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					                    NORTHWEST INDIANA BUSINESS ROUNDTABLE
                                   (NWIBRT)
                     CONTRACTOR DRUG AND ALCOHOL POLICY
                              (Final, April 22, 2006)

STATEMENT OF POLICY

Northwest Indiana Business Roundtable (“NWIBRT”) members have a strong commitment to
provide a safe work place for their employees and other persons working or visiting on their
premises. In order to assist in maintaining a safe working environment and to protect Company
property, this Policy is a condition of contracting with NWIBRT.

SECTION I – STATEMENT OF POLICY REQUIREMENT for CONTRACTORS

Contractors, subcontractors and vendors (hereinafter referred to as “Contractors”) who perform
labor or services for NWIBRT members’ premises, or on whose premises NWIBRT members’
employees spend time, must have and must administer a formal Drug and Alcohol Policy.

Contractors who implement and maintain their own program shall submit a copy of their Drug
and Alcohol Policy and program to the NWIBRT member employee designated to administer
contracts or to a party as otherwise designated by NWIBRT members. At a minimum, each
Contractor’s policy must meet the standards established in this document. NWIBRT members
reserve the right to withhold solicitation of bids or to deny entry to NWIBRT members' premises
of any Contractor, subcontractor, or vendor who fails to present a written policy that meets
NWIBRT minimum standards, or who fails to administer and enforce an acceptable policy.

A Contractor’s policy must require drug and alcohol testing of all Contractor’s employees and
managers as outlined in this document.

A violation of the rules set forth in this document will subject the offending Contractor and/or
employee(s) to denial of entry to NWIBRT members' premises and projects.

The failure of a Contractor to comply with the provisions of this requirement (NWIBRT
Contractor Drug and Alcohol Policy) constitutes cause for cancellation of the contract.



SECTION II - GENERAL APPLICATION OF NWIBRT POLICY

    1. The manufacture, distribution, and dispensation, possession, sale or use of illegal drugs or
       alcohol on NWIBRT members' property, including parking lots and grounds or offices, or
       in other property owned, operated, leased, or under the control of NWIBRT members, is
       strictly prohibited.

    2. Drug paraphernalia are likewise prohibited from NWIBRT members' premises.

    3. Contractor employees, when reporting for work and while on the job and/or on NWIBRT
       members' property, are required to be fit for work and free from the effects of alcohol,
       illegal drugs, prescribed drugs and over-the-counter medications.

    4. A contractor employee taking prescribed drugs or over-the-counter medications is
       responsible for following the instructions provided by the prescribing physician,

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       pharmacist and the manufacturer of such medications.

   5. A contractor employee who tests positive for alcohol or drugs must be immediately
      removed from NWIBRT members' premises.

   6. Following a positive test result, reinstatement of an employee’s access privilege will be
      granted only after receipt of evidence that the employee has successfully completed a
      rehabilitation program under the recommendations of an Employee Assistance
      Counselor, and has subsequently submitted to a return-to-duty drug and/or alcohol test
      with a negative test result.

   7. All testing is required of all employees. No employee will be tested without his/her
      consent. A refusal to be tested is a violation of this policy. The consequences of a
      refusal to be tested are the same as the consequences for a positive test result.


SECTION III - DEFINITIONS

          Adulterated specimen means a specimen that contains a substance that is not expected to be
           present in human urine, or contains a substance expected to be present but is at a
           concentration so high that it is not consistent with human urine.
          Air blank means, in evidential breath testing devices (EBTs) using gas chromatography
           technology, a reading of the device's internal standard. In all other EBTs, a reading of ambient
           air containing no alcohol.
          Alcohol means the intoxicating agent in beverage alcohol, ethyl alcohol, or other low
           molecular weight alcohols including methyl and isopropyl alcohol.
          Alcohol concentration (or content) means the alcohol in a volume of breath
           expressed in terms of grams of alcohol per 210 liters of breath as indicated by an
           evidential breath test under this policy (BrAC).
          Alcohol confirmation test means a subsequent test using an EBT, following a screening test
           with a result of 0.04 or greater, which provides quantitative data about the alcohol
           concentration.
          Alcohol screening device (ASD) means a breath or saliva device, other than an EBT, that is
           approved by the National Highway Traffic Safety Administration (NHTSA) and placed on a
           Conforming Products List (CPL) for such devices.
          Alcohol screening test means an analytic procedure to determine whether an employee may
           have a prohibited concentration of alcohol in a breath or saliva specimen.
          Alcohol testing site means a place selected by the employer where employees present
           themselves for the purpose of providing breath or saliva for an alcohol test.
          Alcohol use means the drinking or swallowing of any beverage, liquid mixture or preparation
           (including any medication), containing alcohol.
          Applicant means a person, independent contractor or employer, or person working for an
           independent contractor or employer, who applies to become an employee of a NWIBRT
           Contractor/employer, and includes a person who has received a job offer made contingent on
           the person passing a drug test.
          Breath Alcohol Technician (BAT) is person who instructs and assists employees in the
           alcohol testing process and operates an evidential breath testing device.
          Canceled test means a drug or alcohol test that has a problem identified that cannot be or has
           not been corrected. A canceled test is neither a positive nor a negative test. A
           Contractor/employer will not take adverse job action based on a canceled test.


