February 03, 2014

Page 1 of 8

USGC GulfstreamProgram

The Dow Chemical Company

Gulfstream Substance Abuse Policy

Introduction / The purpose of the GulfstreamSubstance Abuse Policy is to assure maximum safety and well being of all Dow employees, CONTRACTORS' employees, and all other people located in the construction sites and the surrounding operating facilities.
Applicability / This practice applies to all work activities and personnel working on theGulfstream construction sites.
Overview Statement / The Dow Chemical Company considers the misuse or abuse of alcohol, the use of illegal or unauthorized drugs, and the misuse of prescription drugs to present a serious threat to the health and safety of any person working on its premises and the surrounding community and to interfere with the efficiency and productivity of work being performed on its premises.
Testing Types / The following types of drug testing will be required for employees of contractor companies working on the Gulfstreamprogram on Dow property or Dow leased property. Individual contractors working under D.O.T. requirements must also follow D.O.T. guidelines for drug testing
  • Pre-employment and/or Pre-access drug testing – alcohol swab or breathalyzer test and 10 panel urinalysis. A 10 panel quick test can be utilized for immediate site access with a passing test. The sample needs to be sent to a lab for confirmation via GCMS (Gas Chromatography Mass Spec.). For out of town candidates, a hair test may be substituted for the 10 panel urinalysis. A hair test may always be substituted for a urine test.
  • Random testing – hair follicle.
  • For cause and post incident drug testing – 10 panel urinalysis and alcohol swab. A 10 panel quick test can be utilized for immediate results but follow up testing needs to occur with a lab for confirmation via GCMS.

Continued on next page

Gulfstream Substance Abuse Policy, Continued

Policy / The use (for this purpose includes a positive drug test result), bringing onto Dow premises (which includes all property owned, operated, or leased by Dow, or under the control of Dow), possession, concealment, transportation, promotion, or sale of the following substances and items by any contractor, subcontractor, vendor, and their employees (collectively, "CONTRACTORS" and individually, "CONTRACTOR") is strictly prohibited from Dow premises.
This policy includes:
  • Illegal Drugs
  • Unauthorized controlled substances
  • Look-alikes
  • Designer and synthetic drugs
  • Any other illegal or unauthorized drugs or abnormal substances which may affect an employee’s senses, motor functions, or alter a person’s perception while working
  • Alcoholic beverages
  • Drug paraphernalia

Continued on next page

Gulfstream Substance Abuse Policy,Continued

Contractor Requirements – Pre-employment & Pre-access Testing / CONTRACTORS who perform labor or services on Dow premises must have, and administer, a formal substance abuse interdiction policy.
Such policy must include a provision for tests (such as drug test by hair, urine drug screens or blood, plasma tests, and alcohol test using the “swab test” method for alcohol testing with the use of a breathalyzer test for confirmation of positive alcohol tests) to determine the use of any illegal or unauthorized substances prohibited by this Policy.
Non compliance to the testing requirements of this policy will result in the removal of the individual from Dow property for a minimum of 12 months.
These tests shall be administered under the following conditions:
  1. Pre-employment and pre-access drug and alcohol testing of current employees returning to Dow premises from layoff or outside job assignment shall be accomplished by the use of
  2. swab and/or breathalyzer testing for alcohol and 10 panel urinalysis, with the following exceptions:
  3. Contractor employees that are currently employed by the contractor firm and have been subject to random hair follicle testing (in the random pool) for that company within the last 90 days, and have been tested within the last two years, are exempt from the pre-access testing requirements.
  4. Contractor employees new to a contractor firm which is participating and in compliance with this “Contractor Substance Abuse Policy” and who are designated as “Approved for Work” for the specific Gulfstream construction site (i.e. Texas Operations) in the VECTOR™ database maintained by PsychemedicsCorporation are exempt from the pre-access testing requirements.
  5. Individual contractors that work under Department of Transportation (D.O.T.) requirements must also follow D.O.T. guidelines for drug testing.

Continued on next page

Gulfstream Substance Abuse Policy, Continued

Contractor Requirements – For Cause Testing / For cause testing will occur when
  • CONTRACTOR's supervisor has a reasonable suspicion or belief that CONTRACTOR's employee shows signs of being under the influence of, or in possession of, any substance or item prohibited by this Policy.
For the purposes of this Policy, reasonable suspicion or belief can include occupational on-the-job injury or involvement in a serious or potentially serious accident or incident.
For cause drug testing shall be accomplished using a 10 panel urinalysisquick test with GCMS confirmation and for cause alcohol testing will be accomplished using the swab testing method with breathalyzer testing for confirmation of positive tests.
Contractor Requirements – Random Testing / During each 12-month period, CONTRACTOR will randomly select for drug testing a sufficient number of the employees assigned to Dow construction sites so that the number of tests conducted will equal at least 50 percent of the individual employees who are badged for the construction site.
The method of testing required to accomplish these tests will be
  • hair testing for drugs and swab testing for alcohol with a breathalyzer confirmation required for any positive alcohol swab test.
  • Individual contractors that work under D.O.T. requirements must also follow D.O.T. guidelines for drug testing.
Such testing shall be conducted monthly. In the case of short duration jobs, the contractor may be requested to conduct random tests on a weekly basis. It is our intent that all contractors working at the site be subject to random testing hair.
A report must be sent monthly to Dow GulfstreamEH&S indicating the monthly employee count, the number of individuals tested and the number of “non-compliance” issues detected.
Continued on next page

