The Whiting-Turner Contracting Company

Drug and Alcohol Free Workplace Program

Prepared for

The Whiting-Turner Contracting Company

Prepared by

Douglas Joseph

Terry Smith

TECM 2700.001

02 May 2014

Table of Contents iii

Table of Contents Table of Contents ........................................................................................................................... iii

Introduction ................................................................................................................................... vii

Policy on Drugs and Alcohol ........................................................................................................ 3

Illegal Drugs ............................................................................................................................... 3

Alcohol ....................................................................................................................................... 3

Testing............................................................................................................................................. 7

Circumstances under which drug testing shall be required: .................................................... 7

Pre-employment Testing of Applicants .................................................................................. 7

Compliance with Department of Transportation Guidelines ............................................... 7

Compliance with Company Fleet Policy ............................................................................... 7

Employees operating company vehicles or operating their personal vehicles for company

business are covered hereby and shall be tested in accordance with the Company drug and

fleet policy. ............................................................................................................................. 7

Reasonable Suspicion Testing ................................................................................................ 7

Work-related Accident or Safety Infraction .......................................................................... 7

Random Testing cf Employees .............................................................................................. 7

Unless prohibited by law, collective bargaining agreement or otherwise, employees will be

subject to unannounced random screening for illegal drugs and/or alcohol. AU other drug

testing shall be performed to the fullest extent permitted by applicable law, collective

bargaining agreement or otherwise. Such testing will be done so by random selection. ....... 7

Circumstances under which drug testing shall be required: .................................................... 8

Work-related Accident or Safety Infraction .......................................................................... 8

Alcohol screening will be required where there is reasonable suspicion of alcohol use. ....... 8

Random testing shall include testing for alcohol. ................................................................. 8

Due to the safety or health risk or sensitive security duties of a specific job, as determined

by the Company, at any time. ................................................................................................ 8

Under other circumstances which, in the Company's opinion, suggest that such screening

is job-related and consistent with business necessity. ........................................................... 8

As otherwise required or permitted by applicable law. ........................................................ 8

Right to Search .............................................................................................................................. 11

Violation of Whiting-Turner's Drug and Alcohol Requirements ................................................. 15

Notice of Disciplinary Action and Employee Right to Retest Sample ................................. 15

Termination ............................................................................................................................... 15

Employment by others on Whiting-Turner worksites. ........................................................... 15

Index ............................................................................................................................................. 17

Introduction v

Introduction

The Whiting-Turner Contracting Company has established a Drug and Alcohol Free Workplace

Program for all of our employees on our projects and/or workplaces. The purpose in

implementing this policy is to promote a safe, healthy and productive work environment for

all employees. Further, this policy protects the reputation of the Company and will help to

demonstrate cooperation with our customers and communities in their efforts to contribute

to safe and efficient operations. This policy applies to all employees in all job

classifications and all applicants for those positions.

Policy on Drugs and Alcohol 3

Policy on Drugs and Alcohol

Illegal Drugs "Employees are prohibited from using, possessing, distributing, dispensing, manufacturing,

being under the influence, or otherwise being involved with illegal drugs and from abusive

use of chemicals or controlled substances while on company or client property or while

performing company business. In addition, such use, involvement or abuse is prohibited at any

time to the extent it violates the law or in the Company's judgment negatively affects Whiting-

Turner's business or reputation by undermining public or client confidence in safe and efficient

company operations."

Alcohol "Employees are prohibited from possessing, consuming or being under the influence of

alcohol while on company property or while performing company business except (in

moderation) for authorized, Company-sponsored social activities or business entertainment

purposes. In addition, the abuse or being under the influence of alcohol is prohibited at any time

to the extent in the Company's judgment it negatively affects Whiting-Turner's business or

reputation by undermining public or client confidence in safe and efficient company operations."