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   Chain of custody means the procedure used to document the handling of the urine specimen
    from the time the employee gives the specimen to the collector until the specimen is
    destroyed.
   Collection container means a container into which the employee urinates to provide the
    specimen for a drug test.
   Collection site means a place designated by a Contractor or an employer where individuals
    must present themselves for the purpose of providing a specimen of their urine to be analyzed
    for the presence of controlled substances, or for purposes of providing a saliva or breath
    sample to be analyzed for alcohol concentration.
   Collector means a person who instructs and assists employees at a collection site, who
    receives and makes an initial inspection of the specimen provided by those employees, and
    who initiates and completes necessary forms.
   Company property means all employer-owned and/or -leased property, including but not
    limited to owned and/or leased buildings and other real estate, parking lots and vehicles
    located on parking lots, and employer-owned and/or -leased vehicles, lockers, and desks.
   Confirmation (or confirmatory) drug test means a second analytical procedure performed
    on a urine specimen to identify and quantify the presence of a specific drug or drug
    metabolite.
   Confirmation (or confirmatory) validity test means a second test performed on a urine
    specimen to further support a validity test result.
   Confirmed drug test means a confirmation test result received by an MRO from a
    laboratory.
   Confirmatory test
           For alcohol testing, a confirmatory test is a second test following a screening test
            with a result of 0.02 or greater, conducted 15-30 minutes later, that provides
            quantitative data of alcohol concentration. This test is conducted on an EBT.
           For controlled substances testing, a confirmatory test is a second analytical
            procedure to identify the presence of a specific drug or metabolite. This
            confirmatory test is independent of the initial test and uses a different technique and
            chemical principle from that of the screening test in order to ensure reliability and
            accuracy.
   Controlled substances means marijuana (THC), cocaine, opiates, phencyclidine (PCP),
    amphetamines (including methamphetamines.), barbiturates, benzodiazepine, propoxyphene,
    methadone and Ecstasy.
   Designated Employer Representative (DER) means the Human Resource Manager, or
    Program Administrator, or similar designee of each employer who may receive test results
    and necessary communications related to this program, and who is authorized to take
    immediate action to remove employees from duty and to make required decisions in the
    testing and evaluation processes.
   DHHS means the Department of Health and Human Services. Many of DHHS’s standards
    and procedures related to drug and alcohol testing are mirrored in NWIBRT’s Drug and
    Alcohol Policy.
   DHHS-approved laboratory means a laboratory that is certified by the U.S. Department of
    Health and Human Services. Drug tests under this program will be performed by a DHHS-
    certified laboratory. In this policy, the terms “DHHS-approved” and “DHHS-certified” have
    the same meaning, and they may be used interchangeably.
   Dilute specimen means a specimen with creatinine and specific gravity values that are lower
    than expected for human urine.
   DOT means U.S. Department of Transportation. Many of DOT's standards and procedures
    related to drug and alcohol testing are mirrored in NWIBRT’s Drug and Alcohol Policy.

