SEL 15A Injury Management / Return To Work Process

from Corporate Health & Safety Manual

by Mining Life & Exploration News

SEL 007 Preventative Maintenance

INJURY MANAGEMENT & RETURN TO WORK PROCESS

Document Identification SEL 015A Page Number 1 of 1

Document First Created Mar 22 - 2011 Implementation Date on Revised Document April 20 - 2017

INJURY MANAGEMENT & RETURN TO WORK PROGRAM

Document Identification SEL 015B Page Number 1 of 11

Document First Created Mar 22 - 2011 Implementation Date on Revised Document April 20 - 2017

Injury Management, Return to Work Program

1.0 Introduction & Overview

Belterra’s Injury Management & Return to Work (IM/RTW) program offers injured employees guided information to promote the success of our Occupational Health & Safety Management Program. The organization recognizes that our most valuable asset is our employees; that their work ethic, commitment to service excellence, and strong sense of loyalty allows the organization to excel in a competitive market place.

The organization is committed to developing and maintaining a safe and healthy work environment by playing an active role in minimizing the impact and disruption to the lives of the injured employees, and to assist them back to work in a timely manner.

2.0 Four Step Plan

A four step plan was utilized to develop Belterra’s IM/RTW Program:

Plan

•Policy Development

Act

•Continue Improvement

Apply

•Responsibilities & Training

Check

•Monitor & Review

3.0 Program Evaluation

The IM/RTW program will be evaluated on an annual basis by Senior Management and the Corporate H&S Coordinator with input from JOHSC members. This review will assist Belterra to assess the effectiveness and to introduce continuous improvement plans for the success of the program.

Changes to the program, reason for the changes and how they will affect the program will be communicated to all levels of the workforce.

Introduction and Overview………………………………………………………………… 1 Four Step Plan…………………………………………………………………………… 1 Program Evaluation ……………………………………………………………………… 1 1.0 Purpose and Scope……………………………………………………………… 3 2.0 Program Principles and Objectives: 2.1 Principles ………………………………………………………………… 4 2.2 Program Objectives ……………………………………………………… 4 3.0 Responsibilities: …………………………………………………………………. 5 3.1 Senior Management’s Statement ………………………………………… 5 3.2 Branch Managers Responsibilities ……………………………………… 5 3.3 Corporate Health & Safety and Injury Management Coordinator Responsibilities …………………………………………… 5 & 6 3.4 Branch Safety Representative &/or Supervisor (lead hand)Responsibility ………………………………………………… 6 3.5 Employee Responsibility ………………………………………………… 6 3.6 First Aid Attendant Responsibility ……………………………………… 6 4.0 Responsibilities in the Event of an Injury: 4.1 Employee Responsibility in the Event of an Injury at Work …………….. 7 4.2 Supervisor / Safety Representative Responsibilities in the Event of an Injury at Work ………………………………………………………… 8 5.0 Preparing for Claims ……………………………………………………………... 8 & 9 6.0 Managing Claims: ………………………………………………………………… 9 6.1 Types of Suitable Employment 6.1.1 Modifying an Existing Job ……………………………………… 10 6.1.2 Providing Transitional Work ……………………………………………… 10 6.1.3 Providing Suitable Employment ………………………………… 10 6.1.4 Providing a Training Opportunity ………………………………… 10 6.1.5 All or Any Combination of the Above …………………………… 10 6.2 Identifying Suitable Employment Positions ……………………………… 10 6.3 Suitable Employment Procedures ………………………………………… 10 6.4 Assigning / Offering Suitable Employment ……………………………… 11 6.5 Refusal of Suitable Employment Offer …………………………………… 11 6.6 Return to Regular Duties ………………………………………………… 11 6.7 List of Alternate Duties …………………………………………………11& 12 7.0 Communication ………………………………………………………………… 12 8.0 Guidelines for Modified Work – NOC Table …………………………………… 13 9.0 Corresponding Forms and Document List …………………………………………14

4.0 PURPOSE AND SCOPE

Belterra Corporation is committed to pro-actively managing all WCB claims using the organization’s resources to protect its employees and assets from inappropriate use. In fulfilling this commitment to protect both employees and Belterra’s assets, management will provide and maintain a work environment in accordance with the Provincial Acts and regulatory requirements. Injury Management / Return to Work (IM/RTW) will be controlled through fair and equitable management practices in combination with active employee involvement. IM/RTW is the responsibility of all Senior Managers, Branch Managers, Supervisors and Employees. For claims management to be successful, a systematic and organized approach must be taken to control claims. An effective IM/RTW provides financial benefits by reducing costs due to injuries. A good program will also reduce the “hidden costs” such as:  Reduction of insurance premiums.  Hiring and training costs of replacement workers.  Wages paid to disabled workers.  Production stopped.

IM/RTW is an essential part of doing business and management must lead all efforts in their branch. IM/RTW succeeds when its leadership is committed to the program’s principles. The most important component of Belterra’s IM/RTW program is the integration of its policies, practices and procedures into every aspect of its day-to-day operations. Belterra’s IM/RTW Program is focused on early intervention initiatives that help a worker to remain at work following an injury or illness by matching the worker’s functional abilities to the demands of his/her pre-injury/illness job duties, modified job duties, or available job duties.

Light or modified duties for work, and non-work related injuries & illnesses will be provided where feasible, with possible accommodation to productive work. Consideration will be given as to not create undue hardship on both the workers, and the employee when accommodating on light / modified duties.

5.0 PROGRAM PRINCIPLES AND OBJECTIVES

5.1 PRINCIPLES  Effective management of employee rehabilitation through a knowledgeable cooperative approach.  Ensure that an employee receives prompt, effective, timely access to services required to enhance and facilitate their rehabilitation.  Each branch will be responsible for reasonable accommodation of any employee unable to perform their regular duties.  Where the system is unable to provide a suitable employment assignment, an attempt may be made to place the employee in another position.

5.2 PROGRAM OBJECTIVES Allow the employee to RETURN TO THE WORK FORCE as soon as possible by:

 Encouraging effective rehabilitation.  Promoting timely identification of assistance required such as medical services, methods of accommodation and vocational rehabilitation services.  Helping maintain contact with co-workers.  Reducing the sense of separation from Belterra Corporation.  Reducing the time needed to return to full work capacity.  Helping to maintain a sense of identity and self-respect.  Ensuring that excellent communication is maintained between all parties.  Ensuring that all workers are treated fairly and consistently.  Promoting greater safety and health.  Promoting productivity through the use of experienced trained employees, by more effective management of insurance costs and by more effective management of short term disability costs.  Ensuring compliance with the Human Rights Code, the Workers’ Compensation Act and other related legislation.

6.0 RESPONSIBILITIES

Responsibilities can be defined as an individual’s obligation to carry out assigned duties. For IM/RTW to achieve its desired results, everyone in the organization must know their responsibilities.

The assignment of responsibilities is restricted only to IM/RTW.

6.1 Senior Management’s Statement

The Company’s IM/RTW Program is management-led. By reviewing the responsibilities that have been assigned, branch staff will understand what they have to do. Managers or their designate must also remember to lead by example. Actions speak louder than words. This type of leadership will contribute greatly to the acceptance of the program by all employees.