Testing 7

Testing

Circumstances under which drug testing shall be required:

Pre-employment Testing of Applicants Employment is contingent upon successful completion of pre­ employment drug

screening. Applicants seeking employment are required to complete a form

acknowledging and consenting to participate in pre-employment drug testing. All persons

are subject to this policy.

Compliance with Department of Transportation Guidelines Employees subject to Federal Motor Carrier Safety Regulations shall be tested in

accordance with D.O.T. Guidelines.

Compliance with Company Fleet Policy

Employees operating company vehicles or operating their personal vehicles for company

business are covered hereby and shall be tested in accordance with the Company drug

and fleet policy.

Reasonable Suspicion Testing Employees will submit to testing whenever, in the company's sole judgment, there is a

reasonable suspicion that drugs are being used or that the employee is impaired by

alcohol.

Work-related Accident or Safety Infraction Whiting-Turner may drug and alcohol test each employee who either contributed to a

work-related accident or safety infraction that does or might cause bodily injury or

damage to property or cannot be completely discounted as a contributing factor to the

accident or infraction. Testing will be conducted during and as part of, or after medical

attention is rendered, if required.

Random Testing cf Employees

Unless prohibited by law, collective bargaining agreement or otherwise, employees will

be subject to unannounced random screening for illegal drugs and/or alcohol. AU other

drug testing shall be performed to the fullest extent permitted by applicable law,

collective bargaining agreement or otherwise. Such testing will be done so by random

selection.

8 Drug and Alcohol Free Workplace Program

Circumstances under which drug testing shall be required:

Work-related Accident or Safety Infraction

Alcohol screening will be required where there is reasonable suspicion of alcohol use.

Random testing shall include testing for alcohol.

Due to the safety or health risk or sensitive security duties of a specific job, as determined by the Company, at any time.

Under other circumstances which, in the Company's opinion, suggest that such screening is job-related and consistent with business necessity.

As otherwise required or permitted by applicable law.

Right to Search 11

Right to Search

In support of Whiting-Turner's drug and alcohol policy, the company will conduct

searches considered appropriate to ensure- safe and efficient operations. The

Company reserves the right, in its discretion, to the extent permitted by law, to

search employees' packages, vehicles, lockers, handbags and similar items while on

Company worksites, property, or business. Employees are subject to drug and

alcohol testing and are subject to search at any time while entering, on, or leaving

the location or worksite.

Conditions under which a search may be considered include, but are not limited to,

reasonable suspicion of drug or alcohol use or possession, or following an accident,

which triggers a drug and/or alcohol test.

Violation of Whiting-Turner’s Drug and Alcohol Requirements 15

Violation of Whiting-Turner's Drug and Alcohol Requirements

Notice of Disciplinary Action and Employee Right to Retest Sample An employee notified of a positive test result shall have the right to request a retest of the

original sample. Subject to applicable law, the retest will be at the employee's expense and

must be conducted by a State certified laboratory. Whiting-Turner will consider the results of

any retest conducted hereunder in making its final determination or decision in connection

with this policy. Written notice of the intent to take disciplinary action, terminate employment,

or change the conditions of continued employment; and a statement reminding the person of the

right to have the specimen tested independently, at his or her expense, at a laboratory certified by

the State.

Termination Employees who test positive under this program will be discharged, absent acceptable

extenuating circumstances in the sole discretion of management. The discharge documentation

will indicate that termination is due to “ Failure to comply with Whiting-Turner policy.”

Employment by others on Whiting-Turner worksites. Employees of others that are discharged under this policy will not be permitted back on a

Whiting-Turner project and/or workplace until able to present satisfactory evidence of non-use

or rehabilitation.

In the event that the person who tests positive subsequently provides satisfactory

evidence to the medical review officer that there is evidence of an excused

positive, the person will be re-instated to- their position and compensated for any

lost time.

Index 17

Index Alcohol, 1, v, 3, 8, 15

Illegal Drugs, 3

Search, 11

Violation, 15