IMS9.6 Fitness for Work Procedure

1.0   PURPOSE

The purpose of this procedure is to ensure that all persons are fit to be engaged in activities at the workplace. Physical and psychological conditions such as fatigue, grief, stress and illness as well as alcohol and other drugs impairment can all result in reduced fitness for work. This procedure seeks to reduce individual and organisational exposure to the potentially harmful consequences of conditions or substances which reduce fitness for work. The fitness for work procedure is not intended to include or pre-empt every possible scenario that may be encountered in the course of administering a fitness for work program - it should be read and administered in the context of reason.

2.0   SCOPE 

This procedure outlines the SeaLink program for ensuring, as far as reasonably practical, that Employees, Contract Partners, Suppliers, Sub-Contractors and Visitors are fit for work on SeaLink premises and work sites. It states the monitoring and control methodologies for alcohol and other drugs, fatigue, physical and psychological fitness and travel related health risks associated with Fitness for Work.Sealink recognises that Employees may require assistance in overcoming difficulties with alcohol and other drug dependency, fatigue management and physical and psychological impairments. SeaLink commits to assisting those Employees who seek treatment and/or support, where appropriate. Where SeaLink is in control of a work site engaging Sub-contractors who have their own system for managing Fitness for Work, that system shall be used by the Sub-contractors, providing it meets or exceeds the requirements of this SeaLink Fitness for Work Procedure.

3.0   REFERENCES

This section contains all documentation that is either referenced or applicable to this document, Fitness for Work. Referenced documentation is either quoted from directly or cross-referenced to a specific chapter, section, paragraph or diagram.

• AS 4308:2008 - Procedures for the collection, detection and quantitation of drugs of abuse in urine.

• AS 4760:2006 - Procedures for the collection, detection and quantitation of drugs of abuse in oral fluid.

• Work Health and Safety Act and Regulations 2011

• International Convention on Standards of Training, Certification and Watch keeping for Seafarers, 1978 . STCW - Manila Amendments

4.0   DEFINITIONS

Nil.

5.0   REQUIREMENTS

5.1   Site Specific Requirements

From time to time and as SeaLink see fit, sites that SeaLink operates on may produce their own site specific requirements for Fitness for Work or part there off, of this procedure. Site specific Fitness for Work procedures are to be approved by the SeaLink management team in accordance with IMS4.2.3 Control of Quality Documents. 

5.2    Alcohol and Other Related Drugs

Impairment in the workplace from the use of alcohol or other drugs is prohibited and will not be tolerated by SeaLink.

SeaLink Supervisors / Masters should be prepared to manage situations where alcohol and other drug use have rendered an Employee unfit to perform normal duties or unfit to remain at the workplace.

Alcohol and other drug dependency are recognised as treatable medical conditions and SeaLink encourages those Employees who may be affected to seek assistance from appropriate organisations and support groups.

Where alcohol and other drug testing, using detection methods described by the relevant Standard, are used as part of this Fitness for Work process, it is purely to assist in the assessment as to whether a person may be impaired and therefore not fit for work.

5.3   Education 

SeaLink encourages all Employees to recognize;

• The importance of preparing oneself for work in a fit condition

• The health and safety implications of alcohol and other drugs abuse

• Early indication of alcohol and other drug abuse

• The impact of alcohol on health and home life

• The effects of alcohol and other drug consumption

The SeaLink DataWeb provides links to organisations providing education, information and assistance with alcohol and other drug issues.

5.4   Prescribed Medications

It is recognised that Employees are required to take medication as prescribed by a Doctor or as medication obtained over the counter from a Pharmacist. Some of these medications have the ability to cause impairment and reduce an Employee’s fitness for work.

Each Employee has an obligation to ensure that any medication taken is done so according to instructions from the Doctor, Pharmacist or information included in or on the packaging of the medication. Where medication advice is that it may cause drowsiness, this shall be discussed with the Supervisor / Master so that an assessment can be considered prior to the start of work.

Some medications containing amphetamines, codeine phosphate, morphine or synthetic narcotics are detected by drug testing methods. Testing personnel should be able to advise if medications will show positive. Information related to Doctor prescribed and / or pharmacy medications will be treated confidentially and only be used to consider suitable duties. In the event that a Doctor prescribed or pharmacy medication causes a positive drug test, a laboratory test should be conducted to confirm this result.

