Policies,Administrative,UWMF,UWMF-wide,Human Resources

Substance Abuse Policy (108.048)

Substance Abuse Policy (108.048) - Policies, Administrative, UWMF, UWMF-wide, Human Resources


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Human Resources
Substance Abuse Policy

As of 11/15/2012, this administrative policy applies to the operations and staff of legacy
UWMF. Effective July 1, 2015, the legacy operations and staff of UWHC and UWMF
were integrated into the University of Wisconsin Hospitals and Clinics Authority
(UWHCA). All administrative policies are being transitioned to apply UWHCA-wide, but
until future revision to this policy #108.048, it applies only to the operations and staff of
legacy UWMF.

Effective Date: 11/15/2012
Supersedes Policy Date: 09/01/2009

Drug and alcohol abuse have become a major problem nationally. In the work place,
this abuse contributes to high rates of absenteeism, tardiness, personal and property
injury, as well as decreased production and production quality. University of
Wisconsin Medical Foundation (UWMF) is committed to maintaining a safe,
productive, and drug-free work environment for all employees. The abuse of such
substances poses a danger to the health and safety of each employee, as well as to
the patients and property of the organization. The following policy is meant to
establish clear standards concerning drugs and alcohol, which all employees must

I. To promote a safe, productive, drug and alcohol free work environment.
II. To define the procedures for conducting drug and alcohol screening.
III. To assist employees toward rehabilitation from any alcohol or substance abuse
or dependence.

Since UWMF is a recipient of federal grants, UWMF is required by the federal
government to certify that it will provide a drug free workplace (Drug Free Workplace
Act of 1988). As part of these requirements, UWMF prohibits the unlawful
manufacture, distribution, possession, or use of alcohol, illegal drugs, or controlled
substances, other than prescription drugs, on UWMF work time or on UWMF
business premises. Possession, use, or being under the influence of any of the
above on UWMF work time on UWMF business premises is grounds for disciplinary
action and could include termination.
The Drug Free Workplace Act also requires that UWMF employees notify the Medical
Director, or his / her designee, within five (5) days of any criminal drug conviction
when the violation occurred on UWMF premises. UWMF is required to notify the
federal agency administering the grant, in writing, within ten (10) days after receiving
notice from an employee or otherwise receiving actual notice of such conviction.

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An employee who voluntarily acknowledges a substance abuse problem and
requests assistance with a drug or alcohol rehabilitation program prior to UWMF
identifying drug or alcohol impairment and / or use on the job, will be granted an
unpaid leave in accordance with UWMF's Time Off Policy. No disciplinary action will
be taken when the employee comes forward prior to the UWMF identifying drug or
alcohol abuse on the job. UW Medical Foundation can direct employees to

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appropriate community resources to obtain assistance in the assessment and
treatment of drug and / or alcohol disorders.
No employee will possess, use, or sell illegal drugs, intoxicants, or mind-altering
substances while on the job or on UWMF property. In addition, no employee will
report to work smelling of or under the influence of alcohol, any inhalant, or other
drug, lawful or unlawful, even if because of use off company premises and time,
except with managements’ approval. UWMF reserves the right to do drug and alcohol
testing on any individual(s) whenever reasonable suspicion exists that the employee
is unfit for duty due to alcohol or drug abuse, as well as post-accident or for suspicion
of theft of controlled prescription drugs from the premises.
UWMF takes a "zero tolerance" position with respect to alcohol and illegal drugs: no
alcohol or illegal drug in a person’s system while on the Foundation’s time or
premises will be tolerated. Off the job use, possession, transferring and / or selling of
illegal substances is also prohibited under this policy.
Approval of drug use at the workplace is limited to the use of medications legally
prescribed to the employee or available over-the-counter and based strictly on an
assessment of the employee’s ability to perform regular or other assigned duties
safely and efficiently. It is the employee’s responsibility to be aware of any
performance or behavioral side effects of legally obtained drugs and to advise their
Manager and / or designee of any possible effects. Nothing in this policy precludes
the appropriate use of legally obtained drugs while at work or in work related
situations, as long as such use does not affect the safety of the employee, other
employees or patients.
UWMF considers drug addiction and alcoholism to be treatable diseases and is
committed to providing assistance in this regard. UWMF urges employees with a
substance abuse disorder to voluntarily seek help through the Employee Assistance
Program (EAP). Employees may contact the Employee Assistance Program
confidentially by dialing 1-800-362-3902. However, an employee may be disciplined
for any misconduct related to, or damage or injury caused by, his or her substance
Employees who violate this policy may be required, as a condition of employment, to
complete an assessment and treatment in a certified treatment program for alcohol or
drug abuse disorders. Payment of professional service fees for continuing or long-
term rehabilitation services for any diagnosed alcohol or drug abuse disorder is the
ultimate responsibility of the employee. Violation of these provisions will result in the
employee’s immediate removal from the location of work and appropriate disciplinary
action taken, which may include termination of employment.
Employees may, if necessary, request a leave of absence in order to obtain
treatment. These requests will be considered on an individual basis and in
accordance with the UWMF’s “Family and Medical Leave Policy”.
UWMF reserves the right to approve any prescribed plans of treatment, and to
receive any medical information that would be relevant to the performance of job
responsibilities. Such information will be treated confidentially and will be shared
only with those individuals who need the information to ensure a safe work
environment and quality patient care.

