IMPETECH GROUP

 Purpose

The purpose of this policy is to prevent any of the workforce becoming a risk to themselves or others by the abuse of alcohol, illicit drugs or controlled substances.

1. Definitions

Term	Definition
Abuse	Incorrect, improper or harmful use of any substance in such a way as intentionally to modify mood, behaviour or performance. It does not include the appropriate use of therapeutic medication as directed by a doctor. It includes use which can be described as dependency, habituation or addiction.
Alcohol	The intoxicating agent in Beverage Alcohol, ethyl alcohol, or other low molecular weight alcohol including methyl and isopropyl.
Company	Cairn India Ltd, its subsidiaries and affiliates.
Company Business	It includes all business activities undertaken by individuals in the course of the company’s operations whether conducted on or off Company Premises for which the individual is compensated.
Company Premises	All land, property (including camps), vehicles, offices, buildings and any other faImpetechities that are owned, leased, operated or otherwise directly controlled by IMPETECH.
Controlled Substance	Any substance which may be used in the production or manufacture of narcotic drugs or psychotropic substances.
Dependence	A condition in which an individual has lost control over the use of substance in question. Even after realising negative effect, the person has an increased need to use it and is unable to stop despite attempts to cut down or quit.
Drug	Any chemical or biological substance (including alcohol) that has known mind or motor function altering effects on the human body - a general term for any substance, stimulating or depressing, that can ultimately be habituating or addictive. 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.
Employee	ALL personnel working with or for Cairn – either in form of direct employees, direct consultants, third party consultants or direct contractors, people working for contractors and subcontractors.
Illicit Drug	Any drug or substance which is not legally obtainable and whose use, sale, possession, purchase or transfer is restricted or prohibited by law (e.g. street drugs such as marijuana and cocaine).
Impairment	The alteration of normal physical or mental function which results in diminished ability to perform assigned task in a safe and productive manner.
Narcotic drug	Narcotic drug means coca leaf, cannabis (hemp), opium, poppy straw and includes all manufactured drugs.

 

 

Term	Definition
Psychotropic substance	Any substance, natural or synthetic, or any natural material or any salt or preparation of such substance or material included in the list of psychotropic substances specified in the NDPS act, 1985.
Substance of abuse	This includes alcohol and illicit drugs. In addition, inappropriate use of prescription and “over the counter” medicines or other substances, may result in impairment to health, behaviour, judgment or job performance.

 

3. Procedure

To ensure compliance with the Drug and Alcohol Policy, the company will:

• Subject staff to testing and screening for drugs and alcohol abuse during pre-placement medical assessment for positions that are safety and environmentally sensitive; and during periodic and random medical examinations. Periodic Medical Examinations are done once in 3 years for employees less than 40 years of age and annually for employees who have completed 40 years of age.
• Carry out testing and / or screening for drugs and alcohol “For Cause” e.g.: post incident, substances found on site, suspected substance abuse, behaviour hazardous to personnel, operations or environment.
• Require that employees taking prescription drugs that are not recommended to be taken whilst driving a vehicle or operating machinery shall notify their supervisor.

Provide appropriate education, information, counselling and instruction necessary to have employees understand the workplace risks associated with the use and abuse of alcohol and drugs. The company may also faImpetechitate rehabilitation programs where appropriate. The company may provide reasonable assistance to a member of staff with an alcohol or drug abuse problem who is willing to co-operate in treatment for that problem.

• Require contractors to have a drug and alcohol policy in line with IMPETECH policy.

The company reserves the right at any time to inspect or search any of its own or contractor staff, any place or object on company premises to enforce this policy.

Non-compliance with the drug and alcohol policy will be viewed as a serious policy violation and disciplinary action will be taken which may lead to dismissal. Any other person violating this policy will be removed from company premises.

The contract and procurement department of the Company will include this policy as a part of contract documents for all contracts requiring man power services.

4. Responsibilities

The Managing Director and Chief Executive Officer will empower the Chief Operating Officer with the authority to implement this policy throughout the IMPETECH Group.

The Chief Operating Officer in turn will enforce the above policy through the Director HR and other Directors by divesting them with authority and resources to implement this policy.

The Human Resources department will communicate this policy to all employees and make it a part of the induction training for new employees. HR will also develop training for existing employees and supervisors who play a critical role in monitoring the implementation of this policy and assist departments in dealing with any case of non-compliance with this policy.

 

Managers are responsible for implementing this policy at all locations under their control.

Supervisors are responsible for initiating corrective action when they have reasonable cause to believe that an employee is not in compliance with the policy and to seek confidential and professional advice from the Medical Officer / Occupational Health Adviser to assess the likely safety risks of medication use reported by any employees.

