Table of Contents: Chapter 4

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404 DRUG AND ALCOHOL FREE WORKPLACE 12/12/2019

404.1 Purpose

The City of Lee's Summit considers drug and alcohol abuse a serious matter that will not be tolerated. It is the intent of this Policy to provide all employees with the City's stance on drug and alcohol use, and to provide clear guidelines for handling or avoiding alcohol and drug use situations. It is further the intent of this policy to outline the City's compliance with the Drug-Free Work Place Act of 1988 under the provisions applicable to federal grantees.

Additionally, it is the intent of the City of Lee's Summit to protect the public safety and the efficiency and productivity of the workplace by ensuring that employees are fit for duty while on the job. Unauthorized use of drugs and/or alcohol by employees could pose a threat to public welfare and the safety of employees. Moreover, employee involvement with alcohol or drugs while on duty can adversely affect the work environment, job performance and safety. Therefore, reporting for work or working while under the influence of alcohol, marijuana or illegal or prohibited drugs, or use or possession on work premises of alcohol, marijuana, or illegal or prohibited drugs, is expressly prohibited.

The City encourages employees to take advantage of available programs and services before drug or alcohol usage affects work safety, job performance, and family life. Employees experiencing personal problems which may be affecting their job performance are encouraged to seek help before serious problems occur. To receive assistance from the City, contact their Department Director or Human Resources. The Employee Assistance Program is confidential and will not become a part of the employment record when self-initiated. The City's health insurance provides coverage for substance abuse treatment as well.

404.2 State and Federal Laws

The City is committed to providing the safest working environment possible and therefore intends to maintain and support a drug free work place and work force.
The City recognizes that various state and federal laws may require certain procedures be utilized. Where applicable and when appropriate, and if required by law, the state and/or federal requirements will be followed. Should any part of this policy not comply with new state and/or federal laws, the remaining parts of the policy shall remain in effect.
The United States Department of Transportation (DOT) has issued regulations to implement the Omnibus Transportation Employee Testing Act of 1991 which requires the City of Lee's Summit to conduct mandatory drug and alcohol testing of employees whose positions require a commercial driver's license (CDL). It is the City's intention to comply fully with the DOT's regulations governing drug and alcohol use and testing.

404.3 Definitions

"Alcohol" - The intoxicating agent in beverage alcohol, ethyl alcohol, or other low molecular weight alcohol including methyl and isopropyl alcohol.

"Alcohol Concentration" - The alcohol in a volume of breath as indicated by either an evidential breath test (EBT) or a blood test.

"Collection Site" - A place designated by the City where individuals present themselves for the purpose of providing a specimen of their breath or urine to be analyzed for the presence of drugs or alcohol.

"Drug" - Any substance that can be misused or abused, including controlled substances and over the counter medications. Controlled substances include those listed in Schedules I, II, III, IV, or V of the controlled Substances Act of 1970, 21 U.S.C. 801 seq.; and any amendments or addendums including marijuana, cocaine, opiates, amphetamines and/or phencyclidine. The term "illegal drugs" are those described in Drug Regulations, RSMo Chapter 195, and Chapter 17 of the Code of Ordinances, City of Lee's Summit, Missouri.

“Drug Paraphernalia” - shall mean the same as the term is defined in Section 195.010, RSMo., as amended.

"Drug Test" - A chemical test that consists of a screen to identify the possible presence of drugs and a scientifically recognized confirmation test which can indicate the definite presence of prohibited substances.

"Employee"- A person appointed to a position in the City service as defined by City Ordinance including full-time, part-time, reserve, seasonal and other employees.

"Employee Assistance Program" (EAP) - A counseling program that offers assessment, short-term counseling and referral services to employees for a wide range of problems, including those related to use of drugs and alcohol, and monitors the progress of employees in treatment.

"Evidential Breath Testing Device" (EBT) - A device approved by the National Highway Transportation and used to measure breath alcohol concentration.

"Medical Review Officer" (MRO) - The licensed physician responsible for receiving laboratory results generated from the City's drug testing program under this Policy and who has knowledge of substance abuse disorders and the appropriate medical training to interpret and evaluate all positive test results together with an individual's medical history and any other relevant biomedical information.