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Actions related to the investigation and results of alcohol / drug testing shall remain
confidential and available only to those with a need to know. Any violation or non-
observance of this policy shall result in appropriate disciplinary action up to and
including termination of the employee. The following procedure acts as a guide to
assist management in the application of fair and consistent treatment of individuals
and, in appropriate situations, to assist employees in seeking help where a
suspected or known misuse / abuse problem exists.

Substance Abuse: The illicit use of, consuming, possessing, transferring, or selling
alcohol, drugs or other controlled mind-altering or non-prescription substances on
company premises, in company vehicles, or during work hours, including breaks,
meals, and overtime. Off the job activity including any illegal use in above noted
situations is also prohibited under this policy.
Impairment: Loss of physical or psychological capacity to satisfactorily perform
required job duties.
Chain of Custody: A procedure, as identified by the US Department of Health and
Human Services (DHHS), for ensuring that urine specimens obtained for drug testing
are properly labeled and have not been tampered with en route to the laboratory.
Reasonable suspicion / For cause: Actions, physical appearance, conduct, or
behaviors by an employee that suggest drug or alcohol abuse / use.
Certified Medical Review Officer (MRO). A licensed physician, certified by a
nationally recognized certification board, who is responsible for reviewing laboratory
drug test results and evaluating medical explanations for results on controlled

1. Any employee at work or reporting to work with physical signs and / or
behavioral symptoms of drug or alcohol abuse/use will be investigated by his /
her manager. Human Resources must be notified of the situation, especially
when safety issues are present.
2. Managers will refer to the following for assistance in determining that
reasonable suspicion exists to warrant drug and alcohol testing:
Observable Characteristics in Determining Reasonable Cause / Suspicion
(Attachment A) is a list of physical and mental effects of drug and alcohol
use to assist managers in determining whether reasonable suspicion
exists. Patterns or clusters should be considered and the presence of
behaviors does not necessarily confirm substance use / abuse / addiction.
Managers should attempt to have at least one other supervisor observe
the employee's behavior, if possible.
Supervisor’s Observation Checklist (Attachment B) is a documentation tool
to be used by managers to record the employee's appearance, behaviors,
speech and body odors that give rise to the suspicion of drug or alcohol
use / abuse.

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3. Once it is determined that reasonable suspicion exists, the manager or
designee will meet with the employee IN PRIVATE to discuss the observations
of abnormal behaviors or odors. Managers should refer to the Manager Quick
Reference Sheet (Attachment D) prior to approaching an employee in a
possible substance abuse situation.
4. If a physician is involved, the manager or designee must notify the Medical
Director immediately. If the Medical Director is not available, the Vice
President of Human Resources is to be contacted.

