing, and each computer draw must be retained as a record for a minimum
of two years; or
22
2. Manual selection from a list of employees using a random-number table. The specific
criteria used to select from the table must be documented in writing, including detail on
how the initial starting point in the table was determined. Each draw, as well as a copy
of the table portion used, must be retained as a record for a minimum of two years. See
Appendix C for Model Procedures to Conduct a FRA-Acceptable Random Testing
Program Using a Random Number Table for Selections.
C. If the employee testing pool is so small that it does not allow testing each selection period, then
the employer must have in place a mechanism to randomly determine which selection periods
will have selections and which will not. The specific criteria used to make this determination
must be detailed in writing and the determination itself must be retained as a record for a
minimum of two years.
D. If required drug and alcohol testing rates are different (i.e., 25% for drugs and 10% for alcohol)
and a single pool is being used, it is permissible to select one list of employees and designate a
proportion for both drug and alcohol testing and a proportion for drug testing only. The specific
criteria used to make this determination must be detailed in writing, and the master selection list
with both sub-groups clearly identified must be retained as a record for a minimum of two
years.
E. Employers should carefully monitor significant changes in its workforce in order to ensure that
an appropriate number of tests will be conducted each year. Unless otherwise directed by the
DOT Operating Administration, changes in the employee base of greater than 10% in a quarter
should result in a recalculation of total tests required.
Section III. Implementation of Random Collections
A. Collections must be distributed unpredictably throughout the designated testing period,
covering all operating days (including holidays) and shifts (24-hour clock). There is no
expectation that day/night or shift collection distributions be equal but there has to be sufficient
testing to establish deterrence by generally mirroring employer operations.
B. Collections must be unpredictable within a work shift (some collections must be conducted at
the beginning, middle, and end). There is no expectation that “within-shift” collection
distributions be equal. Sufficient testing must be conducted at the start, middle and end of shifts
to provide deterrence. Both beginning of and ending of shift collections are particularly
important. For alcohol testing, at least 10% of successful collections must fall within each
period of the shift.
C. No discretion is allowed with collection dates or collection times which would result in a
subjective choice by a field manager/supervisor as to who was actually collected. That is, if a
test time frame is permitted in the employer’s program, a manager/supervisor with knowledge
of specific personnel assignments may not have discretion in the selection of who will be tested.
D. Specific reasons for “no-tests” must be documented in writing by the employer, with records
maintained for two years. Acceptable reasons for no-tests should relate to critical safety
concerns, unforeseen or unpredictable significant adverse impact to operations, or employee
illness or vacation.
Section IV. Records
All records which support the random testing program, including notes, memoranda, pool makeups,
number tables, etc., must be retained for a minimum of two years.
23
APPENDIX C
As guidance, attached are two flow charts; one for the handling of primary specimens and one for the handling of split
specimens.
25
FLOW CHART FOR HANDLING OF PRIMARY SPECIMENS
Primary Specimen (Bottle A) Test Results (Laboratory A)
Positive or
positive diluteNegative Invalid Test Adulterated
Reported to
MRO as positive
for drug(s)/drug
classes
Reported to
MRO as
negative for
drugs/drug
classes
Reported to
MRO as "Test
not performed -
specimen
unsuitable,
cannot obtain
valid drug
result."
Reported to MRO
as adulterated with
name of adulterant
or pH level
MRO records
"Primary was
adulterated:
Presence of
__________
(Specify)
detected"
Reported to
DER (after
Review) as
"Negative"
(Prescription
Medication) or
"Positive" for
drug(s) and/or
drug class(es)
Reported to
DER (after
Review) as
"Negative"
MRO reviews
with lab for
adulterants or
interfering
medications
Reported to DER (after
Review) as "Invalid Result".
Conduct unobserved
recollection if neg. result is
required.
Reported to DER (after
Review) as "Invalid
Result - Immediate
recollection required by
direct observation" (with
minimal notice to
employee)
Reported to DER (after
Review where employee
admits tampering with
specimen) as "Specimen
Adulterated / Substituted -
Refusal to Test"
Reported to DER
(after Review) as
"Specimen
Adulterated -
Refusal to Test. **
** Adulterated specimen with no split specimen
available is reported to DER as "Specimen
Adulterated - Refusal to Test"
Substituted
Reported to MRO
as substituted with
specific gravity
and creatinine
concentration
Reported to DER
(after review) as
"Substituted -
Refusal to Test".
