12-1 Alcohol and Drug Free Workplace

Corporate Safety Manual
Procedure 12-1
ALCOHOL AND DRUG FREE WORKPLACE
SECTION 1 - PURPOSE
To provide the framework from which our Companies can effectively and legally engage in a
total Alcohol and Drug Free Workplace.
SECTION 2 - SCOPE
This Alcohol and Drug Free Workplace Program applies to all NORTHSTAR
Branches/Companies. It does not apply to those work locations in which a federally mandated
or client required alcohol and/or drug program is specifically dictated. For example, those
workers covered by the Department of Transportation’s Federal Highway Administration are
required to comply with the alcohol and drug program contained in the Section of the Corporate
Safety Manual entitled DOT Safety and Compliance.
SECTION 3 - POLICY
To initiate and maintain an alcohol and drug free safe workplace and to comply with federal
regulations governing substance abuse.
SECTION 4 - GENERAL
NORTHSTAR Services recognizes that substance abuse in the workplace is a major concern. It
affects not only job performance and the work environment but also undermines the public's
confidence in the Company and the safety of its operations. NORTHSTAR believes that by
identifying substance abuse, the safety, health, and general well-being of employees at all levels
of employment will improve. To further this belief, NORTHSTAR has instituted this Alcohol
and Drug Free Workplace Policy. The purpose of this Policy is to initiate and maintain an
alcohol and drug free workplace and to comply with federal regulations governing substance
abuse.
NORTHSTAR will notify each employee of its commitment to an alcohol and drug free
workplace. To comply with this Policy, NORTHSTAR will (a) establish an ongoing program to
ensure an alcohol and drug free workplace; (b) maintain an effective, safe and healthy workplace
for all employees and others exposed to the work site, including the general public; (c) safeguard
the property and operations of the Company and its customers; and (d) provide direction for
alcohol and drug abuse assistance.
NORTHSTAR GROUP SERVICES, INC. ALCOHOL AND DRUG FREE WORKPLACE

Corporate Safety Manual Procedure 12-1
Revised: 04/01/14 Page 1 of 20
Procedure 12-1
4.1 Safety Sensitive Positions
Because of the inherent risks involving worker safety and health in the construction
industry in general, and the potential risk factors of exposing personnel and the
environment to hazardous or toxic substances in particular, NORTHSTAR personnel are
considered to be employed in highly Safety Sensitive Positions.
SECTION 5 - PROGRAM IMPLEMENTATION
NORTHSTAR will take the following steps to implement the program:
 Inform its employees of the hazards of using alcohol and illegal substances.
 Screen its employees for the bodily presence of alcohol and illegal substances consistent
with federal and state laws.
 Not employ substance abusers consistent with federal and state laws and company policy.
 Remove substance abusers from NORTHSTAR's workplace.
 Where possible, assist employees with substance abuse problems in their rehabilitation
efforts.
SECTION 6 – DEFINITIONS
(For this Section)
Company - The Company, as the term is used in this Program, includes NORTHSTAR GROUP
SERVICES, INC., its Branch offices, subsidiaries and affiliated companies.
Company Vehicle - Any vehicle leased or owned by the company, including rental autos or
trucks.
Alcohol - Any liquid intended for human consumption that contains ethyl (ethanol), methyl or
isopropyl alcohol.
Legal Drugs - Prescribed drugs and over-the-counter drugs which have been (under U.S. law)
legally obtained and are being used for their intended purpose, or as prescribed and
manufactured.
Illegal Drugs - Any drug which is prohibited by law (e.g., cocaine, marijuana, etc.), any drug
which is legally obtainable but which has not been legally obtained, and any prescribed drug
which is not being used as prescribed or used by the person named in the prescription.
Controlled Substance - Any substance as defined in the Schedule of Controlled Substance 29

CFR Part 1308.

Procedure 12-1
Unfit for Duty - For the purpose of this Program, "unfit for duty" shall mean an employee who
is adversely affected by alcohol, drugs or any combination of alcohol and drugs, in an
observable manner. The symptoms are not confined to misbehavior, nor to obvious impairment
of physical or mental ability, such as slurred speech or difficulty maintaining balance. A deter-
mination of influence may be established by a professional opinion or a scientifically valid test.
The definition "Unfit for Duty" includes having a blood alcohol level at or greater than .02.
Medical Review Officer - The Medical Review Officer (MRO) is a licensed physician
knowledgeable in the medical use of prescription drugs and the pharmacology and toxicology of
illegal drugs. The role of the MRO is to review and interpret test results obtained through the
Company's drug testing program. The MRO will consult with the employee to assess and
determine whether alternate medical explanations, such as the use of prescribed medications,
could account for the positive laboratory test results. The MRO acts as a vital screen to assure
that management is not notified of a positive result on a drug test until the MRO is satisfied that
it resulted from illegal drug use.
SECTION 7 - ALCOHOL AND DRUG FREE WORKPLACE PROGRAM
7.1 Position on Substance Abuse
The Company has established the following positions with regard to alcohol or drugs:
 Alcohol
It is prohibited for any employee to be "Under The Influence" of alcohol while