Supervisors using contract personnel are required to ensure compliance with the provisions of this policy. Where practical, the agreement with the contractor should contain provisions mandating compliance with the terms of this policy. Supervisors with the assistance of the local Security Staff will implement search procedures.

All employees are personally responsible for complying with this policy for their own safety, the safety of others, and the protection of the Company’s image and interests. The staff should:

• Be familiar with the policy and ensure full compliance with the policy;
• Advise immediate supervisor if he/she is using medicines, which may have the potential to affect work performance;
• Seek help if he/she has problems related to alcohol or drug abuse;
• Advise management if he/she considers that a co-worker’s alcohol or drug abuse may be endangering the safety of other staff, contractors or the public;
• Cooperate with the responsible company personnel while conducting random medical checks for drug and/or alcohol abuse.

It is every employee’s responsibility to be fit for work.

5. Searching and Testing

Searching

Searches may be conducted to monitor compliance with the policy; consideration will be given to unannounced searches for substances of abuse on company premises, particularly in health, safety and environmentally sensitive positions.

Testing

Alcohol Testing

The recommended testing method for alcohol use is the measurement of breath alcohol concentration. This non-invasive and relatively simple method will be used in all locations and operating conditions. The maximum allowable blood alcohol concentration will be 0.03% in a test by breath analyser. Confirmatory blood alcohol testing will be carried out in case of legal requirement.

Drug Testing

The testing for drugs will be carried out in urine or other body samples (Saliva, Hair). Chain of custody and analysis procedures will be ascertained to guarantee the sample and result validity and confidentiality.

Failure to report directly for a test, refusal to submit to a test, refusal to sign the required acknowledgment form (Appendix 6), refusal to agree to disclosure of a test result to management, or a confirmed attempt to tamper with a test sample are all considered violations of this policy and are grounds for disciplinary action up to and including permanent removal from the Company.

6. Reporting unfit for work due to the influence of alcohol or drugs

Managers, with advice from the medical officer, have the right to determine if an employee is unfit for work due to the influence of alcohol or drugs. Where a Manager on observing the employee, makes the judgement that the employee is unfit for work, the employee will be referred to the medical centre and on confirmation of alcohol or drug influence, suspended immediately from duty with pay. Depending on the circumstances, action may be initiated under the disciplinary procedure.

7. References

• Drug and Alcohol Policy. Doc. No. IMPETECH/HSE/09/000002
• The Narcotic Drugs and Psychotropic Substances Act 1985
• OGP Guidelines for managers on Substance Abuse: Report No. 6.87/306 June 2006

 

Appendix - 1 Health, Safety and Environmentally Sensitive Positions

Health, safety and environmentally sensitive positions are typically positions in which incorrect action of the incumbent, or failure to act, can be a significant factor in events causing, or leading to, unsafe acts, environmental damage or material losses.

Division	Operational Activity	HSE sensitive position
ALL	Planning and execution of work	All field or site supervisory staff that have responsibility for the planning and execution of work.
Exploration and Drilling; Production	Exploration – land marine	Drivers, Explosive handlers, all marine crew (Including catering staff), seismic crew
	Drilling – land - offshore	Drill and work-over crew, roustabouts, drivers and heavy plant operators, Crane drivers, ballast control room attendant electrician, divers, wire line crew, radio operator, catering staff, rig move crew, cementing crew
FaImpetechity operations (plants, depots, pipelines, terminals)	Operations	Panel operators, field operators, oil movement operators, operation schedulers
	Maintenance	Welders, electricians, scaffolders, artisans, fitters, mechanics, riggers, crane drivers, instrument technicians, material warehouse attendants,
	Laboratories	Laboratory technician
	Construction	Crane driver, scaffolders, heavy equipment operators
	Land transport, road /rail	Drivers, riggers, vehicle maintenance staff
	Water transport	All marine operations staff working offshore, quay side crane drivers, jetty crew, shore captain
	Air transport	Air traffic controllers, aircraft maintenance staff
	HSE department	Duty medical staff, firefighting crew
	Drivers	All jobs involving driving

Appendix - 2 Guidelines for alcohol testing

Cut-off levels for alcohol in breath corresponds with blood alcohol concentration of 0.03% (30 mg per 100 ml of blood) in line with Indian regulations.

Determination of breath alcohol concentration

Breath analysis should be performed with a breath analyser that has been calibrated, standardised and approved for confirmatory testing. Breath sampling and analysis should follow the instructions accompanying the test equipment.

Where initial breath alcohol analysis shows that the cut-off level for alcohol is exceeded, the procedure is as follows:

• Breath analysis will be repeated after half an hour to confirm that the alcohol concentration exceeds the cut-off level.
• Where blood alcohol analysis is requested, blood samples should be taken immediately following the second breath analysis.