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   Drug test means a test conducted for controlled substances.
   Drugs mean the substances for which tests are required under this policy and include
    marijuana, cocaine, amphetamines, phencyclidine (PCP), opiates, barbiturates,
    benzodiazepine, propoxyphene, methadone, and Ecstasy.
   Employee means an employee of a Contractor/employer.
   Employee Assistance Program (EAP) Counselor means a masters-level professional with
    an education in psychology, social work, counseling, etc. with knowledge of and clinical
    experience in diagnosis and treatment of alcohol and controlled substance related disorders.
    The EAP will assess and make recommendations concerning education, treatment, follow-up
    testing and aftercare.
   Employer means a company, or a Contractor/employer participant.
   Evidential Breath Testing Device (EBT) means a device approved by NHTSA for the
    evidential testing of breath at 0.04 alcohol concentration, placed on NHTSA's Conforming
    Products List (CPL) for ”Evidential Breath Measurement Devices” and identified on the CPL
    as conforming with the model specifications available from NHTSA's Traffic Safety Program.
   Initial test (for drugs) means an immunoassay screen to eliminate negative urine specimens
    from further consideration.
   Initial validity test means the first test used to determine if a specimen is adulterated, diluted,
    or substituted.
   Invalid drug test means the result of a drug test for a urine specimen that contains an
    unidentified adulterant or an unidentified interfering substance, or which has abnormal
    physical characteristics, or which has an endogenous substance at an abnormal concentration
    that prevents the laboratory from completing or obtaining a valid drug test result.
   Laboratory means a U.S. laboratory certified by DHHS under the National Laboratory
    Certification Program as meeting the minimum standards of the DHHS Mandatory Guidelines
    for Federal Workplace Drug Testing Programs.
   Licensed medical practitioner means a person who is licensed, certified, and/or registered,
    in accordance with applicable Federal, State, local, or foreign laws and regulations, to
    prescribe controlled substances and other drugs.
   Medical Review Officer means a licensed physician with MRO certification who is
    responsible for receiving laboratory results generated by a drug testing program who has
    knowledge of substance abuse disorders and who has appropriate medical training to interpret
    and evaluate an individual’s confirmed positive test result together with his/her medical
    history and any other relevant biomedical information.
   Negative test result (drugs) means a laboratory conclusion that a drug or its metabolite was
    not detected in a specimen at or above acceptable levels.
   Observed collection means the observation by another individual during the urine collection.
    The “observer” must be the same gender as the donor. The observer must have been verbally
    instructed that he/she must watch the urine go from the donor’s body into the collection
    container.
   Positive Test (alcohol) occurs when an employee’s confirmatory test result reads 0.04%
    BrAC or higher.
   Positive Test (drug) occurs when an employee’s confirmatory test or retest result is at or
    above cutoff levels specified by DHHS, and has been verified by the MRO to be a positive
    test.
   Program Administrator means the individual who has administrative responsibilities for
    overseeing the drug and alcohol testing program for an employer. An employer’s Program
    Administrator may serve as that employer’s DER.
   Random selection means a scientifically valid method for selection of employees to be tested
    that results in an equal probability that any employee from a group of employees subject to

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    the selection mechanism will be selected, and does not give an employer discretion to waive
    the selection of any employee under the mechanism. Thus, an employee might be selected
    more than once during a year.
   Refuse to submit (to an alcohol or controlled substances test) means that an employee:
             Fails(ed) to appear for any test (except a pre-employment test) within a reasonable
             time, as determined by the employer after being directed to do so by the employer.
             Fails(ed) to remain at the testing site until the testing process is complete.
             Fails(ed) to provide a urine specimen for any drug test required by this policy.
             In the case of a directly observed or monitored collection in a drug test, fails to
             permit the observation or monitoring of the employee's provision of a specimen.
             Fails(ed) to provide a sufficient amount of urine or breath when directed, and it has
             been subsequently determined, through a required medical evaluation, that there was
             no acceptable medical explanation for the failure.
             Fails(ed) or declines to take a second test the employer or collector has directed the
             employee to take.
             Fails(ed) to undergo a medical examination or evaluation, as directed by the MRO as
             part of the verification process, or as directed by the DER. In the case of a pre-
             employment drug test, the employee is deemed to have refused to test on this basis
             only if the pre-employment test is conducted following a contingent offer of
             employment.
             Fails(ed) to cooperate with any part of the testing process (e.g., refuse to empty
             pockets when so directed by the collector, behaves in a confrontational way that
             disrupts the collection process, provides incorrect or inaccurate information to the
             collection site or on necessary forms, or fails to complete all documents).
             Provides a second specimen that is dilute.
   Screening test (or initial test) means:
             In drug testing, a test to eliminate negative urine specimens from further analysis or
             to identify a specimen that requires additional testing for the presence of drugs.
             In alcohol testing, an analytical procedure to determine whether an employee may
             have a prohibited concentration of alcohol in a breath or saliva specimen.
   Screening Test Technician (STT) means a person who instructs and assists employees in the
    alcohol testing process and operates an Alcohol Screening Device (ASD).
   Shipping container means a container that is used for transporting and protecting urine
    specimen bottles and associated documents from the collection site to the laboratory.
   Specimen bottle means the bottle that, after being sealed and labeled according to the
    procedures in this policy, is used to hold the urine specimen during transportation to the
    laboratory.
   Split specimen means a part of the urine specimen that is sent to a first laboratory and
    retained unopened, and which is transported to a second laboratory in the event that the
    employee requests that it be tested following a verified positive test of the primary specimen
    or a verified adulterated or substituted test result.
   Substituted specimen means a specimen with creatinine and specific gravity values that are
    so diminished that they are not consistent with human urine.
   Testing levels means levels at or above which a specimen is determined to be positive, and
    below which a specimen is determined to be negative.
   Verified test means a drug test result or validity testing result from a DHHS-certified
    laboratory that has undergone review and final determination by the MRO.