Employees are to notify their Supervisor / Master and develop an appropriate management strategy for the use of any medication that could impair their ability to perform tasks.

5.5   Alcohol Limits for SeaLink Employees

The following alcohol limits apply to all SeaLink Employees while undertaking work for SeaLink;

• Alcohol limits (per 100ml of blood) 0.00g or 0.00% BAC

5.5.1 Substance Reference Table - Drugs and Alcohol

5.6   Drug Levels of Presence for SeaLink Workplaces

Bringing illegal drugs into the workplace is prohibited and will result in instant dismissal.

Various methods are available to SeaLink for the testing for presence of illicit drugs. SeaLink will use the most appropriate method at the time after consideration of industry standards, technology development, consultation with testing service provider and community acceptance.

As SeaLink Employees may be required to participate in Clients Fitness for Work programs, including the screening by urinalysis, the following Table and Drug Level Limits (AS 4308:2001- Procedures for the collection, detection and quantitation of drugs of abuse in urine) are included here for reference.

5.7   Testing

All matters relating to alcohol and other drug testing and results of such testing, shall remain confidential.

There are a variety of methods that may be used for alcohol and other drug testing. Any equipment used will require that persons be trained in the use of the equipment prior to using for the purposes of this procedure. All Other Drug testing shall be conducted by an accredited service provider.

Upon request, all Employees, Contract Partners, Suppliers, Sub-Contractors or Visitors must submit for alcohol and other drug testing. Failure of individuals to supply a sample for analysis shall be considered a positive test result. All positive results shall be managed via the SeaLink rehabilitation / disciplinary process outlined within this procedure.

5.8   Challenge as to Fitness for Work

Any person who has reason to believe that another person in the workplace is impaired by the consumption of alcohol or other drugs should immediately notify the Supervisor / Master in charge of the area.

If the person is found to have an alcohol or illicit drug concentration level at or above the limits set within this procedure or as defined by the Clients procedure, then they must be managed via the rehabilitation / disciplinary process outlined within this procedure.

5.9   Testing for Cause

Testing for cause may occur in cases where an act or an omission by a person may have been a contributing factor to an incident or the person is suspected of being impaired by alcohol or drugs.

If the person is found to have an alcohol or illicit drug concentration level at or above the limits set within this procedure or as defined by the Clients procedure, then they shall be managed via the Sealink rehabilitation / disciplinary process outlined within this procedure.

5.10   Random Testing

Random alcohol and other drug testing may be conducted at any time on a Sealink or client operated workplace.

SealLnk Employees attending Client sites shall comply with the Client’s Fitness for Work provisions.

If the person is found to have an alcohol or illicit drug concentration level at or above the limits set within this procedure or as defined by the Clients procedure, then they shall be managed via the Sealink rehabilitation / disciplinary process outlined within this procedure, as well as being subject to the Clients disciplinary process.

5.11  Blanket Testing

Blanket alcohol and other drug testing may be conducted at any time on a Sealink or client operated workplace. In this instance all Sealink employees, including supervisors and managers are required to submit for testing.

Sealink Employees attending Client sites shall comply with the Client’s Fitness for Work provisions.

If the person is found to have an alcohol or illicit drug concentration level at or above the limits set within this procedure or as defined by the Clients procedure, then they shall be managed via the Sealink rehabilitation / disciplinary process outlined within this procedure, as well as being subject to the Clients disciplinary process.

5.12  Pre-Employment

Employees may be required to undertake alcohol and drug testing as part of pre-employment medical examinations. Employees are required to provide a negative sample prior to an offer of employment being confirmed.

In some circumstances employees may be required to undertake a second alcohol and drug test as part of site inductions. Employees are required to provide a negative sample prior to being allowed on site.

If the person is found to have an alcohol or illicit drug concentration level at or above the limits set within this procedure or as defined by the Clients procedure, then they shall be managed via the Sealink rehabilitation / disciplinary process outlined within this procedure, as well as being subject to the Clients disciplinary process.

5.13  Testing Procedure for Alcohol

Breath analysis shall be performed to provide a Blood Alcohol Concentration (BAC). Work must not be undertaken by anyone with a BAC exceeding 0.00%

Should the first alcohol test produce a positive result then the employee will be retested after 20 minutes during which time they will be supervised. During this 20 minute period the employee will only be allowed a maximum of one standard glass of water. No food or smoking is permitted during this time. The outcomes for a Positive Result will be implemented. Should the confirmation results prove to be negative the employee is to be paid for any time lost.