After reasonable suspicion has been determined, the employee will be informed that
he / she will be required to take a breath alcohol test and provide a urine specimen
for drug testing. All drug and alcohol testing will be conducted by a laboratory
certified by the Department of Health and Human Services (DHHS) or the Substance
Abuse and Mental Health Services Administration (SAMHSA).
1. Prior to sample collection, the employee will be required to sign consent and
release forms authorizing and agreeing to the collection and testing of a
sample, or samples, of his/her urine, blood or breath. If possible, this signature
must be witnessed by third party. A sample of such form is attached,
ATTACHMENT C, though any form chosen by UWMF may be used.
2. After the employee consents to testing, the following will be done:
a. The manager will notify Human Resources and then will immediately
escort the employee to the closest designated collection site
(Attachment F) for specimen collection. If after hours, call Human
Resources at 608-235-3403 or 608-843-1965. Human Resources will
notify Employee Health of the testing and the collection site.
 The collection site will administer a Breath Alcohol Test (B.A.T.),
and obtain a Chain of Custody urine specimen for Drug Panel 9
with extended opiates and any additional drug panels being
investigated for suspicion of theft. EXCEPTION: With drug theft
investigations, alcohol testing may not be done.
 After the Chain of Custody Drug Panel and B.A.T. have been
collected, the employee will be suspended with pay until the
Chain of Custody Drug Test results are received. EXCEPTION:
Any employee(s) being tested for suspicion of theft only may
return to work while waiting for final test results.
b. The employee's manager or designee is responsible for assisting the
employee in securing alternate transportation home. DO NOT LET THE
EMPLOYEE DRIVE HOME. Call a family member or friend to assist or
call Patient Resources for a cab voucher. Patient Resources will bill the
employee's department for the cab voucher. If the employee insists on
leaving without assistance call 911.

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3. If the employee refuses to be tested, the following will be done:
a. Have the employee sign the Alcohol / Drug Testing Refusal Form,
Attachment E. If possible, have their signature witnessed by a third
party. Advise the employee that refusal to submit to such medical tests
is a violation of this policy and will result in immediate termination.
b. The supervisor is responsible for assisting the individual in finding
transportation home. DO NOT LET THE INDIVIDUAL DRIVE. See 2b

Test results will be directed by the collection site and drug testing lab to the
designated UWMF contacts in Employee Health, who will then contact Human
Resources and / or the Medical Director.
1. Breath Alcohol Test results are available immediately at the time of testing to
the tester and the test subject. Only designated UWMF contacts in Employee
Health or if after hours, Human Resources, will be contacted by the collection
site with results. UWMF will consider a Breath Alcohol Test positive if any
concentration of alcohol is detected.
2. Chain of Custody Drug Panels and Synthetic Opiate results will be handled as
Negative test results – If all test results are negative, Human Resources
and / or Medical Director will advise the employee / physician and the
respective manager of the results.
Positive test results – If any substance tests positive, the results will be
sent by the lab directly to an independent Medical Review Officer
(MRO) for review.
MRO confirmed positive test results – Drug testing will be considered a
confirmed positive result when the MRO determines that there is no
legitimate medical explanation for the positive test result. Upon receipt
of an MRO confirmed positive result, Employee Health will notify
Human Resources and the Medical Director. The Medical Director will
handle situations involving physicians, Human Resources will handle all
other employee situations, and appropriate disciplinary action up to and
including termination will occur.
MRO confirmed negative results - Drug testing will be considered a
confirmed negative result when the MRO determines that a legitimate
medical reason for the positive test result exists. Upon receipt of an
MRO confirmed negative result, it will be reported and treated the same
as a negative test result (see above).
Human Resources and / or Medical Director with share the results with the affected
employee and manager. The employee may be given a copy of the test results upon
request. Regardless of any final test results, the employee will be given the
opportunity to provide an explanation for his / her actions and behaviors.

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1. When test results are negative, the employee will return to work and will be
advised if any disciplinary action is indicated regarding the work-related
behavior that prompted the testing.
2. When test results are positive, Human Resources will determine if the
employee will be given the opportunity to consent, in writing, to a “Last
Chance” agreement or be immediately terminated. If a “Last Chance
Agreement” is signed, the employee must agree to the following:
The employee will enter and successfully complete a drug or
alcohol treatment program acceptable to UWMF.
Prior to return to the work site, negative Chain of Custody Drug
Panels and Breath Alcohol Tests will be required.
The employee agrees to unannounced random drug / alcohol
testing after return to work.
Any positive drug / alcohol test after return to work will result in
immediate termination.