6.2 Branch Managers Responsibilities

 Oversee control of the direction of IM/RTW program.  Support IM/RTW and ensure it is being administered and enforced in all areas.  Responsible for the day to day administration of IM/RTW program.  Ensure all pertinent WCB claims reports are submitted to the corporate office as required.  Ensure supervisors are given the resources and time to prepare the physical demands analysis of positions.  Supports and participates in IM/RTW seminars or training.  Maintain current knowledge of WCB literature, regulations and codes of practice.  Review Provincial workers’ compensation reports to keep informed about Belterra’s performance

6.3 Corporate Health & Safety and Injury Management Coordinator Responsibilities

 Ensure Injury Management and Return to Work Program is in compliance with local, provincial and / or federal regulations.  Ensure all pertinent WCB claims reports are submitted to the regulatory bodies in a timely manner.  Implement training programs to increase proficiency in safe and early return to work after an injury/ illness.  Communicate legislative changes or new regulations to senior management, operational personnel, supervisors and employees.  Work closely with WCB, including medical providers, adjusters, investigators, and safety consultants to ensure the return to work programs are well coordinated and professionally administered.  Develop specific strategies to implement and manage a comprehensive and proactive Return-to-

Work Program and Claims Management Program in a company wide application.

 Maintain current knowledge of WCB literature, regulations and codes of practice.  Review Provincial workers’ compensation reports to keep informed about Belterra’s performance  Assist in investigations, analysis and preparation of WCB claims reports and summaries.

6.4 Branch Safety Representatives and /or Supervisor (Lead -hand) Responsibility

 Provide instructions to workers in IM /RTW. As part of their routine duties, the Supervisor shall require, if possible, the injured employees to perform alternative duties.  Prepare physical demands analysis of positions.  Undertake the investigation of incidents to determine the validity of claims. These must be reported in detail to the branch Manager or designate and to the IM /RTW Coordinator.  Provide equal treatment to all injured employees.  Provide injured employees with information about suitable employment on the job.

6.5 Employee Responsibility

 Carry out their suitable employment in a manner that will not create a hazard to their own (and/or other’s) health and safety.  Assist in the IM/RTW process. Report any incidents, near misses and/or injuries immediately to their Supervisor.  Report any anticipated loss of work time to his/her Supervisor as soon as possible after being treated by a physician following injury.

6.6 First Aid Attendant Responsibility

 Treatment of the injured worker.  Support IM and ensure that all injured workers are aware of their responsibilities.  Ensure all injuries are reported to the Branch Manager and the injured worker’s supervisor.  Follow-up and ensure the injured workers are receiving the appropriate first aid treatment.

7.0 Responsibilities in the Event of an Injury

7.1 Employee Responsibilities in the Event of an Injury at Work

When an employee is injured at work:

a) The employee must immediately report to the Supervisor or First Aid as soon as an injury has occurred. An Incident/Investigation Report must be completed as soon as possible.

b) If the injury prevents the employee from continued work, the employee will seek care from the Hospital Emergency, Walk In Clinic or Family Physician immediately upon leaving work

c) In case of severe injury, an Ambulance will be contacted immediately for assistance.

The employee must contact the supervisor prior to seeking medical care (if possible and practical).

The Supervisor will provide the employee with a Letter to Employee’s Physician, the Physician Physical Assessment Report and a copy of the Physical Demand Analysis for the Employee’s position.

d) The employee must have the attending Physician complete Belterra`s Physician Physical

Assessment Report form at the initial medical assessment.

e) Following receipt of medical attention, the employee must report in person to the Supervisor to arrange a return to work.

f) The employee will be instructed by Belterra`s First Aid Attendant or Supervisor the reporting requirement of WCB.

g) If deemed unfit to return to work by the attending physician, the employee must contact their supervisor in person, or if not practical by telephone.

The employee must submit the Physician Physical Assessment Report to the Branch Manager/Injury Coordinator

h) If declared fit to return to regular or modified duties, the employee will report immediately to the Supervisor with the completed Physician Physical Assessment Report to coordinate his/her return to work.

Following the initial medical evaluation, employees must maintain regular contact as directed by the Branch Manager/Injury Coordinator to report progress and any active treatment.

The employee will be informed of his/her ongoing responsibilities.

7.2 Supervisor / Branch Safety Representative Responsibilities in the Event of an Injury at Work

1. The Supervisor/ Safety Representative or their designate, shall interview the employee to ascertain full details of the injury. An Incident/Investigation Report must be completed as soon as possible.

2. If medical attention is required, the Supervisor /Safety Representative will:  Provide the employee with the Physician Physical Assessment Report, Letter to the Employee’s Physician and the Physical Demand Analysis which includes the employee’s responsibilities.

Note: The employee must seek immediate medical attention upon leaving work, for 2 reasons:

1) Employees injured at work will be paid for time lost on the day of injury, provided that he/she presents authorization from the attending physician, certifying that he/she was disabled and unable to return to work on that day.

2) If the employee indicates he/she is unable to continue working – the injury must be deemed significant enough to seek immediate medical attention. Failure to do so may prolong or aggravate the nature of the disability.

Provide transportation to the appropriate health care facility where injury can be treated by a professional health care provider.

Receive the completed Physician Physical Assessment Report from the employee and coordinate a return to regular or modified duties where appropriate. Every reasonable effort must be made to accommodate the worker’s limitations.

Forward the Incident/Investigation Report and Physician Physical Assessment Report to the Branch Manager and the Injury Management coordinator as soon as possible.

8.0 PREPARING FOR CLAIMS

8.1 Physical Demand Analysis

The information gathered by the Physical Demand Analysis not only defines the jobs and positions in the Company, it also provides the basis for determining how physically demanding each task is on the different parts of the human anatomy.

Physical Demand Analysis outlines the physical requirements of jobs and should be used when hiring to determine if a person can physically perform a job. They should also be provided to the WCB Claims providers to determine if an employee is physically able to return to work, either on regular duties or alternative duties.

When completing the Physical Demand Analysis focus on measurable information including weight amounts, the percentage of time spent on each activity and the length of the workday. Four important components of the analysis are as follows:

 Mobility – standing, sitting, crawling, climbing;  Strength – lifting, working above or below shoulder height, pushing, pulling;  Sensory – vision, hearing, reading, writing, talking;  Environment – work surfaces, indoors, outdoors, cold, hot, noise.

Seek employees’ input when the jobs are being analyzed. They are the ones most familiar with the positions. Once an analysis is completed, it will be kept on file.

9.0 MANAGING CLAIMS

Suitable Employment assists in the rehabilitation and early return to work of an ill or injured employee and ensures that all claims are effectively managed.

Belterra Corporation will make every reasonable effort to provide suitable (temporary) employment to any employee unable to perform his/her regular duties. This may include a modification of the employee’s original position or providing a suitable employment position, depending on the employee’s medical restrictions.

Only work that is considered to be meaningful and productive shall be considered for use as Suitable Employment.