If the worker declines a first or second test, or registers a BAC reading exceeding 0.00% on the second test, or has an initial reading exceeding 0.02% then;

• The worker shall be sent home

• If a worker provides BAC reading at or higher than 0.05%, Sealink or the Client shall arrange for the worker to be transported home.

For a first offence;

• Suspended for 24 Hrs without pay

• Recommended to seek counselling

• Negative Result to be recorded before resumption.

• Regular testing to establish pattern of negative results

For a second offence;

• Suspended 24Hrs without pay

• Employee Must attend counselling.

• Negative result to be recorded before resumption

• Regular testing to establish pattern of negative results

For subsequent positive results;

• The employee shall be terminated and where applicable pay the full cost of demobilisation.

If an employee does not present for work their Supervisor / Master must;

• Make contact with the worker

• If there is reason to believe that the failure to attend work is alcohol related, then a breath analysis will be performed in accordance with the above procedure

5.14  Testing Procedure for Other Drugs

Testing for drugs will conform to AS/NZ 4308-2008 for urine sampling or to AS 4760-2006 for the collection of oral fluids (saliva).

Should the drug test record a presence above the prescribed levels as per Australian Standards 4308 or 4760 - 2006 the test sample is to be analyzed at an approved NATA laboratory for confirmation of type and levels of drugs detected. The outcomes for Positive Results will be implemented. Should the confirmation results prove to be negative the employee is to be paid for any time lost.

• Post accident / incident

Tests will be conducted after marine accidents and or incidents. Employees who record a confirmed positive test result may be subject to dismissal.

• Reasonable suspicion

Any employee who has a reasonable suspicion that an employee or contractor is under the influence of drugs or alcohol shall contact their Supervisor / Master or a Sealink Testing Officer. Testing will be conducted in accordance with the drug and alcohol procedures.

Following confirmation of an initial positive result, the employee shall be stood down pending confirmation via a second test;

• The second test shall be at the employer’s expense

• The employee’s stand down period shall be without pay

• Should the second test come back negative, the employee shall resume normal duties and shall be reimbursed the ordinary pay lost during the stand down period

• Should the second test come back positive the employee shall be stood down untill such time as they are able to provide a negitive test result.

Following the stand down the employee will be required to undergo a third test, at an approved testing facility, at the employee’s expense

• Should the third test come back negative, the employee shall be allowed to resume duties

• Pay lost during the stand down will not be reimbursed

• Should the third test come back positive employment shall be terminated

• Following resumption after the stand down and negative third result, the employee may be subject to random testing for the next 12 months.

If during a pre-employment medical a worker provides a positive sample, a second test of the provided sample must be undertaken. Should the second test return a positive result, any offer of employment will be withdrawn.

5.15 DISCIPLINARY ACTIONS - ALCOHOL AND OTHER DRUGS

Presenting for work or being present in the workplace under the influence of alcohol or other drugs is prohibited and will not be tolerated by Sealink.

Such behaviour is regarded as serious misconduct and shall result in disciplinary action and/or result in termination of employment with Sealink.

5.16 TOBACCO SMOKING

The ill effects of long-term smoking are well documented and include lung cancer, heart disease and blindness.

Smoking at Sealink premises, site offices and buildings, within four (4) meters of a building entrance, in Sealink vehicles, or any other area where passive smoking may be a health hazard is prohibited.

Employees are encouraged not to smoke or to quit smoking. Assistance can be obtained from several professional bodies including www.QuitNow.info.au and the various states and territories alcohol and drug education services.

5.17 FATIGUE

It is recognised that a person can cause harm to themselves or others due to fatigue. Whilst there is no specific process to monitor that a person’s fatigue over a shift may put themselves or others at risk, the following shall occur;

• If an employee believes that they are suffering from fatigue and could be placing themselves or others at risk, they shall immediately report this to their Supervisor,

• Any person who has reason to believe that another person in the workplace, is impaired by fatigue, should immediately notify the Supervisor / Master in charge of the area,

• The Supervisor / Master shall immediately take steps to manage the risk to a reasonable level.

Supervisors / Management have a general duty to manage the risk of the potential onset of fatigue or illness.

Employees are to notify their Supervisor / Master and develop an appropriate management strategy for fatigue that could impair their ability to perform tasks.