All results related to the administration of drug and alcohol testing shall be kept in a
separate and confidential file in the Employee Health Department, NOT filed in
personal Employee Health records. The records will be retained in Employee Health
for a minimum period of five years. Additionally, Employee Health will retain all
appropriate contracts related to drug and alcohol collection and Medical Review
Officer services.

Licensed professional employees with drug and / or alcohol abuse issues will be
reported to the Wisconsin Department of Regulation and Licensing as indicated.

1. When a supervisor or management representative has reason to believe an
employee or physician is engaged in the illicit use, consumption, possession,
sale, or transfer of alcohol, illegal drugs or other mind altering substances on
the job or on UWMF property, the supervisor should use his / her best
judgment in utilizing the following suggestions. NOTE: It may not be possible
or practical to utilize all of the suggestions given; further, circumstances may
dictate taking actions other than those outlined below.
a. Contact Administration or Human Resources to define a plan of action
to immediately confiscate all alcohol, drugs, mind-altering substances,
and / or drug paraphernalia so evidence can be accurately labeled and
preserved. A member of Administration will determine the
appropriateness of contacting local law enforcement authorities.

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b. Take the employee(s) involved to a location where each individual can
be questioned privately about the incident. The Medical Director will
handle cases involving physicians.
c. Do not allow the employee to work or to remain on the premises
following the initial investigator interview. Inform the employee(s) that
they are suspended with pay pending results of the investigation. If the
results of the investigation are negative, the employee will return to
d. Make a detailed record of all actions, statements and other pertinent
facts which follow any incident that might fall under these guidelines.
e. If alcohol and / or drugs or drug paraphernalia are found on UWMF
property, and it is not obvious who the owner is, report the incident to
the Human Resources Department. An effort will be made to determine
the owner of the property by questioning personnel who may have been
in the immediate area.

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General Physical and Mental Effects of Drug and Alcohol Use
The physical and mental effects of substance abuse occur not only during intoxication (from less than one hour
to 24 hours after intake), but also show up in residual hangovers, fatigue rebounds and mental impairment. Other
physical and mental effects may include the following:
• Slow reactions • Poor coordination
• Fatigue • Delayed decision making
• Erratic judgment • Confusion
• Learning difficulty • Poor memory
• Loss of concentration • Depression or anxiety
• Refusal to accept authority • Neurotic or psychotic behavior
• Difficulty in sorting out priority tasks from non-essential activity
Common Job Sites Where Drugs are Used
Drug users tend to frequent certain job sites that allow for either the privacy necessary to prevent detection or the
anonymity that may be provided by the cover of a crowded area. Common job sites where drugs are used
• Lunchrooms and lounge areas • Parking lots, cars and other vehicles
• Remote areas of the worksite • Equipment or storage rooms
• Restrooms
Behavior Signs of Substance Abuse
General performance or behavior problems with an employee may suggest drug or alcohol use. Examples of
such behavior include:
• Hangover symptoms • Drug culture jargon
• Changes in personal appearance and hygiene • Carelessness
• Impulsive and temperamental behavior • Jitters, hand tremors, hyper-excitability
• Deteriorating or erratic performance • Sleeping on the job
• A sudden change, usually for the worse, in attitude, work performance or behavior.
• A lackadaisical or “I don’t care” attitude (often an indication of marijuana use)
• Secretive behavior; for instance, inappropriate whispering or wearing sunglasses indoors
• Wanting to be alone, avoiding “straight” (non-substance abusing) coworkers
• Forgetfulness, indecision and erratic judgment

Each symptom by itself may point to problems other than drug abuse. However, when a pattern begins to
develop, the supervisor or manager needs to be alert and act quickly. When fueled by drug or alcohol abuse,
these behaviors can lead to greater absenteeism, higher operating costs, serious production problems and a
definite increase in accidents and health care costs.