Gulfstream Substance Abuse Policy, Continued

Substance Testing Requirements / A 10 panel urinalysis will be completed and each specimen will be tested for at least the following drugs:
  • COC, THC, OPI, AMP, MAMP, BZO, OXY, PCP, PPX, BAR
  • Cocaine - COC, Cocaine, Crack, Coke
  • Marijuana - THC, Hash, Pot, Cannabis, Hashish, Weed
  • Opiate - OPI
  • Amphetamine– AMP,Tyramine, ,benny, dexy, whizz, pep pills. sulph, phets
  • Methamphetamine - mAMP, Meth, Ice, Speed, Crank, Ecstasy
  • Benzodiazepines - BZO, Benzos, Clonazepam, Oxazepam, Diazepam,
  • Oxycodone - OXY, Oxycodone, Oxycotin, Dilaudid, Hydrostat, Hydromorphone, Loratab, Lorcet, Vicodin, Hydrocodone
  • Phencyclidine - PCP
  • Propoxyphene – PPX, Propoxyphene, Co-proximal, Darvocet, Darvon, Dextropropoxyphene
  • Barbiturates - BAR
  • Additional testing for Look-Alikes and Designer or Synthetic drugs will be used when necessary
Alcohol testing: Alcohol tests will be considered positive if the blood alcohol level of an individual is at or above .02.
Test Result Action / Site entry may be granted based on negative results of a 10 panel urinalysis quick test. However, if confirmation by GCMS indicates a non-negative result, then a review of the results must occur with an MRO. Based on that review, the person’s site access may be revoked.
Non-negative test results will result in immediate Texas Operations site removal and revocation of site access.
Continued on next page

Gulfstream Substance Abuse Policy, Continued

General Requirements /
  • Hair testing must be accomplished using third party collection and must be conducted through the use of the Psychemedics Corporation.
  • Post incident drug testing is required for all incidents including first aids, significant near misses involving equipment damage, spills greater than 14 gallons, when requested and all recordable injuries.
  • Additional testing for Look-Alike and Designer or Synthetic drugs may also be required at the discretion of Dow or Contractor Company supervision.
  • Chain of custody of the individual requiring a drug/alcohol test must be accomplished by using a member of the contractor company’s supervision to escort the individual to the test site.
  • All testing and collection of test specimens must be administered by a qualified third party (no in-house testing will be accepted).
  • Positive drug test results MUST be reviewed by a Medical Review Officer (MRO).
  • Post accident/incident and for cause testing must be completed as soon as possible.
  • Failure to comply with the stated drug program will result in the individual being removed from Dow property for 12 months. Contractor Company must notify Dow Security per the GulfstreamBadging Process.
  • All contractor employees working in Dow Freeport are expected to be registered and demarcated as working in Dow Texas Operations Freeport in the VECTOR™database maintained by Psychemedics.

Continued on next page

Gulfstream Substance Abuse Policy, Continued

Reporting and Notifications / A report must be sent monthly, to the Dow GulfstreamEH&S functional mailbox at indicating
  • the monthly employee head count,
  • the number of individuals tested,
  • the number of “non-compliance” issues detected.
  • NOTE: If your company had no work during the month then a report still needs to be sent indicating as such.
(Refer to the “GulfstreamContractor Monthly Reporting Requirements”)
Prescription Re-Testing / Since Texas Operations is a safety sensitive environment, some prescription drugs have a risk of impairment including some sedative and narcotic pain medicines and an individual should not be working in a safety sensitive environment until their course of treatment is complete.
As such, the MRO will require a “retest” using urinalysis for workers that are taking a prescription that could cause impairment, once the course of treatment is completed before reporting a negative result. The MRO will also implement a restriction as applicable to the situation.
Medical Review Officer (MRO) / All contractor companies will contract with a Medical Review Officer (MRO) vendor for test results. A qualified MRO is engaged to receive and evaluate positive drug test results. An MRO is a licensed and accredited physician knowledgeable about controlled substances and substance abuse disorders, including knowledge of medical explanations for laboratory confirmed drug test results.
The MRO’s primary responsibility is to review and assess test results, interview the sample donor to determine if a legitimate medical reason exists for a positive test result, and to report substance test results. Should a positive laboratory test result be overturned by the MRO, the sample donor will be required to have a medical review to determine if the donor may be accepted or denied access due to the nature of their work.
The Dow Chemical Company, Texas Operations, is a safety sensitive area and should be considered as such when determining whether or not an employee with an overturned positive test result should be allowed access back on site.
Continued on next page

Gulfstream Substance Abuse Policy, Continued

Definitions / Definition of key terms is below.
Item / Description
Hair Testing / Analysis of hair samples to detect the presence of tested drugs and/or their metabolite(s) at reportable levels.
Testing will be performed by a laboratory whose screening methods are cleared by the U.S. Food and Drug Administration (FDA) for both head and body hair types.
Qualified Third Party Collection / Companies contracted by the contractor firm for the purpose of collection of drug and alcohol testing samples. The contracted company must be certified and those individuals that collect samples must be trained and qualified.
As it applies to “hair testing”, the process used must be approved, cleared, or otherwise recognized by the Food and Drug Administration as accurate and reliable for the testing of such specimens. In addition, hair testing must include all panels and all hair types and must assure the test excludes contamination.
Lab Contact Information / Phone number: 800-637-1645

Hours: M-F, 7am - 4pm PT
Revision history / The following information documents at least the last 3 changes to this document, with all the changes listed for the last 6 months.
Date / Revised By / Changes
8/21/2012 / Mary Schwartz / Added Gulfstream references.
2/12/2013 / Mary Schwartz / Removed hair follicle testing and added urinalysis for pre-employment and pre-access requirements.
3/12/2013 / Mary Schwartz / Clarified pre-access requirements, 10 panel quick test use, and 10 panel requirements.
2/3/2014 / Mary Schwartz / Clarified post incident drug testing.

Substance Abuse Policy This is a controlled document. No un-authorized modifications.

Health, Safety, and Environmental

DOW CONFIDENTIAL – Do not share without permission