SUBSTANCE MISUSE CONTROL PROCEDURE

Table of Contents

1.0 OBJECTIVE 4

2.0 LINKAGE WITH OTHER PROCEDURES AND STANDARDS 4

3.0 DEFINITIONS AND TERMINOLOGIES 4

4.0 ROLES & RESPONSIBILITIES 5

5.0 STANDARD STATEMENT 6

6.0 TRAINING 7
7.0 SELF-REFERRAL 7
8.0 INSPECTIONS 7

9.0 PROHIBITED SUBSTANCE TESTING 7

10.0 RESULTS 9

11.0 DISCIPLINE 9

APPENDICES

Appendix-I Process summary for risk based random drug testing program 10

Appendix-II Random drug testing program for Professional Drivers 11

Appendix-III Risk based random drug testing program 13

Appendix-IV Training Needs Analysis 15

Appendix-V Self-Assurance Certificate 15

Page 1 of 12
1.0 OBJECTIVE

The Company is committed to provide a safe and healthy workplace that enables
individuals to perform at their best. Consistent with this commitment, the Company
has developed this Procedure regarding substance misuse and its effect on
workplace with an objective to establish and maintain a work environment that is free
from the adverse effects of drugs and alcohol.

2.0 LINKAGE WITH OTHER PROCEDURES AND STANDARDS

This document has linkages with the following procedures, rules, standards and
regulations:

a) Consolidated Mines Rules, 1952

3.0 DEFINITIONS AND TERMINOLOGIES

Prohibited Means drugs and alcohol.

Substances
Alcohol Means ethyl alcohol or ethanol and alcoholic beverages of any
kind.
Drugs Means any substance taken into the body, other than alcohol,
which may impair one’s mental faculties and/or physical
performance and include all forms of the following:
- Narcotics
- Hallucinogens
- Depressants
- Anti-Depressants
- Stimulants
- Other drugs whose possession or transfer is restricted by
the law.
Company Means all persons who work full time, part time, or under
Employees contract with the Company.
Individuals Means and includes Company Employees, Contractors,
consultants, their workforce and individuals working with the
Company at Company Premises and shall include visitors.
Company Premises means Company’s workplaces including without limitation
offices, warehouses, yards, wells, fields, camps, facilities,
vehicles, and all other workplaces controlled by the Company
but shall not include Company Staff houses.
Contractor a person or business which performs services for the Company
pursuant to a contract and includes the Contractor’s sub-
contractors, employees, agents and consultants.

4.0 ROLES & RESPONSIBILITIES

4.1 Line Managers/TLs/Supervisors / Designated UEP Representatives

 Ensure this procedure is correctly implemented in their area of responsibility.

4.2 Occupational Health Advisor / Designate

  Provide advice and support to field and office staff and other relevant personnel
in all matters concerning drug and alcohol misuse, screening, tests and
treatment.
 Provide assurance that this procedure is being correctly implemented. Use KPIs
and dashboards as tools to gauge its compliance.

4.3 Field Health Staff

 Liaise as necessary with the OH Advisor in all matters concerning drug and
alcohol misuse, screening, tests and treatment.

4.4 Field HSE Advisor

 Provide assistance and support to the Line Managers/TLs/Supervisors and field

health staff in the correct implementation of this procedure.

4.5 HSE Manager

 Ensure competent persons review the procedure at appropriate intervals.

 Provide timely advice, support and assistance to the Line Managers / TLs /
Supervisors and other relevant personnel in implementation of this procedure.

4.6 Head of HR

 Provide timely advice, support and assistance to Line Managers / TLs /

Supervisors and other relevant personnel in the implementation of this
procedure.
 Ensure HR disciplinary policy/procedures are invoked or operated whenever
required by this Procedure.

4.7 Employees

 Comply with this Procedure as part of their conditions of employment or contract

terms.
 Inform their immediate line manager/TL/supervisor, of the use of any medications
that may:
o Cause drowsiness or other side effects and/or
o Impair the employee’s ability to carry out his / her job function safely.
 Comply with searches of belongings and give reasonable permission to accept
body searches, if required.
 Report any breach of this Procedure by other persons to their supervisor or
management.

5.0 STANDARD STATEMENT

(a) No individual shall acquire, distribute, dispense, possess or use Prohibited

Substances while on the job or at Company Premises.

(b) No individual shall report to work, be on the job or be at the Company’s

premises under the influence of Prohibited Substances.

(c) The test results for prohibited substances should not exceed the cut off level
for that particular substance.
 (d) The Company reserves the right to report known illegal activity at its premises
to law enforcement authorities.