Participants placed on Suitable Employment will be expected to provide feedback in order to improve the program.

The Return to Work plan is to be used to track the employee during his/her return-to-work.

9.1 Assigning/Offering Suitable Employment

Medical approval is needed in order to make a suitable IM/RTW placement. If required, a Physical Demand Analysis will be provided to the employee’s physician(s) so that they can give an opinion on the employee’s fitness to perform the work.

Should an offer of suitable employment be made to the employee, the offer letter should state the following information:

 Specific job duties to be performed.  Hours of the employment (these are important in the case of transitional employment where the hours may vary during placement).

 Length of placement (this will be noted and made clear to the employee).  Offer will be signed by the employee and the branch manager or designate and will be forwarded to WCB.

Once placed on an IM/RTW placement, the Safety Representative / Supervisor will monitor the progress of the employee and address any concerns immediately.

9.2 Refusal of Suitable Employment Offer

Any refusal by an employee to participate in the Suitable Employment program shall be dealt with immediately. The reasons for not participating will be recorded and WCB will be notified immediately.

9.3 Return to Regular Duties

When confirmation of medical clearance to return to regular duties is received, the Corporate Health & Safety Coordinator or designate will inform WCB. The Supervisor or designate will continue to monitor the employee’s return to regular duties.

9.4 List of Alternate Duties

The following alternate duties are identified to accommodate an injured worker depending on his/her restrictions:  Light duty belt work, e.g. lacing, putting cleats on belts or lagging a pulley.  Provide guidance and/or practical training to junior employees (or new hires). This light duty will be available to senior and competent employees only  Update (Material) Safety Data Sheets (MSDS) on-line, and prepare binders for all trucks.  Light sanitation; cleaning up the shop floor and dusting.  Organizing inventory including inventory counting.  Training and/or retraining on safety materials  Any other light duties that may be assigned by the supervisor or manager within the physician’s restrictions and limitations.

10.0 COMMUNICATION

All levels of the workforce will be made aware of the specifics of the IM/RTW program and advised of the desired outcomes as follows:

 As part of the new hire orientation package  Annual training for the first year to all levels of workforce; thereafter, a mandatory crew talk / refresher training on the importance of IM/RTW program each year.  Reiterated to any worker who is injured in the workplace or when first aid is administered with possible modified duties.  First Aid Attendants – re-fresher training on their roles and responsibilities for IM/RTW.

The line of communication will be open throughout the worker’s absence; starting from the very first day of absence. For Lost Time Injuries, the worker will be contacted and advised of all their options.

Belterra will have a strong and open line of communication throughout the IM/RTW program. This ethic will result in quicker and more efficient resolutions to worker injury or illness, and subsequent time off and return to work procedures. The ultimate goal is to ensure that injured or ill workers return back to work in the most efficient and healthiest manner possible.

11.0 GUIDELINES FOR MODIFIED WORK – NOC TABLE

WorkSafeBC extracted table is nationally accepted and referenced throughout Canada as part of National Occupational Classification (NOC)

12.0 CORRESPONDING FORMS AND DOCUMENTS

No. Document # Document Name

1 SEL 015 IM/RTW - Policy

2 SEL 015A IM/RTW - Process

3 SEL 015B IM/RTW - Program

4 FRM 019 IM/RTW - Offer letter of Suitable Employment

5 FRM 020 IM/RTW - First Aid Attendant checklist

6 FRM 020A IM/RTW – Worker Instructions

7 FRM 020B IM/RTW - Safety Representative OR Supervisor Checklist

8 FRM 020C IM/RTW - Branch Manager IM RTW Coordinator Checklist

9 FRM 020D IM/RTW – RETURN TO WORK PLAN

10 FRM 020E IM/RTW – Communication Log

11 FRM 021 IM/RTW - Letter to Employees Physician

12 FRM 022 IM/RTW - Physicians Physical Assessment Report

13 FRM 023 IM/RTW – Medical Release Form

14 FRM 024 IM/RTW – Physical Demand Analysis

Document Identification SEL 016 Page Number 1 of 24

Document First Created Mar 22 - 2011 Implementation Date on Revised Document April 20 - 2017

1.0 POLICY

Belterra Corporation is committed to promoting a safe, healthy and productive work environment, and to maintaining the public’s trust and confidence. We recognize that the use of illegal drugs and the inappropriate use of alcohol and medications can adversely affect job performance, the work environment and the safety of our employees, and potentially, the general public.

It can also place the integrity and safety of Company property and operations at risk. This Drug and Alcohol Policy and its related Guidelines are intended to communicate the standards and expectations associated with drug and alcohol use and to confirm the Company’s commitment to health and safety.

2.0 APPLICATION

This Policy and its related Guidelines apply to all Company employees while they are engaged in Company business, working on or off Company premises, and operating Company vehicles and equipment. One of the tools used in this Program is Drug Testing.

The Company recognizes that Drug Testing does not necessarily demonstrate impairment nor does it necessarily reveal a substance abuse problem or chemical dependency. A verified positive Drug test only means that a Drug or alcohol is in the donor’s system.

The Company a l s o realizes that substance dependency is considered t o b e a disability under the Human Rights Code and intends to comply with the requirements of the Code and any other applicable laws in the implementation of this Program.

Unless otherwise stated, Drug testing will only be required of those Employees who work in Safety Sensitive Positions.

2.1 Pre-Employment Testing

The Company will require that applicants for Safety Sensitive Positions undergo a Drug test after being given a conditional offer of employment with the Company. In the event of a positive test result, the steps laid out in section 14.0 of this Program will apply.

3.0 PROVISIONS

To minimize the risk of unsafe and unsatisfactory performance due to drugs or alcohol, all employees are expected to report fit for work and remain fit for work throughout their workday or shift and when on scheduled call.

The following are expressly prohibited while on Company business or premises:  The use, possession, distribution and offering for sale of drugs or drug paraphernalia.  The unauthorized use, possession, distribution, offering for sale of beverage alcohol.  Possession of prescribed medications not authorized for personal use.  Reporting for duty with the presence in the body of alcohol or drugs above the accepted standards outlined in Belterra’s Drug and Alcohol Guidelines.

Various investigation and testing procedures outlined in the Guidelines may be used in support of this Policy. Belterra provides prevention, assessment, treatment and aftercare support for employees who suspect they have a substance dependency or an emerging alcohol or drug problem.

Employees concerned about or experiencing alcohol and drug problems are encouraged to seek assistance from Belterra's Employee and Family Assistance Program (EFAP), their personal physician or appropriate community service before job performance is affected or violations occur.

Disciplinary action up to and including termination will be taken for violations of this Policy and its related Guidelines.

4.0 GUIDELINES

The purpose of these Guidelines is to promote health and wellness, support performance management and provide some practical tools for addressing inappropriate use of drugs and alcohol in the workplace.

The Guidelines establish Belterra’s standards and expectations for ensuring employees report fit for work and remain fit for work while on Company business, on Company Premises, on Company Worksites, and when Scheduled On-Call.

