DRUG & ALCOHOL POLICY USA

Purpose

The purpose of this Drug & Alcohol Policy (the “Policy”) is to protect the safety of all Phoenix employees, contractors, the environment, and third parties. Phoenix is committed to ensuring that a safe, healthy, and productive workplace is provided for all employees and contractors.

Employees and contractors of Phoenix must report for work fit for duty, and free from the influence of any drugs (including any prescription drug that could cause impairment) or alcohol that could prevent them from conducting work activities safely and effectively.

This Policy clearly defines the standards to which employees and contractors are held accountable and how we will attest to those standards. Phoenix will also follow and adhere to the mandate as set by our customers and comply with their requirements.

 

Responsibilities

This policy will be maintained and enforced by the Human Resources and Health, Safety & Environment departments.

Every manager and supervisor will undergo Reasonable Suspicion Training to ensure correct recognition of impairments and appropriate response procedures.

Every employee and contractor is responsible for reporting to their supervisor or the HR or HSE departments any suspicions of worker impairment.

 

Zero Tolerance

Phoenix has a zero tolerance for employees or contractors who work under the influence of alcohol, illicit drugs, or prescription drugs which impair the employee’s/contractor’s ability to perform their job safely. No worker will accept relief from another worker if the relieving employee/contractor is believed to be under the influence of alcohol or drugs.  The worker must notify their supervisor immediately if they suspect an employee or contractor is working or on Phoenix premises under the influence of alcohol or drugs.

The consumption, use, manufacture, dispensation, possession, distribution, promotion, transfer, or storage of unauthorized, prohibited, illegal, or controlled substances and/or any substance related paraphernalia while performing Phoenix work or while on Phoenix premises is strictly prohibited. Any employee or contractor found engaging in such illegal activity while at work or on Company premises, including Company vehicles, will have their employment/contract services immediately terminated for just cause.

Employees/contractors under the influence of drugs or alcohol are prohibited from driving Company vehicles. Phoenix will seize the Company vehicle upon charge or conviction of a DUI, loss of a driver’s license, or positive test results.

 

Prescribed Medications

Any employee/contractor who is prescribed medication must check with their physician or pharmacist to ensure that the medication will not have negative effects on their job performance. Employees/contractors must immediately notify their supervisor if they are taking prescription drugs or non-prescription drugs that may affect their ability to do their job. The supervisor and the HR or HSE Manager will determine whether that individual can remain at work, whether work restrictions are required, and what those work restrictions may be.

 

Types of Testing and Procedures

Conditional Offer – All potential Phoenix employees will be offered conditional employment subject to testing for drugs and alcohol. All potential Phoenix contractors must also complete a drug and alcohol test.  A urine test will be conducted along with a breath alcohol test. Applicants who test positive, without a legitimate medical reason, will be denied employment/contract services at that time.  In appropriate circumstances, Phoenix may, in its sole discretion, authorize a retest.

Pre-Access/Site-Access – Phoenix may have customers who mandate Pre-Access or Site-Access drug & alcohol testing.  Field employees/contractors will be required to successfully complete drug and alcohol testing before going to the rig site and will be subject to customer on site testing. Phoenix will follow the mandate as set by our customers and comply with their test level requirements.

Random – Random testing will be conducted at all Phoenix locations, through a computer based program. All employees/contractors that are in safety sensitive positions will be included in the list for testing. 25% of these safety sensitive positions will undergo Random drug & alcohol testing on an annual basis.  A safety sensitive position is one in which incapacity due to drug or alcohol impairment could result in direct and significant risk of injury to the employee, contractors, others, or the environment, and includes all field and shop positions. Phoenix will follow the mandate as set by our customers and comply with their test level requirements.

Reasonable Suspicion – It is the responsibility of all managers and supervisors to identify any situation in which they have concerns about an individual’s immediate ability to perform their job.  If the supervisor has documented reasonable cause to suspect that an employee/contractor is impaired due to alcohol, medication or drugs, the supervisor will immediately notify Phoenix management/HR of the situation and remove the individual from their work environment, as mandated by their completed Reasonable Suspicion Training.  Phoenix maintains the right to require the employee/contractor to undergo drug & alcohol testing.

