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a <br />1. Development of "Combined" Plan <br />The Pipeline and Hazardous Materials Safety Administration (PHMSA) is the agency within the <br />Department of Transportation (DOT) that regulates operators in the natural gas and hazardous liquid <br />pipeline industry. PHMSA's Drug and Alcohol Testing Regulation, 49 CFR Part 1991, requires each <br />operator to develop, maintain, and follow an Anti -Drug Plan and an Alcohol Misuse Prevention Plan. <br />Historically, companies have produced these plans as two separate documents. This "combined" <br />Anti -Drug and Alcohol Misuse Prevention Plan," merges both PHMSA-required plans into a single <br />document. <br />Authorization for a combined plan was granted by PHMSA's Office of Pipeline Safety stating. <br />"PHMSA will allow the combining of the two plans into one written plan, as long as all requirements of <br />each regulation are met." The "requirements of each regulation" means the requirements of Part 199 <br />and the requirements of DOT's "Procedures for Transportation Workplace Drug and Alcohol Testing," <br />49 CFR Part 402, <br />The Anti -Drug and Alcohol Misuse Prevention Plan, henceforth referred to as the "Plan," meets all the <br />requirements of Part 199 and Part 40. <br />2. Approach <br />The Plan will use the generic word " Company" in reference to the operator or contractor, as <br />applicable, for which it is written. PHMSA's requirement for plan development and implementation <br />applies equally to each operator and contractor that performs safety -sensitive operations, <br />maintenance, or emergency -response functions on a pipeline or LNG facility within the natural gas <br />and hazardous liquid pipeline industry. The Plan will describe how the Company will comply with <br />government requirements. <br />The Plan will identify "Company -additional" requirements — those that go beyond the minimum <br />requirements of DOT. n I , i Therefore, consider <br />anything that is not underscored a requirement of DOT or a process put In place by the Company to <br />meet a DOT requirement. Appendix D outlines the Company disciplinary actions and additional <br />procedures. <br />The Plan is written in "plain language" and follows the requirements of each rule. However, the Plan <br />does not repeat the language of either Part 40 or Part 199. Doing so would require the Company to <br />produce a new plan every time DOT or PHMSA issued a change to their respective rule. The goal of <br />DOT is to know that the Company understands the requirements of the rules and how the Company <br />will go about achieving compliance. The Plan makes use of existing DOT language in places where <br />summaries are used to explain a more detailed process e.g., specimen collection and alcohol test <br />procedures are extracted from DOT's "Employee Guide" ). <br />' Title 49 Code of Federal Regulations (CFR), Part 199, "Drug and Alcohol Testing Requirements," Pipeline and <br />Hazardous Materials Safety Administration, Department of Transportation, 53 FR 47096, Nov. 21, 1988 as <br />amended. <br />2 Title 49, Code of Federal Regulations (CFR), Part 40, "Procedures for Transportation Workplace Drug and <br />Alcohol Testing Programs," Office of the Secretary, Department of Transportation, 65 FR 79462, Dec. 19, 2000 as <br />amended. <br />3 "What Employees Need To Know About DOT Drug & Alcohol Testing," ODAPC, DOT, October, 2010. <br />J. RANCK ELECTRIC, INC. <br />PHMSA DRUG/ALCOHOL PLAN <br />NATIONAL COMPLIANCE MANAGEMENT SERVICE, INC. (NCMS) - 2010 <br />