As a condition of employment each employee must abide by the terms of the Policy and Guidelines, as amended from time to time by the Company. The Company reserves the right to change, expand, reduce, amend or revise this Policy and Guidelines at any time, in its sole discretion, as it determines appropriate. Employees and contractors will be provided notice prior to these changes.

Employees may be unable to comply with this Policy and Guidelines because they are addicted to a substance. Such employees are regarded as having a disability under human rights legislation and must be accommodated to the point of undue hardship by the Company.

This does not mean that addicted individuals must be allowed to work while impaired. However, the Company may be required to facilitate a leave of absence for treatment and then a return to work with assurances that the addiction is under control.

The Company acknowledges that it has a duty to accommodate employees who have a substance addiction and that it will accommodate such employees as it is legally required. The Policy and Guidelines are also subject to the provisions of any Collective Bargaining Agreements in force between the Company and any unions/or employee organizations to which its employees belong.

5.0 APPLICABILITY

The Policy and Guidelines apply to every Employee of the Company and any person applying for a job with the Company that is safety-sensitive. `

6.0 DEFINITIONS

 Collection Site - refers to a facility engaged or set up in advance by Belterra to perform drug and/or alcohol testing.  Company - (for the purpose of the Policy and Guidelines) means Belterra Corporation and all of its

Canadian affiliates and subsidiaries.

 Company Business - refers to all business activities undertaken by employees and contractors in the course of the Company's operations, whether conducted on or off Company premises.  Company Premises - includes but is not restricted to all land, facilities, mobile equipment and vehicles owned, leased or otherwise directly controlled by the Company for the purpose of conducting Company business.  Company Worksites - includes any customer worksite to which employees have been assigned for the purpose of conducting Company business.  Drug - means any substance, including alcohol, illegal drugs and drug paraphernalia, or medications, the use of which has the potential to change or adversely affect the way a person thinks, feels or acts. For purposes of this Policy, drugs of concern are those that inhibit a worker’s ability to perform his or her job safely and productively, including the following:  Alcohol - means the intoxicating agent in alcoholic beverages, ethyl alcohol, or other low molecular weight alcohols including methyl and isopropyl.  Alcoholic Beverage or “Beverage Alcohol - refers to beer, wine and distilled spirit in a concentration of more than 0.5%.

 “Illegal Drug - means any drug or substance that has been obtained illegally and the use, sale, possession, purchase or transfer of which is restricted or prohibited by local law (e.g. street drugs such as marijuana and cocaine).  Drug Paraphernalia - refers to any equipment, product, or material that is modified for making, using, or concealing illegal drugs such as cocaine, heroin, marijuana, and methamphetamine, or to facilitate the improper use of legal drugs.

 Medication - refers to a drug obtained legally, either over-the-counter or through a doctor’s prescription.

 Employee - includes all regular full-time, part-time, temporary, seconded, casual and fixed-term employees on the Company payroll.

 Fit for Duty/Work - means that an individual is in a state (physical, mental, and emotional) which enables them to perform the assigned tasks competently and in a manner that does not threaten or endanger the safety or health of themselves or others.

 Management - means all persons who have supervisory responsibility over employees, whether or not on Company premises or Company worksites, and includes members of the Human Resources

Department.

 Medical Review Officer or MRO - means a licensed physician with knowledge of substance abuse disorders and who has the ability to evaluate an employee’s positive test results. A MRO is responsible for receiving and reviewing laboratory results generated by an employer’s drug testing program and evaluating medical explanations for certain drug test results.

 Policy - refers to Belterra’s Drug and Alcohol Policy and its related Guidelines, as may be amended from time to time.

 Safety Sensitive Work - means any work that the impaired performance of which could endanger the individual performing the work, other employees, customers, their employees, the public, property, equipment and/or the environment.

 Safety Sensitive Position or SSP - means any position that engages in Safety Sensitive Work. This category includes any and all employees required to temporarily relieve in a safety-sensitive position, or who may perform the same duties from time to time.

Safety Sensitive Positions shall include employees working in safety sensitive environments and all persons working in the shop, field and warehouse.  Scheduled On-Call - refers to specifically designed scheduling wherein the individual is assigned set times and dates where he or she can expect to be called in to work, and excludes situations where an individual’s position responsibilities results in the possibility that he or she could be called unexpectedly at any time.  Substance Abuse Professional or SAP - is an individual with knowledge of and clinical experience in the diagnosis and treatment of drug and alcohol related disorders. An employee who violates this Policy may be referred to an SAP to assess if he or she has a potential disability, and the SAP may make recommendations regarding education and treatment, and recommend a return-to-duty monitoring program, including unannounced testing.  Supervisor - means the individual accountable for a particular facility, department or area, including managers and others in supervisory positions that are directly responsible for the performance of individuals.

7.0 STANDARDS AND APPLICATIONS

To minimize the risk of unsafe and unsatisfactory performance due to the use of Drugs and/or Alcohol, Employees are expected to comply with the following standards, and to report Fit for Duty and remain Fit for Duty throughout their workday. Failure to comply may result in disciplinary action up to and

including termination. The Company acknowledges that it has a duty to accommodate Employees who suffer from a disability or dependency up to the point of undue hardship. All Employees who are Scheduled On-Call must remain Fit for Duty in compliance with these standards. If unexpected circumstances arise where an Employee is requested to perform unscheduled services while under the influence of Drugs and/or Alcohol that could prevent the Employee from working safely and/or breach the standards of this Policy, it is the responsibility of that Employee to decline the call.

7.1 Illegal Drugs:

The following are prohibited while on Company Business, Company Premises and Company Worksites:  The use, possession, distribution, offering or sale of Illegal Drugs or Drug Paraphernalia;  The unauthorized possession of prescribed Medications without a legally obtained prescription;  Unauthorized distribution, offering or sale of prescription Medications (trafficking);  Reporting for work under the influence of Illegal Drugs; and  Presence in the body of Illegal Drugs as determined through the testing program.

7.2 Alcohol:

Employees are expected to use Alcohol responsibly in those situations where it is permitted, and to report and remain Fit for Work in compliance with this Policy. The following are prohibited:

 The use, distribution, offering for sale of Alcohol on designated Company Business, Company Premises or Company Worksites except as noted below;  Possession of open containers of Alcoholic Beverages on designated Company Business, Company Premises or Company Worksites except as noted below;  An Alcohol test result of .04% Blood Alcohol Concentration (BAC) or greater; or  Use of Alcohol within the first 8 hours after an incident or until tested or advised by the Company that a test is not required.

7.2.1 Alcohol Standards Are Subject To The Following Exceptions:

 Sealed containers of Alcoholic Beverages may be stored in vehicles parked on Company Premises and Company Worksites provided it is locked in the trunk of the vehicle or otherwise appropriately secured;  Sealed containers of Alcoholic Beverages may be transported or stored in vehicles provided, assigned or subsidized by the Company when not being used for Company Business, provided it is locked in the trunk of the vehicle or otherwise appropriately secured;

7.2.2 Employees May Use Alcohol:

When on travel status, at a training event or seminar, or in any other similar business-related situation, provided:  The formal business or training is completed;  They use Alcohol responsibly;

 They are not returning to work; and  They are able to report to work, as required by their job requirements, Fit for Duty in compliance with the standards set in this Policy.