Negative Dilute
Reported to
MRO as
negative dilute
Reported to DER
(after Review) as
"Negative Dilute"
Employer may
require second
collection (not under
direct observation)
NOTE: Positive, adulterated and substituted
specimens are retained by the laboratory for 1 yr.
Effective August 1,2001
Rejected for
Testing
Reported to
MRO as
"Rejected for
testing"
Reported to
DER as
"Cancelled w/
reason for
cancellation"
No further
action. Conduct
unobserved
recollection if
neg. result is
required.
26
Split Specimen (Bottle B) Tested (Laboratory B) Upon Documented Request from Donor to MRO
Reconfirmed Failed to Reconfirm - (Required to test for adulterants)
Reported to
MRO as positive
for drug(s) /
drug(s) classes
Adulterant(s) /
SubstitutedAdulterant(s)
Cannot test for adulterants
(Laboratory B) Specimen
sent to Laboratory C
Adulterant present in
specimen
Recorded by
laboratory as "Split
Specimen
adulterated:
presence of (insert
strong acid, nitrate,
glutaraldehyde or
__________
(specify) detected"
and reported to MRO
MRO reports to
ODAPC of the
failure to
reconfirm
Reported to DER
and donor as
"Failed to
Reconfirm - Both
Tests Canceled"
MRO records
"Primary and/or split
specimen(s) were
adulterated: Presence
of ___________
(Specify) detected"
Recorded by laboratory
as "Split Specimen
adulterated: presence of
(insert strong acid,
nitrate, glutaraldehyde, or
__________ (specify)
detected" and reported to
MRO
Reported to DER and
donor as "Specimen
Adulterated - Refusal to
Test"
MRO records "Primary
and/or split specimen(s)
were adulterated:
Presence of __________
(Specify) detected"*
Reported to DER and
donor as "Specimen
Adulterated - Refusal to
Test"
Reported to
DER and donor
as "Split
Specimen
Reconfirmed for
drug(s) and/or
drug
classes(es)"
Reported to
MRO as
"Adulterant(s) /
Substituted: not
found within
criteria"
Substituted
Reported to MRO
as substituted with
specific gravity
and creatinine
concentration
Reported to DER
and donor as
"Substituted -
Refusal to Test".
Drug(s)
Reported to
MRO as
"Drug(s) /
metabolite(s) not
detected"
Reported to
DER and donor
as "Split
specimen not
reconfirmed for
drug(s) and/or
drug classes(es)
- Both Tests
Canceled"
Drug(s) No split specimen
Reported to MRO
as "Specimen not
available for
testing"
Reported to DER
as "Cancelled: no
specimen
available"
FLOW CHART FOR HANDLING OF SPLIT SPECIMENS
DER to ensure
immediate collection
of another specimen
under direct
observation w/ no
notice to employee
until immediately
before collection
Effective August 1,2001
27
APPENDIX D
Regulated Service Contractors – April 2018:
Xorail, Inc. – Positive train control installation
Brittain Frerichs
5011 Gate Parkway
Building 100, Suite 400
Jacksonville, FL 32256
402-541-9625
5 – 10 regulated service employees on property (of which 2-3 will be covered service)
Ironhorse – Miscellaneous track repairs
Paula Phelps
901 W. Myrtle St.
Baldwin, IL 62217
618-785-2221
TBD
R. J. Corman – Miscellaneous track repair
Heidi Caudill
PO BOX 788, 101 RJ Corman Drive
Nicholasville, KY 40356
859-881-6624
TBD
Hulcher – Miscellaneous track repair
Magen Autwell
PO Box 203532
Dallas, TX 75320
940-387-0099 Ext. 3440
TBD
Reinhold Electric – Miscellaneous regulated work
Mark Palmer
2511 Lemay Ferry Rd
St. Louis, MO 63125
Phone 314-562-6104
2-4 regulated service employees
Sperry Rail, Inc. – Track inspection
Mark Alves
320 Evans Road
National Stock Yards, IL 62071
203-791-4542
2-4 regulated service emloyees
28
Modjeski and Masters (CSA) – Bridge Inspection
Aaron C. Kober
#4 Sunset Hills Professional Center
Edwardsville, IL 62025
618-659-9102 Ext. 21
2-4 regulated service employees
Asplundh – Weed Sprayer
Janet Holderby
720 County Road 400
Ironton, OH 45638
800-826-3379
2-3 regulated service employees
Walsh Construction Company – Bridge contractor
Dave Shier
929 West Adams Street
Chicago, IL 60607
15-20 regulated service employees
29
ALCOHOL AND DRUG EFFECTS
Dear Employee,
The attached information regarding alcohol and drugs is important not only for you, but every
member of your family. If you have questions or would like counseling or treatment resources in
your community, please contact me.