"Refusal to Submit to an Alcohol or Drug Test" - An employee's (1) failure to provide adequate breath for alcohol testing without a valid medical explanation; (2) failure to provide adequate urine for drug testing without a genuine inability to do so as determined by a medical evaluation; or (3) conduct that clearly obstructs the testing procedure.

"Safety Sensitive Function" - All time (1) waiting to be dispatched; (2) inspecting, servicing, or conditioning a commercial motor vehicle; (3) at the driving controls of a commercial motor vehicle; (4) not driving but in or upon a commercial motor vehicle; (5) loading or unloading a commercial motor vehicle, supervising or attending a vehicle being loaded or unloaded, remaining ready to operate the vehicle, or giving or receiving receipts for shipments loaded or unloaded; and (6) repairing, obtaining assistance for, or attending a disabled vehicle.

"Safety Sensitive Position" - A position that requires performance of a safety sensitive function.

"Substance Abuse professional" - A licensed physician, or licensed or certified psychologist, social worker, or employee assistance professional, or certified addiction counselor, with knowledge of and clinical experience in the diagnosis and treatment of alcohol and drug disorders.

"Vehicle" - Any means of transportation including construction and maintenance equipment.

"Under the influence" - A condition which affects the ability to work in a safe and productive manner; or, impairs job performance; or, creates a safety risk to the employee, co-workers, the public or property; or, is manifested by a detectable level of drugs, drug metabolite, or alcohol in the body.

404.4 Prohibited Conduct

The following conduct is strictly prohibited:
• Reporting for or remaining on duty while under the influence of any controlled substance not medically authorized and use has been pre-approved by the City;
• Reporting for duty or remaining on duty with a breath or blood alcohol concentration of 0.02 or greater; Use of alcohol within four (4) hours before reporting for duty if the employee holds a safety-sensitive position;
• Use of alcohol within eight hours following an accident for which post-accident testing is required or until the employee undergoes a post-accident alcohol test, whichever occurs first;
• Refusal to submit to a drug and/or alcohol test required by this policy;
• Possession, sale, or use of alcohol or prohibited drugs or drug paraphernalia while on duty or on workplace premises;
• The unlawful manufacture, distribution, dispensation, possession, sale, purchase, or use of any drug paraphernalia, drug or controlled substance which, under the circumstances is illegal, is also prohibited while on City property, while utilizing City equipment, while performing City business and/or during work hours;
• Being under the influence of alcohol or drugs (legal or illegal) while on City property, while performing or conducting City business, and/or during working hours;
• The consumption of alcohol on City property (owned or leased), except during off duty licensed events in City parks.

404.5 Marijuana and City Employment Effective 07/01/2024

1. The City recognizes that Medical and Recreational use of Marijuana is permitted under the Missouri Constitution.

2. The City recognizes that Marijuana remains a Schedule 1 Controlled Substance under 28 U.S.C. 812 Schedule 1 (c) (10)

3. The City recognizes that under Missouri law individuals over the age of 21 years, may use Marijuana as allowed by Article XIV Sections 1 and 2 of the Missouri Constitution.

4. The City prohibits all employees from using, possessing, or being under the influence of Marijuana while on duty for the City or on City property, or while operating City owned equipment/vehicles. The City further expressly prohibits employees from using, possessing, or being under the influence of Marijuana in any the following situations:

a. Any use which prevents an employee from holding a Commercial Driver’s License (CDL) where one is required for the job while on duty for the City or on
City property.
b. Any use which prevents an employee from holding a Police Officer Standards and Training (POST) certification in the State of Missouri where such certification is required for the job while on duty for the City.
c. Any use which prevents an employee from holding any professional or technical licensure or certification where such license or certification is required for the job while on duty for the City.

5. Testing for Marijuana will occur in these circumstances:

a. For applicants for position requiring a Commercial Driver’s License a post-offer/pre-employment test,
b. For applicants for promotion to a position requiring a Commercial Driver’s License a pre-promotion test,
c. Testing any employee upon reasonable suspicion of impairment based on articulable facts including but not limited to direct observation of the employee,
d. Testing any employee involved in an accident situation shall be conducted consistent with Section 404.10 .4 of the Lee’s Summit Personnel Resources Policies:

i. By a supervisor as soon as practicable, or,
ii. Upon reasonable suspicion the employee is under the influence of drugs or alcohol.
e. But no test shall be administered when an initial inquiry excludes the possibility that the employee is a cause of the accident and there is no reasonable suspicion that the employee is under the influence of any drugs or alcohol.

