DOT Safety Regulation Update Fast-Fax™
Week of October 8, 2012
Foley Services Your Single Source for DOT Compliance
The Department of Transportation’s Office of Drug and Alcohol Policy and Compliance confirmed changes to the process by which heroin is identified in a urine sample. Under the new rules, testing for and identifying heroin use should be more streamlined.
Under the new rules, Laboratories and MROs will no longer be required to consult with one another about testing for morphine usage when the laboratory finds 6-AM in a urine sample. In a Final Rule issued on Wednesday, October 3, the Office of Drug and Alcohol Policy and Compliance chose to enact the rules unchanged from the Interim Final Rule issued on May 3 (see Fast-Fax 736).
6-AM and Morphine
Opiates, one of the ‘drugs’ tested for under the DOT 5-Panel are in fact not a unified, single substance, but instead a broad family that includes legitimate medications and illegal substances. Morphine, an opiate, is a legitimate pain management medication. Heroin, also an opiate, does not have any legitimate usage.
Heroin differs from Morphine in a variety of ways. Most importantly, in terms of drug testing, it is marked by a unique metabolite — 6-AM. When laboratories test your urine sample, they look for these metabolites as a sign of drug use. While heroin use may produce Morphine metabolites, it will also always produce 6-AM. However, Morphine (or any other drug) will never produce 6-AM: only Heroin will.
By this process, the MRO can tell if the positive test can be explained by the use of legitimate medication or not. Heroin has no legitimate use, so the MRO will know the positive cannot be explained away.
So What Has Changed?
During the last revision of the drug testing regulations, the DOT was confronted by industry figures who claimed that a provision of the rules was unnecessary. Under the current rules, if a laboratory finds 6-AM, the must consult with the laboratory about whether traces of morphine were also found in the sample. These traces would be lower than the normal cut-off level but higher than the laboratories’ minimum level of detection.
That was quite complicated, and, according to many of the experts that contacted the DOT, not necessary. DOT has agreed, and, in the Interim Final Rule, has removed the complicated relationship entirely.
The new regulations were scheduled to go into effect on July 3 of this year. ODAPC did not explain why they were delayed.
How Does This Affect You?
This is one of those ‘behind-the-scenes’ regulations that won’t affect you very much at all (unless you get a heroin positive). In reality, you probably won’t notice any changes.
The change does, however, streamline the process of identifying a heroin user; hopefully speeding up the time it takes to get the individual off the road.
Avoiding Trouble With Opiates
It is safe to claim that opiates are the cause of more unintentional violations of the regulations than any of the other controlled substances that the DOT tests for. Safety-Sensitive personnel need to be very careful when they are being prescribed a painkiller, as failure to follow the rules can lead to very serious consequences. Most importantly, they need to ensure that the doctor prescribing the drug knows that the patient drives a truck for a living.
In fact, this is good advice for any time a safety-sensitive individual is given a new prescription. If the individual is sent for a test, and has been taking a prescription opiate, the initial test will come back positive. The MRO will investigate, including contacting the prescribing doctor. One of the questions asked will be ‘were you aware of the patient’s job and would you still have prescribed this medication if you were?’ If the Doctor assures the MRO that they knew and that the medication will not affect the patient’s job-skills, the MRO will declare the test negative. If, however, the patient had not told the MRO that he or she was a truck driver the likely result is a confirmed positive test.
Ensure that all safety-sensitive personnel know to talk to their doctors BEFORE they start a new medication.
Editor: Roxanne Swidrak, Vice President, Operations • 1-800-253-5506 • www.FoleyServices.com • Vol. 112, No. 758 • © Foley Carrier Services, LLC. 2012