Responsible Alcohol use is permitted at Company sponsored social events. In case of Company related social activities appropriate regard must be taken for safety and wellbeing of the individuals present and the community.

Social events held on Company property will not serve alcohol. Company social events, which involve consumption of Alcohol and are organized by Company representatives off Company property, must keep in mind the following:

 Employees attend as a guest and are not to be performing work functions;  Social events will be held in establishments which have their own liquor license and their own servers;

 In the event that the Company sponsors events serving alcohol, alternate transportation arrangements shall be made to prevent the foreseeable risk that someone could be injured by impaired driving.  The Company representative responsible for organizing the event will notify the bar staff that those persons who appear to be impaired are to be “cut off”;

 The announcement of “last call” will be issued and the bar will be closed before the end of the function;  In situations where impairment is suspected, alternative transportation will be made available.

7.3 Medications:

Employees are expected to responsibly use prescribed and over-the-counter Medications. The intentional misuse of Medications (e.g. using the Medication not as it has been prescribed or directed by the pharmacy, using someone else’s prescription Medication, combining Medication and Alcohol use against direction) while on Company Business, Company Premises or Company Worksites, is prohibited.

Medications of concern are those that inhibit or may inhibit an Employee's ability to perform their job safely and productively.

7.3.1 Employees Are Required To:

 Investigate (through their doctor or pharmacist) whether a Medication can affect their ability to work safely in a manner that does not endanger themselves or others;

 Take appropriate action to minimize safety risk by advising Management of any need for modified duties if the Medication will affect their ability to work safely; and

 Report any requirement for modified work to their Supervisor if they hold a Safety Sensitive Position, and follow any recommended course of action to minimize safety risk, which could include temporary reassignment if possible or leave, as appropriate to the situation.

The Company reserves the right through the Company’s medical services provider, to confirm the nature and duration of modified work requirements with the treating physician, without any breach in medical confidentiality.

8.0 PREVENTION, ASSISTANCE, REHABILITATION AND AFTERCARE

8.1 Prevention:

This Policy stresses the importance of prevention and early identification of potential problem situations.

Employees are encouraged to access the Company Employee and Family Assistance Program (EFAP), their personal physician, or appropriate community services for help with a Drug and/or Alcohol problem, or any other problem that may be affecting work performance.

8.2 Assessment/Rehabilitation:

The Company recognizes that Drug and Alcohol dependency are treatable illnesses and that early intervention greatly improves the probability of a lasting recovery. Individuals who suspect they have a substance dependency or an emerging Drug and/or Alcohol problem are encouraged to seek advice and to follow appropriate treatment promptly before job performance is affected or violations of this Policy occur.

Employees that voluntarily seek help with a Drug and/or Alcohol problem will not be subject to disciplinary action. However, the help must be accessed prior to being notified that they must report for a test under this Policy, or prior to engaging in activities which may lead to disciplinary action under this Policy, up to and including termination. Accessing assistance or declaring a problem does not eliminate the requirement for maintenance of satisfactory performance levels.

8.3 Others:

Where a medical professional, Substance Abuse Professional (SAP), or other counseling professional advises that there may be a risk that would prevent an Employee from doing his or her job safely, a medical work modification may be issued, and the Employee may be assigned to alternate duties at the discretion of the Company.

8.4 Aftercare:

An Employee who completes primary treatment (e.g. residential or out-patient treatment) for Drug and/or Alcohol problems may be required to participate in an aftercare program when returning to duty in order to help them maintain recovery. The Employee may also be expected to enter into a written agreement, which will outline the conditions governing their return to the job and the consequences for failing to meet those conditions.

The written agreement will be documented using the Drug and Alcohol Return to Work Agreement (FRM

028).

Confidentiality will be maintained except where limited disclosure is necessary for related health and safety concerns (e.g. where there is deemed to be a potential for risk to self, others or the Company). That is, only the information strictly limited to the level of functionality (e.g. if the Employee is Fit for

Duty and any restrictions that may apply) may be shared with Management for purposes of determining if the Employee is Fit for Duty, appropriate work accommodation, and/or work re-entry initiatives.

8.5 Investigative Procedures

The normal process of job performance monitoring and counseling will continue to be emphasized. Through this process, Employees with apparent performance problems will be reminded that they should access assistance should a personal problem be affecting their job performance.

8.6 Responsible Escort Procedures:

In all situations when there are reasonable grounds to believe an Employee is not Fit for Duty on Company Business, Company Premises or Company Worksites, responsible escort procedures will be followed. The Employee (with union representation where applicable) will be escorted to a safe and private place for an interview meeting. Where practicable, the Supervisor will engage a Human Resources representative or a second Supervisor on site to be present at the meeting with the Employee.

The Employee will be given an opportunity to explain why he or she appears to be in a condition that is not Fit for Duty. If the Supervisor conducting the interview meeting still believes the Employee is in a condition that is not Fit for Duty (with confirmation of a Human Resources representative or a second Supervisor present at the meeting), then he or she may take any of the following actions:  Refer the Employee for medical attention if there are immediate medical concerns (to a health center, local hospital or clinic);

 Refer the Employee for a Drug and/or Alcohol test, if there are reasonable grounds to believe Drug and/or Alcohol use may be a factor in the situation;  Provide transportation and escort to the Collection Site or hospital/clinic depending on the circumstances, and then provide Employee with transportation to the Employee’s place of residence or the care of another adult person.

 In the alternative, where arrangements are made for a collection agent to attend the Collection Site, stay with the Employee until collection agent attends the Collection Site and then provide the Employee with transportation to the Employee’s place of residence or the care of another adult person.

The Employee may be temporarily removed from his or her duties or reassigned pending completion of any investigation. Depending on the test result, a Fit for Duty assessment may also be required before allowing the Employee to return to work.

A request to submit to testing must be made outside the presence of other Employees, but should, where practicable, be made in the presence of a Human Resources representative or a second Supervisor.

If the Employee refuses to be tested, then that Employee must be informed that his or her failure to do so is in violation of the Company’s Drug and Alcohol Policy and that the refusal may result in disciplinary action up to and including termination of his or her employment for just cause.

A Supervisor may not physically restrain the Employee and prevent him or her from driving on public streets after being placed on a paid leave of absence for a suspected Drug and/or Alcohol-related offense. Utilize the following guidelines in front of a witness:

 Offer the Employee a ride home.

 Offer to call a relative for the Employee.

 Tell the Employee that the Company will notify the police if the Employee attempts to drive in his or her condition.

If the Employee does drive away, then notify the police and tell them only the observed facts about the Employee’s appearance.

DO NOT draw conclusions or state any opinions as to whether the Employee is under the influence of Drugs and/or Alcohol.

If the information is available, give the police a description of the car, the location of the car and the license plate number.

Do not physically detain the Employee.

Drug and Alcohol testing must be done immediately. Take note that tests for Alcohol are not reliable after 8 hours and tests for Drugs are not reliable after 32 hours. No collection attempts will be made beyond these times.

