Substance Abuse Prevention Program

Construction projects include renovations, new construction, tenant fit-outs, utility upgrades, and major repairs.

You must enroll your construction project in SAPP if it meets all these criteria:

• The contract value is equal to or greater than $300,000.
• The contract was bid and executed on or after January 1, 2009.

If your construction project value exceeds $300,000, you must also enroll it in the Contractor Safety Assessment Program (CSAP).

Each SAPP for a specific construction project. Use a SAPP to meet Harvard project labor agreement and construction safety standard requirements.

• SAPP requirements apply to all dedicated contractor project staff and tradespeople of all tiers.
• General contractors (or other contractors who are contracted directly with Harvard) are responsible for establishing, maintaining, and overseeing the construction project SAPP.

OHS Training & Consulting, Inc., a third-party drug screening and substance abuse prevention program administrator, helps implement SAPP at Harvard.

Through agreement and as a recipient of federal funding, Harvard must follow federal Health and Human Services regulations for illicit substances, including marijuana.

When the federal government changes screen or confirmation threshold cutoffs or adds new drugs or procedures to screen for, Harvard's substance abuse screening is automatically amended.

Massachusetts laws do not affect an employer's authority to enact and enforce workplace policies restricting employee marijuana consumption. They also do not amend existing penalties for conduct involving performing any task while impaired by marijuana. Accordingly, Harvard's pre-hire, post-accident, and reasonable suspicion substance abuse screening still includes marijuana.

OHS administers pre-hire screenings, which screen for key substances identified as a safety concern in the construction industry.

All construction project staff must complete pre-hire drug screening before reporting for work on each specific project.

Staff undergo OHS drug screening unless they provide test documentation within the past six months from a lab certified by the Substance Abuse and Mental Health Services Administration.

Staff must receive their screening passport before they can begin SAPP screening. Every staff member must have their own passport to submit a drug screening. Staff without passports cannot be screened.

Each construction project manager and general contractor has job-specific passport authorization forms. Subcontractor staff can use these forms to request and authorize drug screening.

Notify OHS if your DER changes during the construction project.

After receiving their screening passport from their DER, staff must bring either of the following to the screening facility:

• A picture ID and signed paper copy of the passport.
• A signed digital copy of the passport.

After OHS administers drug screenings, they instantly analyze the results onsite.

1. OHS reports negative results electronically within two hours of collection.
2. OHS sends positive and inconclusive samples to certified labs for analysis. They usually send results in two to three days.
3. The appropriate general contractor DER receives emails of instant and lab-based screening results.
4. After a negative SAPP test, each staff member receives a passport card (a small plastic card approximately 3.5 in by 2 in). General contractors can provide physical or electronic passport cards for their staff.

Negative drug screening results expire after a certain period:

• Staff who travel between construction projects: Results expire six months from the results date.
• Staff who remain on a single construction project: Results expire after the project ends.