Lab Results That Would
Prompt an Invalid Test Result
12 lab results that would
prompt an invalid test result are listed below. Should a person have an invalid
test result, the airline's medical review officer (MRO) will call the flight
attendant and ask her/him if they are on any medication. During that
conversation, if the MRO does not obtain information from that flight attendant
about a medication or situation that could explain why that urine sample came up
invalid, then the employee would be subject to a direct observation testing for
an invalid test result without medical explanation.
(7) A urine specimen from
a single specimen collection or the primary (Bottle A) specimen from a split
specimen collection is reported as an invalid result when:
(i) Inconsistent
creatinine concentration and specific gravity results are obtained (i.e.,
the creatinine concentration is less than 2 mg/dL on both the initial and
confirmatory creatinine tests and the specific gravity is greater than
1.0010 but less than 1.0200 on the initial and/or confirmatory specific
gravity test, the specific gravity is less than or equal to 1.0010 on both
the initial and confirmatory specific gravity tests and the creatinine
concentration is greater than or equal to 2 mg/dL on either or both the
initial or confirmatory creatinine tests);
(ii) The pH is greater
than or equal to 3 and less than 4.5 or greater than or equal to 9 and less
than 11 using either a colorimetric pH test or pH meter for the initial test
and a pH meter for the confirmatory test on two separate aliquots;
(iii) The nitrite
concentration is greater than or equal to 200 mcg/mL using a nitrite
colorimetric test or greater than or equal to the equivalent of 200 mcg/mL
nitrite using a general oxidant colorimetric test for both the initial test
and the confirmatory test or using either initial test and the nitrite
concentration is greater than or equal to 200 mcg/mL but less than 500 mcg/mL
for a different confirmatory test (e.g., multi-wavelength spectrophotometry,
ion chromatography, capillary electrophoresis) on two separate aliquots;
(iv) The possible
presence of chromium (VI) is determined using the same chromium (VI)
colorimetric test with a cutoff greater than or equal to 50 mcg/mL chromium
(VI) for both the initial test and the confirmatory test on two separate
aliquots;
(v) The possible
presence of a halogen (e.g., bleach, iodine, fluoride) is determined using
the same halogen colorimetric test with a cutoff greater than or equal to
the LOD for both the initial test and the confirmatory test on two separate
aliquots or relying on the odor of the specimen as the initial test;
(vi) The possible
presence of glutaraldehyde is determined by using the same aldehyde test (aldehyde
present) or characteristic immunoassay response on one or more drug
immunoassay tests for both the initial test and the confirmatory test on two
separate aliquots;
(vii) The possible
presence of an oxidizing adulterant is determined by using the same general
oxidant colorimetric test (with a greater than or equal to 200 mcg/mL
nitrite-equivalent cutoff, a greater than or equal to 50 mcg/mL chromium
(VI)-equivalent cutoff, or a halogen concentration is greater than or equal
to the LOD) for both the initial test and the confirmatory test on two
separate aliquots;
(viii) The possible
presence of a surfactant is determined by using the same surfactant
colorimetric test with a greater than or equal to 100 mcg/mL dodecylbenzene
sulfonate-equivalent cutoff for both the initial test and the confirmatory
test on two separate aliquots or a foam/shake test for the initial test;
(ix) Interference
occurs on the immunoassay drug tests on two separate aliquots (i.e., valid
immunoassay drug test results cannot be obtained);
(x) Interference with
the GC/MS drug confirmation assay occurs on at least two separate aliquots
of the specimen and the laboratory is unable to identify the interfering
substance;
(xi) The physical
appearance of the specimen is such that testing the system may damage the
laboratory's instruments; or
(xii) If the physical
appearances of Bottles A and B (when a split specimen collection is used)
are clearly different, the test result for Bottle A is one of the reasons
stated in (i) through (xi) of this section and/or was screened negative for
drugs.
Definition of
return to duty and follow-up tests
These 2 types of
testing are only conducted on employees who have violated the DOT drug
and alcohol rules and are being returned to safety sensitive functions.