performing Company business, while on a Company job site, or in a Company
facility, or while in or operating vehicles or equipment owned or leased by the
Company. "Under The Influence" is defined as having a blood alcohol level at or
greater then .04.
Use of alcohol or possession of an open container of alcohol while on a Company

job site or in a Company facility or Company vehicle is prohibited.
 Legal Drugs
Any employee utilizing a prescribed medical treatment involving a legal drug or

substance which may alter the employee's physical or mental ability to perform
the job, must report this treatment to his/her supervisor. A medical evaluation
may then be required to determine fitness for duty. The physician and the
supervisor will discuss whether a temporary or permanent change in the
employee's job assignment is warranted. If such use of legal drugs adversely
affects fitness for duty, the employee will be relieved of his/her job duties or
re-assigned.

Procedure 12-1
Individuals taking prescribed medication shall indicate taking this medication on

the collection form at the time of the drug test.
 Illegal Drugs
The manufacture, distribution, dispensation, possession, use, sale or being under

the influence of an illegal drug by any employee while performing Company
business, while on a Company job site or in a Company facility, or while in or
operating vehicles or equipment owned or leased by the Company is prohibited.
Illegal substance concentrations in excess of the cut-off levels are considered to
be "under the influence".
7.2 Employee Awareness
In its efforts to develop employee awareness of the hazards of substance abuse, the
Company will provide employee awareness components which may, for example, utilize
videotapes, toolbox talks, alcohol and drug awareness days, and distribution of written
materials. Information contained within these components will be made available to
employees.
7.3 Supervisory Training
NORTHSTAR's Alcohol and Drug Free Workplace Program includes a commitment to

train supervisors and managers to identify and respond to substance abuse use by
Company employees. This training includes information on NORTHSTAR's Alcohol
and Drug Free Workplace Program and Program implementation, and will provide, at a
minimum, sixty minutes of training each, in both alcohol abuse and drug abuse.
SECTION 8 - SUBSTANCE SCREENING
The Company reserves the right to require employees to undergo alcohol or drug screening as
described in this Program.
8.1 The Laboratory
The Company will utilize a Department of Health and Human Services (DHHS)
accredited laboratory which is able to assure that appropriate methods will be used.
Laboratory procedures will follow the context of a quality assurance program.
Adequately trained personnel will be used in the analysis and interpretation of the results.
When selecting a laboratory, the Company will consider equipment, personnel, quality
assurance, standardized procedures, quality control, and certification.

Procedure 12-1
8.2 Collection Of Specimens
The collection of urinary specimens from the employee (donor) will be accomplished to
assure each donor that personal dignity and privacy will be respected. Both urinary drug
and breath alcohol specimens will be collected by trained medical personnel. The donor
will be present until the container is sealed and the donor writes his/her initials across the
seal. The chain of custody will be documented thereafter.
8.3 Test Results
If the results of the initial screening exceed the specific cut-off levels, a confirmation test
will automatically be conducted by Gas Chromatograph Mass Spectrometry (GCMS) to
confirm the initial results. If this confirmation test is negative, then the results will be
reported as negative and entered into the donor's file.
However, if the confirmation test exceeds the prescribed limits and the result is positive,
the Medical Review Officer will contact the donor to evaluate potential interference with
the test protocol. If none are identified, the results will be reported as positive. Test
results will be handled in a confidential manner and available only to those individuals
who need to know the results to administer or apply this policy and program.
With the exception of those employees who are required to be screened under U.S.
Department of Transportation (DOT) regulations, or other regulatory requirements, the
panel of drugs for which these test are conducted will include, but will not necessarily be
limited to, the following: amphetamines; barbiturates; benzodiazepines; cannabinoids;
opiates; phencyclidines; and cocaine.
8.4 Action Levels for Positive Results
The action levels for positive test results for controlled substances will be the metabolic
levels accepted by consensus of the scientific community.
SECTION 9 - EMPLOYEE ASSISTANCE PROGRAM
Presently NORTHSTAR does not offer an independently contracted Employee Assistance

Program (EAP), however NORTHSTAR will offer every assistance to an employee who
requests help.
9.1 Self-Referral
At any time, if any employee should recognize that he or she has a substance abuse
problem and wishes help, the employee may contact NORTHSTAR management for