Reasonable Suspicion may include (but is not limited to) one or more of the following:

-      Odor of alcohol on breath

-      Slurred speech

-      Glassy eyes

-      Unsteadiness in walking and/or standing

-      Flushed face

-      Disoriented and/or drowsy

-      Accidents, injuries, serious near misses

-      Repeated errors in job performance

-      Excessive absenteeism or lateness

 

 

Post-Accident – Drug and alcohol testing of employees/contractors will be required after an accident/incident and may be required after a near miss. The drug testing shall be conducted within 32 hours of the accident/incident or near miss and alcohol testing within 8 hours.  If there is a situation where the tests cannot be conducted, documentation is required.

Positive Test Procedure

Potential employees/contractors who are positive on Conditional Offer screening tests will be encouraged to seek assistance from a substance abuse professional, after which they may reapply for available positions when they can meet the Company requirement.

Employees/contractors who test positive on drug tests as verified by a M.R.O. (Medical Review Officer) or who have a confirmed alcohol concentration of 0.04G or greater, will be informed of the results, may be suspended without pay pending further investigation, and upon review may be subject to disciplinary action, up to and including termination of employment/contract services.  Should an addiction problem exist with an employee, they will be accommodated through encouragement to seek rehabilitation from a substance abuse professional.

Refusal To Test Procedure

No employee/contractor shall refuse to submit to a drug or alcohol test.  No supervisor shall permit an employee or contractor who refuses to submit for required testing to perform or continue to perform their job functions. An employee/contractor who refuses to submit to a required test will be relieved of their duties, referred to a Substance Abuse Program for assessment and may face disciplinary action or termination of employment/contract services. If an employee/contractor tampers or attempts to tamper with a test sample or obstructs the testing process, they will face disciplinary action, up to and including termination of employment/contract services.

Return To Duty

Before returning to duty, an employee/contractor who is returning to work after an assessment by a substance abuse professional must successfully pass a drug and/or alcohol test.

Follow Up

As part of accommodation and rehabilitation efforts, and when a substance abuse professional identifies the need, an employee/contractor will be required to submit to Follow Up drug and/or alcohol testing. Phoenix will determine the frequency of testing and the time period involved.

Phoenix Social Functions

Employees/contractors, their guests, and guests of Phoenix who attend Phoenix sponsored social functions are not to drive or operate their vehicles from such social functions if they consumed alcohol.  It is expected that employees/contractors and guests who wish to consume alcohol at Phoenix social functions will make responsible or alternate arrangements for safe transportation. Taxi receipts can be submitted on expense reports or invoices.

Phoenix is committed to providing and maintaining a safe environment for all employees and contractors.

PHOENIX DRUG & ALCOHOL POLICY ACKNOWLEDGEMENT

By signing below, I confirm receipt and understanding of Phoenix’s Drug & Alcohol Policy (the “Policy”).

I agree that I will abide by the terms of the Policy. I acknowledge that I may be subject to testing under the requirements outlined in the Policy, and that the test results will be reported by a third party testing provider to Phoenix’s HR Manager. I hereby consent to the collection, use and disclosure of my personal information for the reasonable purposes specified in the Policy.

I understand that employees and contractors found in violation of the Policy may be subject to discipline, up to and including termination of services, based upon the severity of the offence and the circumstances.

