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©National Compliance Management Service (NCMS): NCMS Model - Revised June 2021 3 <br />1) PURPOSE <br />To ensure a safe, healthy, and productive work environment for the employees of the company, <br />customers, and others on company or customer property. To protect company and customer <br />property and assets, ensure efficient operations, and meet any specific requirements of <br />customers. Company shall enforce this drug, alcohol, and contraband policy in a fashion <br />consistent with the laws of the states in which the company employees’ are employed. <br />2) DEFINITIONS <br />a)Company Personnel: <br />All company employees, agents, subcontractors or subcontractors’ employees performing <br />field operations work on company or customer property, or those being considered for <br />employment by the company. This includes temporary and part-time personnel. <br />b)Property or Customers Property: <br />All real or tangible personal property, including facilities, buildings, vehicles, products and <br />equipment, either owned or controlled by the company or its customers. <br />c)Prohibited Substances: <br />i) Illicit or un-prescribed drugs, controlled substances and mood or mind-altering substances <br />including all forms of naturally occurring and synthetic drugs (for example: any synthetic <br />derivative/product that produces a marijuana-type high and any herbal products not <br />intended for human consumption); <br />ii) Potentially impairing medications (e.g. may be prescription drug or over-the-counter <br />medication or herbal medicine): <br />(1) Used without a prescription, or <br />(2) Used in a manner inconsistent with the prescription or directions for usage, or <br />(3) Used without disclosure to company as provided by Section 3(b)(iii) of this Policy <br />iii) Alcohol; <br />iv) Medical Marijuana/Recreational Marijuana – The use of marijuana for medical or <br />recreational purposes, even if permitted by state law, regulation or ordinance, will not be <br />considered an acceptable explanation for a confirmed positive laboratory report for <br />marijuana and will be reported by the Medical Review Officer (MRO) as a verified positive <br />drug test for marijuana. The company will treat marijuana like they would alcohol; they are <br />not required to tolerate individuals being under the influence while at work, or on customer <br />property. The company will not permit or accommodate the use, consumption, <br />possession, transfer, display, transportation, sale or growing of marijuana in the workplace. <br />*** Please note that the use of CBD oil, which is a cannabinoid extract from marijuana or <br />hemp plants, may cause a positive drug test result, depending on the product used. <br />Furthermore, some CBD products may contain compounds deemed illegal under federal <br />law, and therefore the use of such products would violate the company’s substance abuse <br />policy. A positive drug test will not be excused based on an employee’s claim that he or <br />she used a CBD product, even if it is for a claimed medical purpose, except as otherwise <br />provided under applicable law. <br />d)Reasonable Suspicion: <br />A belief based on objective and articulable facts sufficient to lead a supervisor to suspect use <br />of prohibited substances.