Procedure 12-1
confidential assistance. NORTHSTAR management will assist the employee in obtaining

a referral to an recognized local substance abuse program. Notification to NORTHSTAR
management does not preclude disciplinary action, up to and including termination, in
the event the employee is tested positive for drugs or alcohol use under the circumstances
as outlined in this policy.
1. Exception NORTHSTAR Assistance
There is only one time period when an employee is not allowed to voluntarily
request substance abuse assistance from NORTHSTAR, and that is during the
twenty-four (24) hour period just preceding his or her being notified to report to a
medical provider to provide a sample for a random drug test.
2. Eligibility
Employees who have tested positive for substance abuse are not eligible to obtain
assistance from the Company during the twelve month period immediately
following the date of the positive test results.
9.2 Procedure
The employee may contact a substance abuse program directly or ask NORTHSTAR
management for assistance. In either case the employee must notify NORTHSTAR
management that they are in treatment. The employee is responsible for all cost of
treatment not covered by his or her Health Insurance Plan.
In the event the employee does not elect to contact the treatment program directly, then
the employee should notify his or her supervisor or the Company’s Benefits Coordinator
(HSO) and advise them of the substance abuse problem. If the supervisor has been
notified, then he or she will immediately notify the Branch’s Program Administrator
(HSO) and the Company’s Benefits Coordinator. The Company’s Benefits Coordinator
will make a referral. Since the treatment program should keep the Company’s Benefits
Coordinator informed of the employee’s progress, the Benefits Coordinator will in turn
keep the Supervisor and the Program Administrator informed. The Benefits Coordinator
will continue to work with the employee, the supervisor, the Program Administrator and
the Treatment program in the event of non-compliance with the "Last Chance
Agreement."
9.3 Employer Referral
If the employee acknowledges to the company that he or she has a substance abuse
problem and is willing to follow an approved rehabilitation and follow-up program for
one year, the employer will make every effort to:

Procedure 12-1
 hold the job open while the employee is going through inpatient rehabilitation; or
 place the employee in a job where the employee is not in a position to hurt other
workers while he or she is going through an outpatient rehabilitation program.
Under both conditions, the employee must sign a "Last Chance Agreement." The "Last Chance
Agreement" stipulates the following:
 the employee will participate in a sponsored substance abuse program;

 the employee will sign a waiver allowing the substance abuse program to keep the
employer notified as to whether the employee is successfully participating in the
program. The employee will be required to sign a waiver allowing the Branch Program
Administrator to receive progress reports;
 an employee who does not, either satisfactorily participate in or satisfactorily complete,
both the rehabilitation program and the one-year prescribed follow-up program , will be
subject to disciplinary action, up to and including discharge;
 when the employee returns to work, the employee will be randomly tested for the greater
of two years or the length of time required by the customer's substance abuse policy or
mandated by local, state or federal regulations; and
 while the employee is actively working, if the employee tests positive or refuses to be
tested, the employee may receive disciplinary action consistent with this policy.
SECTION 10 - IDENTIFICATION OF SUBSTANCE ABUSERS
The following screening (testing) procedures are used to detect the abuse of alcohol and
controlled substance. Compliance with this Program is a condition of employment.
NORTHSTAR is free to utilize some or all of the following components to assure an alcohol and
drug-free workplace.
10.1 Pre-Employment Testing
Pre-employment testing may be utilized in selected locations. When used, it is a

condition of employment. An offer for employment will not be tendered if the test is
positive or if the applicant does not submit to testing.
When pre-employment testing is required it can be tailored to the specific requirements

of either the customer or the project.
10.2 Random Testing
Random testing of employees may be conducted at any time during their employment
with NORTHSTAR. Since random selection will be conducted by the MRO, employees

Procedure 12-1
may be selected for random testing more than once. Random selection of employees will
normally be conducted on a quarterly basis.
When required, the frequency of random selection for testing can be tailored to the
specific requirements of either the customer or the project.
10.3 Post-Accident Testing
Post-accident testing is used to assist in determining the true cause of accidents or

injuries. Post-accident testing must be performed immediately following an accident
involving any type of injury requiring off-site medical treatment or property damage.
Testing must be performed for all workers who are involved in the incident.
10.4 Reasonable Cause Testing
Reasonable Cause Testing can be utilized when supervision, with the concurrence of the
Branch’s Program Administrator, determines that an employee's conduct sustains a
reasonable suspicion that the employee is impaired by drugs or alcohol.
10.5 Customer or Regulatory Agency Required Testing
Customer or Regulatory Agency required testing will be conducted as required by the

customer or regulatory authority. If an employee tests positive in a client test, he or she
shall be removed from the client's premises and may be tested for cause under the
NORTHSTAR program.
10.6 Follow-up Testing
Testing for re-hire or follow-up testing will be conducted in the same manner as pre-
employment testing and/or random testing.
SECTION 11 - PRE-EMPLOYMENT TESTING
Although pre-employment substance abuse testing must be performed after the offer of
employment, a negative test results will still be considered a condition of employment. The
offer of employment will be withdrawn if the test is positive.
11.1 Procedures For Pre-Employment Testing
 The applicant will sign the Acknowledgement of Substance Abuse Testing form.
 The medical personnel will confirm the identity of the donor by requesting to
view a picture I.D. The sample may not be collected unless the donor provides a

Procedure 12-1
valid picture I.D. or is physically identified by an NORTHSTAR supervisor.