                                                                                                      5
SECTION IV – DRUG TESTING

A.       DRUG COLLECTIONS AND LABORATORY STANDARDS

The following standards apply to drug testing:

     1. Contractors will be responsible for ensuring that substituted or adulterated samples are
        not submitted.
     2. Contractors must use a DHHS-certified laboratory.
     3. Chain of custody protection will be applied to specimens collected from current
        employees and applicants.
     4. Contractors will use detection/confirmation levels no higher and no lower than those
        established by DHHS.
     5. Contractors who are subject to DOT drug and alcohol testing regulations must follow the
        federal regulations of the transportation mode that covers its employees.
     6. On an initial drug test, a test result below the cutoff concentration must be reported as
        negative. If the test result is at or above the cutoff concentration, the lab must conduct a
        confirmation test.
     7. On a confirmatory test, a test result below the cutoff concentration must be reported as
        negative. If the test result is at or above the cutoff concentration, the lab must report the
        test as a confirmed positive.
       Analyte                               Initial Screening            Confirmatory test
       Amphetamines                              500 ng/mL                     250 ng/mL
       Cocaine                                   150 ng/mL                     100 ng/mL
       Marijuana                                  50 ng/mL                      15 ng/mL
       Opiates (Codeine/Morphine)                2000 ng/mL                    2000 ng/mL
       6-Acetylmorphine (Heroine)                 10 ng/mL                      10 ng/mL
       Phencyclidine                              25 ng/mL                      25 ng/mL
       Barbiturates                              300 ng/mL                     200 ng/mL
       Benzodiazepines                           300 ng/mL                     200 ng/mL
       Methadone                                 300 ng/mL                     200 ng/mL
       Propoxyphene                              300 ng/mL                     200 ng/mL
       MDA-Analogues (Ecstasy)                   500 ng/mL                     250 ng/mL

B.       MEDICAL REVIEW OF TEST RESULTS

         A Medical Review Officer (MRO) will review all drug test positives prior to verification of
         positive test results. The MRO will review confirmed positive test results to ensure proper
         procedure, protocol, and reporting. The MRO will interview the individual who has a
         confirmed positive test result by telephone to investigate whether a legal prescription has
         caused the specimen to test positive. If the individual has no legal prescription, the MRO
         will report a verified positive to the Program Administrator.

C.       INSUFFICIENT SPECIMEN (DRUG TESTING)

         An employee who provides an insufficient specimen of urine for a required drug test must be
         examined by a medical professional, at the employee’s expense.



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         If the medical examination fails to identify a medical explanation for the employee’s
         inability to provide a specimen, the employee shall be considered to have refused to submit
         to a required drug test. If a medical explanation is identified, the drug test will be canceled
         and no further action will be taken.

         The MRO, in consultation with the medical professional, will order the medical exam, and
         will have the final authority in this determination.