5.1 To ensure that all Company Premises are free from Prohibited Substances; all
Company Employees / Contractor and Contractor’s employees working at the
Company Premises shall abide by the following:

 Use, possession, transportation or sale of narcotics, illegal drugs, or drug

paraphernalia is prohibited while on duty or on Company’s Premises or in any
of the Company’s or its Contractor’s vehicles. The only exception shall be
for properly used prescription medication prescribed by a licensed
physician.
 Use, possession, transportation or sale of alcohol or intoxicating beverages is
prohibited while on the Company’s Premises or any jobsite or in any of the
Company’s or its Contractor’s vehicles.
 The Company reserves the right to perform biological testing on individuals for
Prohibited Substances whenever deemed necessary for which the individual
should extend the Company complete cooperation.
 Any Company Employee working at the Company’s premises, found engaged in
any of the prohibited activities set forth in this procedure, will be subjected to
disciplinary action which may lead to termination of employment / contract
and / or removal from the Company’s Premises in accordance with the
Company’s Disciplinary Policy and applicable laws, rules and regulations.
 In the event any Contractor working at the Company’s Premises or jobsite or in
any of the Company’s or Contractor’s vehicles is found engaged in any of the
prohibited activities set forth in this procedure, the Company shall reserve the
right to forthwith terminate the Contract to the complete risk and loss of the
Contractor. The Company may also request the Contractor to remove from
the Company’s premises any such Contractor’s employee found to be
involved in such prohibited activities. The Contractor shall take immediate
disciplinary action against such employee in accordance with applicable laws,
rules and regulations.
6.0 TRAINING

All Company Employees and Contractors will be informed about the risk of using
Prohibited Substances. The Company will provide to selected employees working in
a supervisory role adequate training, for them to be able to identify signs indicating
the usage of Prohibited Substances and the manner and appropriateness of carrying
out suspicion testing. All Company Employees will receive appropriate substance
misuse awareness education as well as information concerning their obligations
under this Procedure.

7.0 SELF-REFERRAL

Substance misuse impacts individual’s health and safety. The Company encourages
its employees to utilize the benefits and resources available to gain the assistance
they may need for substance misuse problems including, as available, self-referral
for assessment.

8.0 INSPECTIONS

The OH Advisor / Designate will conduct inspections to ensure compliance with this
Procedure. Inspections will be conducted without any prior announcement.
Inspections of an individual's personal effects will be conducted in the presence of
the relevant individual save and except under unavoidable circumstances. Entry in
any Company Premises is deemed consent to an inspection that may include, but is
not limited to, person, vehicle, and personal effects at any time while entering, on, or
leaving the Company Premises.

Company Employees who refuse to cooperate with Company inspections without

reasonable excuse may be suspended from service pending an enquiry to determine
misconduct. In the event the employee is found guilty of misconduct as defined under
the relevant laws, he/she shall be subject to disciplinary action in accordance with
law and the Company’s disciplinary policy. Other individuals who are not Company
employees and who refuse to cooperate with Company inspections shall be removed
from Company Premises immediately.

9.0 PROHIBITED SUBSTANCE TESTING

The Company will conduct individual testing as required by federal or provincial/local

law. In addition to testing mandated by law and as allowed by law, in accordance
with this Procedure, the Company may conduct the following types of testing:

 Reasonable Cause testing

 Post-accident/incident testing
 Random testing

Except as otherwise stated, all Prohibited Substance testing will be conducted using
collection, documentation, chain-of-custody and testing methods. On-site screening
devices (such as Point of Collection Screening Devices) approved by HSE
Department may be utilized in addition to or in lieu of more traditional specimen
collection or screening.
(a) Reasonable Cause Testing
 When the Company through specific, objective and articulate facts and reasonable
inferences has reason to believe that an individual is using or has used drugs or
alcohol in violation of this Procedure, the Company will require the individuals to
submit to a fitness evaluation and a Prohibited Substance test. The individual will be
temporarily removed from his/her position pending receipt of test results.

(b) Post-Accident/Incident Testing

Following a non-minor work-related accident/incident/near-miss, the individuals

involved in the accident/incident shall submit himself/herself to Prohibited Substance
testing when such individual's conduct either contributed, or may have contributed to
the accident/incident. Breath testing for alcohol (if required) will be done immediately
and testing for other Prohibited Substances within 12 hours of the accident/incident.
Delayed testing may be considered for drugs only, if circumstances exist which do
not allow for testing within these timeframes. The individual will be temporarily
removed from his/her position until the test results are complete.

