As you know, the D.O.T. Research and Special Programs Administration requires Pipeline Operators and their contractors that perform certain safety sensitive functions to maintain an Anti-Drug and Alcohol testing program that complies with all the guidelines set forth in 49 CFR Parts 40 and 199. These guidelines require that Operator and the Contractor to:

• Write and maintain both corporate and federal drug and alcohol policies

• Adhere to all federal recordkeeping and reporting protocols

• Train supervisory personnel

• Offer an Employee Assistance Program (EAP)

• Ensure that employees are randomly screened for 5 specific drugs at precise concentration levels by a properly certified government approved laboratory

• Ensure that drug and alcohol testing is conducted appropriately and as required by federal regulations

• Have all test results reviewed by a Medical Review Officer (MRO)

• Conduct alcohol a testing utilizing DOT approved instruments

• Provide referral to a qualified Substance Abuse Professional (SAP) for evaluation

Failure to comply with any of the above requirements can result in fines and penalties as well as the obvious civil liability exposure (for the Pipeline Operator) and the failure and/or loss of contracts on the part of the Pipeline contractors.