 The donor will provide the sample as directed by the medical personnel
conducting the test.
 After the sample container is closed, it will be sealed in accordance with the
instructions from the laboratory.
 The donor will then sign the tamper seal.
 The medical provider will complete the chain of custody form, package the
sample and send it overnight express delivery to the laboratory.
SECTION 12 - RANDOM TESTING
Random substance abuse testing is applicable to employees only. Random testing is a method of
randomly selecting a fixed percentage of the entire work force to be screened on a quarterly
basis. The random computer generated selection process will be conducted by the MRO from a
list of eligible names furnished by the Branch's Program Administrator on a monthly basis.
12.1 Informed at Time of Hiring
All employee applicants must be informed at the time of application and hiring, that
NORTHSTAR conducts random substance testing. The candidates for employment must
be given time to read and understand the Company's Acknowledgement of Substance
Abuse Testing form and then be required to sign the form as a condition of employment.
12.2 Eligibility List
Each month, a list of all personnel eligible for random testing will be sent by the
individual Branch’s Program Administrator to the Medical Review Officer (MRO). The
MRO will then use a computer generated program to randomly select the names of
individuals until the appropriate number is selected from the pool. If the name selected
is no longer an employee, the MRO will randomly select another name. The names of all
employees shall return to the random selection pool after selection, thus it is possible for
a given employee to be selected more than once.
12.3 Number of Random Tests
The number of positive results will be statistically evaluated for conformance with
historical experience. If there is a significant difference, the number of participants for
the next sample period may be increased. The statistical analysis will be used to assure
the number of participants remains at least twice the size of the number of anticipated
substance abusers.

Procedure 12-1
12.4 Request for Screening
The MRO will contact the Branch's Program Administrator to identify the individuals
who will submit a sample before the end of the next shift they work. Failure to submit
the sample within this time frame will result in termination of employment. The MRO
will match the lists of samples submitted versus samples required. The names of all
"required to" who did not submit will be directed to the Branch Manager for resolution.
12.5 Reporting Results
The MRO will report the positive or negative test results to the appropriate Branch's
Program Administrator. A quarterly summary of the names of personnel testing both
positive and negative will be sent to the Company’s Benefits Coordinator for follow-up.
12.6 Eligibility for Re-Hire
Employees whose employment is terminated due to violation of this policy and program
will not be eligible for re-hire for a 12 month period. To be eligible for re-hire, they
must be able to furnish evidence of successful completion of an approved substance
abuse rehabilitation program and sign the agreement that provides for unannounced
testing. Refer to paragraph 17.0 of this policy. However, these employees will not be
permitted to return to a jobsite of a customer who has a “zero tolerance” policy.
12.7 Procedures for Random Testing
The same testing procedures will be followed as outlined in paragraph 11.1 of this
policy.
SECTION 13 - REASONABLE CAUSE TESTING
An employee may be screened for alcohol or drug abuse for reasonable cause only when the
Company has determined that reasonable cause for screening exists. Justification must be
performance oriented and determined by a supervisor's direct and documented observation of the
employee.
13.1 Abnormal Performance
If a supervisor observes that an employee's performance abnormally varies from

performance standards, or that the employee's on-the-job conduct endangers the
employee or others, the supervisor may require the employee to undergo screening.
However, before the screening can be accomplished, the supervisor must document the
observation in writing, personally consult with the employee and review the observation

Procedure 12-1
and evidence with the Branch Manager, Branch HSO or a Regional Safety Director.
The responsibility for the decision to screen the individual will, however remain with the
supervisor and it is not necessary for either the Branch Manager, HSO or the Regional
Safety Director to concur with the supervisor's observations in order to commission this
screening. It is however, necessary that one be notified prior to its taking place.
13.2 Procedures for Reasonable Cause Testing
policy.
SECTION 14 - POST-ACCIDENT TESTING
The Company has resolved that all persons who are involved in any way in an accident or
incident involving any type of off-site medical treatment, will be immediately tested for
substance abuse to determine if any of the individuals involved were impaired by drugs or
alcohol at the time of the accident or incident.
14.1 Time Limit for Post-Accident Testing
In cases involving post-accident screening, the screening must be performed as soon as

