Creating An Industry Drug-Free Program

1. Creating An Industry Drug-Free Program ScreenSafe Inc. Program Administrators

2. The Program PAMCANI along with Plumbers Local 93 have formed a partnership to address the problems caused by drug and alcohol abuse

3. Goals and Objectives • Recognition of the problem; • Development of a comprehensive policy; • Educate Participants; • Promote the Member/Employee Assistance Program (M/EAP); • Implement a fair and respectful drug testing program that conforms to Federal drug testing standards.

4. Key Policy Issues • Contractor participation and commitment is critical. • Participant education. • Supervisory training. • Drug testing.

5. Policy Requirements and Prohibitions • The use of alcohol or drugs by employees during working hours on the job site or on company property (including company vehicles) is absolutely prohibited. • Participants are required to submit to drug and/or alcohol testing in accordance with this policy.

6. Policy Requirements and Prohibitions • No participant will be tested for alcohol unless a reasonable suspicion exists that the person is under the influence of alcohol, or they are involved in an OSHA recordable on the job accident. • Participants subject to this policy continue to have access to the usual protections provided as part of their union membership.

7. Policy Requirements and Prohibitions • All participants shall be considered part of the testing pool and will be tested over a 2 year period. • Participants will be selected randomly from the 50% pool. • Participants who complete the testing process will not be returned to the 50% pool. • At the same time there will be an ongoing 10% pool.

8. Testing Procedures • Names picked from the random pool. • ScreenSafe has access to the Unions database to find out where the union member is working. • Designated (Company or Union) Representative called and informed to expect a fax regarding participants being tested.

9. Testing Procedures • ScreenSafe makes calls to Designated Representative in the AM. • Forms sent to Designated Representative: • Testing Procedures for the Plumbing Industry Drug Free Program • List of Collection Sites • By the end of the business day, the Designated Representative informs participant that his/her name has been selected.

10. Testing Procedures • If participant is unemployed they will receive 1 hour wages with regular fringe benefits • Participants are given until end of next business day to take test.

11. At the Collection Site • Authorization for Consent to Drug Analysis and Authorization of Release of Results for testing • Release of Information Signed for Medical Review Officer (MRO), M/EAP and ScreenSafe

12. At The Collection Site • Participant Signs Consent Forms • Collection Site Technician faxes Consent and Release Form Back to ScreenSafe

13. Testing Procedures • If the test is negative, no further action is taken. • If the test is positive, the Medical Review Officer (MRO) calls participant to validate reason for positive. • If no valid reason found, participant is in violation of policy.

14. Testing Procedures • Testing will also be done when there is “reasonable suspicion”. • Accelerated testing (follow-up) takes place once a participant has been non-compliant. It is based on M/EAP evaluation.

15. Testing Procedures - Safeguards • Integrity of specimens insured by utilization of one collection procedure at all sites • All labs have DHHS certification • All positives confirmed by GC/MS • MRO reviews all drug test positives

16. Testing Procedures – Safeguards • Urine samples separated into two containers at time of collection • Other forms of testing for participants with confirmed medical conditions

17. Pre-Employment Testing • Pre-employment testing is not covered under this program, however a contractor may still administer pre-employment testing at the contractor’s own cost.

18. Testing Occasions - Portability • These provisions will apply to those individuals working under the portability rules. • All traveling craftpersons will be subject to: • Initial testing • Random testing – 10% pool

19. Testing Occasions - Portability • Craftperson will be allowed to report to work immediately after providing proof of taking required urine test. • A positive test for any prohibited substance results in immediate termination. • Craftperson who tests positive must wait 30 days to test again in order to work in the jurisdiction.

20. Policy Violations • Policy Violations can include; • Having a positive test result. • Failing to take a test as scheduled • Failure to call the MRO • Failing to keep a scheduled appointment with M/EAP or • Failing to participate in and/or complete the assigned treatment or education program

21. Policy Violations • Policy Violations can include (continued); • Substituting another substance or specimen • Providing a dilute specimen for a second time without a valid medical explanation • Providing a urine specimen which shows the presence of an adulterant

22. Consequences 93 • Upon a first notice of unavailability the participant; • will be referred to the M/EAP for evaluation • must complete recommended treatment or education program • An apprentice or participant in training shall be referred to the training coordinator and action could include referral to M/EAP, disciplinary action or cancellation from the training program

23. Consequences (con’t) • The participant will be placed in an accelerated testing program. • Participant may choose to wait out 30 days. Participant may not work and will not be reinstated until a negative urine test is received. The participants may only wait out on the first non-compliance, any preceding non-compliances the participant would be required to attend the M/EAP

24. Consequences Local 93 • Upon a second notice of unavailability from the preceding first within a 3 year period the participant; • will be referred to the EAP for evaluation • must complete recommended treatment or education program • Will be suspended for 7 calendar days • The participant will be placed in an accelerated testing program.

25. Consequences (con’t) • Must sign a last chance agreement between union/contractors and themselves. • An apprentice or participant in training shall be referred to the training coordinator and action could include referral to EAP, disciplinary action or cancellation from the training program

26. Consequences 93 • Upon a third notice of unavailability from the preceding second within a three year period the participant; • Will NOT be eligible for referral per the U.A. Standard for Excellence.

27. Implementation of Program • Decide upon a “Helping Program/M/EAP” • Register all contractors • Identify “Designated Representatives” at all the contractor sites. • Enroll all contractor employees in program. • Participant education • Supervisory training • Initiate testing