ALCOHOL, DRUGS AND WEAPONS POLICY

SCOPE:

This policy applies to all facilities controlled or operated by GW & ASSOCIATES LIMITED and to all personnel of the Company and to all contracted personnel.

PURPOSE

This policy defines the Company's position regarding alcohol, drugs and weapons. It is intended to prevent the problems associated with alcohol, drugs and weapons in the workplace, thereby providing our employees with a safer workplace environment.

GW & ASSOCIATES LIMITED is committed to a safe and efficient operation at all of our job sites. The safety of all personnel, as well as the quality of work is of paramount concern.

It shall be the responsibility of the HSSE Representative to review the effectiveness of the Alcohol, Drugs and Weapons Policy on an annual basis in consultation with the Managing Director and present any recommended policy changes to the Board of Directors. It is also the responsibility of the Managing Director to ensure that this and all policies shall be distributed to all GW & ASSOCIATES LIMITED worksites and a copy of same in clear view at the Company’s Head Office. The Alcohol, Drugs and Weapons Policy will also be a key element of new employee and contractor orientations. It shall also be detailed in all bridging documents with clients and contractors.

It shall be the responsibility of the Board of Directors to review any recommendations of the Managing Director and HSSE Representative on the Company’s Alcohol, Drugs and Weapons Policy.  Following the review and acceptance of the policy by the Board of Directors, the Managing Director shall sign off the Alcohol, Drugs and Weapons Policy.

It is the responsibility of all employees of GW & ASSOCIATES LIMITED to become acquainted with the contents of the Alcohol, Drugs and Weapons Policy and to comply fully with all aspects of this policy.

TESTING REQUIREMENTS

Employees shall be subject to drug/alcohol testing as part of the Company’s programme for drug and alcohol testing. It is the aim of the program to meet the requirements under the following:-

• Trinidad and Tobago OSH Act 2004
• The U.S. Department of Transport (USDOT) Drug Testing Program: 49 CFR Part 40
• IMCA SEL Guidance Notes Nos. 008 and 011.

Drug and Alcohol testing shall be completed for the following reasons:

• Post accident or incident investigations
• Pre-employment
• At the request of clients prior to the commencement of work on their behalf.
• Random testing at any GW & ASSOCIATES LIMITED  site or project
• Under suspicion of substance or alcohol abuse the employee shall be requested to undergo drug or alcohol screening. Reasonable Cause Testing provides management with a means to identify those who might be affected by drugs or alcohol, who might be a danger to themselves or others in the workplace.

POST-ACCIDENT TESTING

Difficulties arise from the wide range of post accident situations that can develop and the following factors affect the effectiveness of post-accident testing. Details are as follows:

• Care needs to be taken that injured personnel are treated for their injuries first.
• The Medical Treatment administered might affect the validity of a test.
• Testing might not be possible or might affect the proper care of the injured person.
• There could be an interval of time from the accident to when a test is possible that would make it unlikely that any test would reveal whether drugs or alcohol affected the subject’s performance.

Given the above it is the responsibility of the HSSE Representative to use the best medical advice available to him or her at the relevant time to judge whether a test is practicable. If administration of a drug and alcohol test is practicable, then all personnel involved should be tested as soon as possible.

The treatment of injuries is however to be given priority.

REFUSAL TO CONSENT TO TESTING

The refusal to consent to testing by an employee shall result in an investigation into the reason for refusal. Following this investigation by the HSSE Representative, disciplinary action shall be commenced if the reason for the refusal is not satisfactory.
If an employee refuses to submit to or cooperate in the administration of a timely chemical test when directed by a duly authorized company official, medical practitioner or law enforcement officer based on reasonable cause, evidence of the refusal is admissible in evidence in any administrative proceeding.

INSUFFICIENCY OF SAMPLE AMOUNT

In cases where the subject fails to provide a sufficient sample volume of urine for testing, the subject shall be asked to drink a certain amount of fluid over a reasonable period of time and then attempt to produce a sample at that point. This information should be included in the testing records for that subject.