This may include (but is not limited to);

• Job rotation,

• Ad-hoc rest breaks as required,

• Proper management of meal breaks,

• Education of fatigue management,

• Allocation to alternate duties.

5.18 FATIGUE EDUCATION

5.18.1 What Causes Fatigue

• Sleep Loss

• Long periods awake (greater than 17 hours)

• Inadequate amount of sleep or poor quality sleep

• Sustained mental or physical effort

• Disruption to circadian rhythms (internal biological clock)

• Inadequate rest breaks (varies with the task)

• Health and emotional issues

• Time of day when work is performed (e.g. shift workers)

5.18.2 Consequences of fatigue

• Decreased alertness

• Slowed reaction time

• Poor hand-eye coordination

• Poor Communication

• High error rates

• Reduced vigilance

• Reduced decision making ability

• Poor judgement of performance, especially when assessing risks

• Being easily distracted during complex tasks

• Difficult responding to emergencies

• Loss of Awareness of critical situations

• Inability to remember the sequence of events

5.18.3 Signs and Symptoms of Fatigue

• Blurred vision

• Difficulty keeping your eyes open

• Head nodding

• Drowsy relaxed feeling

• Irritability

• Not feeling refreshed after sleep (waking tired)

• Falling asleep at work

• Micro sleeps – falling asleep for less than a second to a few seconds, and being aware that you have done so (usually due to sleep loss)

5.18.4 What You Can do to Manage Fatigue

• Avoid large meals 1 to 2 hours before sleeping

• Avoid high energy, high fat and high carbohydrate meals 

• Have an afternoon nap before the first night shift.

• Drink alcohol in moderation as it can disturb your sleep

• Make the room as dark as possible

• Reduce the volume of the telephone and the television

• Plan your social activities and ensure you get sufficient sleep

5.18.5 Fatigue Facts

• Being awake for 17 hours is the equivalent of having a blood alcohol Content (BAC) of 0.05%

• Being awake for 20 hours is the equivalent of having a blood alcohol Content (BAC) of 0.1%

5.19 ROSTER DEVELOPMENT

Sealink Rosters have been developed in accordance with the fatigue management guidance in the Standards for Training, Certification and Watchkeeping (STCW).

Sealink are required not only by law but by the companies EBA to abide by these conditions. As a marine operation Sealink have a number of legislative acts that need to be complied with, these include the Work Health and Safety Act 2011 and all Australian Maritime Safety Authority Acts and related Regulations.
 
During the development of rosters Sealink use a Fatigue Calculator that was acquired from the United Kingdoms Health and Safety Executive (HSE) so as to be able to compare the various rosters and ensure that there is a measure of the potential fatigue levels that staff may face.

5.20 TRAVEL TIME

Sealink Employees and Sub-Contractors whose place of rest is remote from the Sealink work site are encouraged to plan appropriate rest periods prior to and after their rostered shifts. Sleeping following the working of night shifts and prior to travelling extended distances is encouraged.

5.21 PHYSICAL AND PSYCHOLOGICAL IMPAIRMENT

An example of physical impairment is illness or inability to meet physical requirements of a position; examples of psychological impairment are personal grief or stress.

It is recognised that a person can cause harm to themselves or others due to physical or psychological impairment. Where an Employee becomes aware that they are suffering from a physical or psychological problem that will cause harm or problems to others, the following shall occur;

• If an Employee suspects that they may be suffering from physical or psychological impairment and could be placing themselves or others at risk, they shall immediately report this to their Supervisor. If any person has cause to suspect that another person is suffering from a physical or psychological condition which may affect their ability to safely carry out their tasks, then they should report this to a Supervisor / Master or the relevant Department Manager

• The Supervisor / Master shall immediately take steps to manage the risk and shall report to the relevant Supervisor / Master / Manager as soon as is practical

• Supervisors / Management have a general duty to manage the risk due to physical or psychological impairment

Employees are to notify their Supervisor / Master / Manager and assist in development of an appropriate management strategy for physical and psychological issues that could impair their ability to perform tasks.