possible following the accident, but in no case will it be conducted after thirty-two (32)
hours have exceeded the time of the accident.
14.2 Seriously Injured Employee
If the employee is seriously injured and sent directly to a health care provider, the health
care provider that normally obtains the samples should be requested to obtain the sample.
14.3 Who Should be Tested
In addition to the injured worker, all individuals who were in any way involved in the
incident must also be screened. This is to help determine if someone other than the
injured worker contributed to the accident.
14.4 Under the Influence
The MRO must be requested to make the statement, based upon the results of the
screening that the employee either was or was not under The Influence of the substance
at the time of the testing. Just using the word "Positive" to identify the employee's
condition will not be sufficient.

Procedure 12-1
14.5 Procedures for Post-Accident Testing
policy.
SECTION 15 - TESTING UPON RE-HIRE
An employee, whose employment with the Company is interrupted for other than disciplinary
reasons, will not be required to undergo additional pre-employment substance testing as long as
the employee's re-hire with the Company occurs within the twelve (12) month period following
the employee's last substance test under the NORTHSTAR program.
SECTION 16 - CUSTOMER AND REGULATORY REQUIREMENTS
When necessary, NORTHSTAR will supplement its Alcohol and Drug Testing Program to meet
testing required by regulatory, contract or customer requirements for access to a facility, site, or
operation.
16.1 DOT Testing
DOT Testing is required by the Federal Department of Transportation for drivers of

vehicles governed by DOT regulations. NORTHSTAR's DOT testing policy is outlined
in detail in the Section of the Corporate Safety Manual entitled Procedures for DOT
Testing.
SECTION 17 - DISCIPLINARY ACTION
The Company reserves the right and authority to initiate the following disciplinary actions with
reference to any employee found to have violated this Alcohol and Drug Free Workplace
Program:
1. If the employee's alcohol or drug test is confirmed positive, the employee will be
immediately discharged from employment unless this is specifically prohibited by
State Law. In situations of this type, each case will be handled on a case-by-case
basis;
2. Refusal to produce a timely sample will result in discharge; and
3. Refusal to sign the Acknowledgement of Substance Abuse Testing form will result in
discharge.

Procedure 12-1
4. Negative Dilute Test Results - In the event that the MRO reports the results of the
testing regarding a specific urine sample to be negative, but in addition specifies that
that urine sample is “diluted”, has a “low creatinin level”, or other synonymous
result, the employee in question shall be required, at a time of our choosing, to repeat
the collection and analysis process. Should the MRO report the results of the testing
regarding a specific urine sample as “substituted”, the employee in question shall be
considered to have refused testing and shall be subject to disciplinary action
commensurate with a positive test for prohibited substances.
The employee may be eligible for rehire after a period of 12 months following termination
provided that:
1. Evidence, acceptable to the company, of the successful completion of an approved

substance abuse rehabilitation program; and
2. The employee successfully passes each subsequent alcohol and/or drug test; and
3. The employee continues to maintain contact with the rehabilitation facility and
participates in the follow-up maintenance program as recommended by the
rehabilitation facility; and
4. The employee agrees to be subject to unannounced substance abuse tests from time to
time for a period of three (3) years following completion of the rehabilitation
program; and
5. There is no evidence the employee has been tampering with any of the required tests.
17.1 Suspension Without Pay
In the event the MRO has made a specific effort to contact an employee for any reason,
and it becomes apparent the employee is not returning the effort by contacting the MRO,
then the employee will be immediately suspended without pay until such time as a
successful contact is made with the MRO. After contact with the employee, the MRO
has obtained sufficient information to make a final decision and that decision is that the
employee's test results are positive, the employee will be immediately discharged.
If however, the MRO's final decision is that the test results are negative, and the
employee has a good excuse for not contacting the MRO, then the employee will be
immediately reinstated and the suspended wages will be reimbursed.
SECTION 18 - PROGRAM CLARIFICATION AND ADMINISTRATION
A copy of the Company's Alcohol and Drug Free Workplace Policy and acknowledgement will
be provided to all applicants and employees. Copies of this policy and acknowledgement will be
posted in a prominent place at each branch. Each applicant and employee shall read and

