Dow Freeport contractor substance abuse policy

Significant revisions
Added verbiage and clarification to the pre-employment and preaccess exception B.1.a:
….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.
Added to Policy section C:
…….Additional testing for Look-Alikes and Designer or Synthetic
drugs will be used when necessary.
Added the following statements:
Post incident drug testing is required for all incidents
unless Dow Contractor EH&S agrees there is no
indication that the contractor employee’s action/inaction
contributed to the incident.
 Additional testing for Look-Alikes and Designer or
Synthetic drugs may also be required at the discretion of
Dow or the Contractor Company supervision.
 Positive drug test results MUST be reviewed by a Medical
Review Officer (MRO).
 …….Contractor company must notify Dow Security of a
“failure to comply” as per the Contractor/Sub Contractor
Badgeing Process.
Added section titled “Reporting and
All Contractor employees are expected to be
registered and demarcated as working Dow Freeport
Operations in the VECTOR database maintained by
Report must be sent monthly indicating:
 monthly employee headcount
 Number of individuals drug tested
 Number of non-compliances
Reporting is to be made through the Dow Contractor
EH&S functional mailbox at [email protected]
Added section titled “Re-Test on Prescriptions”:
Dow Texas Operations is defined as a safety
sensitive environment.
Medical Review Officers (MRO) are required to
retest positives using urinalysis for workers that
could cause impairment, once the course of
treatment is completed, before reporting a negative
The MRO may also implement a restriction as
applicable to the situation.
Added section titled “Medical Review Officer
All positive drug test results must be evaluated by a
qualified MRO.
 Defined “qualified MRO”.
 The MRO may also implement a restriction as
applicable to the situation.
 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.
Dow Freeport is a safety sensitive environment
and it is critical that workers are not impaired
when working here – for their safety and the safety
of their co-workers
Dow Freeport requires post-incident drug testing
Testing for synthetic drugs may also now be
A Medical Review Officer (MRO) is required to
review all positive tests
A confirmed positive substance abuse test will
result in restriction from the site for a minimum of
365 days

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