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G. TESTING PROCEDURES

1) Confidentiality: The following procedures have been established with the objectives of
maintaining the highest levels of employee privacy and dignity consistent with applicable laws
and ensuring high levels of test reliability and validity.

2) Laboratory: All drug testing will be conducted by an approved medical testing laboratory,
as the same is defined by applicable statutes. Initial tests shall be done with the enzyme
multiplied immunoassay (EMI) technique or other reliable method. Every specimen which
tests positive with the EMI technique or other reliable method will be subjected to confirmatory
testing using gas chromatography/mass spectrometry (GC/MS) techniques or other reliable
techniques.
3) Second Confirmation: Employees with a confirmed positive test result may, at their
option and expense, have a second confirmation test made on the same specimen within 90
days from the time the results of the confirmed positive examination are mailed or otherwise
provided to HEPACO. An employee will not be allowed to submit another specimen for
testing.

4) Privacy: Procedures for collecting urine specimens shall allow individual privacy, and no one
shall be observed unless there is reason to believe that a particular individual may alter or
substitute the specimen to be provided.

5) Delivery of Results: Test results will be delivered to Home Office. All results are to be
kept confidential. The employee will be informed of the results by HEPACO’s President or
Designated official.

6) Use of Results: “Need to Know”: The results of the physical examination, including the
drug screen and the results of testing, will be reported to HEPACO and will not be disclosed to
anyone except the applicant or employee unless otherwise required by any governmental, state
or local agent. HEPACO shall not discuss the results of an applicant’s physical or employee
testing with anyone outside the company and should only discuss the results of the physical or
employee testing with those within the company who have a real need to know in the
performance of their job duties.
7) Restricted Access to Results: Results of the physical and employee testing will be filed
separate from the individual’s personnel file. Such file shall be labeled “confidential” and
access to it restricted to the appropriate HEPACO officials, employee or those authorized in
writing by the employee.

H. CONVICTIONS

Any employee arrested or convicted of a drug or alcohol-related offense is required to notify
HEPACO no later than five (5) days after the conviction. “Conviction” includes pleas of guilty or
nolo contendre (“no contest”).

Document No. 804: Drug and Alcohol Abuse Policy
Revised December 2000 Page 6