9.0 DRUG AND ALCOHOL TESTING PROTOCOLS

Alcohol tests will be administered by a calibrated breath-testing device with a printout of test results. If a breath-testing device is not available, a saliva specimen may be collected for Alcohol testing. Where possible, positive saliva should be confirmed by Breathing Alcohol Technician (BAT)

Drug tests will be administered by a certified occupational testing service laboratory using construction industry Canadian Model for Providing a Safe Workplace standards set out for testing and will allow for verification testing if required. Regardless of the type of test or method, chain of custody protocols must be followed to ensure samples are collected and handled in a manner that allows for accurate analysis.

Alcohol and Drug test lab results are released directly to the designated Human Resources representative. Except for the release of information in accordance with this Policy and in situations affecting the health and safety of workers and the public, results of all testing will be kept confidential.

Chain of custody protocols is developed by the service providers engaged by the Company to collect and test samples. Chain of Custody protocols will not vary and remain consistent to ensure accuracy and legal defensibility. Protocols will be as following:

 Proper identification of the individual being tested (e.g. by photo identification).

 Steps to inform the individual being tested about the testing process.

 Secure testing methods and collection of samples to avoid tampering and contamination.

 Collection of samples within appropriate time limits for the substances being collected.(In postaccident and reasonable cause testing situations, samples must be collected immediately after the triggering incident, but collection attempts will end 8 hours after the incident for an Alcohol test, and 32 hours after the incident for a Drug test.)

 Verification that the samples collected were provided by the individual whose name is on them.  Appropriate handling and communication of results in compliance with this Policy and applicable privacy legislation.

Testing will take place in Canada.

Confirmed positive test results will be reviewed by a qualified Medical Review Officer (MRO) who will discuss the result with the Employee in an effort to determine whether a positive test could have resulted from the legitimate use of Medications or other medical explanations. The Employee concerned will be given an opportunity to explain the finding to the MRO who will then determine whether the result will be reported to the Company as a negative, a verified positive, or as a safety advisory.

9.1 Positive Testing Results

A positive Alcohol test will be one in which the Blood Alcohol Concentration (BAC) is at or above .04%.

A positive Drug test is one in which the amount of Drug in the sample identified by the confirmation test is at or exceeds the cut-off levels established by the construction industry Canadian Model for Providing a Safe Workplace standards for workplace testing programs .

In certain situations, Drug testing may include other drugs as identified as unique to particular requirements. Before additions can be made to a testing program, the benefits and objectives of the additions must be carefully considered, and a lab qualified to complete the testing must be contracted and advised of the Company's cutoff levels for the newly added drugs.

When urine or an oral fluid test is conducted in accordance with this Policy and is verified as positive, the individual who has been tested may request the MRO to direct the sample to be tested by an equally accredited laboratory of that individual's choice within 72 hours of receiving his or her results.

Any positive test result will be considered a violation of this Policy, whether or not the Drugs and/or Alcohol were actually consumed on Company Business, Company Premises, or Company Worksites. Failure to report directly for a test, refusal to submit to a test, refusal to agree to disclosure of a test result to Management or an attempt to tamper with a test sample are grounds for disciplinary action up to and including termination.

9.2 Negative Testing Results

If the Employee has a negative test result, Management shall immediately notify the Employee and advise him or her of the negative test result. The Employee returns to work if Fit for Duty.

The Employee is also to be advised that their return to work is subject to dealing with behavioral or performance problems that resulted in the testing. Supervisor may then deal with the performance or behavior problems as not related to Drugs and/or Alcohol. In the normal course, this may involve no action, a warning, or more serious disciplinary consequences up to and including termination. Accommodation of other disabilities, if such exist, may be appropriate.

Even when test results are negative, depending on the circumstances, there is the possibility that the Employee has a Drug and/or Alcohol problem. The Employee should be allowed to self-identify as having a problem with an addiction. In such circumstances the Employee shall be treated in the same manner as any other Employee who self-identifies a disability.

Where Management has reasonable cause or reasonable suspicion again in the future, repeat the steps in this procedure. However, if the results return negative again, discuss with Human Resources whether there are sufficient grounds to believe that the Employee is unfit for his or her regular duties on the basis that, whatever the reason, the Employee appears to pose a health or safety threat either personally or to others.

9.3 Drug and Alcohol Testing

All Employees will be subject to testing in accordance with the testing protocols as outlined in the following circumstances:

9.3.1 Pre-Employment and Pre-Assignment Testing’s: Pre-Employment Testing (new hire) and Pre-Assignment Testing (existing Employee) for Safety Sensitive Positions in branch locations with active customer requirements for Pre-access Testing. New hires requiring Pre-Employment Testing may not be assigned any Safety Sensitive Work until such time as the testing results are known.

All applicable individuals offered Safety Sensitive Positions must pass a Drug and Alcohol test as a condition of employment for that position, whether as a condition of hire for a new Employee or as a result of a change in position for an existing Employee.

Failure to pass the test or refusal to participate in the testing process means the applicant is not eligible for the Safety Sensitive Position (as per Belterra’s Critical Task List) – FRM 045) Reference section 14.0.The applicant may reapply for another Safety Sensitive Position in the future, subject to the requirement to pass a pre-employment or pre-assignment Drug and Alcohol test. The applicant may also be considered for other positions for which he or she is qualified.

9.3.2 Pre-access Testing:

From time to time it may be necessary for the Company to meet a client or customer’s Drug testing requirements (which may differ from those outlined in this Program), in order to qualify for work and

get access to their work sites. Prior to agreeing to do so, the Company will evaluate the requirements, then take appropriate actions as deemed necessary.

9.3.3 Reasonable Cause: Drug and/or Alcohol testing will be required whenever the Company has reasonable grounds to believe that the actions, appearance or conduct of an Employee while on duty are indicative of the use of Drugs and/or Alcohol. The decision to test shall be made by a Supervisor (where practicable, the Supervisor will engage a Human Resources representative or a second Supervisor on site to confirm the assessment of the Employee’s actions, appearance, and conduct, e.g. jointly present at private meeting with Employee).

Where applicable, the union or employee organization shall be notified. The referral for a test will be based on specific, personal observations resulting from, but not limited to, such indicators as:

 Observed use or evidence of use of a substance (e.g. smell of Alcohol).  Erratic or atypical behavior of the Employee (e.g. lack of balance, unsteady or staggered walk, muscle twitching, difficulty focusing eyes, uncoordinated movement of body and hands, memory loss, disorientation, or drowsiness).  Changes in the physical appearance of the Employee (e.g. face/cheeks flushed, face sallow, red, watery or glassy eyes, dilated or constricted pupils).  Changes in the behavior of the Employee.  Changes in the speech patterns of the Employee (e.g. slurred speech).  Additional indicators as outlined in the Reasonable Cause and Post Incident Drug and Alcohol Testing Referral Checklist (FRM 025).

9.3.4 Post Incident:

Post Incident Testing for Drugs will not be required unless it has been determined that an individual’s actions did or could have contributed to the incident and the incident in question involved.

Employees will be subject to Post Incident Testing’s for Drugs in accordance with the preceding criteria. Because post Incident Testing is an investigative procedure, testing is required even in the absence of direct evidence or suspicion of Drug use.

