established
that well developed safety programs that include drug and alcohol
testing are not only legal but actually have a significant impact on
reducing workplace incidents.
That’s why it’s important to consider a few basic
rules when choosing a drug testing technology as part of a “Fitness
for Duty Program.”
First become familiar with and follow all
legislative requirements for the state or region where you operate,
and build protective measures into the process that protects workers
and your company.
Second, look for defensible results, in the event of
a grievance or litigation. Thirdly, address the business needs of
each segment of your organization.
Legislative requirements include complying with
privacy acts, labor laws and human
rights
guidelines. Some protective measures include the continuity of the
sample (chain of custody), split sample collections, medical review
of results and proper storage of information. In terms of business
needs, many companies today have different needs within different
divisions or geographic areas.
It may be as simple as union workers in one division
and non Union workers in another. Or, it may be more complex like
one division being located in the USA while another is located near
the Arctic Circle, with different legal requirements (Canada and
USA) and different resources available in each area.
This is why it is important to understand the
positive and negative aspects of the technologies you’re considering
so you can make an informed decision as
to which
one will provide the best possible results and meet the company’s
business needs. There are two main fluids which are used for
testing, urine and oral fluid (saliva). The first technology is
laboratory based urine testing which is the Gold Standard method.
This method has been in use the longest and is considered the gold
standard because of legal defensibility and accuracy when done in a
certified laboratory setting.
The second fluid medium is oral fluid (saliva),
which can also be collected and analyzed by a laboratory. In terms
of defensibility, the choice of urine testing in a certified
laboratory is the most proven method with proper custody and control
of the specimen, peer reviewed publications supporting approved
cutoff levels, and years of success against countless challenges.
Typically, you should receive laboratory confirmed
Medical Review Officer (MRO) verified results within 24 to 36 hours
from the time of collection. Another technology that is currently
used allows the collector to test for drug sat the point of
collection. This is sometimes referred to as Point of Collection
Testing (POCT), Table Top Testing, Quick test, Screening Test, etc.
This technology allows you as a company to receive
passing test results in a shorter period of time, typically within 4
hours. What you give up is accuracy. Point of Collection Testing
devices are plentiful and come in all shapes and sizes.
Those that are FDA approved only need to be within
25 percent of the approved cutoff levels. Those that are not FDA
approved are not held to this wide range of level of accuracy.
Therefore, it is very important that Quality Control is conducted by
a laboratory on each lot which is produced to ensure some level of
accuracy. POCT testing technology will give instant results on
negatives, and if nonnegative, the specimen should be sent to a
certified laboratory for confirmation. Due to the limited accuracy
level that POCT technology provides, it is easy to understand that
there will be some false positives and some false negatives. But
there are situations where the business needs outweigh the lack of
accuracy. This fact needs to be taken into consideration when
choosing this
testing method. If the business needs require faster results than 24
to 36 hours, then maybe an instant test would be the answer.
Decisions on whether a result is
non negative should never be made before the instant test result is
confirmed by a certified laboratory and verified by a qualified MRO.
If a definitive decision is made of the nonnegative instant test
result the company is incurring a legal risk since that approach
cannot be legally defended. The better approach would be to ensure
that the individual does not perform a safety sensitive job or work
in a safety sensitive area until the confirmed verified result you
can act on is obtained.
The newest technology that has
been introduced is oral fluid or saliva testing. This technology is
appealing because every specimen is collected under direct
observation making cheating very difficult. Also, oral fluid
collection does not require a washroom or the need to handle a urine
specimen.
Cheating or specimen substitution has
become
a real concern in recent years and is a constant dilemma for the
trained urine collector and the laboratory. There is a perception
that oral fluid testing tests for impairment. This is not true. What
is true is that if the test is positive the chance that the
substance is in your system at a point and time of the collection is
greater.
Impairment is based on signs and symptoms such as
unsteady gait, slurred speech, red eyes, etc. The drug test just
adds to the reasonable and probable grounds to believe the
individual is impaired.
That same principle applies to workplace drug
testing. Employees with drug levels in their system above or below
the cutoff levels may not be impaired. Here is data to support that
workers who test positive are at higher risk to have an accident.
Drug testing is a safety program just like wearing hardhats or
utilizing other personal protective equipment. It is true that oral
fluid testing provides results that are closer to the blood level at
the time of collection than
urine
testing, but neither method can test for impairment.
Like urine testing, there are two
different oral fluid testing technologies. The first is laboratory
based which can produce the most accurate results. To clarify no
laboratory is certified by DHHS (Department of Health & Human
Services) for oral fluid testing. The reason is that for DHHS to
certify laboratories for that technology all the laboratories need
to produce the same result in specimens within a narrow range of
acceptability.
To date the laboratories have not
been able to meet this standard. The second problem with oral fluid
technology is the cutoff levels that are applied to report a
verified positive result.
Again there are companies with a
business need that is best met utilizing oral fluid testing. These
needs may include very remote areas with lack of urine collection
facilities, or transportation issues, or a high prevalence of
cheating.
Oral fluid testing has a place
but its shortfalls must be considered. Oral fluid is a promising
alternative to the gold standard of laboratory based urine testing
but more definitive studies need to be done to validate cutoff
levels.
Keep in mind that even though oral fluid has a
closer relationship to blood levels it does not measure impairment.
At this time, a laboratory confirmed MRO verified oral fluid result
is more legally defensible than an instant urine test, but not as
defensible as the gold standard urine testing technology. The
turnaround time on laboratory based oral fluid testing should be
close to the 24 to 36 hours achieved with laboratory based urine
testing but may be slightly longer due to the sophistication of the
instrumentation and techniques required in the laboratory
confirmation process.
The second oral fluid technology is instant or POCT
oral fluid testing. At this time there are no FDA approved oral
fluid instant testing devices, so accuracy is a real concern. We
know that the instant urine devices that are FDA approved must
perform within plus or minus 25 percent of the stated cut off
levels, but we have no similar data on the instant oral fluid
devices because they have not been validated as to what standard
within which they can perform.
With this lack of verification of performance,
instant oral fluid testing is like flipping a coin. We really do not
know if the result can be trusted or not within a given range of
acceptability. Companies with “Fit for Work Programs” that include
drug testing need to understand that no matter what technology they
utilize to meet their business needs they must be aware of the
positive and negative aspects of each of the technologies and choose
wisely. Still, “Fit for Work Programs” have helped to improve safety
in the workplace and are an integral part of a comprehensive
workplace safety program.
FSM