Brad Ragland
Director of Labor Relations Phone: (618) 451-8430
Effects of Alcohol
Alcohol is a socially acceptable drug that has been consumed throughout the world for centuries.
It is considered a recreational beverage when consumed in moderation for enjoyment and
relaxation during social gatherings. However, when consumed primarily for its physical and
mood-altering effects, it is a substance of abuse. As a depressant, it slows down physical responses
and progressively impairs mental functions.
Signs and Symptoms of Use
• Dulled mental processes
• Lack of coordination
• Possible constricted pupils
• Sleepy or stuporous condition
• Slowed reaction rate
• Slurred speech
(NOTE: Except for the odor, these are general signs and symptoms of any depressant substance).
Health Effects The chronic consumption of alcohol (average of three servings per day of beer-12 ounces, whiskey-1
ounce, or wine-6 ounce glass) over time may result in the following health hazards:
• Decreased sexual functioning
• Dependency (up to 10 percent of all people who drink alcohol become physically and/or
mentally dependent on alcohol and can be termed "alcoholic")
• Fatal liver diseases
• Increased cancers of the mouth, tongue, pharynx, esophagus, rectum, breast, and
malignant melanoma
• Kidney disease
• Pancreatitis
• Spontaneous abortion and neonatal mortality
• Ulcers
• Birth defects (up to 54 percent of all birth defects are alcohol related).
ALCOHOL & DRUG EFFECTS-1
30
Social Issues
• Two-thirds of all homicides are committed by people who drink prior to the crime.
• Two to three percent of the driving population is legally drunk at any one time.
• 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.
• Forty percent of family court cases are alcohol problem related.
• Alcoholics are 15 times more likely to commit suicide that are other segments of the
population.
• More than 60 percent of burns, 40 percent of falls, 69 percent of boating accidents, and 76
percent of private aircraft accidents are alcohol related.
The Annual Toll
• 24,000 people will die on the highway due to the legally impaired driver. 12,000 more will
die on the highway due to the alcohol-affected driver.
• 15,800 will die in non-highway accidents.
• 30,000 will die due to alcohol-caused liver disease. 10,000 will die due to alcohol-induced
brain disease or suicide. Up to another 125,000 will die due to alcohol-related conditions or
accidents.
Workplace Issues • It takes one hour for the average person (150 pounds) to process one serving of an
alcoholic beverage from the body.
• Impairment in coordination and judgment can be objectively measured with as little as
two drinks in the body.
• A person who is legally intoxicated is 6 times more likely to have an accident than a sober
person.
Alcohol-Related Birth Defects
Definitions ---
• Fetal alcohol syndrome (FAS) is one of the top three known causes of birth defects with
accompanying mental retardation - and the only preventable cause among those three.
FAS can be prevented by abstaining from alcohol consumption during pregnancy.
• FAS is characterized by a cluster of congenital birth defects that develop in the infants of
some women who drink heavily during pregnancy. These defects include prenatal and
postnatal growth deficiency; facial malformations such as a small head circumference,
flattened mid-face, sunken nasal bridge and flattened and elongated philtr central nervous
system dysfunction; and varying degrees of major organ system malformations.
• Fetal alcohol effects (FAE), a less severe version of FAS, is characterized by milder or less
frequent FAS signs. Low birth weight, subtle behavior problems or partial display of
physical malformations, for example, may be seen in the newborns of women who consumed
less alcohol during pregnancy than women with FAS newborns.
ALCOHOL & DRUG EFFECTS-2
31
Incidence and Risks Factors ----
• Nearly 5,000 babies - one in every 750 - are born with FAS every year. (FAS prevalence
rates range from one in 1,000 to one in 200). Comparatively, FAE may affect 36,000
newborns each year.
• One in six women in the peak childbearing years of 18-34 may drink enough, either
chronically or episodically, to present a hazard to an unborn infant.
• Alcoholic women are at highest risk of bearing children with FAS. Alcoholism is a
primary, chronic disease often progressive and fatal. It is characterized by impaired control
over drinking, preoccupation with alcohol, use of alcohol despite adverse consequences and
distorted thinking (most notably denial).