SECTION V – ALCOHOL TESTING

A.       BREATH SAMPLING AND TESTING STANDARDS

     The following standards apply to alcohol testing

     1. Alcohol tests (screening and confirmatory) will be performed on a device that appears on
        the National Highway Traffic Safety Administration’s (NHTSA) Conforming Products
        List (CPL) and that meets the DOT’s testing requirements.
     2. When a specific time for an employee’s test has been scheduled, and the employee does
        not appear at the collection site at the scheduled time, the BAT will contact the DER,
        who may determine that the employee has refused to be tested.
     3. For alcohol testing (screening and confirmatory), a breath sample will be collected and
        analyzed by a Breath Alcohol Technician (BAT) using an Evidential Breath Testing
        device (EBT). For the screening test, a saliva or breath sample may be collected by the
        Screening Test Technician, using an Alcohol Screening Device (ASD).
     4. If the result of the screening test indicates an alcohol concentration of 0.02 or greater, a
        Breath Alcohol Technician (BAT) will perform a confirmatory test, no less than fifteen
        (15) and no more than thirty (30) minutes after the completion of the screening test.
     5. If the confirmatory test is positive (0.04 and above, BrAC), the Breath Alcohol
        Technician (BAT) shall immediately notify the employer’s DER.
     6. Results of additional tests arranged by an employee, or requested by a medical
        practitioner, will not be considered. This includes testing of blood samples, hair samples,
        DNA, or any other testing methods or protocols.

B.       INSUFFICIENT SPECIMEN (ALCOHOL TESTING)

         An employee who provides an insufficient specimen of saliva or breath for a required
         alcohol test must be examined by a medical professional, at the employee’s expense.

         If the medical examination fails to identify a medical explanation for the employee’s
         inability to provide a specimen, the employee shall be considered to have refused to submit
         to a required alcohol test. If a medical explanation is identified, the test will be canceled and
         no further action will be taken.

         The MRO, in consultation with the medical professional, will order the medical exam, and
         will have the final authority in this determination.




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SECTION VI – CONFIDENTIALITY

When a contractor, subcontractor or vendor conducts drug and alcohol testing of its employees
for the purpose of establishing eligibility to enter NWIBRT members' premises, such drug testing
results which are positive will not be disclosed to NWIBRT members. NWIBRT members
require, however, that contractors, subcontractors, and vendors certify that each employee
assigned to work on NWIBRT members' premises has passed a drug test that meets the standards
of this policy. Contractors must maintain records that validate compliance with this policy. Such
records shall be subject to independent audit by NWIBRT members (See Section IX).

The results of drug and alcohol tests conducted for-cause or for accident/incident investigations
as outlined below must be disclosed to local NWIBRT members upon request. Information
disclosed will be limited to whether a test was positive or negative, and if positive, for drugs
and/or alcohol. If positive for drugs, the drug will not be identified. Quantitations and levels will
not be disclosed.



SECTION VII – REQUIRED TESTING

Contractors are required to conduct drug and/or alcohol tests in the following situations:

A.      PRE-EMPLOYMENT / PRE-ACCESS TESTING.
        A contractor shall require a contractor employee/applicant who the contractor intends to
        hire or use on the premises of a NWIBRT member company to be drug tested and given
        an “available/clear for work” status before that employee may enter said premises.

        Exceptions:

        Contractors and contractors' employees who are contracted or hired on an EMERGENCY
        BASIS may be permitted to begin work onsite pending receipt of the results of Pre-
        Access drug testing. This permission will not extend beyond 3 business days from the
        first date after work starts by contractor.

        Any person working under this provision must be removed from the work site
        immediately upon receipt of a positive test result, or at the end of 3 business days if test
        results have not been reported.

        Contractors or vendors who need site access and who, in the sole judgment of a NWIBRT
        member company, pose a minimal safety risk, may be exempted from Pre-Access drug
        testing

        Validity Period of Pre-Access Tests

        A Pre-Access drug test must have been administered within 90 days immediately
        preceding access. This requirement may be waived by local NWIBRT members for
        persons who are regaining access after an absence of not more than 90 days or where in
        the sole judgment of NWIBRT members this requirement is satisfied through such other
        acceptable Pre-Access testing.

        NWIBRT members will recognize an employee’s drug test conducted while that
        employee worked for a different employer provided that (1) the test is conducted within

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     the 90-day period required of this policy; (2) the collection and laboratory procedures
     meet the standards set forth in this policy

B.   RANDOM TESTING
     (1)     A contractor shall be responsible for drug testing on a random basis those
     employees that are assigned to work on NWIBRT premises. A contractor employee must
     be randomly tested for drugs at least once every 24 months with no more than 24 hours
     notice prior to testing.