The decision to refer an Employee for a test will be made by the Supervisor investigating the incident (where practicable, the Supervisor will consult with a Human Resources representative or a second Supervisor). Where applicable, the union or employee organization shall be notified.

An incident (within the significant category) includes, but is not limited to:

 A fatality or serious personal injury to any individual;  An environmental accident with significant implications; 

 Significant loss or damage to any property, equipment or vehicles, including the estimated property damage, the cost of clean-up and recovery, and the cost of lost product with a total value of $450.00 or more ;

 Emergency shutdown of a facility or part thereof;

 Possible exposure to legal action or liability for the Company; or

 A near-miss incident that, in the Company’s opinion, may have resulted in any of the above.

In the case of an incident, the following procedures apply:

 Employees referred for Drug and/or Alcohol testing will only be those who are identified, with reasonable grounds, as having been directly involved in the chain of acts or omissions leading up to the incident;

 If the Supervisor investigating the incident determines there are no reasonable grounds to conclude that the use of Drugs and/or Alcohol by the Employee may have contributed to the incident, then

Drug and/or Alcohol Testing will not be required;

 Employees to be tested are not allowed to consume Alcohol or use Drugs, except prescribed

Medications according to the prescription, until after the test has been completed, or until they are advised a test is not required;

Employees are obliged to report the incident to their immediate Supervisor as soon as possible following an incident; and Employees are expected to participate fully in any subsequent investigation.

9.3.5 Return to Duty – Post Violation: In those situations where employment is continued after a Policy violation where an Employee tested positive, the Employee may be required to pass a return to duty test and may be subject to unannounced testing (as a condition of continued employment) for a period to be determined by the Company in consultation with a Substance Abuse Professional.

9.3.6 Return to Duty - Post Treatment: Any Employee assuming duties after treatment for a Drug and/or Alcohol problem may be required to pass a return to duty test. In addition, he or she may be subject to unannounced testing with a casespecific program designed to support his or her ongoing recovery.

The need for unannounced testing will be determined by the Company in consultation with a Substance Abuse Professional.

9.3.7 Failure or Refusal to Test: The following are violations of this Policy:

 Failure to report directly for a test;  Refusal to submit to a test;

 Refusal to agree to disclosure of a test result to the Company; and  A confirmed attempt to tamper with a test sample.

Compliance with the Program, including acceptance of Drug testing, is a condition of continued employment with the company. Refusal to be tested will be viewed as a failure to comply with Company policy and a breach of the program. Such a refusal will result in the Employee being referred to an SAP for assessment and, depending on the facts of each case (including the nature of the breach, the existence of prior violations, the seriousness of the breach, and the Employee’s own efforts to correct the situation), could lead to a treatment recommendation, a requirement to attend educational sessions, or to a variety of progressive disciplinary measures by the Company up to and including termination of employment for cause.

10.0 COMMERCIAL MOTOR VEHICLE DRIVERS THAT DRIVE IN THE USA

Any Employees who drive a commercial motor vehicle requiring a commercial driver’s license that drive into the United States will be subject to Drug and Alcohol testing standards that have been set by the United States Department of Transportation.

10.1 Documentation:

In a test referral situation, the following documentation must be completed as soon as possible (within 24 hours):

Reasonable Cause and Post Incident Drug and Alcohol Test Referral Checklist (FRM 025) Reasonable Cause Drug and Alcohol Testing Referral Form or the Post Incident Drug and Alcohol Test

Referral Form (FRM 026 and FRM 027)

11.0 REASONABLE GROUNDS SEARCHES

The Company reserves the right to investigate any situation when there are reasonable grounds to believe that Drugs and/or Alcohol are present on Company Premises or Company Worksites (including Employee lockers and lunch buckets), in violation of this Policy. Supervisors are responsible for identifying situations where a search is justified based on a combination of indicators which could include behavior, odor, or presence of Drug Paraphernalia. The Supervisor will be responsible for advising his or her manager of the situation, who, in consultation with the Union or employee organization if applicable, will make the decision as to whether to initiate a search. Seizure and future control of any Alcohol, Drugs, or Drug Paraphernalia will be determined in consultation with Management personnel, who will also advise whether law enforcement agencies will be involved.

12.0 LOSS OF LICENSE / IMPARED DRIVING CHARGE

All Employees who operate a motor vehicle on behalf of the Company are required to maintain a valid driver’s license. Any loss of license must be reported to the Employee’s Supervisor, and the Employee will no longer be qualified to drive on behalf of the Company outside of Company Premises.

Employees must inform their Supervisor immediately if they have been charged or convicted for an impaired driving offense while operating a Company vehicle or driving on behalf of the Company. Failure to report the charge or conviction will be grounds for disciplinary action up to and including termination of employment.

13.0 CONSEQUENCES OF A POLICY VIOLATION

13.1 General Procedures:

Any violation of the provisions of this Policy may result in disciplinary action up to and including termination of employment. In all situations, an investigation may be conducted and documented to verify that a Policy violation has occurred.

Therefore, Management has the authority and discretion to suspend any Employee who is believed to be involved in an incident that could lead to disciplinary action pending the results of the investigation. The appropriate action in a particular case depends on the nature and severity of the Policy violation and the circumstances surrounding the situation. At all times, however, the Company recognizes its obligation to accommodate an Employee with a disability or dependency to the point of undue hardship.

14.0 CONDITIONS OF CONTINUED EMPLOYMENT

For Potential Employees If an applicant tests positive and can establish that he/she suffers from a substance related disability, they will be informed that the conditional offer of employment will be honored by the Company provided they submit to the requirements of this Program. If the applicant agrees, he/she will be required to sign a Conditions of Employment – Potential Employees (FRM 028A)- an agreement which allows the Company to accommodate the individual knowing that he/she is not refusing treatment where required), and will be contacted for an interview by a SAP.

This interview will determine whether the applicant requires assistance in resolving problems with substance misuse. If after the evaluation by the SAP, the Company is advised that the applicant needs assistance, the applicant will be required to complete the education, assistance or treatment program recommended by the SAP prior to attending at the work site. In cases where the applicant tests positive but is advised by the Qualified Program Administrator following an SAP interview with the applicant, that the applicant does not need any such assistance and is not suffering from a disability, the Company will review its conditional offer of employment and determine on the individual circumstances of each case, whether the conditions for employment have been met or not.

For Current Employees: Any current employee who has a positive Drug and/or Alcohol test result will be temporarily removed from duties or reassigned pending assessment results and recommendations from a SAP. Employees who have a positive test result will be required to sign a Condition of Employment – Current employees (FRM 028B) and submit to an assessment by a SAP who will determine whether the employee requires assistance in resolving problems with substance misuse.

If after the evaluation by the SAP, the Company is advised that the employee needs assistance, the employee will be required to complete the education, assistance or treatment program recommended by the SAP before returning to work.

In cases where the employee tests positive but is advised by the Qualified Program Administrator following an SAP interview with the employee, that the employee does not need any such assistance and is not suffering from a disability, the Company will apply appropriate disciplinary measures, which includes up to the termination of employment.