6. Applicants for any position within the Police Department and the personnel within that department may be tested for Marijuana as designated by the General Order of the Chief of Police,

7. All city employees who are required to hold a Commercial Driver’s License to perform the duties and responsibilities of their positions are subject to random testing for Marijuana as required by the U.S. Department of Transportation. All selected and tested employees must pass the test or be subject to appropriate consequences as required by the Federal Motor Carrier Safety Administration.

8. The city reserves the right to modify, without prior notice, any of its testing protocols for detecting illegal drugs or substances. As of the date of the approval of this policy the City will generally use a complete 10-panel test for drugs, a test that covers 1. Marijuana, 2. Cocaine, 3, Amphetamines, 4. Phencyclidine (PCP) 5. Opiates, 6. Barbiturates, 7. Benzodiazepines, 8, Methadone, 9. Oxycodone and 10. Methamphetamine.

9. The City reserves the right to discipline employees, up to and including termination, for working or attempting to work while under the influence of Marijuana.

10. The City reserves the right to discipline employees, up to and including termination for any use of Marijuana that results in the loss of the any licensure required to do the job for which they are employed.

11. This policy does not waive or alter the City’s Drug Free Workplace provisions included in the employee handbook. The City cannot provide an accommodation for medical Marijuana; however, the City is committed to providing accommodations for an employee’s medical condition to the fullest extent permitted by law.

12. The table below titled Employee Drug Testing Decision---Type of Test = With Marijuana / Without Marijuana is incorporated herein by reference. In the event that any interpretation of the spread sheet and the words of this policy create a conflict the wording of this policy shall prevail.

This policy shall become effective on July 1, 2024.

Employee Status	Post Offer/Pre-Employment and before transfer or promotion to CDL required position	Post Accident where initial investigation does not preclude the employee may have some fault	Reasonable Suspicion based on articulable facts including but not limited to direct observation	Notes
Employees (Other than CDL and Police)	Test without Marijuana Result for Decision	Test with Marijuana	Test with Marijuana
CDL as Position Requirement	Test using Marijuana Result for Decision	Test with Marijuana	Test with Marijuana
Police	Test using Marijuana Result for Decision	Test with Marijuana	Test with Marijuana	Testing for Police Department employees is subject to the General Order of the Chief of Police

404.6 Prescription or Over the Counter Drugs

An employee's use of a prescription or over-the-counter drug may pose a safety risk. The City cautions against use of prescribed or over-the-counter drugs, which can affect an employee’s ability to perform the employee’s job safely, or the use of prescribed or over-the-counter drugs in a manner violating the recommended dosage or instructions from the employee’s doctor.

Employees must have a valid prescription for any drug requiring a prescription used while working for the City and must use the prescribed drug in accordance with the prescription. An employee must inform the employee’s supervisor before working under the influence of a prescribed or over-the-counter drug that may affect the employee’s ability to perform the employee’s job safely. The duty to inform includes when an employee is taking any prescription or over-the-counter drug(s) whose advertisement, warnings, or usage instructions indicate to the user a potential for impaired performance or safety risk. Failure to inform the supervisor is strictly prohibited.
In the event the employee is unable to perform the essential duties of the job during the use of the prescription or over the counter drug, the employee will be placed on sick leave if available, or unpaid leave.

Any questions about impairments should be clarified by a doctor or qualified pharmacist in writing before reporting for work. In such instances, the supervisor, in conjunction with Human Resources will determine appropriate action based upon the type of drug(s), the employee's job responsibilities and other relevant circumstances and if necessary consult the opinions of the City's authorized medical facility.

Failure to comply with these guidelines concerning prescription or over-the-counter drugs may result in disciplinary action, up to and including termination of employment.
The City may assist its employees who seek treatment or rehabilitation for drug or alcohol dependency. The City may consider continued employment as long as the employee adequately addresses continued concerns regarding safety, health, production, communication, or other work-related matters. Employees may also be required to obtain a medical clearance, and agree to random testing and a "one-strike" rule as a condition of continued employment.