Note: When considering options to assist Employees the following types of actions may be appropriate;

• Offering leave

• Alternative hours of work arrangements

5.21.1 Physical and Psychological Impairment Education

Sealink encourages all Employees to recognise;

• The awareness of health and safety implications of physical or psychological impairment

• The recognition of physical or psychological impairment

• The impact of physical or psychological impairment on health and home life

• The contribution of physical or psychological impairment to accidents and injury

5.21.2 Routine Medical Assessment Development

SeaLink will conduct routine annual medicals on all staff within the Gladstone Operations

The following list identifies the positions that have been identified as operationally critical

• All positions that are assigned to an operational vessel
• Maintenance Staff not in an administrative role 
  • Marine Fitters
  • Trades Assistants

The following list identifies positions requiring annual Medicals for personnel in lower risk positions 

• Administrative Staff
• Cleaners
• Gardeners
• Yardsman
• Storeman

SeaLink has engaged Sonic Health to assist in the development of the companies medical assessment via the following components

•  Job Task Analysis
• Occupational Physicians review
• Medical assessment components paperwork development

Job Role Profiling highlights the inherent risks associated with job roles as well as the tasks within the job role. The job role profile commonly includes photographs of the worker performing their tasks which act as a helpful reference guide. Subsequently, this information is collated outlines specific functional requirements inherent in each job role.

Following onsite observations,  data collected is analysed including comparison of findings against state and national WHS guidance material.

The following state and national guidance material will be consulted as a minimum:

• National Code of Practice for the Prevention of Musculoskeletal Disorders from Performing Manual Tasks at Work (2007)
• Procedure for Managing Injury Risks Associated with Manual Tasks — Lurgess-Limerick, R. (2008)

The JTA will include aspects including:

• Short job description
• Duties
• Critical demands
• Work rate and pace
• PPE, environment and similar        
• Functional demands including
  • Postural tolerances
  • Weights tolerances
  • Range of motion
• Job suitability, and potential hazards
• Recommendations and control measures (if required).

As part of the observation and reporting, SeaLink will also prepare a manual handling/suitable duties register for the observed tasks. The aim of the register is to identify and categorise tasks to assist with injury management and return to work processes. From the job task analysis and suitable duties register, Manual handling toolbox talks can also be created.

Annual Medical recommendations are based on review of the Job Task Analysis (Oversight by an Occupational Physician) 

5.21.3 Annual Medical

All Personnel identified in section 5.21.2 will undertake an annual medical 

5.21.4 Annual Medical Review on Completion

The HSEQ Manager will review the results of all completed medicals based on the independent medical examiners declaration. The staff member will be assessed by the medical examiner as being in one of the four categories. Based on the classification the following action will be taken

1. Is Fit to safely carry out the duties of the proposed employment without significant risk to self or others.
   1. No further action to be taken. Worker returns to normal employment
2. Is Fit for the proposed employment provided they work within the following restrictions
   1. Work is informed of requirements identified by the medical examiners (e.g. corrective lenses to be worn at work)
   2. No further action to be taken. Worker returns to normal employment
3. Is not Fit to safely carry out the duties of the proposed employment without significant risk to themselves or others
   1. Worker is stood down from normal work immediately after management is informed of the result. This includes phone and or email notification from medical centre before official medical paperwork is received.
   2. A meeting is arranged at first available opportunity with worker to discuss medical results and reason for "not fit" classification
   3. Worker and their manager will come to mutual agreement on a plan for the worker to rectify the cause of the "not fit" classification. This may include but is not limited to;
      • Worker takes personnel leave until they can be deemed Fit and have rectified cause of the initial classification. 
      • Worker is stood down with pay for a period agreed with management to rectify the cause of the "not fit" classification.
      • The worker is placed in another position (if available) where the cause of the "not fit" classification does not impact on the risk to the worker. 
   4. A worker who is deemed "not fit" will be liable for costs associated with assessments to have their classification modified to "Fit” unless expressly agreed to by the General Manager
   5. In the event that a chronic condition is identified with little to no expectation of the worker being re-classified as "Fit" the workers ongoing capacity for employment in the company will be reviewed.      
4. Requires further assessment / information before risk assessment can be completed
   1. Worker will complete medical once information has been made available.
   2. Requested information must be made available in an agreed timeframe.
   3. If a worker does not provide requested information within the agreed timeframe they are to be deem "not fit" and number 3 of this section is to be implemented 

5.22 NON WORK RELATED INJURIES

Sealink employees must report all non work related injuries to their immediate Supervisor / Master / Manager prior to commencing any work related activities.

The Supervisor/Manager in consultation with the Rehabilitation and Return to Work Co-ordinator shall be responsible for reviewing the injury and medical information to assess if the employee is fit for work without placing themselves at risk of aggravation or other workers at risk.

