Employee substance abuse program

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June 2011

ConocoPhillips Canada may revise this program at any time without prior notice.

Table of Contents



June 2011 1

Table of Contents 2

Appendix A - Testing Circumstances and Types 6

Appendix C 9

  1. Introduction

At ConocoPhillips, our objective is to create and maintain an operating environment free of any negative impacts associated with substance abuse. Everywhere the company does business, we seek to preserve a safe, healthy and productive work environment for employees. We believe that substance abuse increases the potential for accidents, absenteeism, substandard performance, and poor employee morale and health, as well as damage to the company’s reputation. ConocoPhillips Canada has developed and implemented this program in furtherance of ConocoPhillips Global Substance Abuse Policy - see Appendix C.

  1. Interpretation

Every effort has been made to develop an easy to understand program of general application. However, no program can anticipate every situation. If you have questions concerning the application of this program or require an explanation of any of its terms please contact your supervisor or contact your Human Resources Business Partner.

  1. Program Statement

While on duty or on call for duty or on a company worksite or while operating or while a passenger in a company vehicle*, ConocoPhillips Canada employees are prohibited from:

              1. Using, possessing or distributing any illegal drug;

              2. Being impaired by any illegal drug or a having a positive drug test result;

              3. Being impaired by alcohol or having an alcohol level equal to or in excess of 0.02 grams per 210 litres of breath;

              4. Consuming, possessing or distributing alcohol in unsealed containers except where such consumption, possession or distribution has been authorized in accordance with this program;

              5. Using, possessing or distributing any prescription drug, except in accordance with a prescription issued by an authorized medical practitioner;

              6. Using or possessing over the counter medicines except in accordance with the manufacturers’ or a medical practitioner’s dosage recommendations and usage cautions;

              7. Using, possessing or distributing any other intoxicant or hallucinogen, or other substances that may alter an individual’s mood, perception, coordination, response, performance or judgment;

              8. Using, possessing or distributing any illegal drug paraphernalia or any product or device that could be used to defeat a drug or alcohol test or tamper with any sample for an alcohol or drug test.

Those eight prohibitions are individually referred to in this program as a “Prohibition” and collectively as the “Prohibitions”.

In this program, the term “illegal drug” means any substance or chemical the possession of which is prohibited under the Controlled Drugs and Substances Act, Canada. A drug will not be considered to be an illegal drug in circumstances authorized in accordance with that Act. Illegal drugs include but are not limited to: cannabis (marijuana, THC) cocaine, opium, amphetamines and phencyclidine.


* Company vehicle includes any vehicle supplied by the company (whether or not owned by the company) and any vehicle used by an employee in conjunction with work for the company and may include the employee’s own vehicle.

Company Sponsored Events

Employees of ConocoPhillips Canada are subject to all of the Prohibitions while attending or participating in company sponsored events. However, a member of the Canadian Leadership Team may modify the Prohibitions concerning alcohol for the duration of a company sponsored event. Employees are expected to act responsibly at all company sponsored events and limit their consumption of alcohol accordingly. Company sponsored events include all events, that have been sanctioned, sponsored or paid for by the Company, regardless of whether the event takes place during regular working hours, or not. Under no circumstances will the use of illegal drugs be permitted or condoned at company sponsored events. No one should ever drive a motor vehicle to or from a company sponsored event while impaired by alcohol or having a blood alcohol level in excess of the legal limit.

Prescription / Over the Counter Drugs

Employees must ensure that their use of prescription drugs and over the counter medications will not unduly impact their ability to work safely. Employees who are aware that their ability to work safely may be adversely impacted by prescription or over the counter drugs must advise their supervisor. HR Connections is available to answer questions regarding the potential work-related impact of over-the-counter or prescription medications.

  1. Supervisor Responsibilities

It is the responsibility of every supervisor to ensure that this program is followed and enforced within their areas of responsibility. Supervisors must ensure that the employees they supervise are aware of, understand and follow this program.

No supervisor having actual knowledge that any worker is consuming alcohol, a drug or any other intoxicant, hallucinogen or other substances that may alter an individual’s mood, perception, coordination, response, performance or judgment, while performing a Safety Sensitive Position (Safety Sensitive Positions are described in Appendix B), shall permit that worker to continue to perform his or her duties.

A supervisor who has reasonable grounds for believing that a worker is impaired by alcohol, drug or other substance must remove that worker from duty immediately. Refer to Appendix A.

No supervisor shall permit an employee who refuses to undergo drug and alcohol testing when required to do so in accordance with this program to perform or continue to perform in a Safety Sensitive Position.

A supervisor, who has reason to believe that an employee may have a substance abuse problem, must consult with the Human Resources Business Partner and/or Team Lead Integrated Health to determine an appropriate course of action.

In discharging responsibilities under this program, supervisors must take all reasonable steps to ensure that information concerning an individual worker is maintained in confidence.

  1. Enforcement

ConocoPhillips Canada will conduct drug and alcohol testing in accordance with Appendix A.

Employees who do not comply with the Prohibitions or any other aspect of this program, without reasonable excuse, will face disciplinary action which may include termination for cause.

No employee may refuse a request for a drug and alcohol test made in accordance with this program. Any employee who refuses to submit to a required test or who switches, tampers with or attempts to tamper with a test sample or obstructs the testing process will be relieved of his or her duties, may be potentially referred to a substance abuse expert for assessment and will face disciplinary action.

Employees who enter the rehabilitation stream and test positive during a follow-up test, will be terminated for cause.