404.7 Searches

Where the City has reason to believe an employee is in violation of this Policy, then the employee may be asked to surrender for inspection his or her personal property including but not limited to the contents of lunch box, purse, briefcase, parcels, duffle bags, vehicle, or any other receptacle used in or located on City property (owned or leased). An employee's consent to such a search may be considered a condition of employment. An employee's refusal to consent will be considered insubordination.

The City reserves the right to conduct searches, without employee consent, of City property (owned or leased), including but not limited to lockers, desks, files and City vehicles regardless of whether it is assigned to a specific individual even if the employee has placed a personally owned lock on City property.

404.8 Convictions

The federal Drug Free Work Place Act of 1988 requires employees to notify their supervisor of any criminal drug statute conviction or driving under the influence conviction within five (5) working days of the conviction. The City, in turn, is required to notify any federal agencies providing grant monies to the City within ten (10) days after receiving notice of a conviction from an employee or other means. Any employee so convicted, or who fails to report a conviction, will be subject to disciplinary action up to and including termination.

404.9 Effect on Workers Compensation

Pursuant to Section 287.120, RSMo., as amended, if an employee violates the City’s policy concerning alcohol or non-prescribed controlled drugs and is injured or killed in conjunction with alcohol or drug use the compensation or death benefit shall be reduced by fifty percent (50%).

If the use of alcohol or non-prescribed drugs is the proximate cause of the injury, benefits shall be forfeited altogether.
Pursuant to Section 287.120, RSMo., as amended, if an employee refuses to take a test for alcohol or a non-prescribed controlled substance, as defined by section 195.010, at the City’s request, the employee shall forfeit the employee’s benefits under Chapter 287, RSMo.

For accidents occurring on or after August 28, 2017, if an employee tests positive for a non-prescribed controlled drug or the metabolite of such a drug, then the City will presume that the drug was in the Employee’s system at the time of the accident/injury and that the injury was sustained in conjunction with the use of such drug, unless the City does not:

a) Administer the Initial testing within 24 hours of accident or injury;
b) Notify the employee of the test results within 14 calendar days of the insurer or group self-insurer receiving actual notice of the confirmatory results;
c) Give the Employee an opportunity to perform a second test upon the original sample; and
d) Confirm the initial or any subsequent testing that forms the basis of the presumption by mass spectrometry using generally accepted medical or forensic testing. An employee may rebut this presumption by a preponderance of the evidence.

404.10 Tests Required

Drug tests for prohibited drugs and alcohol tests shall be conducted in the following situations:

1. Pre-employment/post-offer testing - Any applicant who is offered employment shall submit to a drug and alcohol test as a condition of employment. Drug and alcohol test results must be negative as a condition of employment.

2. Internal transfer testing -__ Any employee who is promoted, demoted or otherwise makes a change from a position that does not require a commercial driver's license to a position that does require a commercial driver's license shall submit to a drug and alcohol test as a condition of such placement. The employee's test results must be negative to be eligible for placement.

3. Reasonable cause testing -__ Employees shall submit to drug and/or alcohol test when there is reasonable suspicion to believe the employee has used alcohol and/or drugs in violation of DOT regulations or this policy. Reasonable cause may be based on confidential reports, but may not be based on anonymous allegations. Reasonable cause will be based on specific, contemporaneous, observations concerning the appearance, behavior, speech, body odors, or performance indicators of the employee without a reasonable explanation, including but not limited to the following:

A. Physical signs of being under the influence of drug or alcohol include:
i. Unsteady gait or movements
ii. Slurred speech
iii. Dilated or constricted pupils
iv. Decreased consciousness
v. Smell of alcoholic beverages or alcohol metabolites
vi. Bloodshot eyes
vii. Seizures (unless the individual has a known seizure disorder)

B. Behavioral signs of being under the influence of a drug or alcohol include:__
i. Excessive or inappropriate sleepiness or sleeping on the job
ii. Excessive restlessness, pacing, inattention, inability to focus, etc
iii. Aggressive behavior such as hitting, pushing, or intimidation with or without physical contact
iv. Inappropriate or aggressive speech such as cursing, shouting, etc
v. Paranoid behavior or excessive fearfulness
vi. Excessive sadness, weeping, etc
vii. Changed mental status such that the employee does not make sense, cannot follow orders, or cannot function normally at his/her job.

Testing may also occur when there is reasonable cause to believe that use or possession of alcohol or prohibited drugs or illegal drugs while on duty, at the work site, or during breaks or lunch either on or off the work site has occurred.