Those employees assessed as being unfit for work as a result of Non Work related injuries will be managed in accordance with Workplace Rehabilitation Procedure.

5.23 GRIEF OR STRESS

Managers and Supervisors / Masters should be prepared to manage situations where grief, stress or some other psychological disturbance renders an Employee unfit for work. If the situation arises that an Employee expresses or shows signs of grief or overwhelming stress, Sealink will offer assistance to the Employee.

Transportation home should be considered for persons suffering from grief or stress.

Note: When considering options to assist Employees with grief or stress the following types of actions may be appropriate;

• Offering leave

• Alternative hours of work arrangements

5.24 TRAVEL RELATED HEALTH RISK

Travel related health risks, if any, should be identified and documented for each site. Some projects such as those in remote or overseas locations may present a high risk of exposure to vaccine-preventable diseases and nominate immunisation and other preventative measures.

Management must consider risks of vaccine-preventable illnesses when allocating personnel to projects and ensure, as far as reasonably practical, that Employees are aware of potential communicable diseases, including those which cannot be immunised against and the measures that will protect them from such health risks.

Information about risks overseas is contained in the Department of Foreign Affairs Travel Advisories. These and other travel tips can be found at www.smartraveller.gov.au. Sealink Employees travelling overseas should also subscribe to automatically receive email updates of Travel Advisories.

5.24.1 RESPONSIBILITIES

Area Manager

• Provide adequate resources to Departments to fully implement this procedure

• To authorise if appropriate, any variation in work arrangements that goes beyond the hours of work limits specified by this procedure

• To approve all work rosters 

HSEQ Manager

• Ensure training in Fitness for Work is conducted across all Sealink 

• Ensure that the Fit for Work procedure is implemented at all Sealink

Operations Manager

• Provide adequate resources within the Department to fully implement this procedure

• To authorise if appropriate, any variation in work arrangements that goes beyond the hours of work limits specified by this procedure

• Manage the Disciplinary Actions in relation to Fitness for Work

• Actively assist the Supervisor / Master in managing this procedure

• Actively assist the Supervisor / Master in developing suitable management strategies for potential impairment in an Employees, Contract Partners, Suppliers, Sub-Contractors or Visitors ability to perform work through;

• Medication

• Fatigue

• Physical or psychological reasons

• Travel related health risks

• In consultation with the Safety Advisor, arrange for a provider to conduct any Alcohol and Other Drug testing that may be required

• Monitor the Fitness for Work procedure for each specific project

Supervisor/Master

• Manage this procedure for the Supervisors / Masters particular area of responsibility

• Develop suitable management strategies for potential impairment in an Employees, Contract Partners, Suppliers, Sub-Contractors or Visitors ability to perform work through;

  • Medication

  • Fatigue

  • Physical or psychological reasons

  • Travel related health risks

• Refer any Disciplinary Actions in relation to Fitness for Work to the appropriate parties

All Employees

• To present themselves at work in a fit state to be able to conduct their duties without presenting a risk to the health and safety of themselves or others in the workplace

• To comply with all requirements of this procedure

• Advise the Supervisor / Master of any potential impairment in ability to perform work through;

  • Medication

  • Fatigue

  • Physical or psychological reasons

  • Travel related health risks

5.25 TRAINING

All persons who have designated responsibilities for the administration of this procedure shall be adequately trained and be competent to do.

New and existing Sealink Employees shall be made aware of this procedure during the Sealink Induction and via toolbox talks.

5.26 CONSULTATION, COMMUNICATIONS & REPORTING

Employees within Sealink including Supervisors / Masters / Managers as well as Clients Representatives who have HSE responsibilities, should be consulted as necessary for guidance on fitness for work and/or for suggesting improvement opportunities.

5.27 MONITORING AND MEASURING

Compliance with and the effectiveness of this Fitness for Work procedure should be monitored by all Supervisors / Managers during the performance of work activities.

Measuring should be achieved by;

• The conduct of Site Observations, and

• Inspections and HSE Audits 

Incident Investigation Report Forms may provide an indication of the type, severity and frequency of fitness for work related incidents. The results of these observations, inspections, audits and reports will, over time, indicate a trend in compliance with and effectiveness of this procedure.

6.0   RECORDS

All records of Alcohol and Other Drug testing are confidential and will not be accessible to persons without the approval of the Area Manager after a request with good and sufficient reason i.e. by request of a regulatory official.