• FAS is prevalent in 9.8 of every 1,000 American Indians form a particular high-risk
culture. Other American Indian populations have rates ranging from 1.3 to 10.3 for every
1,000.
• A daily average of one to two reported drinks is linked to decreased birth weight, growth
abnormalities and behavioral problems in the newborn and infant. Increased risk of
spontaneous abortion has been found at an even lower dose: one to two drinks weekly.
• The probability of having a child with FAS or FAE increases with the amount and
frequency of alcohol consumed. Whenever a pregnant woman stops drinking, she reduces
the risks of FAE and the consequences of alcohol exposure.
• There is no known safe dose of alcohol during pregnancy, nor does there appear to be a
safe time to drink during pregnancy. Although 90 percent of the public is aware that
drinking during pregnancy may damage the fetus, one study showed that one-third of
women interviewed believed that drinking no more than three drinks a day during
pregnancy was safe.
Economic Factors ----
• Assuming a conservative estimate of one FAS newborn for every 1,000 live births in 1980,
it cost approximately $14.8 million to treat them; $670 million to treat the 68,000 FAS
children under 18; and $760 million to treat 160,000 FAS adults. Plus, indirect productivity
losses were $510.5 million.
• Women are now heavily targeted for marketing alcoholic beverages. (Women will spend
$30 billion on alcoholic beverages in 1994, up from $20 billion in 1984.)
ALCOHOL & DRUG EFFECTS-3
32
Public Health Recommendations ----
• The best advice for pregnant women is to abstain from alcohol consumption during
pregnancy. There is no evidence to establish an alcohol consumption level free of risks to
the fetus.
• Women who breast-feed should continue to abstain from drinking alcohol until their
babies are weaned. Alcohol readily enters breast milk and heavy alcohol consumption has
been shown to reduce lactation.
• Nine states and 18 cities/counties require that signs warning of the dangers of drinking
during pregnancy be posted wherever alcoholic beverages are served or sold.
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THE 9 SIGNS OF ALCOHOLISM…
1. Increase in alcohol tolerance.
"I can drink them under the table."
2. Occasional or partial memory lapses.
"Did I really do that last night?"
3. Drinking beyond one's intentions.
"Boy did I get smashed! I should have eaten something."
4. Increased dependence on alcohol.
"I can't wait…got to have a quickie."
5. Sneaking drinks.
"I needed the extra one … who's to know?"
6. Preoccupation with alcohol.
"Election day tomorrow…better pick up a bottle."
7. Resentful whenever one's drinking is discussed.
"It's none of their business….I can handle it."
8. Futile, frustrating water-wagon attempts.
"This time I've just got to dot it….Just got to!"
9. Rationalizing loss of control.
"If they had my problems, they'd drink too!"
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A Chart of Alcohol
Onset Occasional Relief Drinking Addiction Enlightened and Interesting Way of Realizations
of Memory Constant Relief Drinking Commences & Life Opens Up with Road to Recognized
Blackouts Increase in Alcohol Tolerance Recovery Higher Levels Than Ever
Before
Increasing Surrepitous Drinking Group Therapy and Mutual Help Continue Care of Personal
Dependence on Appearance
Alcohol Increasing Tolerance
Feelings of Guilt Urgency of First Drinks Contentment in Sobriety First Steps Toward
Economic Stability
Memory Blackouts
Increase Unable to Discuss Problems Confidence of Employers Increase of Emotional Control
Decrease of Ability to Stop Drinking Bolstered by Excuses Appreciation of Real Values Facts Faced with Courage
Drinking When Others Do So Rebirth of Ideals New Circle of Stable Friends
Persistent Remorse New Interests Develop Family and Friends Appreciate
Grandiose and Aggressive Efforts
Behavior Promises and Resolutions Fail Adjustment to Family Needs Natural Rest and Sleep
Efforts to Control Fail Repeatedly Loss of Other Interests Desire to Escape Goes Realistic Thinking
Tries Geographical Escapes Work and Money Troubles Return of Self Esteem Regular Nourishment Taken
Family and Friends Avoided Neglect of Food Diminishing Fears of the Appreciation of Possibilities of New Way of Life
Unknown Future
Unreasonable Resentments Tremors and Early Morning
Drinks Start of Group Therapy Onset of New Hope
Loss of Ordinary Willpower
Physical & Moral Right Thinking Begins Spiritual Needs Examined
Decrease in Alcohol Tolerance Deteriation
Meets Former Assisted in Making Personal
Onset of Lengthy Intoxications Drinking with Inferiors Addicts Normal & Happy
Stops Taking Alcohol
Impaired Thinking Unable to Initiate Action Told Addiction Learns Alcoholism is an Illness
Can Be Arrested
Indefinable Fears Vague Spiritual Desires Honest Desire for Help
Obsession with Drinking
All Alibis Exhausted
Complete Defeat Admitted
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ALCOHOL'S TRIP
THROUGH THE BODY
Mouth and Esophagus: Alcohol is an irritant to the delicate linings of
the throat and food pipe. It burns as it does down.
