DRUG-FREE WORKPLACE PROGRAM

1. DRUG-FREE WORKPLACE PROGRAM Program Administrators ScreenSafe Inc. 877-727-3369

2. DRUG-FREEWORKPLACE PROGRAM Sheet Metal Industry labor and management program to address the problems caused by drug and alcohol in the workplace. Sponsored By SMACNA Chicago And Sheet Metal Workers Local 73 Administered by ScreenSafe, Inc.

3. Goals and Objectives • Recognition of the problem; • Development of a comprehensive policy; • Educate Individuals; • Promote the Member/Employee Assistance Program, MAP/EAP; • Implement a fair and respectful drug testing program that conforms to Federal drug testing standards.

4. Policy Requirements and Prohibitions • The use of alcohol or drugs by employees during working hours on the job site or on company property (including company vehicles) is absolutely prohibited. • Individuals are required to submit to drug and/or alcohol testing in accordance with this policy.

5. Policy Requirements and Prohibitions • No individual will be tested for alcohol unless a reasonable suspicion exists that the person is under the influence of alcohol, or they are involved in an OSHA recordable on the job accident. • Participants will be required to take an alcohol test by way of evidential breath testing device (breathalyzer). • Individuals subject to this policy continue to have access to the usual protections provided as part of their union membership.

6. Policy Requirements and Prohibitions • All employees who are employed by a signatory to the agreement will be subject to this program, including union and staff employees. • Individuals will be selected randomly from the 50% pool. • Individuals who complete the testing process will not be returned to the 50% pool. • At the same time there will be an ongoing 10% pool.

7. Testing Procedures • Names picked from the random pool. • ScreenSafe refers to the union/contractor database find where union member is working. • Designated (Company or Union) Representative is called and informed to expect a fax regarding individuals being tested.

8. Testing Procedures • ScreenSafe makes calls to Designated Representative. • Designated Representative faxes/emails Notification Form back to ScreenSafe

9. Testing Procedures • Forms sent to Designated Representative: • Sheet Metal Industry Drug-Free Workplace Program Information Sheet • Employee Notification Form • List of Testing Sites

10. Testing Procedures • By the end of the business day, the Designated Representative informs Individual that his/her name has been selected. • Individuals are given until end of next business day to take test. • Individuals are given one hour off with regular pay and fringe benefits by their employer.

11. Testing Procedures • If the member is unemployed he/she will receive a dollar amount equal to one hour regular pay with fringe benefits from the Industry Fund.

12. Testing Procedures • If the test is negative, no further action is taken. • If the test is positive, the Medical Review Officer (MRO) calls individual to validate reason for positive. • If no valid reason found, the individual is in violation of policy.

13. Testing Procedures • Testing will also be done when there is “reasonable suspicion”. • Accelerated testing (follow-up) takes place (based on MAP recommendation) once a Individual is non-compliant and has returned to work.

14. Testing Procedures - Safeguards • All testing sites are DHHS approved • Integrity of specimens insured by utilization of one collection procedure at all sites • All labs have DHHS certification and are NIDA approved • All positives confirmed by GC/MS • MRO reviews all drug test positives

15. Testing Procedures – Safeguards • Urine samples separated into two containers at time of collection • Other forms of testing for Individuals with confirmed medical conditions • Blind testing

16. Policy Violations • Policy Violations can include; • Having a positive test result. • Failing to take a test as scheduled • Failing to keep a scheduled appointment with MAP or • Failing to participate in and/or complete the assigned treatment or education program

17. Policy Violations • Policy Violations can include (continued); • Substituting another substance or specimen • Providing a dilute specimen for a second time without a valid medical explanation • Providing a urine specimen which shows the presence of an adulterant

18. Consequences • Upon a first positive test; • Individual will be referred to the MAP for evaluation • Individual must begin recommended treatment or education program • Individual will mostly be returned to work prior to program completion • The Individual will be placed in a one year accelerated testing program.

