This is Part I of two articles to explain and analyze the Department of Transportation (DOT) Final Rule Published November 13, 2017. This analysis is provided by Robert Schoening, the former Drug and Alcohol Program Manager for the US Coast Guard. Part I shall discuss the new changes regarding expanded opiates and Part II shall discuss the additional provisions of the Transportation (DOT) Final Rule Published November 13, 2017.
The major changes and most important are the addition of more drugs in the Opiate Class. This will harmonize with the Mandatory Guidelines (MG) recently published by Department of Health and Human Services (DHHS). This includes the additional opiates and cutoff levels for screening and confirmation analysis.
For those readers that are not fully aware of the connection between DHHS and DOT/ODAPC, this is a requirement that is based on a Pubic Law passed in 1991. That law is commonly referred to as OTETA (Omnibus Transportation Employees Testing Act). There are many requirements in OTETA but the primary effects are that DHHS does all the scientific guidelines and then ODAPC must implement regulations for regulated employers based on those MG.
The first and most important of the changes are taking place in the testing panel. The following Schedule 2 Opiates are being added: Hydrocodone, Hydromorphone, Oxymorphone and Oxycodone.
One other change on the testing panels is that MDEA (3, 4-Methylenedioxy-N-ethylamphetamine) is being removed as a confirmatory test analyte. The MDEA confirmation had previously been a part of the Amphetamines testing since October 2010. MDMA and MDA confirmation testing shall remain part of the testing for amphetamines so that the Ecstasy or Molly type drugs will continue to be detected.
Why the change to the opiates panel is taking place should be well understood by all in the testing industry. The Secretary of Transportation had to answer the question of why the additional opiates are not on the testing panel at a Congressional Hearing.
A minor but significant change is the name change of “Opiates” to” Opioids”. The drugs that are will be tested in the Opioids drug class are as follows: 6-Acetylmorphine (Heroin); Codeine; Morphine, Hydrocodone; Hydromorphone; Oxymorphone; and Oxycodone.
Several other changes to DOT drug and alcohol testing requirements include revisions to the following components of 49 CFR Part 40 regulation:
- Blind Specimens
- ODAPC List-Serve
- Additional Testing Available to MRO’s
- Fatal Flaws
- Shy Bladder
- Urine – only allow specimen
- Use of DOT or Modal names, logos or other official branding.
These shall be discussed in Part II of this article. Read Part II
Readers are advised to obtain a copy of the Federal Register printed on November 13, 2017.