In response to the nation’s opioid epidemic, the Department of Transportation (DOT) amended its testing program requirements to require inclusion of four semi-synthetic opioids, hydrocodone, oxycodone, hydromorphone and oxymorphone, to the required drug testing panel. DOT also added methylenedioxyamphetamine (MDA) to the panel and removed methylenedioxyethylamphetaime (MDEA) as a confirmatory test analyte as redundant since MDA is a metabolite for MDEA. Because the added opiods can be legally taken pursuant to a doctor’s prescription, this may result in more initial positives that trigger MRO review and require the MRO to evaluate whether the employee is taking the opioid pursuant to a valid prescription.

The new rule adds three “fatal flaws” to the list of when a laboratory would reject and discard a specimen and modifies the “shy bladder” process so that the collector will discard certain questionable specimens and proceed under the shy bladder process for the second specimen.

The new rule also removes the requirement for consortium/third party administrators to submit blind specimens because it is unneeded and imposes unnecessary administrative burdens and costs.

Companies that are covered by DOT should amend their drug testing programs accordingly before Jan. 1, 2018. Companies that voluntarily comply with the HHS Mandatory Guidelines for Federal Workplace Drug Testing Programs should consider amending their programs as well.