(c) Random Testing

The Company may implement random testing provided circumstances warranting

random testing occur. The random testing selection process will be administered
using a selection procedure accepted in the statistical and epidemiological
communities.

The modalities for testing are elaborated as follows:

i) Process summary for risk based random drug testing program for
employees and contractors – to inculcate high level understating of the end
users (Appendix-I).
ii) Random drug testing program for contractual professional drivers and heavy
equipment operators at UEP (Appendix-II).
iii) Risk based random drug testing of UEP employees and contractors
(Appendix-III).

(d) Confidentiality of Test Results

Test results and related information shall not be released to anyone other than
OH Advisor, Field health staff, Manager HSE, HR Head / Manager, Designated UEP
representative and the individuals itself unless: (1) the individual or applicant
requests, in writing, that the Company release the information to another party, (2)
the Company reserves the right to disclose the information to any authority or body
under the law or under the orders by a court of competent jurisdiction.

10.0 RESULTS

 An employee with a positive result of the use of Prohibited Substances shall be

suspended for an appropriate period (minimum 45 days). He will be referred for
further evaluation, treatment and rehabilitation via company’s employee
assistance program (EAP) if required. The employee shall submit for re-testing
 (one-time only) prior to resuming duty which re-test can only take place at-least
45 days after the initial positive test.
 A contractor with a positive result of the use of Prohibited Substances shall be
suspended for an appropriate period (minimum 45 days). The contractor
employee shall submit for re-testing (one-time only) prior to resuming duty, in
such cases re-test can only take place at-least 45 days after the initial positive
test. Furthermore, the contractor shall give assurance in writing that individual
has been completely rehabilitated before re-joining duties.
 In the event that a re-test gives a positive result, the Company reserves the right
to initiate disciplinary proceedings against Company Employees in accordance
with the Company’s Disciplinary Policy. Where the individual is a contractor
employee, the Company reserves the right to request the Contractor to
permanently remove such Contractor employee from Company Premises and
take disciplinary action against such Contractor if deemed appropriate.
 Subsequent to re-joining work, the Company may carry out/ cause the
Contractor to carry out regular monthly random testing of the individual up-to one
year as per drug testing program.

11.0 DISCIPLINE

Violation of this Procedure by a Company Employee shall be considered as

“misconduct” as defined under the relevant law and shall be subject to appropriate
disciplinary action in accordance with the law and the Company’s Disciplinary Policy.

Violation of this Procedure by a Contractor, consultant or any other individual will be

considered as breach of the applicable contract and the Company shall reserve the
right to remove the individual from Company Premises forthwith and terminate the
applicable contract without notice or compensation of whatsoever nature.
Appendix-I: Process summary for risk based random drug testing program for
employees and contractors

Process Summary - Risk based random Drug testing of UEP Employees & Contractors
Representative
/ Contractor

Step 1: Organize End

Designated

Ensure
monthly random sampling
UEP

testing of target
poupulation.
ADVISOR
UEP-OH

Step 7: Maintain Drug

& Alcohol Program.
HR / PSCM

Step 6: Coordinate action

as per company
/Contract
Sponsor

disciplinary policy.

Step 2: Employee Step 4:

Contractor
Employee,

Doctors / Lab OR Visitor

or contractor to Refer for

YES medical
submit for
evaluatio
YES
n&
treatmen
NO
t. Retest
Collectors

Step 3: Conduct tests

(Ziauddin
3rd Party

Negative after 45 Step 5:

Techs)

NO
& report results in Result? Restest
days Follow-up
(min). +ve?
testing for
upto 1 year.

Appendix-II: Random drug testing program for contractual professional drivers and
heavy equipment operators at UEP
IIA) Random drug testing program for professional drivers at field operations (Badin & MKK)
and Offices (Step by step guide):
 Recommended KPI is 25% (min) per annum tested over a period of 12 months.
 The testing frequency should be at-least once a month.
 Drugs: Urinary Opiates, Urinary Cannabinoids. Alcohol / Other substances as per requirement.
 Recommended labs: Aga Khan Hospital Labs, Ziauddin Hospital Labs; or any other lab
approved by UEP, Drug testing kits can only be used with prior approval of OH Advisor.
 The Designated UEP Representatives will be responsible for organizing Random Drug Testing.
The details are as follows:

Field Manager, Badin / Designate Professional Drivers at Badin

Field Manager, MKK / Designate Professional Drivers at MKK

Manager / TL Transport / Designate Professional Drivers at Karachi Office

Manager Administration Professional Drivers at Islamabad Office

Logistics Team Leader Professional Drivers at Crude Haulage

Contractors
Head of Drilling / Designate Professional Drivers at Drilling Contractors