Stomach and Intestines: Alcohol has an irritating effect on the
stomach's protective lining, resulting in gastric or duodenal ulcers. This
condition, if it becomes acute, can cause peritonitis, or perforation of the
stomach wall. In the small intestine, alcohol blocks absorption of such
substances as thiamine, folic acid, fat, vitamin B1, vitamin B12, and
amino acids.
Bloodstream: 95% of the alcohol taken into the body is absorbed into
the bloodstream through the lining of the stomach and duodenum. Once
in the bloodstream, alcohol quickly goes to every cell and tissue in the
body. Alcohol causes red blood cells to clump together in sticky wads,
slowing circulation and depriving tissues of oxygen. It also causes anemia by reduction of red blood cell
production. Alcohol slows the ability of white cells to engulf and destroy bacteria and degenerates the
clotting ability of blood platelets.
Pancreas: Alcohol irritates the cells of the pancreas, causing them to swell, thus blocking the flow of
digestive enzymes. The chemicals, unable to enter the small intestine, begin to digest the pancreas, leading
to acute hemorrhagic pancreatitis. One out of five patients who develop this disease dies during the first
attack. Pancreatitis can destroy the pancreas and cause a lack of insulin thus resulting in diabetes.
Liver: Alcohol inflames the cells of the liver, causing them to swell and block the tiny canal to the small
intestines. This prevents bile from being filtered properly through the liver. Jaundice develops, turning the
whites of the eyes and skin yellow. Each drink of alcohol increases the number of live cells destroyed,
eventually causing cirrhosis of the liver. This disease is eight times more frequent among alcoholics than
among non-alcoholics.
Heart: Alcohol causes inflammation of the heart muscle. It has a toxic effect on the heart and causes
increased amounts of fat to collect, thus disrupting its normal metabolism.
Urinary Bladder and Kidneys: Alcohol inflames the lining of the urinary bladder making it unable to
stretch properly. In the kidneys, alcohol causes increased loss of fluids through its irritating effect.
Sex Glands: Swelling of the prostate gland caused by alcohol interferes with the ability of the male to
perform sexually. It also interferes with the ability to climax during intercourse.
Brain: The most dramatic and noticed effect of alcohol is on the brain. It depresses brain centers,
producing progressive uncoordination; confusion, disorientation, stupor, anesthesia, coma, death. Alcohol
kills brain cells and brain damage is permanent. Drinking over a period of time causes loss of memory,
judgment and learning ability.
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EFFECTS OF DRUGS
Marijuana
Marijuana is one of the most misunderstood and underestimated drugs of abuse. People use marijuana for
the mildly tranquilizing and mood and perception altering effect it produces. Marijuana does not depress
central nervous system reactions. It’s action is almost exclusively on the brain, altering the proper
interpretation of incoming messages.
Description----
• Usually sold in plastic sandwich bags, leaf marijuana will range in color from green to light tan.
The leaves are usually dry and broken into small pieces. The seeds are oval with one slightly pointed
end. Less prevalent, hashish is a compressed, sometimes tar-like substance ranging in color from pale
yellow to black. It is usually sold in small chunks wrapped in aluminum foil.
• Marijuana has a distinctly pungent aroma resembling a combination of sweet alfalfa and incense.
• Cigarette papers, roach clip holders and small pipes made of bone, brass or glass are commonly
found. Smoking "bongs" (large bore pipes for inhaling large volumes of smoke) can easily be made
from soft drink cans and toilet paper rolls.
Signs and Symptoms of Use----
• Reddened eyes (often masked by eyedrops)
• Slowed speech
• Distinctive odor on clothing
• Lackadaisical, "I don't care" attitude
• Chronic fatigue and lack of motivation
• Irritating cough, chronic sore throat.
