WASHINGTON REPORT BY LAURA SHELTON, CMP
DATIA Submits Comments on Department of Transportation Proposed Rules On March 23, 2017 DATIA submited official comments on the Department of Transportation’s (DOT) Procedures for Transportation Workplace Drug and Alcohol Testing Programs: Addition of Certain Schedule II Drugs to the Department of Transportation’s Drug-Testing Panel and Certain Minor Amendments Notice of Proposed Rulemaking. DATIA strongly supported the DOT’s
forward movement to add hydrocodone, hydromorphone, oxycodone, and oxymorphone (and their corresponding test cutoff concentrations) to the DOT testing panel, as well as to add MDA as an initial test analyte, and remove MDEA. Opioid and synthetic opioid use has reached epidemic proportions in the United States. To protect the safety of employees and the American public DATIA has consistently advocated for an increased drug testing panel for federally mandated drug testing programs, and we were glad to see this important program change finally come to fruition. DATIA also supported the majority of the other proposed changes including elimination of blind specimen submission requirements and prohibiting companies from using logos or language to give a sense of “DOT endorsement” of their products or services. Te one proposed change that DATIA
opposed was a provision that would require collectors, Substance Abuse Professionals (SAPs), MROs, Screening Test Technicians (STs), and Breath Alcohol Technicians (BATs) to subscribe to the DOT Office of Drug and Alcohol Policy and Compliance (ODAPC) list-serve. DATIA opposed this proposed change since turnover rate with collectors, STs, and BATs can be very high. In addition, many do not have individual email accounts with their employer, but rather a general email for all collectors, etc.
34 datia focus
within a collection facility. Furthermore, monitoring compliance would be very time consuming. DATIA agrees that subscribing to the list-serve is a best practice and could be listed as such within the regulations, but to be a regulatory requirement would be unatainable. View DATIA’s full comments at htp://
datia.org/datia/DOT_NPRM_3.23.17.pdf.
New Report Issued on Health Effects of Cannabis and Cannabinoids In one of the most comprehensive studies of recent research on the health effects of recreational and therapeutic cannabis use, a new report from the National Academies of Sciences, Engineering, and Medicine offers a rigorous review of relevant scientific research published since 1999. Tis report summarizes the current state of evidence regarding what is known about the health impacts of cannabis and cannabis-derived products, including effects related to therapeutic uses of cannabis and potential health risks related to certain cancers, diseases, mental health disorders, and injuries. Areas in need of additional research and current barriers to conducting cannabis research are also covered in this comprehensive report. Te purpose of the study was to understand if there is value in pursuing further investigation of CBD based products. Members can view the report at htp://
nationalacademies.org/hmd/ reports/2017/health-effects-of-cannabis-
and-cannabinoids.aspx?platform=hootsuite
HHS Issues New Notice Regarding Regulated Specimens Received with a Non-Regulated ECCF Te National Laboratory Certification Program (NLCP) issued two Notices in 2016 addressing laboratory actions and reporting when a laboratory receives a regulated specimen collected using an
incorrect electronic custody and control form (ECCF).1,2
Te NLCP recently
released a new notice providing additional guidance on the reporting of regulated specimens submited using a non-regulated ECCF, and is based on recent issues reported to the Department of Health and Human Services (HHS). 1. When a laboratory receives a specimen collected using a non-regulated ECCF and the Medical Review Officer (MRO) submits a request to change the speci- men to a regulated test, the laboratory must take action as described in the NLCP Decision Trees (page 4).1
2. If the laboratory does not change the specimen to a regulated test, the labora- tory must reject the specimen.3,4
3. When the laboratory rejects the speci- men, the laboratory should include the reason for rejection on the non-regu- lated CCF and the laboratory report to the MRO. For clarity and consistency in reporting, the laboratory should use the comment “Incorrect CCF” as specified in the NLCP Table U-2.2 Te labora- tory may choose to include additional wording to clarify the noted deficiency along with the standard comment (e.g., on the same line aſter the comment on the CCF or in a separate comment field on an electronic report).
If you have any questions concerning
these issues, please contact the NLCP staff by email
NLCP@rti.org or phone (919) 541-7242. The full NLCP notice can be viewed at
http://www.datia.org/ datia/NonRegulatedECCFNotice 03072017pdf.pdf ❚
References 1
April 8, 2016 NLCP Notice, Specimens Received with an Incorrect/Incomplete Custody and Control Form (CCF) and Decision Trees
2
August 9, 2016 NLCP Notice, Required Comments for Specimen Reports; Revised Table U-2.
3
HHS Mandatory Guidelines for Federal Workplace Drug Testing Programs, section 6.2
4
Department of Transportation Procedures for Transportation Workplace Drug and Alcohol Testing Programs, section 40.83(g)
spring 2017
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