If the subject does not provide a sample after the prescribed reasonable period then this information should be also recorded and the appropriate company official notified.  The Medical Review Officer (MRO) would then be consulted to evaluate the nature of the reason provided by the individual and to provide advice on the issue. Based on this advice the HSSE Representative and the Managing Director would then determine the course of action(s).

All records of drug and alcohol tests shall be kept confidential and lodged with the Managing Director.
Records are to be kept for a period of two (2) years and records where employees have been found positive for alcohol or drugs, the retention period for records shall be three (3) years.

COMPETENT HANDLING OF SAMPLES

Only qualified professionals shall administer any drug and alcohol testing and the results shall be analyzed in a competent laboratory. Further, it is the responsibility of the person collecting the sample to ensure that the samples taken are properly labeled and secured from the possibility of contamination or tampering at all times.

THE COLLECTION SITE

Collections of samples shall be done at any location deemed appropriate by the company. The collection site shall be an area amenable to control by the duly authorized personnel conducting the test, whilst providing some measure of privacy during the actual collection of the sample.

Collection personnel shall have the authority to ban entry to the sample collection area by anyone who is not part of the collection process. Additionally, if the collection site should have secure areas for the storage of all samples collected prior to shipment to a laboratory, as well as the materials and equipment need for the collection of same.

All collection personnel shall have the authority to check the pockets of the personnel being tested to ensure no devices are being held that may be used to contaminate a sample.

COLLECTION AND MOVEMENT OF SAMPLES

Prior to the collection of samples from subjects, the identity of the subject to be tested must be verified, and an explanation provided of the basic sample collection procedure to the subject including the fact that failure to comply with the prescribed procedure would be construed as “a refusal to take a test”. The test subject will then be required to sign a release confirming that the reason for the test being performed has been explained to them.

REVIEW OF POSITIVE SAMPLES

These shall be taken to establish the presence of drugs or alcohol in a person. If a urine or blood sample taken turns up a positive result for alcohol or drugs then the matter shall be further investigated by a Medical Review Officer (MRO). The (MRO) will in turn advise the Company of the most reasonable explanation for the test result obtained.

Any employee determined by the Company to have engaged in any of the prohibited activities set forth in this policy, without an explanation that is deemed satisfactory to the Company, will be subject to disciplinary action up to and including immediate termination from employment.

GW & ASSOCIATES LIMITED adheres to a zero tolerance policy for the possession, transportation, sale or use of alcohol, drugs and weapons. Accordingly, the following activities are regarded as completely inconsistent with our goal of a safe work environment and are grounds for disciplinary action.

• Possession, use, distribution or sale of alcohol, drugs or weapons (not including work knives) on the job site or on company property is “Gross Misconduct” and shall result in disciplinary action.
• The presence of drugs or alcohol in the body while on the jobsite or on company property as evidenced by positive “Breathalyzer”, saliva, blood tests, or urinalysis testing is violation of company policy shall result in disciplinary action.

“Drugs” for the purpose of this policy includes all drugs, narcotics, restricted by law as to their possession or use, along with synthetic or “designer” drugs that have not been so regulated, yet are capable of adversely affecting employee safe work performance. 

Drugs also include alcohol or any substances used in an abusive or intoxicating manner, and or possession is in violation of state or national law. Persons under medical care shall discuss the potential side effects of prescribed medication with the physician and with their supervisor and/or on site medical personnel prior to starting work.

WEAPONS

A weapon for the purposes of this policy refers to firearms, explosives, knives not approved for work or implements contrived to cause injury or harm (hereafter referred to as “weapons”). All weapons are prohibited from the premises of GW & Associates Limited or clients (either onshore or offshore). This is regardless of whether or not a national license to possess the same has been issued to the possessor.

POLICY STATEMENT

GW & Associates Limited is committed to an alcohol, drug and weapon free environment and adheres to a zero tolerance policy with respect to the possession, use, manufacture, or distribution of same at any of its worksites.

To provide a number of products and services which include Corrosion Protection, Consulting, Project Management and Inspections to the Marine sector whilst continuously sourcing other products and services applicable to all industrial sectors.