Health Effects----
• The active chemical, tetrahydrocannabinol (THC), and 60 other related chemicals in marijuana
concentrate in the ovaries and testes.
• Chronic smoking of marijuana in males causes a decrease in the sex hormone, testosterone, and an
increase in estrogen, the female sex hormone. The result is a decrease in sperm count, which can lead
to temporary sterility. Occasionally, the onset of female sex characteristics including breast
development occurs in heavy users.
• Chronic smoking of marijuana in females causes a decrease in fertility and an increase in
testosterone.
• Pregnant women who are chronic marijuana smokers have a higher than normal incidence of
stillborn births, early termination of pregnancy, and higher infant mortality rate during the first few
days of life.
• In test animals, THC causes birth defects, including malformations of the brain, spinal cord,
forelimbs and liver, and water on the brain and spine.
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• Offspring of test animals who were exposed to marijuana have fewer chromosomes than normal,
causing gross birth defects or death of the fetus. Pediatricians and surgeons are concluding that the
use of marijuana by either or both parents, especially during pregnancy, leads to specific birth defects
of the infant's feet and hands.
• One of the most common effects of prenatal cannabinoid exposure is underweight newborn babies.
• Fetal exposure may decrease visual functioning and causes other ophthalmic problems.
Mental Function---- Regular use of marijuana can cause the following effects:
• Delayed decision making
• Diminished concentration
• Impaired short-term memory, interfering with learning
• Impaired signal detection (ability to detect a brief flash of light), a risk for users who are operating
machinery
• Impaired tracking (the ability to follow moving objects with the eyes) and visual distance
measurements
• Erratic cognitive function
• Distortions in time estimation
• Long term negative effects on mental function known as "acute brain syndrome" which is
characterized by disorders in memory, cognitive function, sleep patters and physical condition.
Acute/Overdose Effects---
• Aggressive urges
• Anxiety
• Confusion
• Fearfulness
• Hallucinations
• Heavy sedation
• Immobility
• Mental dependency
• Panic
• Paranoid reaction
• Unpleasant distortions in body image
Workplace Issues---
• The active chemical, THC, is stored in body fat and slowly releases over time. Marijuana smoking
has a long-term effect on performance.
• A 500 to 800 percent increase in THC potency in the past several years makes smoking three to five
joints a week today, equivalent to 15 to 40 joints a week in 1978.
• Combining alcohol or other depressant drugs and marijuana can produce a multiplied effect,
increasing the impairing effects of both the depressant and the marijuana.
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Cocaine
Cocaine is used medically as a local anesthetic. It is abused as a powerful physical and mental stimulant.
The entire central nervous system is energized. Muscles are more tense, the heart beets faster and stronger,
and the body burns more energy. The brain experiences an exhilaration caused by a large release of
neurohormones associated with mood elevation.
Description ---
• The source of cocaine is the coca bush, grown almost exclusively in the mountainous regions of
northern South America.
• Cocaine Hydrochloride- "snorting coke" is a white creamy granular or lumpy powder that is
chopped into a fine powder before use. It is snorted into the nose, rubbed on the gums or injected in
veins. The effect is felt within minutes and lasts 40 to 50 minutes per "line" (about 60 to 90
milligrams). Common paraphernalia includes a single-edged razor blade and a small mirror or piece
of smooth metal, a half straw or metal tube, and a small screw-cap vial or folded paper packet
containing the cocaine.
• Cocaine Base --- "rock, crack or free base: is a small crystalline rock about the size of a
small pebble. It boils at a low temperature, is not soluble in water, and is up to 90 percent
pure. It is heated in a glass pipe and the vapor is inhaled. The effect is felt within seven
seconds. Common paraphernalia includes a "crack pipe" (a small glass smoking device for
vaporizing the crack crystal) and a lighter, alcohol lamp or small butane torch for heating.
Signs and Symptoms of Use----
• Financial problems
• Frequent and extended absences from meetings or work assignments
• Increased physical activity and fatigue
• Isolation and withdrawal from friends and normal activities
• Secretive behaviors, frequent non-business visitors, delivered packages, phone calls
• Unusual defensiveness, anxiety, agitation
• Wide mood swings
• Runny or irritated nose
• Difficulty in concentration
• Dilated pupils and visual impairment
• Restlessness
• Formicating (sensation of bugs crawling on skin)
• High blood pressure, heart palpitations and irregular rhythm
• Hallucinations
• Hyper-excitability and overreaction to stimulus
• Insomnia
• Paranoia and hallucinations
• Profuse sweating and dry mouth
• Talkativeness
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Health Effects ---
• Research suggests that regular cocaine use may upset the chemical balance of the brain. As a
result, it may speed up the aging process by causing irreparable damage to critical nerve cells. The
onset of nervous system illnesses such as Parkinson's disease could also occur.