 

Appendix - 3 Guidelines for drug testing

Drugs to be tested for and their cut-off levels

Drug testing programmes should address at least the six drugs listed below. Each drug is given a detection limit or cut-off level both for the immuno assay and the confirmation test. The cut of levels may change as advances in technology or other considerations warrant identification at other concentrations

Drug	Immuno Assay	Confirmation Test
Barbiturates	200 ng/ml	100 ng/ml
Benzodiazepines	300 ng/ml	100 ng/ml
Opiates	300 ng/ml	150 ng/ml
Amphetamines	1000 ng/ml	500 ng/ml
Cocaine	300 ng/ml	150 ng/ml
Cannabinoids	20 ng/ml	10 ng/ml
Other Drugs
Methadone	750 ng/ml	100 ng/ml
Propoxyphene	300 ng/ml	300 ng/ml
Methaqualone	750 ng/ml	100 ng/ml
Lysergides	0.5 ng/ml	0.1 ng/ml
Phenocyclidines	25 ng/ml	25 ng/ml

 

Techniques and procedures:

For drugs, urine is the body fluid most often tested because it can be readily obtained by non invasive means. Reliable discrimination between the presence and absence of specific drug or their metabolites in urine is critical, not only to achieve the goals of the testing Programme, but also to protect the rights of the individuals being tested. Drug test results must be as error free as possible and defensible in the event that they are challenged in a court of law. Thus it is imperative to meet the following conditions:

-     Rigorous chain of custody procedures for test samples.

-     Reliable high quality laboratory testing and testing techniques.

-     A scientific valid evaluation and interpretation of test results.

 

Appendix - 4 Progressive Effects of Alcohol

		Progressive Effects of Alcohol
BAC (%)		Behaviour		Impairment
	•	Average individual appears	•	Subtle effects that can be
0.01–0.029		normal		detected with special tests
	•	Mild euphoria
	•	Sense of well-being	•	Alertness
	•	Relaxation	•	Judgment
0.03–0.059	•	Talkativeness	•	Coordination
	•	Joyous	•	Concentration
	•	Decreased inhibition
			•	Reflexes
	•	Blunted Feelings	•	Reasoning
	•	Dis-inhibition	•	Depth Perception
0.06–0.10	•	Extroversion	•	Distance Acuity
	•	Impaired Sexual Pleasure	•	Peripheral Vision
			•	Glare Recovery
	•	Over-Expression	•	Reaction Time
	•	Emotional Swings	•	Gross Motor Control
0.11–0.20	•	Anger or Sadness	•	Staggering
	•	Boisterous	•	Slurred Speech
	•	Stupor	•	Severe Motor Impairment
	•	Loss of Understanding	•	Loss of Consciousness
0.21–0.29	•	Impaired Sensations	•	Memory Blackout
	•	Severe Depression	•	Bladder Function
	•	Unconsciousness	•	Breathing
0.30–0.39	•	Death Possible	•	Heart Rate
	•	Unconsciousness	•	Breathing
>0.40	•	Death	•	Heart Rate

 

Appendix - 5 Selection Criteria for Breath Alcohol Analyser Instrument

The criteria for selection of an evidential breath alcohol instrument are both analytical and procedural. The instrument must conform to certain scientific standards, but also faImpetechitate procedural issues, which include, but are not limited to, data management, instrument certification, repairs, training of operating staff, portability and ease of use by law enforcement.

The instrument shall have following specifications as minimum.

1. semi conductor type of sensor,
2. portable battery operated (dry cells or rechargeable cells),
3. digital display,
4. operating temperature between 5^o to 50^o C,
5. light weight (less than 500 gms).

Following features / accessories are desirable (optional).

1. Audio alarm or visual display of different colour if the concentration is higher than the ceiling.
2. FaImpetechity of in build printer or plug of external printer device to deliver a comprehensive test record.
3. Carry case.

 

Appendix - 6 Drug Testing Acknowledgment Form

I, ______________________________________ , understand that as part of the drug

Testing process for pre-employment, periodic medical examination and or random testing; Cairn will conduct a drug test to determine my suitability for the position in which I am applying or currently hold.

I understand that a NEGATIVE drug test result is a condition of employment. I understand that if I refuse to undergo the testing, or if I produce a Positive test result for illegal drug use and or alcholol, I may be rejected for employment or terminated from employment.

I understand that if I produce a positive test result for Illegal drug use that information can be made available by court order or as part of a confidential investigation relating to employment with a criminal justice agency.

I have read and understood the information contained in this "Acknowledgement Form". I agree to undergo drug testing as part of the employment process.

 

Signature of Donor:    Date: