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

2. 2 The Program PAMCANI along with Plumbers and Pipefitters Local 501 have formed a partnership to address the problems caused by drug and alcohol abuse

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

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

5. 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. 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. Participants are required to submit to drug and/or alcohol testing in accordance with this policy.

6. 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. 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. Participants subject to this policy continue to have access to the usual protections provided as part of their union membership.

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

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

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

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

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

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

13. 13 Testing Procedures If the test is negative, no further action is taken. 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 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. If no valid reason found, participant is in violation of policy.

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

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

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

17. 17 Pre-Employment Testing Pre-employment testing is not covered under this program, however a contractor may still administer 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. 18 Testing Occasions - Portability These provisions will apply to those individuals working under the portability rules. These provisions will apply to those individuals working under the portability rules. All traveling craftpersons will be subject to: All traveling craftpersons will be subject to: Initial testing Initial testing Random testing – 10% pool Random testing – 10% pool

19. 19 Testing Occasions - Portability Craftperson will be allowed to report to work immediately after providing proof of taking required urine test. 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. 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. Craftperson who tests positive must wait 30 days to test again in order to work in the jurisdiction.

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

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

22. 22 Consequences Upon a first notice of unavailability the participant; Upon a first notice of unavailability the participant; will be referred to the M/EAP for evaluation will be referred to the M/EAP for evaluation must complete recommended treatment or education program 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 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. 23 Consequences (con’t) The participant will be placed in an accelerated testing program. 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 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. 24 Consequences Upon a second notice of unavailability from the preceding first within a 3 year period the participant; Upon a second notice of unavailability from the preceding first within a 3 year period the participant; will be referred to the M/EAP for evaluation will be referred to the M/EAP for evaluation must complete recommended treatment or education program must complete recommended treatment or education program The participant will be placed in an accelerated testing program. The participant will be placed in an accelerated testing program.

25. 25 Consequences Upon a third notice of unavailability from the preceding second within a 3 year period the participant; Upon a third notice of unavailability from the preceding second within a 3 year period the participant; will be referred to the M/EAP for evaluation will be referred to the M/EAP for evaluation The participant MUST COMPLETE the recommended program determined by the M/EAP prior to returning to work. The participant MUST COMPLETE the recommended program determined by the M/EAP prior to returning to work. The participant will be placed in an accelerated testing program. The participant will be placed in an accelerated testing program.

26. 26 Consequences Upon a fourth non-compliant incident within a three-year period from preceding (third), the participant will NOT be eligible for Referral per the UA Standard for Excellence. Upon a fourth non-compliant incident within a three-year period from preceding (third), the participant will NOT be eligible for Referral per the UA Standard for Excellence.

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