19. Consequences • Upon a second positive test; • Individual will be referred to the MAP for evaluation • Individual must begin recommended treatment or education program • Individual may be returned to work prior to program completion • The Individual will be placed in a one year accelerated testing program.

20. Consequences • Upon a third positive test within a two-year period from the preceding (second); • Individual will be referred to the MAP for evaluation • Individual must beginrecommended treatment or education program • Individual will be returned to work prior to program completion • The Individual will be placed in a one year accelerated testing Program. • The Individual will be required to sign a “Last Chance Agreement" between him/herself and the Program.

21. Consequences • Upon a fourth positive test within a two-year period from the preceding (third); • Individual will be referred to the MAP for evaluation • Individual must completerecommended treatment or education program • Individual will not be returned to work prior to program completion • The Individual will be placed in a one year accelerated testing Program. (continued)

22. Consequences • The Individual shall be terminated from employment and, is ineligible for referral until he/she has satisfactorily completed the assigned treatment or other program.

23. Consequence Procedures • ScreenSafe informs the Designated Representative from the employer that the Individual is non-compliant and must be removed from the worksite immediately. • Individuals will receive written notice confirming their non-compliance and providing them with information to assist them in returning to compliance.

24. Testing Occasions - Portability • These provisions will apply to those individuals working under the portability rules. • All traveling craftpersons will be subject to: • Initial testing • Random testing –10% pool • Craftsperson will be allowed to report to work immediately after providing a urine specimen for testing.

25. Post-Accident Testing • Post accident testing may be done when employees are involved in a work related accident or incident that results in a fatality, a lost time injury, OSHA recordable incident or significant property damage or monetary loss. • Post Accident testing is done at the employers expense and the employer is entitled to the results.

26. Pre-employment Testing • Pre-employment testing is allowed to be conducted pursuant to the pre-existing process contained in the Agreement. • The cost is paid by the employer.

27. Job Seeker Card • All members who test and are compliant will receive a job seeker card. • When the individual seeks employment with a signatory contractor they must show the card and sign a consent form so the contractor can verify the individuals compliance.

28. Job Seeker Consent Form • You will be asked to sign a the job seeker consent form when you apply for employment with a signatory contractor. • By signing that you are allowing ScreenSafe to inform the contractor of your compliance. • If you refuse to sign the consent form the employer will not hire you.

29. A Non-Compliant Contractor • Will be subject to the following • SMACNA and Local 73 will be notified • prohibited from hiring union members • May be subject to the withdraw of their men by the Union • Undergo a payroll audit to be paid for by the contractor

30. A Non-Compliant Contractor • Will be subject to the following (continued) • Anything beyond the JAB associated with non-bargained lawsuits will be shared equally by the Union and SMACNA Chicago. • a minimum $2,500.00 fine

31. Designated Representative Responsibilities • Register names of new employees with ScreenSafe. • Send names of people who have left the company. • Information Needed: • Name, social security number/union card number, address, city, state, zip, and phone number • For people who work 20 hours or more per week and are not a part of another union or bargaining unit. • Notify people who need to test

32. Designated Representative Responsibilities • After employee notified “Notification Form” must be faxed to ScreenSafe with time and date the person was notified • Remind employee • They need a picture I.D. or be accompanied by a foreman. • They need to test before the end of the next business day. • They should keep receipt or give to Designated Representative • They need to inform the testing site that they are testing through ScreenSafe/Sheet Metal • They need to give their UNION CARD NUMBER if they are a union member

33. Designated Representative Responsibilities • Non-Compliant Participants • When you are notified about a non-compliant person this information must remain confidential. • A non-compliant person is not allowed to work until ScreenSafe faxes a copy of the “Release to Work” form to you. The person must be removed from duty immediately. • Please discretely notify the person they are non-compliant. Quietly and calmly explain to them that you were notified of their non-compliance from ScreenSafe and they must leave the job site immediately. Inform the person they need to call ScreenSafe 877/727-3369.

34. CONCLUSION • Our approach is always fairness and objectivity for the employee and for the employer. • Our intention is always to help. • Our goal is always to assist in providing a safe and drug-free workplace.