Drug and Alcohol Policy (Updated Fields)

Drug and Alcohol Policy
Corporate Policy
Print Date: 2019/3/19 Page 1 of 9
http://portal/sites/Safety/APC/
15.7 Drug and Alcohol Policy
POLICY STATEMENT
Propak Systems Ltd. (the Company) is committed to maintaining a safe, healthy and productive work
environment for all employees. To further this commitment the Company has developed a Drug and
Alcohol Policy prohibiting substance use and the presence of illicit substances in the workplace. It is
the Company’s position substance abuse increases the potential for accidents, property damage,
absenteeism, and sub-standard quality or workmanship. Any violations may result in disciplinary
action up to and including termination.
15.7.1 PURPOSE
The purpose of this policy is to balance individual’s rights with the need to maintain an alcohol and
drug-free environment.
The Company prohibits the use, possession, purchase, sale, transfer or transportation of illegal drugs,
synthetic or “designer drugs”, or any other non-prescription; chemical or mind controlling substances,
which adversely affect the way a person thinks, acts or reacts.
The Company further prohibits the possession of drug-related equipment or paraphernalia while on
the Company’s premises, and/or while on Company business and/or at any customer’s workplace or
jobsite.
The only exception to the above prohibition is for properly documented prescription (non-impairing)
drugs authorized by a licensed physician when the person for whom they are prescribed uses the
prescription drugs as they are prescribed.
Workers must notify their supervisor if they are taking prescription or over-the-counter medication that
may impair their ability to work safely.
The Company prohibits the possession, purchase, sale or transportation of intoxicating beverages or
food on the Company’s premises, and/or at any customer’s workplace or job site. The Company
further prohibits its employees or other persons subject to this policy from engaging in Company
business while being legally impaired by or exhibiting signs of impairment from licit or illicit substances
or alcohol, resulting in being unfit for work.
15.7.2 SCOPE
This Policy applies to all Employees and Contractors and their sub-contractors who are working for
Propak in all circumstances and where Employees are conducting Propak business.
REV. Brief Description of Changes

04 5 Mar 19 Revised DLH
03 16 Nov 18 Revised DLH
02 11 Aug 17 Post Incident Review CW
01 19 Feb 14 Revised DLH
Effective30daysafterapproved
This document is the property of PROPAK SYSTEMS LTD. and shall not be disclosed to Others or reproduced in any manner or used for any purpose
whatsoever except by written consent of PROPAK. All printed copies are uncontrolled.
Corporate Policy
While this Policy applies to all Employees, alcohol and drug testing pursuant to the Policy will only be
required of those Employees who work in Safety-Sensitive Positions or Tasks as defined in this policy.
A safety-sensitive position is one in which incapacity due to drug or alcohol impairment could result
in injury to the employee, other or property damage. Safety-sensitive positions at the Company include
but are not limited to
a) Fabrication employees
b) Warehouse employees
c) Yard employees
d) Quality Control employees
e) Construction employees
f) Compression Services employees
g) Field Services employees
h) Truck delivery and inter-shop drivers
i) Employees driving on company business in personal vehicle, driving a company vehicle or
company-rented vehicle.
15.7.3 ROLES & RESPONSIBILITIES
Workers must:
a) Must report to work fit for duty.