• Cocaine use causes the heart to beat faster and harder and rapidly increases blood pressure. In
addition, cocaine causes spasms of blood vessels in the brain and heart. Both effects lead to ruptured
vessels causing strokes and heart attacks.
• Strong psychological dependency can occur with one "hit" of crack. Usually, mental dependency
occurs within days (crack) or within several months (snorting coke). Cocaine causes the strongest
mental dependency of any known drug.
• Treatment success rates are lower than for other chemical dependencies.
• Cocaine is extremely dangerous when taken with depressant drugs. Death due to overdose is
rapid. The fatal effects of an overdose are usually not reversible by medical intervention. The number
of cocaine overdose deaths has tripled in the last four years.
• Cocaine overdose was the second most common drug emergency in 1986, up from 11th place in
1980.
Workplace Issues ----
• Extreme mood and energy swings create instability. Sudden noises can cause a violent reaction.
• Lapses in attention and ignoring warning signals greatly increase the potential for accidents.
• The high cost of cocaine frequently leads to workplace theft and/or dealing.
• A developing paranoia and withdrawal create unpredictable and sometimes violent behavior.
• Work performance is characterized by forgetfulness, absenteeism, tardiness and missed
assignments.
Opiates
Opiates are narcotic drugs that alleviate pain, depress body functions and reactions and, when taken in
large doses, cause a strong euphoric feeling.
Description ----
• Natural and natural derivatives - opium, morphine, codeine and heroin
• Synthetics - meperidine (Demerol®), oxymorphone (Numorphan®), and oxycodone (Percodan®).
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• May be taken in pill form, smoked or injected depending upon the type of narcotic used.
Signs and Symptoms of Use ----
• Mood changes
• Impaired mental functioning and alertness
• Constricted pupils
• Depression and apathy
• Impaired coordination
• Physical fatigue and drowsiness
• Nausea, vomiting and constipation
Health Effects ----
• IV needle users have a high risk for contracting hepatitis and AIDS due to the sharing of needles.
• Narcotics increase pain tolerance. As a result, people could more severely injure themselves or fail
to seek medical attention after an accident due to the lack of pain sensitivity.
• Narcotics' effects are multiplied when used in combination with other depressant drugs and
alcohol, causing increased risk for an overdose.
Social Issues ----
• There are over 500,000 heroin addicts in the U.S., most of whom are IV needle users.
• An even greater number of medicinal narcotic dependent persons obtain their narcotics through
prescriptions.
• Because of tolerance, there is an ever increasing need for more narcotic to produce the same effect.
• Strong mental and physical dependency occurs.
• The combination of tolerance and dependency creates an increasing financial burden for the user.
Costs for heroin can reach hundreds of dollars a day.
Workplace Issues ---
• Unwanted side effects such as nausea, vomiting, dizziness, mental clouding and drowsiness place
the legitimate medical use in alleviating pain. Workplace use may cause impairment of physical and
mental function.
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Amphetamines
Amphetamines are central nervous system stimulants that speed up the mind and body. The physical sense
of energy at lower doses and the mental exhilaration of higher doses are the reasons for their abuse.
Although widely prescribed at one time for weight reduction and mood elevation, the legal use of
amphetamines is now limited to a very narrow range of medical conditions. Most amphetamines that are
abused are illegally manufactured in foreign countries and smuggled into the U.S. or clandestinely
manufactured in crude laboratories.
Description ----
• Amphetamine ("speed") is sold in counterfeit capsules or as white, flat, double-scored "mini
bennies". It is usually taken by mouth. Methamphetamine ("meth", "crank", or "crystal") is nearly
identical in action to amphetamine. It is often sold as a creamy, white and granular powder or in
lumps and is packaged in aluminum foil wraps or sealable plastic bags. Methamphetamine may be
taken orally, injected or snorted into the nose.