4. Post-accident - An Employee shall submit to an alcohol and drug test if, while on duty, the Employee is:__
(A) the Employee is involved in a vehicle or equipment (e.g. heavy equipment, riding lawnmowers, and other similar equipment) accident, AND
(B) (i) The accident involves the loss of human life; or
(ii) There is any disabling damage to any vehicle or equipment involved as a result of the accident requiring the vehicle or equipment to be transported from the accident scene by a tow truck or other vehicle; or
(iii) The Employee receives a citation for a moving traffic violation arising from the accident; or
(iv) The accident resulted in bodily injury to any person requiring medical treatment away from scene of the accident.
The City may require an Employee to submit to an alcohol and drug test if, while on duty, the Employee is involved in a vehicle or equipment (e.g. heavy equipment, riding lawnmowers, and other similar equipment) accident that damages City property.

An employee who is subject to post-accident testing must remain readily available for testing or be deemed to have refused to submit to testing. The employee must not use alcohol within eight hours following an accident for which post-accident testing is required or until the employee undergoes a post-accident alcohol test.
Pursuant to Section 287.120, RSMo., as amended, refusal to take a test for alcohol or a non-prescribed controlled substance, as defined by Section 195.010, RSMo. at the City’s request, shall cause the employee to forfeit the employee’s worker’s compensation benefits under Chapter 287, RSMo.

5. Random Testing -__ All employees who hold positions which require a commercial driver's license will be subject to random drug and alcohol tests. Employees shall be informed if they hold a position that requires random testing.

Every employee who is subject to random testing will have an equal chance of being selected each and every time the selection is conducted regardless of how recently or how often the employee has previously been tested. Tests will be conducted monthly in accordance with DOT regulations.
Any CDL employee who refuses to submit to a random test, who fails to report for the test as directed, or who tests positive, will be subject to disciplinary action, up to and including termination.
Time taken for CDL Random, Reasonable Cause, and Post Accident testing shall be time worked and compensated accordingly by the City.

404.11 Testing Procedures

An employee shall comply with the following procedures regardless of the purpose of the test:

• Each individual to be tested shall present picture identification at the test site.
• Each individual to be tested shall remain at the test site until a sample is given.
• Employees shall follow all clinic procedures and regulations.
An employee shall comply with the following procedures for each respective test:
• Pre-employment Tests: All newly hired employees shall present themselves at the drug test site as directed by Human Resources as part of the standard application process. Test results will be released by the laboratory only to the Director of Human Resources, who will inform the Hiring Manager if the applicant cannot be employed due to a positive drug screen.
• CDL Random Tests: The Director of Human Resources will inform the appropriate supervisor on the day of the test. The supervisor will promptly inform the employee. Upon notification, the employee shall immediately proceed as directed by the supervisor. Employees will be accompanied to the collection site by a designated supervisor.
• Reasonable Suspicion & Post Accident Tests: A supervisor or other designated employee will transport the employee to the test site as soon as possible. The City will attempt to contact someone designated by the employee to make arrangements for transporting the employee to his/her home after the test is completed. In the event that the City is unable to contact someone, the City will make arrangements for transporting the employee home.

Attempts to delay drug and/or alcohol testing by either the employee or the supervisor shall result in disciplinary action.

404.12 Follow-up Testing

Employees subject to follow-up testing shall present themselves at the test site as directed by the Director of Human Resources or the designated supervisor.

404.13 Testing Methodology and Integrity

Alcohol tests: In the event of a positive test, there will be a 15 minute delay, the test equipment will be recalibrated, and the test will then be repeated.
Individuals unable to blow an EBT will have the option to have a blood draw to determine the employee alcohol concentration level via the employee’s blood.

Testing Integrity: To ensure the integrity and accuracy of each test, all specimen collection, analysis and laboratory procedures shall be conducted in accordance with DOT's procedural protocols and safeguards. This includes, but is not limited to:
• Procedures to ensure the correct identity of each employee at the time of testing;
• A strict chain-of-custody procedure to ensure that the employee's specimen is not tampered with;
• The use of a trained breath alcohol technician (BAT) and DOT approved testing devices for conducting alcohol tests;
• The use of a laboratory which has been certified by the national Institute for Drug Abuse (NIDA);
• The confirmation of an initial positive drug screen by a second analysis;
• The confirmation of an initial positive alcohol screen by a second analysis; and
• The appointment of a qualified Medical Review Officer (MRO) to review drug test results before they are reported to the City's Director of Human Resources.