Physical Symptoms of Substance Abuse
Observable physical signs and symptoms are usually not apparent until the employee’s drug or alcohol abuse has
reached an advanced level. At advanced stages of drug use the employee is less able to disguise these physical
indicators, and often becomes careless because of a clouded mental state. Specific signs include:
• Hand tremors • Intoxicated behavior (swaying, staggering)
• An odor of alcohol on breath • An odor of marijuana smoke
• Actual on-the-job, out-in-the-open drug use • Poor coordination
• Slow reactions • An unsteady gait
• Blood spots on shirt-sleeves (suggesting intravenous needle use)
• Bloodshot or watery eyes (usually caused by marijuana use)
• Changes in speech (slowed, slurred or incoherent)
• Very large or small pupils (narcotics and depressants will cause the pupils to constrict, cocaine and
amphetamines will cause the pupils to dilate).
• A runny nose or sores around nostrils (caused by chronic snorting of cocaine)
• Racing heart, irregular rhythms (cocaine and amphetamines often cause the heart to react unpredictably)

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Directions: The supervisor should record any signs, conditions and/or observations that cause the supervisor to
suspect that an employee may be under the influence of alcohol, any inhalant or other drugs.
Observations should focus on items which deviate from the employee’s normal or usual behavior.

1. Walking (e.g., stumbling, staggering, falling, swaying, unsteady, holding on).

2. Standing (e.g., swaying, rigid, unable to stand, feet wide apart, sagging at knees)

3. Speech (e.g., shouting, silent, whispering, slow, rambling, slurred, slobbering, incoherent)

4. Demeanor (e.g., uncooperative, inattentive, sleepy, crying, withdrawn, agitated, talkative, excited,
argumentative, sarcastic, challenging)

5. Actions (e.g., resisting communications, fighting, disoriented, threatening, calm, drowsy, use of profanity,
hyperactive, hostile, pacing, erratic)

6. Eyes (e.g., dilated pupils, pinpoint pupils, watery, bloodshot, glassy, glazed, droopy, closed)

7. Face (e.g., flushed, pale, sweaty)

8. Appearance (e.g., unkempt, messy, dirty)

9. Breath/Odor (e.g., alcohol odor, marijuana or uncharacteristic odor on breath or clothes)

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10. Movements (e.g., fumbling, jerky, slow, nervous, hyperactive)

11. Eating/Chewing (e.g., gum, candy, mints, other-identify if possible)

12. Balance (e.g., falling, swaying, staggering, sagging knees)

13. Turning/Changing Directions (e.g., swaying, stumbling, arms extended for balance, falling, reaching for

14. Awareness (e.g., confused, bewildered, sleepy, alert)

15. Did you attempt to discover alternative explanations for the employee’s behavior and/or appearance other
than potential substance use? Yes No Explain further:

16. Other Observations/Comments

Supervisor Signature Date Time
Witness Signature Date Time

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I, , hereby consent to and authorize testing for drug
and alcohol use under the Drug Testing Policy of UW Medical Foundation, which will be
conducted by an independent testing establishment utilizing standard testing methods.
Furthermore, I hereby consent to and authorize the disclosure of the results of the test and
other test-related information to the Company’s Medical Director, as well as such intra-
corporate disclosure of the test results and other test-related information as the Company may
deem reasonably necessary to carry out the purposes of its Drug Testing Policy and Program
or as law may require.

I understand that, if I decline to complete and sign this Consent/Authorization form, the
Company will be so notified and my employment will be terminated. I further understand that
if my drug test result is confirmed as positive, I may be subject to discipline, up to and
including discharge, or may be treated as an employee/driver seeking rehabilitation under the
provisions of the Company’s Drug Testing Policy and Program at the Company’s discretion
and will be subject to all of the same terms and conditions under that Policy/Program as any
employee seeking rehabilitation.

I understand the company may, by means of contacting my physician(s) or by whatever
means it deems advisable, investigate whether it will be necessary to impose any restrictions
on my employment or contract as a result of my ingestion of any prescribed or over-the-
counter drugs or substances, and if so determined, impose such restrictions, which may
include termination of my employment or contract.

I have received and read a copy of the Company’s Drug Testing Policy and Program, and
I hereby:
Consent to and authorize testing for breath alcohol and drugs.
Refuse to consent to or authorize testing for drugs and alcohol.


Social Security Number Date Time

Witness: Date Time

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Manager/Designee Quick Reference

1. Observe the employee suspected of being under the influence of alcohol or drugs.

2. Document complete and accurate observations utilizing (Attachment A and B)
A – Observable Characteristics in Determining Reasonable Cause
B – Supervisor’s Observation Checklist
Attempt to have another supervisor observe the employee’s behavior.

3. Contact your Human Resources representative to discuss observations.
After hours: contact the Human Resources at 608-235-3403 or 843-1965.
If a physician is involved, the Medical Director must be notified.