b) Have an understanding of the Drug and Alcohol Policy
c) Take responsibility for ensuring their own safety and the safety of others as per duties
and obligations of a worker under appropriate legislation.
d) Refrain from using or being impaired by alcohol or drugs (legal or prescription) while on
duty.
e) Refrain from possessing, purchasing, selling, distributing or engaging in any other
conduct involving alcohol; legal or illegal substances or paraphernalia while on duty
f) Refrain from misusing or being impaired by prescription or non-prescription drugs while
on duty
g) Notify their supervisor if they suspect that either a co-worker is unfit for duty
h) Submit for drug and alcohol testing in accordance with Propak’s Drug & Alcohol Policy.
i) Use medications responsibly, be aware of potential side effects and notify their
supervisor of any potential unsafe side effects where applicable,
j) If a physician or the medication labels indicate that there may be some effects or impairment
with use of medication, the worker must disclose this to their supervisor to ensure safety of the
worker as well as others around them, and
Supervisors Must:
a) Be knowledgeable about and comply with the company’s alcohol and drug work rule and
procedures
b) Ensure they comply with work standards as part of their responsibility to perform their
work-related activities in an effective and safe manner
c) Be knowledgeable about the use of alcohol and drugs and be able to recognize the
symptoms of the use of alcohol and drugs
d) Understand their company’s performance management policy
e) Take action on performance deviations
f) Take action on reported or suspected alcohol or drug use by workers, and
g) Complete supervisor awareness training provided, as provided
Corporate Policy
15.7.4 GROUNDS FOR DRUG AND ALCOHOL TESTING
1. Reasonable Cause Testing:
Where the Company reasonably believes that an employee may be under the influence of drugs or
alcohol. Grounds for such reasonable belief include but are not limited to:
a) Reasonable Cause means that testing will take place whenever a Propak representative has
reasonable grounds to believe that the actions, appearance or conduct of an Employee while
on duty are indicative of the use of Drugs or Alcohol. The decision to test shall be made by a
supervisor, with concurrence of a second person whenever possible (for example, another
supervisor, manager, safety personnel or human resources).
b) The basis for the decision will be documented as soon as possible after action has taken
place. The referral for a test will be based on circumstances surrounding an incident or
specific, personal observation resulting from, but not limited to such indicators as:
i. The presence of drugs or alcohol on or about the employee’s person or in the
employee’s vicinity.
ii. Conduct by the employee that suggests impairment or influence of drugs or alcohol
iii. A report of drug or alcohol use while the employee is at work or on duty
iv. Information that an employee has tampered with drugs or alcohol testing at any time
v. Negative performance patterns
c) observed use or evidence of use of a substance (for example, smell of Alcohol);
d) observed signs of Drug or Alcohol impairment;
e) erratic, disruptive or atypical behaviour or changes in behaviour of the Employee;
f) illogical responses to questions or instructions;
g) changes in the physical appearance or speech patterns of the Employee;
h) the presence of Alcohol, Drugs or Drug Paraphernalia in the vicinity of the Employee or the
Company Worksite where the Employee was present; or any other observations that
suggest Alcohol or Drug use may be a factor (for example, sleeping on the job).
i) The decision to test shall be made by Safety personnel and / or Human Resources.
j) The basis for the decision will be documented as soon as possible after action has taken
place.
k) In all situations when a Propak Foreman / Supervisor believes that an Employee is unfit to
be on the work site, responsible escort procedures will be followed. Safety personnel or
Human Resources may need to be involved to ensure that the policy is being followed to
protect the rights of the worker as well as the safety of those on the worksite.
2. Post Incident Testing:

The Company shall require an employee to submit to drug and alcohol testing if the employee is
involved in or engages in conduct which results in a work related injury or causes damage to property,
including Company vehicles, machinery, equipment, tools or buildings.
a) any accident that results in a fatality and/or serious personal injury to any individual;
b) any accident that involves a pre-determined loss or damage to any motor vehicle, property
or equipment;
c) an environmental spill with significant implications;
d) significant loss of any revenues;
e) a near-miss incident that had the potential to cause significant injury or damage.
Corporate Policy
f) whether the incident is significant or not, (i.e. categorized as minor, noticeable, or a near
miss) should the employees involved present indicators that support a determination to test
for reasonable cause that will suffice to justify testing;
g) employee referred for a test will only be those who are identified, with reasonable grounds,
as having been directly involved in the chain of acts or omissions leading up to the event (i.e.
spotters);
h) a test is automatic after any significant incident
3. Scheduled Periodic Testing:
Employees may be required to submit to drug and alcohol testing as a routine part of a scheduled
fitness for duty Substance Abuse Professional recommendation.
4. Pre-Site Access Testing:
As required by a client in order to obtain access to that worksite and work on behalf of the Company.
Examples of Prohibited substances include but are not limited to:
Alcohol Marijuana Phencyclidine
Cocaine Opiates,
Amphetamines
** An employee in a safety sensitive position must be accommodated on light duty if using medical
marijuana until such a time as Drug and Alcohol testing determines THC concentrations would be
impairing at time of testing and then follow standard procedures for negative / non-negative findings.
5. Self-Disclosure Testing:
An Employee must self-disclose as per 15.7.3 i) & j) Worker’s Responsibility under the Drug & Alcohol
Policy i) - “Use medications responsibly, be aware of potential side effects and notify their supervisor
of any potential unsafe side effects where applicable. j) If a physician or the medication labels indicate
that there may be some effects or impairment with use of medication, the worker must disclose this
to their supervisor to ensure safety of the worker as well as others around them.”
If the employee self-disclosing is in a non-safety sensitive position, the information should still be
shared with their supervisor to ensure that the employer is aware of any side effects that could impair
their job performance. Human Resources can be consulted if there is any accommodation required.
If the employee self-disclosing is in a safety sensitive position (as described in 15.7.2 a) to e), an
employee must self-disclose to their supervisor who will then share the information with the HSE
Advisor or Co-ordinators.
In order to ensure the health & safety of the person disclosing as well as those around them, drug
and alcohol saliva tests will be conducted.
- If negative, the worker may return to their regular duties.
Corporate Policy
- If positive, then a urine sample will be taken and the employee will be accommodated in a
non-safety sensitive position until a confidential MRO review with the employee has been
conducted.
- Based on the MRO’s report, if negative, the worker may return to their regular duties.
- Based on the MRO’s report, if positive, the worker will be accommodated in a non-safety
sensitive position and will also be referred for a consultation with a Substance Abuse
Professional (SAP) for an assessment, who will determine addiction vs. non-addiction.
- Based on the SAP report, the SAP will provide direction to the employer on whether the
employee can return to safety sensitive duties or be accommodated in a non-safety
sensitive duties.
If an employee is tested following post-incident, reasonable cause, pre-site access or periodic testing
and tests positive and has chosen not to self disclose, protection from the policy will be lost and the
employee may be subject to termination.
15.7.5 US Market Employee DOT (Department of Transportation US) Requirements
a) Random Testing – In addition to required testing noted throughout this policy, all US Market
Employees classified as being in a safety sensitive role will also be subject to random drug
and alcohol testing. Random testing will be insured by utilizing a Third Party Administrator
(TPA) for the program.
b) Pre-Employment Testing – in order to be included in the random pool, it is also required that
any employee being hired to fill a safety sensitive role must agree to, and submit to a pre-
employment drug screening. Additionally, depending on the client, it may be necessary for
any employee being assigned to a safety sensitive role (even temporary) from another
division of the company to agree to, and submit to a pre-access drug screening to be
included in the random pool.
c) Annual Test on File – in addition to pre-employment/pre-access screening and random
screening, to maintain availability for a safety sensitive role, all employees subject to random
testing must have on record (at a minimum) an annual drug screening.
***Please note that all testing of employees working in a US Market work site, or for a US Market
client will be tested according to DOT equivalent standards (or client requirements if more
restrictive), notwithstanding Standard Propak Corporate Policy measurements and/or limits noted
throughout the rest of this policy
15.7.6 Procedures for Drug and Alcohol Testing:
Any employee, contractor, sub-contractor, or consultant who is involved in an on-the-job accident /