The Company will follow any monitoring programs recommended by the SAP. Failure on the employee’s part to meet the requirements of the agreement during the monitoring period may be grounds for termination of employment.

The cost of assessment by a SAP and any subsequent rehabilitation and other related services will be the full responsibility of the applicant / employee.

15.0 OFF-DUTY SITUATIONS

In addition to the above, the Company may investigate any situation where off the job actions involving Alcohol and/or Drugs may have direct implications for the workplace, and will take appropriate action under the circumstances.

16.0 IMPAIRING MEDICATION INCLUDING MEDICINAL MARIJUANA

Is any impairing effect prescription including medical Marijuana, over the counter medications, mind altering synthetic or designer drugs or other substance which may have an effect on performance of safety sensitive duties. These include medicinal and recreational Marijuana; the use of which the company requirements and safety reasons in-line with this drug-free workplace program is unable to accommodate.

If the fact that an individual is taking or using an impairing effect medication or substance is not disclosed pre-duty by a safety-sensitive individual, and the individual tests positive, or is otherwise determined to be taking or using such, or is determined by the MRO to be a potential safety risk due to taking or using an impairing effect medication or substance, that individual will be subject to discipline, up to and including termination

17.0 RESPONSIBILITIES

All Belterra Employees and contractors covered by this Program share a legal and moral duty under the “Belterra Fit for Duty Program” and applicable occupational health and safety legislation, to ensure its successful implementation for the safety and wellbeing of all. This includes the duty to identify and report all safety issues and breaches of the program to the Company.

17.1 Employer Responsibilities:

An employer is required by law to provide a safe workplace and safe systems of work, which includes the elimination of known hazards in the workplace. Part of that duty of care includes taking reasonable precautions to ensure that all Employees on Company property and customer sites are in a fit condition to work so as to minimize risks both to themselves and others.

17.2 Employees Responsibilities:

Employees are expected to perform their job in a safe manner consistent with established Company policies. In addition, it is expected that Employees will:  Read and understand this Policy and their responsibilities under it;  Report Fit for Duty for any and all scheduled assignments and remain Fit for Duty while on Company Business, Company Premises and Company Worksites;  Seek advice and follow appropriate treatment if they have a current or emerging problem, and follow recommended monitoring programs after attending treatment;  Co-operate with any work modification related to safety concerns;  Intervene as appropriate to encourage a co-worker to access assistance before a Drug and/or Alcohol problem impacts performance or safety; and  Co-operate with the implementation of this Policy and with an investigation into a violation of this Policy, including any request to participate in the testing program as and when required to do so under this Policy. Because all individuals working for the Company have a shared responsibility for workplace safety, Employees are encouraged to look out for other Employees or visitors in terms of being Fit for Duty.

They are expected to take appropriate action to ensure no individual remains in an unfit condition on Company Business, Company Premises or Company Worksites, such that they may endanger themselves or others, by ensuring their Supervisor or another member of Management is advised of the situation.

17.3 Senior Management Responsibilities:

The senior management of the Company will be responsible for ensuring the adoption and implementation of this Program including:  Company Wide Implementation:

Ensure that frontline managers and any contractors they may oversee or audit understand and implement the Program in all their areas of responsibility.  Provision Of Resources: Ensure that adequate resources are allocated for the education, training, counseling and other requirements of the program throughout the Company’s offices and operations.

17.4 Supervisors Responsibilities:

 Actively engaging in training activities;  Understanding this Policy and all facets of implementation of supporting processes;  Applying this Policy in a consistent manner;

 Ensuring ongoing performance management to promote safe operations and effectiveness of the program;  Guiding Employees who seek assistance for a problem to appropriate resources (e.g. the Employee and Family Assistance Program or community services) while maintaining confidentiality as may be appropriate under the circumstances;  Taking appropriate steps to investigate any violation of the standards set out above;  Documenting the situation as soon as possible, within 24 hours (forms provided);  Making referrals for a Drug and Alcohol test in a post-accident or reasonable cause situation, as and when required to do so under this Policy;  Involving Human Resources, as required;  Involving the union or employee organization, as required;

 Ensuring that no disciplinary action is taken without the involvement of Human Resources or the Legal Department. Where Human Resources are not available, Branch Managers will be Designated Human Resources representatives at each site and will support carrying out this Policy. The Company may, at its discretion, designate other Employees as responsible to administer all or part of the Policy.

17.5 Human Resources Responsibilities:

 Resolving any questions regarding the interpretation of this Policy;  Supporting Supervisors in meeting their responsibilities;  Coordinating delivery of Employee education and Supervisor/Management training programs;  Supporting and assisting any Employee who seeks assistance for a problem;  Assisting Management in any investigation or meeting, in the development of any performance improvement plan, and the determination and administration of any disciplinary action;  Overseeing implementation of modified work, return to work agreements, or similar accommodation situations; and  Receiving results from lab testing and communicating them to Supervisor.

18.0 CONFIDENTIALITY AND PRIVACY

Confidentiality will be maintained to respect the personal privacy of individual Employees and to secure the integrity of any investigation. Consequently, information concerning the basis for any decision to investigate any alleged impairment of Drugs and/or Alcohol, the results of the investigation, the results of any Drug and/or Alcohol test, related medical records, or any individual's participation in a Drug and/or Alcohol rehabilitation program shall remain confidential.

Such information will be only be accessible to Company personnel on a strict need-to-know basis.

Medical information will be handled (including collection, use, disclosure, storage and retention) in compliance with all applicable legislation.

Note: In order to protect the confidentiality of the test results, all health assessment information must not be kept with the Employee’s personnel file.

19.0 DRUG AND ALCOHOL SUPERVISORS REASONABLE CAUSE FLOWCHART

Supervisor questions the Fitness for Duty of Employee

Use Reasonable cause and Post Incident Testing Referral Checklist

20.0 DRUG AND ALCOHOL SUPERVISORS POST INCIDENT FLOWCHART

Supervisor questions the Post Incident Fitness for Duty of Employee

Does the employee require immediate medical attention or transport to medical aid ?

21.0 DRUG AND ALCOHOL TEST RESULT FLOWCHART

22.0 CONTACT INFORMATION FOR COMPANY CONDUCTING DRUG & ALCOHOL

TESTING’S

LOCATION CONTACT INFORATION

Delta  1st Choice: 1100 Melville Street, Vancouver, BC  2nd Choice: 19237 122A Avenue, Pitt Meadows, BC  3rd Choice: 8207 Swenson Way, Delta, BC

After Hours: Services provided at - Option 3

Nanaimo   1st 2nd Choice: 2349 East Wellington Road, Nanaimo, BC Choice: 149 Ingram Street, Duncan, BC

After Hours: 1-800-440-0023 Option 2

Kamloops   1st 2nd Choice: 635 Victoria Street, Kamloops, BC Choice: 1103 12th Street, Kamloops,

After Hours: 1-800-440-0023 Option 2

Kelowna   1st 2nd Choice: 1715 Dickson Avenue, Kelowna, BC Choice: 3907 27th Street, Vernon BC.