1. Significant revisions

2.  Added verbiage and clarification to the pre-employment and pre- access exception B.1.a: ….Contractor employees that are currently employed by the contractor firm and have been subject to random hair follicle testing (in the random pool) for that company within the last 90 days, and have been tested within the last two years, are exempt.  Added to Policy section C: …….Additional testing for Look-Alikes and Designer or Synthetic drugs will be used when necessary.

3.  Added the following statements:  Post incident drug testing is required for all incidents unless Dow Contractor EH&S agrees there is no indication that the contractor employee’s action/inaction contributed to the incident.  Additional testing for Look-Alikes and Designer or Synthetic drugs may also be required at the discretion of Dow or the Contractor Company supervision.  Positive drug test results MUST be reviewed by a Medical Review Officer (MRO).  …….Contractor company must notify Dow Security of a “failure to comply” as per the Contractor/Sub Contractor Badgeing Process.

4.  Added section titled “Reporting and Notifications”:  All Contractor employees are expected to be registered and demarcated as working Dow Freeport Operations in the VECTOR database maintained by Psychemedics.  Report must be sent monthly indicating:  monthly employee headcount  Number of individuals drug tested  Number of non-compliances  Reporting is to be made through the Dow Contractor EH&S functional mailbox at ffrcntr@dow.com.

5.  Added section titled “Re-Test on Prescriptions”:  Dow Texas Operations is defined as a safety sensitive environment.  Medical Review Officers (MRO) are required to retest positives using urinalysis for workers that could cause impairment, once the course of treatment is completed, before reporting a negative result.  The MRO may also implement a restriction as applicable to the situation.

6.  Added section titled “Medical Review Officer (MRO)”:  All positive drug test results must be evaluated by a qualified MRO.  Defined “qualified MRO”.  The MRO may also implement a restriction as applicable to the situation.  The Dow Chemical Company, Texas Operations, is a safety sensitive area and should be considered as such when determining whether or not an employee with an overturned positive test result should be allowed access back on site.

7.  Dow Freeport is a safety sensitive environment and it is critical that workers are not impaired when working here – for their safety and the safety of their co-workers  Dow Freeport requires post-incident drug testing  Testing for synthetic drugs may also now be requested  A Medical Review Officer (MRO) is required to review all positive tests  A confirmed positive substance abuse test will result in restriction from the site for a minimum of 365 days