incident may be directed to take a drug and alcohol-screening test before returning to work if, in the
view of senior management, drugs and alcohol may have been a contributing factor.
Drug testing will be done as soon as practicable but can still be done within 32 hours of the
accident/incident. Alcohol testing will be done within 2 hours (if practicable) of the accident/incident
with attempts to test within 8 hours. If unable to test, reasons will be documented.
The testing will consist of an initial saliva test for drugs and saliva alcohol tests on site or at the nearest
collection site at time of incident or shortly thereafter performed in a confidential environment. The
collection will be taken by a certified collector at Propak.
If a Propak certified tester is unavailable due to absence OR off-site location such as field work or
offices other than Airdrie, then E-Screen will be called at 1-888-378-4832 or WellPoint at 403-236-
Corporate Policy
8400 who will provide a certified collector to make the collection, process the paperwork and send it
off to the Medical Review Officer (MRO) for verification.
After a negative saliva alcohol test result, an employee will return to full regular duties unless there
are further disciplinary issues.
A non-negative drug test result will result in a urine specimen being collected and sent to E-Screen or
WellPoint for confirmation testing as well. Employees will return to work in a non-safety sensitive
position until the non-negative test results are confirmed by the Medical Review Officer (MRO) at E-
Screen or WellPoint.
A positive saliva alcohol test will result in Section 15.7.7 of the Drug & Alcohol policy taking effect
immediately.
All positive test results are confidential and reviewed by the MRO. The MRO’s responsibility is to
review the lab test results and determine if there is a legitimate medical explanation for a confirmed
positive lab test result. The MRO will discuss the lab test results with the employee in private.
15.7.7 Refusal to Test - A refusal to test without medical justification will follow the same
process as a positive test.
Employees refusing to test as stated in section 1.0 may be terminated at the Company’s discretion.
a) Employees are required to submit proof of a drug saliva test including all drugs noted in 15.7.4
(4) and an alcohol saliva test performed by a certified Propak tester. If the employee refuses
to comply the employee may be terminated
b) Employees may apply to return to work six months after the date of refusal to test.
15.7.8 Positive Drug Test
a) Employees with an MRO confirmed positive result will be immediately suspended without
pay and removed from the worksite. A Company Health and Safety person and / or Human
Resources will advise the employee and advise on return to work conditions
b) At the scheduled meeting the employee will be provided with a Drug Test Suspension Letter
and a referral to the Substance Abuse Professional through Propak’s Employee Assistance
Program. The suspension will continue until the employee has completed an assessment by
a substance abuse professional (SAP) and complied with any required treatment plan or
conditions and a negative return to duty drug test as outlined in the Drug Suspension Letter.
c) The employee will be required complete additional unannounced testing up to six (6) months
after their return to work date as a result of a positive drug test.
d) A positive test result because of a pre-access testing as noted in 15.7.4 (4) (client
requirement) will result in the Company employee being prohibited access to any client work
site or Company safety sensitive work.
15.7.9 Positive Alcohol Test
a) An employee with an initial saliva alcohol test result at .020 to .039 will be removed from
duty and suspended without pay for the remainder of his/her shift and removed from the
work site. The employee will be sent home via taxi. The employee can return
Corporate Policy
to work the next regular shift; however, disciplinary action will be taken. Employee must
pass a return to duty saliva alcohol test in order to return to full regular duties.
b) An employee with a Confirmed saliva alcohol test result at .040 or higher will be removed
from duty, suspended without pay and removed from the work site. The employee will be
sent home via taxi. A Company Health and Safety person will advise the employee of the
return to work conditions.
c) The employee will be provided an Alcohol Test Suspension letter and a mandatory referral to
a Substance Abuse Professional (SAP). The suspension will continue until the employee
has completed an assessment by a substance abuse professional and complied with any
required treatment plan or conditions and a return to work confirmed alcohol test with results
indicating saliva alcohol concentration of less than .020.
d) The employee will be required to complete additional unannounced testing up to six (6)
months after their return to work date as a result of a positive alcohol test result over .020.
e) A positive test result over .020 because of pre-access testing as noted in 15.7.8 client
requirements will result in the Company employee being prohibited access to any client work
site or Company safety sensitive work until negative testing can be provided the following
day.
15.7.10 Duty to Accommodate
a) The Company recognizes its duty to accommodate addiction. Therefore, the SAP will assist
any employee that has a positive drug or alcohol test to resources that provide professional
help for rehabilitation and return to work. In addition, any employee voluntarily seeking help
for addiction will be entitled to the same assistance.
b) Employees seeking assistance for substance abuse will be directed to the EAP and requested
to sign a mandatory referral letter. The Employee Assistance Plan provider will assist with
providing resources that an employee can arrange for.
The Employee Assistance Plan provider will monitor the employee’s progress and upon successful
completion of their program, EAP will notify the Company. Based on a return to duty Confirmed
negative drug and alcohol tests the Company will determine if the employee is fit to return to work.
Subsequent drug and alcohol testing may be a condition of the return to work order
15.7.11 Failure to Comply
a) The Company may terminate the employment of an employee who fails to comply with this
Drug and Alcohol Policy. If an employee is terminated due to failure to comply with this Drug
and Alcohol Policy that person may re-apply for employment with the Company by
completing the following:
i. Supply a certificate from the rehabilitation institution that the person who was
terminated has successfully completed its program and continues to comply with all
the requirements of the rehabilitation program.
ii. Supply a signed Physical Demand Analysis, provided by the Company, by a licensed
physician with knowledge of substance abuse that certifies the person is able to
safely perform the duties the person will be required to do if re-employed.
Corporate Policy
iii. A signed statement by the person who is terminated acknowledging they agree to
additional reasonable conditions imposed by the Company upon their return to work
(i.e. additional drug and alcohol unannounced testing within a six-month period from
return to work date).
DEFINITIONS
"Alcohol" means the intoxicating agent in beverage alcohol, ethyl alcohol or other low molecular weight alcohols
including methyl or isopropyl alcohol.
"Company Worksite" means any place where Propak conducts business, including, without limitation, property,
buildings, equipment, road systems, facilities, work camps and vehicles, whether owned, leased or rented.
"Contractor" means any individual that is not a Propak employee, or a business entity, that is engaged by Propak
to perform services at a Company Worksite.
"Drug" means any drug, chemical or agent that may be used to alter the way the body or mind functions.
Employees will ensure that the consumption of Medications will not result in impairment whether that manifests
as fatigue, drowsiness, or loss of mental capacity.
"Drug Paraphernalia" means any equipment, product or material intended or designed for use in manufacturing,
compounding, converting, concealing, processing, preparing or introducing an illicit Drug or Alcohol into the
human body. This also refers to any product or device that may be used to attempt to mask, tamper with or
adulterate an Alcohol and Drug testing sample.
"Employee(s)" means all regular full time, part time, temporary, casual, co-op, summer and seasonal employees
on the Propak payroll.
"Failure to Test" includes the failure to report directly for a test, refusal to submit to a test, or refusal to agree to
disclosure of a test result to Human Resources. A failure to test will also include inability to provide sufficient
quantities of breath or urine fluid to be tested without a valid medical explanation acceptable to Propak.
"Fitness for Work" or "Fit for Work" in the context of this Policy means being able to safely and acceptably
perform assigned duties without any limitations.
Medication" means a Drug obtained (i) over-the-counter, or (ii) by the Employee through a physician's
prescription, or (iii) through a Health Canada authorization.
"Negative Test Result" means a report from a certified lab showing that an individual who provided a specimen
for Alcohol or Drug testing did not have an Alcohol or Drug concentration equal to or in excess of the limits set
out in this Policy.
"Positive Test Result" means a report from a certified lab showing that an individual who provided a specimen
for Alcohol or Drug testing had an Alcohol or Drug concentration equal to or in excess of the limits set out in this
Policy.
"Reasonable Cause" means that testing will take place whenever a Propak representative has reasonable
grounds to believe that the actions, appearance or conduct of an Employee while on duty are indicative of the
use of Drugs or Alcohol. The decision to test shall be made by a supervisor, with concurrence of a second
person whenever possible (for example, another supervisor, manager or human resources). The basis for the
decision will be documented as soon as possible after action has taken place. The referral for a test will be
based on circumstances surrounding an incident or specific, personal observation resulting from, but not limited
to such indicators as:
Corporate Policy
Safety-Sensitive Position" means a position in Propak designated as such, and includes all Employees who
perform management, operations, maintenance, emergency response functions on a facility or system, and/or
are using a vehicle for company business.
ACKNOWLEDGEMENT OF DRUG & ALCOHOL POLICY AGREEMENT TO SUBMIT TO