     (2)    The number of tests conducted under this section annually shall equal or exceed
     50% of the total qualified contractor workforce assigned to work on NWIBRT premises.

     (3)     An employee who has not been randomly tested in a two-year period will be
     required to take a Pre-Access test.

C.   FOR-CAUSE TESTING
     When a contractor has determined that there is reasonable basis to suspect alcohol or drug
     use, the contractor will require the employee to immediately submit to for-cause testing
     for both alcohol and drugs. An employee shall be considered unfit for work if the
     employee's physical or mental ability appears to be impaired or inconsistent with
     operating or safety procedures based on demonstrated judgment, performance, speech,
     body odor, attendance, declining job performance, actions or coordination.
      An employee who is required to submit to a for-cause test will be escorted to the
     collection site by the contractor. The employee will then be transported to his/her home
     by either the contractor or by a family member of the employee. The employee will not
     be permitted to return to work until negative test results have been received.

     (Note: In contracts that permit NWIBRT members to remove a contractor's employee for
     any reason, the contractor may do so without conducting a for-cause test.)

D.   POST-ACCIDENT / POST-INJURY TESTING
     When a contractor employee is involved in or has contributed to an accident involving
     mobile equipment or vehicles, potentially recordable injury, or property damage,
     knowingly or unknowingly, the contractor will require the employee to be immediately
     tested for drugs and alcohol.

     When a contractor employee is involved in or has contributed to an unsafe practice, the
     contractor may require the employee to be tested for drugs and alcohol.

     At the option of the contractor, an employee who has been tested under post-accident or
     post-injury may be suspended pending receipt of the test result. If a result is negative, the
     employee shall be compensated for all lost time. If the test result is positive, the
     employee will not be paid from the time of the accident.

     When an employee has been injured, priority must be given to the employee’s medical
     treatment before any consideration is given to collecting a specimen for testing.

E.   RETURN-TO-WORK TESTING
     An employee who has tested positive for drugs and/or alcohol, or who has refused to
     submit to a required test, must be cleared by his/her EAP Counselor in order to take a
     return-to-work test. A negative test result is required before an employee will returned to
     his/her job.


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F.       FOLLOW-UP TESTING
         Follow-up testing for drugs and alcohol is required after an employee has returned to
         his/her job following a positive test or a refusal to be tested. A follow-up testing plan
         will be recommended by the EAP Counselor. An employee is subject to follow-up
         testing for two years.



SECTION VIII – SEARCHES AND INSPECTIONS

NWIBRT members will continue to conduct unannounced searches of contractors,
subcontractors, vendors, and their employees, including their effects, lockers, baggage, desks,
tool boxes, lunch containers, clothing, and vehicles. The purpose of such searches is to ensure
compliance with this policy.

A contractor employee who refuses to submit to a search will have his/her access privileges
revoked.



SECTION IX - COMPLIANCE AUDITS

NWIBRT members reserve the right to periodically audit a contractor's records to verify
compliance with this policy. Such verification may include, but not be limited to:

     1. Examination of the contractor's drug and alcohol policy and its implementation of
        directives and procedures.
     2. Verification that drug and alcohol testing is being conducted in those situations which
        require it and that the testing meets the standards of this policy.
     3. Examination of chain of custody procedures that ensure integrity of collected specimens.
     4. Evaluation of laboratory services.

Audit results will be considered confidential.



SECTION X - SUBCONTRACTORS

In all cases where a contractor is permitted to employ a subcontractor, the contractor is
responsible for ensuring that the subcontractor and subcontractor's employees are in compliance
with this policy. Contracts between contractors and subcontractors must stipulate that NWIBRT
members reserve the right to audit subcontractors' drug and alcohol testing programs.



SECTION XI -NOTICE

The contractor must ensure that each of its employees and subcontractor employees is informed
of the provisions of this policy and of the contractor's substance abuse policy. Notice will include


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the consequences of failure to comply, and notice will be made prior to entering NWIBRT
members' premises.



SECTION XII - CONCLUSION

Consideration for work on NWIBRT members' premises will be conditioned upon contractor's
implementation of a policy that, in NWIBRT members' sole judgment, conforms to the minimum
standards expressed in this policy. Program development, implementation, administration, and
enforcement are the responsibility of the contractor.




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