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December 2010
Question - Can you direct me to the procedures for a torn seal during a DOT Urine collection?
Answer -Occasionally, the tamper-evident label/seal provided with the CCF will not properly adhere to the specimen bottle because of environmental conditions (e.g., moisture, temperature, specimen bottle material) or may be damaged or broken during the collection process. When this occurs, the collector should use the following corrective procedures:
(a) If the seal is broken while being removed from the chain of custody form or during the application of the first seal on the primary bottle, the collector should transfer the information to a new CCF and use the seals from the second form.
(b) If one seal is already in place on a bottle and the second seal is broken while being removed from the CCF or is broken during application on the second bottle or while the employee is initialing either seal, the collector should initiate a new CCF and provide an appropriate comment on the "Remarks" line in Step 5. The seals from the second CCF should be placed perpendicular to the original seals to avoid obscuring information on the original seals and must be initialed by the employee (both sets of employee initials should match). The collector should draw a line through the Specimen ID number and bar code (if present) on the original seals to ensure that the laboratory does not use that number for reporting the results. The collector should not pour the specimen into new bottles.
(c) In both cases, the collector should ensure that all copies of the original (first) chain of custody form are destroyed or disposed of properly (e.g., shredded, torn into pieces). (DOT's Specimen Collection Guidelines)
annual random testing rates for 2011. These rates will remain the same as the 2010 year. These rates can be viewed at be viewed on ODAPC's website at: http://www.dot.gov/ost/dapc/rates.html
The testing rates for DOT/FMCSA have not changed; they are still 50% for drugs and 10% for alcohol.
Why are we testing for Heroin and Not Synthetic Opioids?
Patrice M. Kelly, Deputy Director, U.S. D.O.T., Office of Drug & Alcohol Policy and Compliance recently provided informative updates on the new ruling concerning Heroin. The most significant portion was an answer to the question of why are we testing for Heroin (see article above from Dr. Ben Gersen) and not prescription drugs.
First, D.O.T. must follow the same testing of drugs as specified by Health and Human Services (HHS).
How the testing occurs can vary, but not the basic specimens, drugs and levels. Also, going forward ODAPC will have a representative seat at the discussion table around drugs of abuse and there will be a voice presenting synthetic opioids.
Note: The reason for testing the Heroin metabolite is that there is a great increase of Heroin product shipped into the U.S., yet it is not showing up proportionally in the U.S. testing results.
Opioids - Why So Much Interest?
This opioids issue is going to become more and more of a topic for discussion, understanding, and policy making, both at a company and regulatory level. There are various issues with prescription Opioids, but we are focusing as to why opioids are becoming an issue and the need to test for including the unique heroin metabolite 6-acetylmorphine or 6-AM.
It has become the standard practice for physicians; in fact most feel an obligation to treat their patient's complaints of both acute and chronic pain. These complaints are subjective, as there is no instrument or laboratory test to quantify or confirm "pain". Therefore physicians apply a treatment so ideally, the pain is no longer felt.
Opiates are at the top of the list of drugs. Obviously, doctors have a limit as to how much to give, but many times the level that they feel is acceptable "to allow function" may be at odds with an employers' view about workplace safety.
Statistics for number of deaths from 1999 to 2006 show a steady trend as to use of drugs as follows:
| 1999 | 2006 | |
| No drug involved | 14% | 7% |
| Specified drugs other than opioid analgesics | 47% | 34% |
| Only non-specified drugs | 18% | 22% |
| Any Opioid analgesic | 21% | 37% |
So use, mis-use and the problems opioids cause in ensuring safety are increasing, but there is also another issue – The interpretation of the drug testing results around this class is often complex.
Why is this?
The parent drugs metabolize to active metabolites that are available commercially. For example, Heroin has an active metabolite of Morphine, as can Codeine. Thus you cannot look for Morphine as an indicator of Heroin exclusively. How do you know it is not due to a Codeine prescription?
So where did a positive test for Morphine come from?
The possible sources are Heroine, Codeine, Morphine, and Poppy Seeds. What does aid in interpretation for heroin is the 6-AM. Thus the requirement for testing 6-AM in all HHS and DOT testing.