REASONABLE CAUSE SUBSTANCE TESTING AND AGREEMENT TO RELEASE TEST RESULTS
sheldon Joseph jess...
I, ________________________ understand that Propak Systems LTD maintains a Drug & Alcohol
Policy requiring all Employees to report to work in a substance- free condition.
I have received and read a copy of this Policy. If I did not understand the Policy, I have asked for and
have received an explanation. I understand that any breach of the Policy may result in administrative
and/or disciplinary measures, up to and including dismissal for cause.
I also understand that as a condition of my continued employment, where the circumstances requiring
testing outlined in the Policy exist, Propak Systems LTD will require me to undergo substance
screening by urinalysis, Saliva testing and I hereby agree to submit to such testing.
I further consent to the collection, use and disclosure of my Personal Information by Propak Systems
LTD as part of the Policy, and consistent with Alberta's Personal Information Protection Act, and the
federal Personal Information Protection and Electronic Documents Act. I understand that "Personal
Information" when used in this agreement refers to information about me as an identifiable individual.
I expressly understand that my Personal Information will contain my personal health information
collected by Propak Systems LTD for the purposes of enforcing this Policy, including the results of
any substance screenings being released to Propak’s authorized representative.
I also understand and agree that I am responsible for reporting any drug or alcohol addiction to my
supervisor and/or manager. In the event I suffer from a drug or alcohol addiction, I agree to participate
in either the Employee Assistance Program or applicable provincial Alcohol and Drug Abuse program
as recommended by those programs. I further consent to the disclosure of such Personal Information
of mine by the Employee Assistance Program or applicable provincial program officials as is
necessary for Propak to confirm my ongoing participation in, and successful completion of, such
counseling programs.
sheldon Joseph jess... sheldon Joseph jess...