Respective CAM / OH Advisor / Professional Drivers at LV Contractors (KTS, STN

Transport Advisor / Designate etc.), Others
 The Designated UEP Representatives at Badin/ MKK shall be overall responsible for organizing
the testing program.
 He will constitute a facilitation team comprising Admin TL / respective Contract Sponsor /field
doctor / OH Advisor, others (if required) who will execute the program and keep him apprised of
all developments. The team will be responsible for the random selection process, sample
collection and technical support etc.
 Similar facilitation teams may be formed by other designated representatives to carry out
random drug testing at their area of responsibility.
 The facilitation team will randomly pick a date for testing every month which will be kept
confidential.
 Selection of individuals for testing will be done by a transparent process of random selection
through reliable software, balloting, etc. Moreover, picking and choosing suspicious cases
constitutes ‘Reasonable Cause Testing’ not random testing.
 On the day of testing; the randomly selected individual will be asked in confidence to report to
respective field clinic or designated lab for sampling immediately, unless there is a valid reason.
 The sample will be collected; sealed in an envelope countersigned by the concerned Field
Doctor / designate and delivered in a secure manner to the designated lab through UEP Admin.
 In-case an individual has a positive drug test performed by a testing kit then confirmatory urine
sample for that particular drug shall be sent to designated lab immediately.
 The test reports will be collected by concerned Field Doctor / OH Advisor.
 The test records and data-base will be maintained at respective field clinics / suitable location in
confidence.
 The test results will be communicated in confidence to the Designated UEP representative /
Field Manager / HSE Manager / Head of HR /concerned TL / Contract Sponsor/ MCAM / the
individual tested as per requirement.
 All information related to drug testing will be kept confidential by the individual involved in
random testing program.
 Disciplinary action shall be taken for drivers testing positive in-line with UEP’s Substance Misuse
Control Procedure and regulatory requirements (refer to sections 10 & 11).
IIB) – Random Drug Testing Program for Professional Drivers at Crude Haulage, LPG
Bowzers, Drilling Contractors & Others (Step by step guide):

The crude haulage, drilling and other contractors shall adopt a substance misuse and random drug
testing procedure which is equivalent to UEP standards. The concerned contractors shall be responsible
to arrange all necessary logistics, bear the expenses for testing, maintaining the records, communicating
the results, assuming responsibility for quality of testing, outcomes and disciplinary action in accordance
with UEP’s policies, procedures, contractual obligations and regulatory requirements. The progress will
be monitored through Contractor Performance Management (CPM) and Random Audits.

Annual Random Drug Testing Program (KPI) for Contractual Professional Drivers -
(Minimum 25% Drivers / Annum)
Total Random
Random
no. of Tests
S. No. Contractors Name Tests per Remarks
drivers required
year
* per month
Rajput, Abdullah
Contractual Professional
1 90 2 24 Rahoo, Khamiso
Drivers - Badin
Khan, Halepota etc.
Contractual Professional Waryah, Usman
2 26 1 12
Drivers - MKK Ghani etc.
UEP Karachi / ISB
3 21 1 12 UEP, Peoples etc.
drivers
4 Shah Transport Network 77 2 24
Khyber Transport
5 22 1 12
Service
6 Shakoor & Co 128 3 36
Shaheen Freight
7 76 2 24
Services
8 JSL 72 2 24
9 BSL 180 4 48
10 Crescent Syndicate 56 1 12
Total Drivers 748 19 228
25%
Random
Testing
KPI Note: *These numbers are subject to change & have been demonstrated as a
guideline.

Appendix-III: Risk based random drug testing of UEP Employees and Contractors
(Step by step guide)

 Recommended KPI is 15% (min) per annum tested over a period of 12 months.
 The testing frequency should be at-least once a month.
 Drugs: Urinary Opiates, Urinary Cannabinoids. Alcohol / Other substances as per requirement.
 Recommended labs: Aga Khan Hospital Labs, Ziauddin Hospital Labs; or any other lab
approved by UEP, Drug testing kits can only be used with prior approval of OH Advisor.