  1. Support for ConocoPhillips Canada Employees

ConocoPhillips Canada will support all of its employees in their efforts to comply with the above Prohibitions and this program by:

    1. Providing mandatory training to all employees on the consequences of program violation, resources available for employee assistance services and testing procedures;

    2. Providing confidential employee assistance and counseling services through the company provided Employee and Family Assistance Program (“EFAP”);

    3. Assisting employees seeking to overcome substance abuse problems with locating substance abuse experts and treatment programs;

    4. Providing accommodative work schedules and job structures for employees seeking to overcome substance abuse problems;

    5. Ensuring that employee information is treated confidentially; and

    6. Making the policy and this program document available to all employees

Voluntary Disclosure

Any employee who wishes to disclose a substance abuse problem may advise his or her supervisor or Human Resources Business Partner, or the Human Resources, Team Lead - Integrated Health.

An employee who voluntarily discloses after having been involved in an incident or having been requested to submit to an alcohol or drug test will be subject to discipline only if (a) the substance abuse expert concludes that the employee is not suffering from a dependency; or (b) the employee does not follow the recommendations of the substance abuse expert or fails to complete a prescribed treatment program, having been given a reasonable opportunity to do so.
Prospective Employees

As part of the pre-employment screening and as a pre-condition to employment ConocoPhillips Canada will require all prospective employees, to be engaged in a Safety Sensitive Position, to undergo a drug test.

Any prospective employee whose offer of employment is withdrawn due to failure to successfully pass a drug test will be permitted to re-apply for employment with ConocoPhillips Canada.

Appendix A - Testing Circumstances and Types

ConocoPhillips Canada will conduct drug and alcohol testing only in the following circumstances:
1. Pre-Employment
ConocoPhillips Canada will require that anyone offered employment in a Safety Sensitive Position will be tested for the presence of the following drugs: cannabinoids, amphetamines, cocaine, opiates, and phencyclidine.
2. Pre-Site Access
A manager or supervisor, with the documented concurrence of a General Manager, HSE may implement a protocol whereby all employees and employees of contractors working in Safety Sensitive Positions at a particular work site are required to undergo drug and alcohol testing of employees and contractors prior to being granted access to any field work site. The protocol may include a requirement for periodic maintenance testing (as per individual site requirements). Where a contractor provides satisfactory evidence that a worker has tested negative for drugs and alcohol within the previous 12 months, ConocoPhillips Canada will not require that worker to undergo site-access testing.
3. Post-Incident

If, following a preliminary investigation, an employee’s manager or supervisor, (or any other, more senior manager) has a reasonable belief that substance use may have been a contributing factor to any incident, the supervisor or manager, with the documented concurrence of a General Manager, HSE may require that any employee involved in a significant incident or near miss, such as a fatality, disabling injury or a high potential near miss undergo a drug and alcohol test as soon as possible.

4. Reasonable Grounds
If a supervisor believes the employee is in a condition unfit for normal work, the supervisor may take any of the following actions:

  • the employee will be escorted by a supervisor to a safe/private place, interviewed, and given an opportunity to explain why they appear to be in a condition unfit for work.

  • referral for medical attention if there are obvious immediate medical concerns (health center, local hospital or clinic); or

  • referral for an alcohol and drug test if there are reasonable grounds to believe alcohol or drug use may be a factor in the situation after appropriate consultation with Human Resources Business Partner and HSE.

5. Random Alcohol and Drug Testing

Random drug and alcohol testing (25%) for Safety Sensitive employees only.

6. Return to Duty and Follow-up Testing

An employee who is returning to work following a suspension of leave from duty as a result of having tested positive for drugs or alcohol or having been referred to a substance abuse expert and with the recommendation of the substance abuse expert, must successfully pass a drug and alcohol test, before being returned to active duty. Thereafter the employee may be subject to follow up testing at the frequency and for the duration determined by the Human Resources, Team Lead Integrated Health, having regard to the recommendation of a substance abuse expert.
Other Testing Considerations

ConocoPhillips will allow employees to discuss test results and the circumstances thereof with the Medical Review Officer, and to have split-samples re-tested by the laboratory engaged by ConocoPhillips Canada or by a certified laboratory of their choosing.

Failure to report for a test, refusal to submit to a test, refusal to agree to disclosure of a test result to the Company Program Administrator, an attempt to tamper with a test sample, inability to provide sufficient quantities of breath, urine or to be tested without a valid medical explanation acceptable to ConocoPhillips, will be considered a positive test result.
Appendix B - Safety Sensitive Positions
A position will be considered to be a Safety Sensitive Position when the position involves:

  1. driving a vehicle, more than “occasionally”;

  2. operating mechanical equipment;

  3. oil and gas field operations or construction, including the direct supervision thereof (including, supervision exclusively from the office);

  4. being on call or on duty for an emergency response position, more than “occasionally”;

or if the position has been permanently or temporarily declared to be a Safety Sensitive Position by a member of the Canadian Leadership Team, having regard to the Guide for Identifying Safety Sensitive Positions as per the Enform Model.

Appendix C

Global Substance Abuse Policy

Canada Addendum to the ConocoPhillips Global Substance Abuse Policy
ConocoPhillips Canada will comply with all aspects of the ConocoPhillips Global Substance Abuse Policy except for the provisions below, due to Canadian legal restrictions.

  • Random alcohol and drug testing will be limited to safety sensitive employees only

  • Periodic alcohol and drug testing will be limited to safety sensitive employees only

  • Pre-employment drug testing of applicants will be limited to applicants of safety sensitive positions only

  • Alcohol and drug testing for reasonable grounds will be limited to safety sensitive employees only

  • ConocoPhillips Canada will automatically terminate the employment of first time offenders where that termination is consistent with Canadian case law and regulatory decisions. Employees who are not terminated will be subject to other disciplinary action as is appropriate in the circumstances or required to undertake a program of rehabilitation.

At ConocoPhillips our work is never so urgent that we cannot take the time to do it safely and in an environmentally prudent manner.”

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