Print Name: ____________________ Signature: _________________________
Date: _____________________________
Carla Gabel Carla Gabel
Witness: _______________________ Signature: _________________________
13/02/2023
Date: _____________________________

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Drug and Alcohol Policy

15.7 Drug and Alcohol Policy

REV. Brief Description of Changes

15.7.3 ROLES & RESPONSIBILITIES

a) Must report to work fit for duty.

15.7.4 GROUNDS FOR DRUG AND ALCOHOL TESTING

1. Reasonable Cause Testing:

2. Post Incident Testing:

3. Scheduled Periodic Testing:

4. Pre-Site Access Testing:

Examples of Prohibited substances include but are not limited to:

Alcohol Marijuana Phencyclidine

- If negative, the worker may return to their regular duties.

15.7.5 US Market Employee DOT (Department of Transportation US) Requirements

15.7.6 Procedures for Drug and Alcohol Testing:

Any employee, contractor, sub-contractor, or consultant who is involved in an on-the-job accident /

15.7.8 Positive Drug Test

15.7.9 Positive Alcohol Test

15.7.10 Duty to Accommodate

15.7.11 Failure to Comply

ACKNOWLEDGEMENT OF DRUG & ALCOHOL POLICY AGREEMENT TO SUBMIT TO

sheldon Joseph jess... sheldon Joseph jess...

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