A return to duty drug
test is required after a person has completed the recommended substance
abuse education and/or treatment required of her/him and has been released by a
substance abuse professional to return to their safety sensitive duties.
A follow up test
is conducted on DOT testing rule violators following return to safety sensitive
function for any DOT regulated employer. Follow-up testing is in addition to
random testing. It must be conducted at least 6 times within the first 12
months following return to duty and may continue for 5 years.
Below is a memo from Jim Swart, Acting Director of
Department of Transportation Office of Drug and Alcohol Policy Compliance, which
provides more background information about observed drug test collections. This
is the office that has recommended and created the enhanced observation process
that will become effective August 25th, 2008. Many of the members
have requested a point of contact within DOT to voice their concern and opinions
about this new rule. Mr. Swart can be reach at
jim.swart@dot.gov or by phone at 202-366-3784 or by fax at 202-366-3897.
New DOT
Urine Specimen Collection Guidelines – Effective August 25, 2008
As you know, the DOT revised 49 CFR Part 40 in a
Federal Register published June 25, 2008. The part 40 amendments are effective
August 25, 2008.
Some urine collection procedures were changed make
it more difficult to beat the DOT drug tests. The DOT Urine Specimen
Collection Guidelines have been updated to reflect changes to the collection
process. The new Guidelines – which are also effective August 25, 2008 – are
now available on our website at:
www.dot.gov/ost/dapc/udsc.html.
The Department changed the observed collection
procedures because there is ample evidence suggesting that more and more devices
are available in the market place designed to tamper with specimens (for
example, devices expressly designed to bring “clean” urine into collections so
specimens would test negative). Many of these were designed to be undetected
even if specimens were observed using the old procedures.
There are three basic types of devices. [Of
course, there could be other devices, but these are currently the basic three
devices]:
1. One device has a
long plastic tube connected to a bottle containing heated urine.
2. Another device
consists of a short plastic tube attached to a battery-heated plastic bag.
3. One device goes a
step further by replacing the tube with very realistic prosthetic genitalia
designed to match the employee’s skin tone.
The new direct observation procedures require the
observer to check for these devices when an employee is subject to an observed
collection. These new procedures are for those employees and situations for
which observed collections are already required, or in the case of #5 below, was
an employer’s option.
1. Employees with
dilute specimens with creatinine in the 2-5 range.
2. Employees with
invalid test results with no valid medical explanation.
3. Employees who tested
positive, adulterated, or substituted & their split specimens were not available
for testing [splits not collected; missing or destroyed in transit].
4. Employees who submit
out-of-temperature range specimens or tampered-with specimens at collection
sites.
5. Employees with prior
positives and refusals. Return-to Duty & Follow-Up drug testing under direct
observation goes from employer option under the old rules to required
under the new amendment.
The Guidelines state that employees having
observed collections must be instructed to raise clothing, just above the
navel; lower clothing, to mid-thigh; then turn around to show the
same gender observers they do not have prosthetic devices for beating the
tests. If no device is detected, the employee is permitted to return clothing
to its proper observed-collection position. Then the observed collection will
take place.
The following refusals to test are also noted in
the Guidelines:
1. An employee admits
to the collector that he or she adulterated or substituted their specimen.
2. The employee behaves
in a confrontational way that disrupts the collection process.
3. The employee fails
to follow the observer’s instructions to raise and lower their clothing and to
turn around to permit the observer to determine if the employee has a prosthetic
or other device that could be used to interfere with the collection process.
4. The employee
possesses or wears a prosthetic or other device that could be used to interfere
with the collection process.
5. The employee refuses
to wash his or her hands – after being directed to do so.
Part 40 and the observed collection procedures, as
always, apply to DOT-regulated testing.
Jim L. Swart
Acting Director
Office of Drug and Alcohol Policy and Compliance
U.S. Department of Transportation
"Flight Attendants
Helping Flight Attendants"