Signs and Symptoms of Use ---
• Hyper-excitability, restlessness
• Dilated pupils
• Increased heart rate and blood pressure
• Heart palpitations and irregular beets
• Profuse sweating
• Rapid respiration
• Confusion
• Panic
• Talkativeness
• Inability to concentrate
Health Effects ---
• Regular use produces strong psychological dependence and increasing tolerance to drug.
• High doses may cause toxic psychosis resembling schizophrenia.
• 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.
• The euphoric stimulation increases impulsive and risk-taking behavior, including bizarre and
violent acts.
• Withdrawal from the drug may result in severe physical and mental depression.
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Workplace Issues ----
Since amphetamines alleviate the sensation of fatigue, they may be abused to increase alertness because of
unusual demands or failure to get rest.
Low dose amphetamine use will cause a short term improvement in mental and physical functioning. With
greater use or increasing fatigue the effect reverses and has an impairing effect. Hangover effect is
characterized by physical fatigue and depression, which make operation of equipment or vehicles dangerous.
Phencyclidine (PCP)
Phencyclidine (PCP) was originally developed as an anesthetic, but the adverse side effects prevented its use
except as a large animal tranquilizer. Phencyclidine acts as both a depressant and a hallucinogen, and
sometimes as a stimulant. It is abused primarily for its variety of mood altering effects. A low dose
produces sedation and euphoric mood changes. The mood can change rapidly from sedation to excitation and
agitation. Larger doses may produce coma-like condition with muscle rigidity and a blank stare, with the
eyelids half closed. Sudden noises or physical shocks may cause a "freak out" in which the person has
abnormal strength, extremely violent behavior, and an inability to speak or comprehend communication.
Description ----
• PCP is sold as a creamy, granular powder and often packaged in one inch square aluminum foil or
folded paper "packets".
• It may be mixed with marijuana or tobacco and smoked. It is sometimes combined with procaine,
a local anesthetic, and sold as imitation cocaine.
Signs and Symptoms of Use -----
• Impaired coordination
• Severe confusion and agitation
• Extreme mood shift
• Muscle rigidity
• Nystagmus (jerky eye movements)
• Dilated pupils
• Profuse sweating
• Rapid heartbeat
• Dizziness
Health Effects -----
• The potential for accidents and overdose emergencies is high due to the extreme mental effects
combined with the anesthetic effect on the body.
• PCP is potentiated by other depressant drugs, including alcohol, increasing the likelihood of an
overdose reaction.
• Misdiagnosing the hallucinations as LSD induced, and then treating with Thorazine, can cause a
fatal reaction.
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• Use can cause irreversible memory loss, personality changes, and thought disorders.
Workplace Issues ---
• PCP abuse is less common today than in recent years. It is also not generally used in a workplace
setting because of the severe disorientation that occurs.
• There are four phases to PCP abuse. The first phase is acute toxicity. It can last up to three days
and can include combativeness, catatonia, convulsions and coma. Distortions of size, shape and
distance perception are common. The second phase, which does not always follow the first, is a toxic
psychosis. Users may experience visual and auditory delusions, paranoia and agitation. The third
phase is a drug induced schizophrenia that may last a month or longer. The fourth phase is PCP
induced depression. Suicidal tendencies and mental dysfunction can last for months.
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The Warning Signs of Substance Abuse
The existence of an alcohol or drug problem often manifests itself in an employee's work performance,
behavior or appearance in the following ways:
1. Excessive absences and/or tardiness (especially after a weekend holiday).
2. Frequent requests for time off during the workday.
3. Numerous accidents without explanation.
4. Pattern of accidents in area during a particular time shift.
5. Noticeable increase in medical insurance claims, particularly for non-job injuries.
6. Unsatisfactory work performance.
7. Lack of concentration or decreased productivity after lunch or breaks.
8. Non-work-related visits from other employees or strangers.
9. Frequent trips to the restroom or water fountain.
10. Long lunch hours.
11. Frequent visits to automobile/parking lot.
12. Drowsiness, slurred speech, lack or coordination, inability to concentrate, nausea or other
physical symptoms.
13. Agitation, rapid or slurred speech, dizziness, dilated pupils.
14. Bloodshot eyes, runny nose.
15. Drastic weight changes.
16. Marked change in mood, attitude and behavior.
17. Deterioration in personal grooming and hygiene.
18. Wearing sunglasses and long-sleeved shirts at inappropriate times to hide dilated pupils or
needle marks.
19. Frequent need to borrow money.
20. Avoidance of supervisors.
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