404.14 Reporting Drug Test Results

Drug test results shall be reported as follows:
• Negative Test Results. Negative test results will be reported directly to the Director of Human Resources.
• Negative Dilute. A negative dilute result shall require a second observed test.
• Positive Test Results. All positive test results will first be reported by the testing lab only to the MRO.

The MRO will attempt to contact the employee or applicant in order to consult with the individual to determine if the positive drug test is a result of a legitimate medical use or other reasonable explanation. If the MRO cannot contact the employee within 48 hours the MRO will inform the Director of Human Resources. The Director of Human Resources will attempt to notify the employee that s/he must contact the MRO to determine the results of the drug test. The Director of Human Resources will not consider the test results to be positive until the MRO has made contact with the employee, or the MRO concludes that the employee is avoiding such contact.
Positive drug test results will not be used for purposes of criminal prosecution.

404.14.2 Retests

The employee may request in writing a retest of the original specimen. Upon receipt of the written request for a retest, the City shall provide the employee with a list of laboratories approved for retesting. Any retest will be at the employee’s sole expense. The request must be made to the MRO within 72 hours of the time the employee is notified of the positive test result.

A retest requested on a pre-employment or pre-placement test will be at the applicant or employee's expense. A retest requested on a CDL random test will be paid for by the City. A retest requested on a post-accident or reasonable cause test will be at the employee's expense.

If the MRO determines no legitimate medical use of other reasonable explanation of the drug exists, the results will be reported to the Director of Human Resources as positive. Results of retests will be reported by the MRO to the Director of Human Resources with no further consultation with the employee or applicant.

404.15 Reporting Alcohol Test Results

Test results will be promptly reported by the Breath Alcohol Technician to the employee, any supervisor or other designated individual accompanying the employee and the Director of Human Resources.
• Negative Test Result: When an employee's initial test registers an alcohol concentration level less than 0.02, the test result will be reported as a negative and no additional test will be required.
• Positive Test Result: When an employee's initial test registers an alcohol concentration level of more than .04, the test result will be considered positive.

When an employee's initial test registers an alcohol concentration level of 0.02 or greater, a second, confirmatory test will be performed. In the event that the employee's confirmatory test registers less than 0.02, the test will be reported as negative.

Any employee whose confirmatory test registers 0.02 or more but less than 0.04 will be suspended from work without pay and will not be allowed to return to work for a minimum of 24 hours. Before returning to duty the employee must be retested and have a test that registers less than 0.02. All positive test results and action being taken will be reported by the Director of Human Resources and to the appropriate supervisor and Department Director. When and if the employee is eligible to return to work, the Director of Human Resources will inform the employee and the department.

404.16 Disposition of Cases

• Pre-employment: A positive drug or alcohol test will be a basis to withdraw the employment offer.
• Negative Dilute Drug Test by Applicant or City Employee. Negative dilutes will be retested and observed. An applicant or City employee that has a second negative dilute result shall be placed on unpaid suspension until a negative test result can be produced, unless a medical cause can be documented by a physician.
• Positive Drug or Alcohol Test by City Employee. Any employee who submits a (i) positive drug or (ii) blood or breath alcohol concentration level of 0.04 or greater alcohol test result shall be placed on suspension, will receive a notice of potential termination; and has 3 business days to request a retest, unless a medical cause can be documented by a physician. Absent a medical cause or other explained cause for the positive test, the employee shall be terminated.
• Refusal to Testing. An employee's consent to submit to such testing is required as a condition of employment. Any employee who refuses to submit to a drug or alcohol test will be considered insubordinate and subsequently terminated. Substituting or altering specimens by the donor is considered a refused test.

404.17 Confidentiality

All individual test results will be considered confidential. Disclosure that a test is positive may be made to an employee's supervisor and Department Director in order to carry out the disposition of the employee's case. The release of an employee's results to any other individuals will only be given in accordance with an individual employee's written authorization, or as is otherwise required by the DOT's regulations, or by other applicable federal or state law.
The results of all individual drug and alcohol tests will be kept in a secure location with access controlled by the Director of Human Resources.