Schedule “A”
Documentation For Reasonable Suspicion

  1. Absenteeism
    * Absenteeism may be legitimate and still be a problem.
    • Unauthorized leave or excessive sick leave.
    • Repeated absences, particularly if they follow a pattern, ie. Monday/Friday absences.
    • Excessive lateness, particularly if on Monday or returning from lunch.
    • Leaving work early when inappropriate.
    • Peculiar and increasingly improbable excuses for absences.
    • Higher absenteeism rate than other workers for various health reasons.
    • Frequent unscheduled short-term absences (with or without medical explanation).
    • Use of unscheduled vacation time.
    • Other: (Specify)
  2. On the Job Absenteeism
    • Continued absence from work area more than job requires.
    • Inappropriate conversations with co-workers not pertaining to job.
    • Frequent extended coffee or smoke breaks.
    • Physical illness on the job.
    • Excessive amount of personal telephone time.
    • Other: (Specify)
  3. Risk Potential
    • Accidents or frequent near misses on the job.
    • Undue deliberation when carrying out activities.
    • Inattentiveness to safety procedures or lack of caution when carrying out activities.
    • Covers up accidents/near misses rather than accepting responsibility.
    • Careless handling and maintenance of equipment.
    • Frequent injuries or lost time from accidents on or off the job.
    • Other: (Specify)
  4. Mental/Emotional Concerns
    • Difficulty in recalling instructions, details, etc.
    • Increasing difficulty in handling complex work assignments.
    • Unexplained memory lapses.
    • Outbursts of crying or anger.
    • Difficulty in concentration.
    • Mood swings.
    • Making poor decisions (especially impulsive ones).
    • Fearful, anxious, suspicious.
    • Difficulty adjusting to changes or exploring options (rigid thinking).
    • Excessive feedback required regarding job performance.
  5. Workplace Demeanor
    • Coming to/returning to work in an obviously impaired condition.
    • "Sloppy" appearance.
    • Inappropriate clothing.
    • Other: (Specify)
  6. Generally Lowered Job Efficiency
    • Missed deadlines.
    • Mistakes due to inattention or poor judgment.
    • Wasting materials.
    • Alternate periods of high and low efficiency.
    • Complaints from users of products or services.
    • Improbable excuses for poor job performance.
    • Tasks/projects take more time to complete.
    • Deteriorating quality of work.
    • Easily fatigued.
    • Decreasing reliability.
    • Assuming unreasonably high workload: difficulty delegating or saying "no".
    • Difficulty setting priorities.
    • Difficulty seeking clarification or assistance.
    • Other: (Specify)
  7. Work Relationships
    • Overreaction to real or imagined criticism./li>
    • Blaming co-workers for mistakes./li>
    • Abrasiveness with supervisors or co-workers./li>
    • Borrowing money from co-workers./li>
    • Insisting that co-workers are out to get him/her./li>
    • Avoidance of superiors and/or co-workers./li>
    • Complaints from colleagues./li>
    • Other: (Specify)
  8. Work Attitude
    • Repeated criticism of Company Policies & Procedures without realistic alternative suggestions.
    • Frequent threats of job transfer or quitting.
    • Complaining that management has it in for him/her.
    • Unrealistic expectations of promotion.
    • Continual shifting of responsibility from self to others.
    • Other: (Specify)

Schedule “B”
Cut Off Levels For Screening And Confirmation (in accordance with Industry Standards)

When a urine sample is sent to the lab, the following chart will give guidance as to how the urine will be tested. Below are tested in nanograms to milliliters (ng/mL). Screening test levels are as follows:
Drug Screening Cut Off Levels
Marijuana20
Cocaine150
Opiates:
Morphine2,000
Codeine2,000
Oxycodone300 (Separate Testing called DOX)
Oxycontin300
Percocet300
Phencyclidine25
Amphetamines
Methamphetamine300
MDMA/MDA/MDEA300

Initially an Immunoassay test is first conducted. The specificity and the sensitivity of this test may vary. Positive test results must be on or over the specified levels. Positive test results are considered ‘Presumptive Positives’ and must be confirmed using a different assay technique. The technique usually used is GS/MS (Gas Chromatography/Mass Spectrometry). This technique is very sensitive, and very specific. When a Presumptive Positive test is tested using the GS/MS technique, the substance is broken down into specific metabolites.
Confirmation Cut Off Levels
Marijuana15
Cocaine100
Opiates:
Morphine2,000
Codeine2,000
Oxycodone300 (Separate Testing called DOX)
Oxycontin300
Percocet300
Phencyclidine25
Amphetamines
Methamphetamine250
MDMA/MDA/MDEA250

When completing contract work with other companies, Phoenix will comply to the Contract Company’s Drug and Alcohol Policy. At times, there may be other drugs to be tested for. Should the list below be required, these are the Nanogram Screening and Confirmation levels, nanograms to millilitres (ng/mL).
Screening Levels
Benzodiazepines300
Barbiturates300
Methaquoline300
Propoxyphene300
Methadone300
Confirmation Levels
Benzodiazepines100
Barbiturates100
Methaquoline200
Propoxyphene200
Methadone100

Alcohol
Alcohol screen testing may be conducted with an Evidential Breath Tester or a Saliva Test. All Alcohol Screening Tests of 0.02-0.39G or higher will be confirmed with an approved Evidential Breath Testing Device operated by a Certified Breath Alcohol Technician. Confirmed tests will be 0.04G.