Procedure 12-1
understand this Policy and sign the Acknowledgment of Substance Abuse Testing form. This
Acknowledgment will then be retained in the employee's personnel file.
All classified advertisements for employment with the Company will advise prospective
applicants that the Company has an Alcohol and Drug Free Workplace Program.
Questions regarding any provision of either the Program or the Policy should be forwarded to
the Company’s Benefits Coordinator.
18.1 Responsibility of the Program Administrator
Each Branch, including Corporate, will select and appoint a Program Administrator who
will have responsibility for the day-to-day administration of the Branch's Alcohol and
Drug Free Workplace Program.
Additionally, the Program Administrator will:
 Send the MRO monthly updates of the Branch’s employees who are eligible for
random selection;
 Receive the list of the Branch’s positive and negative test results from the MRO;
 Establish the Branch’s list of medical providers who are available to obtain
samples; and
 Ensure that adequate "supplies" are maintained at the Branch or with the medical
provider.
18.2 Responsibility of Each Employee
It is a condition of employment that all employees abide by the terms of the Company's
Alcohol and Drug Free Workplace Program. In the event of a conviction for any
criminal drug violation, the employee must notify the Company’s Benefits Coordinator
within five (5) days of the date of the conviction.
SECTION 19 - RECORDS RETENTION
All Alcohol and Drug Free Workplace Program records will be retained by the Branch in the
individual employee's Medical Records file for a minimum period of two (2) years.
SECTION 20 - CONTRACTED SERVICES
Services for NORTHSTAR's Alcohol and Drug Free Workplace Program will be provided by

Procedure 12-1
the following:
20.1 DHHS Accredited Laboratory
The Branch may utilize any SmithKline Beecham laboratory or may choose any
Department of Health and Human Services (DHHS) or National Institute of Drug
Awareness (NIDA) accredited laboratory which is able to assure that appropriate
methods will be used. The Laboratory’s procedures must follow the context of a quality
assurance program, and have adequately trained personnel to carry out the analysis and
interpretation of the results. When selecting a laboratory, the Branch must consider
equipment, personnel, quality assurance, standardized procedures, quality control, and
certification.
20.2 Medical Review Officer (MRO Services)
In selecting a Medical Review Officer (MRO), the individual must be a licensed

physician knowledgeable in the medical use of prescription drugs and the pharmacology
and toxicology of illegal drugs. The role of the MRO is to review and interpret test re-
sults obtained through the Company's drug testing program. The Branch may contract
with any knowledgeable physician to provide the MRO services required.

Procedure 12-1
NORTHSTAR'S ALCOHOL AND DRUG FREE WORKPLACE POLICY
The Company has a vital interest in maintaining safe, healthful and efficient working conditions for its employees. Being under
the influence of alcohol or any other drug on the job poses serious safety and health risks not only to the user, but to all those who
work with or come in contact with the user (i.e. fellow employees, customers, the general public). The manufacture, distribution,
dispensation, possession, use or sale of an illegal drug or alcohol in the workplace or during the work day, also poses
unacceptable risks for safe, healthful and efficient operations.
Accordingly, it is the right and intent of the Company to maintain a working environment that is free of substance abuse. For this
reason, the Company has established a policy for pre-employment, random, DOT required, reasonable cause, or customer
required screening procedures designed to prevent the hiring and employment of individuals who use illegal drugs or individuals
whose legal use of alcohol or other drugs indicate a potential for impaired or unsafe job performance.
I. Alcohol
It is prohibited for any employee to be under the influence of alcohol while performing Company business, while on a
Company job site or in a Company facility, or while in or operating vehicles or equipment owned or leased by the
Company.
Possession of alcohol while in or operating a Company vehicle is prohibited.
Use of alcohol or possession of an open container of alcohol while on a Company job site or in a Company facility is
prohibited except for special occasions approved by the manager of the facility.
II. Legal Drugs
Prescribed and/or over-the-counter drugs may affect behavior and performance. Employees are required to notify their
supervisor that they are taking such drugs for medical reasons, and medical evaluation may be required. During any
period that such use of drugs adversely affects job performance, the employee will be relieved of his/her job duties or
re-assigned by the Company.
III. Illegal Drugs
The manufacture, distribution, dispensation, possession, use, sale or being under the influence of an illegal drug by any
employee while performing Company business, while on a Company job site or in a Company facility, or while in or
operating vehicles or equipment owned or leased by the Company is prohibited.
IV. Employee Responsibility
It is a condition of employment that all employees abide by the terms of the Alcohol and Drug Free Workplace Policy.
In the event of any conviction for a criminal drug violation occurring on a Company job site, in a Company facility, or
while in or operating a Company owned or leased vehicle, the employee must notify the Company’s Benefits
Coordinator within five (5) days of the date of the conviction.
V. Disciplinary Action
Violation of this Policy or refusal to comply with a request to be screened will result in discharge from employment.
Employee Assistance
The Company recognizes that chemical dependency is a disease and should be regarded as a disease with no stigma attached.
The Company will assist any employees who suffer from alcohol or other drug dependency . Contact a Manager at
NORTHSTAR for confidential assistance BEFORE your use/abuse of alcohol or other drugs leads to disciplinary action! Your
job will not be jeopardized by contacting NORTHSTAR for help.

