July 2007
Questions & Answers
Question - I received a test result from the MRO (Medical Review Officer) that states: Negative – Dilute Re-Collection Direct Observation Required. I have received test results with negative dilute before so why does this one state an observed re-collection required?
Answer - In May of 2003, there was a revision to the DOT FMCSA 49 CFR Part 40 regulations regarding the verification of a test result involving dilution. Depending on the creatinine concentration, if the level is greater than 5 mg/dl the test result would be a dilute and re-collection may not be required. If the test result is 2mg/dl or more, but less than or equal to 5ml/dl the test result is a negative dilute with a direct observation required, if it is less than 2mg/dl or no creatinine detected the test result would be considered a positive due to adulteration or substitution.
As the employer, if the MRO informs you that a positive drug test was dilute, you simply treat the test as a verified positive test. You must not direct the employee to take another test based on the fact that the specimen was dilute.
If the MRO informs you that a negative drug test was dilute, take the following action:
(1) If the MRO directs you to conduct a recollection under direct observation, you must do so immediately.
(2) Otherwise you may, but are not required to, direct the employee to take another test immediately. Such recollections must not be collected under direct observation, unless there is another basis for use of direct observation. Refer to DOT FMCSA CFR Part 40 §40.67 (b)(c) for further clarification.
l You must treat all employees the same for this purpose. For example, you must not retest some employees and not others. You may, however, establish different policies for different types of tests (e.g., conduct retests in pre-employment test situations, but not in random test situations). You must inform your employees in advance of your decisions on these matters.
l If you direct the employee to take another test, you must ensure that the employee is given the minimum possible advance notice that he or she must go to the collection site.
l If you direct the employee to take another test, the result of the second test -- not that of the original test -- becomes the test of record, on which you rely for purposes of this part.
l If you require employees to take another test, and the second test is also negative and dilute, you are not permitted to make the employee take a third test because the second test was dilute.
l If you direct the employee to take another test and the employee declines to do so, the employee has “refused the test” for purpose of this part and DOT agency regulations. Refer to DOT FMCSA CFR Part 40 §40.197 for further clarification
New Name and New Logo –
American Alliance Drug Testing
"A Solution to Confusion" SInce 1995
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The month of June proved to be a challenging and exciting month for all of us at C-DATA. We started the month off with planning and staffing a booth at the Western Tow Show in Reno. The following week we had a booth with CDTOA at the Las Vegas Truck Show, followed by a booth at the CHP Commercial Vehicle Safety Summit in San Diego and then our CDTOA/C-DATA Summer Board Meeting in Rancho Mirage.
I have to admit it is always refreshing to reunite with our existing clients, some that have been with us since the beginning, meet new and potential clients and listen to the tales, both good and bad others have experienced in the business. Best of all, was the positive feedback that we have received from our clients, affiliates, vendors and the enforcement community. It makes all the hard work worthwhile when we know we are doing something right.
One of the misconceptions we have encountered because of our name, “California” Drug & Alcohol Testing Alliance or the C in C-DATA, is that we only do business within California, when in fact, since the DOT regulations are a federally mandated requirement, we have always been nationwide. This was a common question we all received at the Tow Show and Las Vegas Truck Show. So we felt it was time to consider implementing a name change that would reflect more of a nationwide or national perception.
 L-R: No. Membership Serv. Director, Betty Plowman and C-DATA CS /New Accounts, Diana Renteria staffing the booth at the Western Tow Show in Reno. |
California Drug & Alcohol Testing Alliance (C-DATA) now has a national subsidiary dba called - American Alliance Drug Testing (AADT). See logo left. We believe that this new name and new logo will provide national and even international appeal since there’s Central and South “America” based businesses we could market to. Only the name has changed, we will still offer the same outstanding service and professionally trained Customer Service Team.
So beginning this month, you will see the new name and logo on our literature, advertising and website. We will continue the C-DATA name and operate almost as dual companies until we can transition totally into the American Alliance Drug Testing name some time in the future. We realize the transformation will take a little time, but hopefully not as long as it has been to have our current name referred by our acronym C-DATA, instead of the older CalDATA which we changed from over 5 years ago.
After all, I consider myself an optimist who believes change is good and you truly can teach an old dog new tricks….it just takes a little more time and patience!
Dilute Drug Test Result
As our random selections increase with the construction industry season in full swing, we receive more calls with various questions. One of the more frequently asked questions is, “what does the employer need to do when they receive a test result that is a dilute?”
Note that throughout this article, when I refer to the applicable federal regulations, I’m referring to CFR 49, Parts 40 & 382; these regulations can be found in Section 5 of the AADT Company Compliance Manual or in the AADT website at www.aadrugtesing.com under links at DOT Office of Drug and Alcohol Policy and Compliance at www.dot.gov/ost/dapc or Federal Motor Carrier Safety Administration at www.fmcsa.dot.gov.