The Designated UEP Representatives will be responsible for organizing random drug testing as
follows:
 Field Manager, Badin / Designate UEP Employees & Contractors at Field
Operations, Badin.
Field Manager, MKK / Designate UEP Employees & Contractors at Field
Operations, MKK
Head of Drilling / Designate Rigs and Drilling Contractors
Head of Management Services / Designate UEP Employees and Contractors at Karachi
Office

 The Designated UEP Representative shall be overall responsible for organizing the testing
program at their respective locations.
 He will constitute a facilitation team comprising Admin TL / respective Contract Sponsor / field
doctor / OH Advisor, others (if required) who will execute the program and keep him apprised of
all developments. The team will be responsible for the random selection process, sample
collection and technical support etc.
 Similar facilitation teams may be formed by other designated representatives to carry out
random drug testing at their area of responsibility.
 The facilitation team will randomly pick a date for testing every month which will be kept
confidential.
 The selection of sample population for random testing at field will be risk based i.e. individuals
operating machine / driving like Production Operators, Maintenance Technicians or labor at
production facilities or construction sites, etc. Likewise, random drug testing at Karachi and
Islamabad Offices will also be risk based i.e. UEP and contractual professional drivers, etc.
 Selection of individuals for testing will be done by a transparent process of random selection
through reliable software, balloting, etc. Moreover, picking and choosing suspicious cases
constitutes ‘Reasonable Cause Testing’ not random testing.
 On the day of testing; the randomly selected individual will be asked in confidence to report to
respective field clinic or designated lab for sampling immediately, unless there is a valid reason.
 The sample will be collected; sealed in an envelope countersigned by the concerned Field
Doctor / designate and delivered in a secure manner to the designated lab through UEP Admin.
 In-case an individual has a positive drug test performed by a testing kit then confirmatory urine
sample for that particular drug shall be sent to designated lab immediately.
 The test reports will be collected by concerned Field Doctor / OH Advisor.
 The test records and data-base will be maintained at respective field clinics / suitable location in
confidence.
 The test results will be communicated in confidence to the Designated UEP representative /
Field Manager / HSE Manager / Head of HR /concerned TL / Contract Sponsor/ MCAM / the
individual tested as per requirement.
 All information related to drug testing will be kept confidential by the individual involved in
random testing program.
 The designated UEP representative shall refer positive drug test cases of UEP Employees to
Head of HR for disciplinary action as per company policy (refer to sections 10 & 11).
 The cases of contractors testing positive shall be handled by designated UEP representative,
respective Contract Sponsor / MCAM and PSCM as per Company Procedures, contractual and
regulatory requirements (refer to sections 10 & 11).
 UEP shall take all appropriate measures to ensure compliance with substance misuse control
procedure including random testing by contractors and sub-contractors in-line with Company,
contractual and regulatory requirements. Necessary amendments should be incorporated in
contracts with respect to compliance, monitoring, disciplinary actions etc. The contractors shall
implement a substance misuse program which is equivalent to UEP standards. The respective
contractors shall be responsible to arrange all necessary logistics, bear the expenses for testing,
maintain the records, communicate the results, assuming responsibility for authenticity and
quality of testing, outcomes and disciplinary action in accordance with UEP’s policies,
procedures, contractual obligations and regulatory requirements. The progress will be monitored
through Contractor Performance Management (CPM) and Random Audit.
 United Energy Pakistan Limited

Rev. No.
SUBSTANCE MISUSE CONTROL PROCEDURE
03

Appendix-IV: Training Needs Analysis

Designation Refresher Training

Training Need Assurance
Required Method
Field Health Thorough understanding of Three yearly or Reading & Signing off of
Staff/HR Staff Substance Misuse Control whenever the discussing the self-assurance
Procedure. procedure gets Substance Misuse certificate.
Should be able to provide revised Control Procedure
guidance to the with HSEA-OH (if
teams/contractors on all required)
aspects of Substance
Misuse and clarify any
confusion

Line High level understanding of Three yearly or Email Notification / GCM/ Email
Managers/TLs/Su Substance Misuse Control whenever the Reading & Notification
pervisors/CAM
Procedure procedure gets discussing the /SOC/Safe
revised Substance Misuse Card record on
Control Procedure Substance
with HSEA-OH, Misuse Control
Field Health Staff Procedure
and HR staff (if
required)

Employees / Adequate understanding of Three yearly or Email Notification / Email

Contractors drug testing program whenever the Awareness Notification /
procedure gets sessions by HR GCM record on
revised and Field Health Substance
staff Misuse Control
Procedure

Appendix-V: Self Assurance Certificate (sample)

I (name of individual) have thoroughly read and understood the Substance Misuse Control

Procedure on Date…...

Signature ……………………….

HSE-HLT-000-IN-
Document No. Issue Date: July 2018 Page 12 of 12
PRO-00005-03