Procedure 12-1
"LAST CHANCE AGREEMENT"
TO PARTICIPATE IN A SUBSTANCE ABUSE PROGRAM
In order to continue my eligibility for employment, subject to my participation in the employee

substance abuse treatment and follow-up care programs referred to below, I hereby agree that:
1. I will participate fully and in good faith in the prescribed treatment program at:
____________________________________________________________
____________________________________________________________
until such time as the director of such program determines that I have satisfactorily
completed the program and releases me.
2. I will also participate in good faith in the prescribed follow-up care program until released
as set out in Item 1 above.
3. Upon my completion and release of the treatment program and upon my return to work: (a)
I will be subject to unannounced substance abuse tests from time to time for a period of
three (3) years; (b) in the event any of such tests are positive, or if I should refuse to submit
to any of such tests, I will be immediately discharged from employment; and (c) I will
continue to be subject to all of my employer's employment policies and procedures, and
may also be disciplined or discharged at any time in accordance therewith.
4. I fully release and discharge NORTHSTAR GROUP SERVICES, INC. and its subsidiaries,
affiliates, predecessors, assignees and their officers, directors, employees, agents and
attorneys, past and present (collectively, "NORTHSTAR"), from any and all liabilities and
claims now known or unknown, arising out of my participation in the programs referred to
above or any actions which NORTHSTAR has taken or may take in connection therewith;
and I will indemnify, defend and hold harmless NORTHSTAR from and against any and all
actions, suits, proceedings, judgments and orders, and the costs of defense and settlement
thereof (including reasonable attorney's fees) arising out of my participation in such
programs or any actions of NORTHSTAR.
5. This agreement will be binding upon my heirs and personal representatives.
Date: ____________________ Acknowledged and agreed to:
__________________________ ____________________________________
Witness signature Employee signature
Accepted by: ______________________________________________________

Name and title

Procedure 12-1
ACKNOWLEDGEMENT OF SUBSTANCE ABUSE TESTING
I, the undersigned, hereby acknowledge and agree: (a) that I have received a copy of
NORTHSTAR's Alcohol and Drug Free Workplace Policy; (b) that I have read the Policy
and fully understand the implications of the Policy with regard to its affecting my
employment or continued employment with NORTHSTAR; and (c) that I will fully comply
with said Policy during the term of my employment with NORTHSTAR GROUP
SERVICES, INC., its subsidiaries, divisions or affiliates (NORTHSTAR).
I also understand that as a part of this program, I may be tested for chemical substance
abuse. If required to be tested, I hereby consent to such testing, and whenever the testing is
performed at the request of, or in conjunction with, the Alcohol and Drug Abuse Program
of an NORTHSTAR Customer, I authorize the medical provider to release the results of this
testing to such Customer, the DHHS accredited Laboratory being used by NORTHSTAR,
the licensed physician (MRO) under contract to NORTHSTAR, NORTHSTAR GROUP
SERVICES, INC., its subsidiaries, divisions, and affiliates and to release the Customer, the
Clinical Laboratory involved, NORTHSTAR, and its MRO from any liability they might
otherwise have for conducting such testing, test results, or making employment decisions
based upon the results of such testing.
I further understand and acknowledge that my employment with NORTHSTAR is

contingent upon my ability to successfully pass drug screening tests, and should this
screening produce a confirmed and verified positive test result, or should I refuse to take
this drug screening test, I will be immediately discharged from the Company.
ACKNOWLEDGED AND AGREED TO: _________________________________

(Employee Signature)
DATE OF SIGNATURE: ________________
__________________________________
(Employee's printed name)
__________________________________
(Supervisor's signature)
This Acknowledgment will be maintained in the employee's personnel file.

Procedure 12-1
SUBSTANCE ABUSE PANEL AND DETECTION LEVELS

DEPARTMENT OF TRANSPORTATION
(D.O.T. ONLY)
Substance Abuse Panel - 10 Panel
______________________________________________________________________
Detection Levels
Initial Confirmation Panel

( GCMS )
______________________________________________________________________
1000 ng/ml 500 ng/ml Amphetamines
300 ng/ml 200 ng/ml Barbiturates
300 ng/ml 200 ng/ml Benzodiazepines
300 ng/ml 150 ng/ml Cocaine Metabolites
100 ng/ml 15 ng/ml Marijuana Metabolites
300 ng/ml 200 ng/ml Methadone
300 ng/ml 200 ng/ml Methaqualone
2000 ng/ml 2000 ng/ml Opiates
25 ng/ml 25 ng/ml Phencyclidine
300 ng/ml 200 ng/ml Propoxyphene
Panels may be tailored to meet the requirements of the customer, and therefore may be subject to
change.

