… Will DOT approve oral fluid drug testing??? …


by Robert Schoening, Former Drug and Alcohol Program Manager for the US Coast Guard …

The use of oral fluid for alcohol testing has been in place since 1994 when it was first allowed to be used as a screening test for alcohol.  In order to meet this goal, the alcohol screen devices were required to meet certain specifications as designed by National Highway Traffic Safety Administration (NHTSA). 

The original Model Specifications for screening devices that could measure alcohol were published in the Federal Register on August 2, 1994, by NHTSA in order to meet the planned implementation date of January 1, 1995 for alcohol testing. The impetus for the development of these particular Model Specifications was for the implementation of required alcohol testing for DOT regulated employers as required in the “Omnibus Act*”  The “Model Specifications for Screening Devices to Measure Alcohol in Bodily Fluids” established performance criteria and methods for testing alcohol screening devices to measure alcohol content.  It is these modal specifications that are required to be met in order for a screen test device to test for alcohol in bodily fluids.  There is another set of Model Specifications in place for Evidential Breath Alcohol testing devices.

The use of Oral Fluid for testing for drugs of abuse has been in place for a number of years.  Prior to April 1998, it had been used in several different settings including the general or non-regulated workplace.  There was not established standards in place and oral fluid testing was not an allowable test methodology for DOT regulated employers.

On April 28-30, 1997, SAMHSA held a three day open meeting of the Drug Testing Advisory Board. The purpose of this meeting was to explore other methods and specimens that could potentially be used to test for drugs of abuse.  The specimen sources and testing methodologies that were discussed were oral fluid, hair, sweat patch, and urine on–site testing devices and was appropriately titled “Drug Testing of Alternative Specimens and Technologies”.  

This meeting was the beginning of exploring the different specimens and testing methodologies that could be used by DOT and other Federal agencies in the future.  After the initial meeting in April 1997, there was a series of meetings by DTAB to explore the use of alternative specimens in workplace drug testing.  Meetings and discussions continue to this day exploring and discussing the use of alternative specimens, not only at the DTAB meetings, but also at the annual meetings of drug test associations.

During 2006, there was an effort by SAMHSA to publish proposed Mandatory Guidelines for Federal Agency Drug Testing incorporating alternative specimens.  These proposed Mandatory Guidelines, which included testing using oral fluids, never saw the light of day as there was vigorous opposition from various Federal Agencies, including DOT.  Several of the Federal Agencies recognized significant issues in the guidelines which were annotated in comments to Office of Management and Budget (OMB).  The proposed guidelines were required to be sent to all Federal Agencies for comment by Office of Management and Budget.

The next article will go into the further development of oral fluid for use by DOT and DOT regulated employers.

*In a future article, there will be a discussion of the Omnibus Act and the impact of that Act on the drug and alcohol test industry.

Stay tuned for more articles by Robert Schoening

Click Here for Oral Fluid Drug Testing Development Part – 2

Click Here for Oral Fluid Drug Testing Development Part – 3

About Bob Schoening 

Robert Schoening is well renowned for his knowledge and influence in the drug-testing arena. As the Drug and Alcohol Program Manager for the US Coast Guard (December 2001-March 2013) he developed and managed a successful drug testing program for the marine industry nationwide and internationally.  During this time he developed and implemented a new compliance audit checklist as well as the writing and publishing a new Marine Employers Guidebook for Drug Testing.  He is also the author of the federal regulation commonly known as the two-hour alcohol testing for maritime incidents. 

Robert’s drug testing career began in the Navy Medical Department, where he received the Navy Achievement Medal for his work on development of the Navy drug-testing program which was the first major workplace drug-testing program in the country. He retired in 1985 after serving 24 years. 

Upon his retirement, Robert established his own drug testing consulting company assisting other companies to establish drug-free workplaces and drug testing programs, concentrating primarily on the marine industry. His knowledge of regulations and policy helped build his company to be one of the premier providers of drug testing services for the marine industry. During this time he was instrumental in establishing many of the current federal policies that are in place. 

Robert has served on the Board of Directors of the Substance Abuse Program Administrators Association (SAPAA) as well as chairing the Governmental and Legislative Affairs committee. He was one of the first individuals to be recognized as an expert in the Drug and Alcohol testing industry and to receive designation as a Certified Substance Abuse Program Administrator (1996). 

Robert is active participant in community service.  He recently served on the Policy Board for the Alcohol Safety Action Program in Fairfax, VA (January 1989-December 2012).  Since moving to Whidbey Island in Washington, he has been named to serve on the Substance Abuse Committee and recently been named to serve on the Ferry Advisory Committee both of these committees are located in Island County, WA. 

Robert is currently a consultant for Workplace Drug Testing and Drug Abuse Prevention Programs.