4. Approach employee regarding suspected substance abuse situation:
Meet with the employee in a private area.
Stress to the employee that the interaction is confidential.
Confine criticism to behaviors/actions, not the employee personally.
Present the reasonable cause/suspicion data in detail. Use dates, times, places,
circumstances from the Supervisor’s Observation Checklist.
Do not share with the employee the name(s) of any individuals who
complained of possible substance abuse behaviors.

5. Obtain a signed Consent to Drug Test (Attachment C) from employee.
If employee refuses to consent, obtain their signature on the Refusal for Drug Testing
form (Attachment E), and inform employee of the possible consequences outlined in
the policy and notify Human Resources. If possible, both the consent to drug test and
refusal should be witnessed by a third party.

6. Escort the employee to the closest designated collection site (Attachment F). Have the
employee bring a drivers license or photo ID with first and last name.

7. Allow at least one hour. Breath alcohol testing will be repeated if initial test is
positive. Verify that specimens have been collected prior to leaving the collection site.

8. DO NOT LET THE EMPLOYEE DRIVE HOME! The employee’s supervisor is
responsible for assisting the employee in securing alternate transportation home. If no
options are available, obtain a cab voucher from Patient Resources. The employee’s
department will assume the cost. If the employee insists on leaving without
assistance, call 911.

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I, , have been requested by my Manager
/ Supervisor to obtain breath alcohol and urine drug toxicology tests, and I am refusing to
have such testing done.

The consequences of such action have been explained to me. My refusal, along with
previously described observable abnormal behaviors, constitutes a violation of the UW
Medical Foundation “For Cause” Substance Abuse Policy/Procedure and is considered to be
equivalent to an unconfirmed “positive” test; I understand I will be immediately terminated.

Employee’s Signature Date and Time


Witness’s Signature Date and Time

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Alcohol/Chain of Custody Drug Collection Sites

Site Hours of Operation

Concentra Medical Center-East 8:30 am – 5:30 pm
1619 N. Stoughton Road Mon – Fri
Madison, WI 53704

Concentra Medical Center-West 8:30 am – 5:30 pm
358 Junction Road Mon – Fri
Madison, WI 53717

Drug & Alcohol Testing 24/7 5:00 pm – 8:00 am
On-Site Mobile Drug & Mon – Sun and holidays
Alcohol Testing Service
104 Murray Street, Suite A
DeForest, WI 53532

HEALTHWORKS 8:00 am – 4:30 pm
707 S. University Ave. Mon – Fri
Beaver Dam, WI 53916

Fort Healthcare Business Health 7:00 am – 5:00 pm
520 Handeyside Lane, Suite 3 Mon – Fri
Ft. Atkinson, WI 53538

Mayville Medical Center 8:00 am – 5:00 pm
360 Mountain St. Mon – Fri
Mayville, WI 53050

Compliance Services Inc –On Site 7:00 am – 5:00 pm
4359 State Rd Mon – Fri
Oregon, WI 53575

Mercy Whitewater Medical Ctr. 8:15 am – 3:00 pm
507 West Main St. Mon – Fri
Whitewater, WI 53190

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ATTACHMENT F, page two
Alcohol/Chain of Custody Drug Collection Sites

Site Hours of Operation

Divine Savior Hospital /
Workwise Dept. 10:00 am – 12 pm & 1 pm – 2:30 pm
2817 New Pinery Rd. Mon – Fri
Portage, WI 53901

Stoughton Hospital 24/7
900 Ridge Street
Stoughton, WI 53589

Occupational Health Services 8:00 am – 4:30 pm
109 Air Park Drive Mon – Fri
Watertown, WI 53094

Remote locations

EMSI 9:00 am – 5:00 pm
129 South Phelps Mon – Fri (phone first)
Rockford, Ill 61108

Theda Care at Work 7:00 am – 5:00 pm
2009 South Memorial Drive Mon – Fri
Appleton, WI 54915

EMSI 8:00 am – 4:30 pm
808 3rd St. Suite 108 Mon – Fri (phone first)
Wausau, WI 54403

4252 Southtowne Dr. Suite C2 8:00 am–12:00 pm & 1:00 pm–3:00 pm
Eau Claire, WI 54701 Mon – Fri (phone first)