Procedure 12-1
SUBSTANCE ABUSE PANEL AND DETECTION LEVELS
Substance Abuse Panel - 7 Panel

______________________________________________________________________
Detection Levels
Initial Confirmation Panel

( GCMS )
______________________________________________________________________
1000 ng/ml 500 ng/ml Amphetamines
300 ng/ml 200 ng/ml Barbiturates
300 ng/ml 200 ng/ml Benzodiazepines
300 ng/ml 150 ng/ml Cocaine Metabolites
100 ng/ml 15 ng/ml Marijuana Metabolites
2000 ng/ml 2000 ng/ml Opiates
25 ng/ml 25 ng/ml Phencyclidine
Panels may be tailored to meet the requirements of the customer, and therefore may be subject to
change.


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12-1 Alcohol and Drug Free Workplace

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Corporate Safety Manual

ALCOHOL AND DRUG FREE WORKPLACE

NORTHSTAR GROUP SERVICES, INC. ALCOHOL AND DRUG FREE WORKPLACE

4.1 Safety Sensitive Positions

SECTION 5 - PROGRAM IMPLEMENTATION

NORTHSTAR will take the following steps to implement the program:

Controlled Substance - Any substance as defined in the Schedule of Controlled Substance 29

NORTHSTAR GROUP SERVICES, INC. ALCOHOL AND DRUG FREE WORKPLACE

SECTION 7 - ALCOHOL AND DRUG FREE WORKPLACE PROGRAM

7.1 Position on Substance Abuse

It is prohibited for any employee to be "Under The Influence" of alcohol while

Use of alcohol or possession of an open container of alcohol while on a Company

Any employee utilizing a prescribed medical treatment involving a legal drug or

NORTHSTAR GROUP SERVICES, INC. ALCOHOL AND DRUG FREE WORKPLACE

Individuals taking prescribed medication shall indicate taking this medication on

The manufacture, distribution, dispensation, possession, use, sale or being under

7.2 Employee Awareness

7.3 Supervisory Training

NORTHSTAR's Alcohol and Drug Free Workplace Program includes a commitment to

SECTION 8 - SUBSTANCE SCREENING

8.1 The Laboratory

NORTHSTAR GROUP SERVICES, INC. ALCOHOL AND DRUG FREE WORKPLACE

8.2 Collection Of Specimens

8.3 Test Results

8.4 Action Levels for Positive Results

SECTION 9 - EMPLOYEE ASSISTANCE PROGRAM

Presently NORTHSTAR does not offer an independently contracted Employee Assistance

NORTHSTAR GROUP SERVICES, INC. ALCOHOL AND DRUG FREE WORKPLACE

confidential assistance. NORTHSTAR management will assist the employee in obtaining

1. Exception NORTHSTAR Assistance

9.3 Employer Referral

NORTHSTAR GROUP SERVICES, INC. ALCOHOL AND DRUG FREE WORKPLACE

 the employee will participate in a sponsored substance abuse program;

SECTION 10 - IDENTIFICATION OF SUBSTANCE ABUSERS

10.1 Pre-Employment Testing

Pre-employment testing may be utilized in selected locations. When used, it is a

When pre-employment testing is required it can be tailored to the specific requirements

10.2 Random Testing

NORTHSTAR GROUP SERVICES, INC. ALCOHOL AND DRUG FREE WORKPLACE

10.3 Post-Accident Testing

Post-accident testing is used to assist in determining the true cause of accidents or

10.4 Reasonable Cause Testing

10.5 Customer or Regulatory Agency Required Testing

Customer or Regulatory Agency required testing will be conducted as required by the

10.6 Follow-up Testing

SECTION 11 - PRE-EMPLOYMENT TESTING

11.1 Procedures For Pre-Employment Testing

NORTHSTAR GROUP SERVICES, INC. ALCOHOL AND DRUG FREE WORKPLACE

valid picture I.D. or is physically identified by an NORTHSTAR supervisor.

SECTION 12 - RANDOM TESTING

12.1 Informed at Time of Hiring

12.2 Eligibility List

12.3 Number of Random Tests

NORTHSTAR GROUP SERVICES, INC. ALCOHOL AND DRUG FREE WORKPLACE

12.4 Request for Screening

12.5 Reporting Results

12.6 Eligibility for Re-Hire

12.7 Procedures for Random Testing

SECTION 13 - REASONABLE CAUSE TESTING

13.1 Abnormal Performance

If a supervisor observes that an employee's performance abnormally varies from

NORTHSTAR GROUP SERVICES, INC. ALCOHOL AND DRUG FREE WORKPLACE

13.2 Procedures for Reasonable Cause Testing

SECTION 14 - POST-ACCIDENT TESTING