Comments Support Adding Oral Fluid Testing

Many large companies providing drug testing services offered suggestions for implementing it in comments responding to SAMHSA's questions about it.

Comments submitted by Aug. 9 from many companies providing drug testing services offered suggestions for implementing oral fluid drug testing and for the most part supported including it in the Mandatory Guidelines for Federal Workplace Drug Testing Program, which are the basis for testing in DOT-regulated industries. The comments responded to the Substance Abuse and Mental Health Services Administration's questions about it in a June 10 request for information.

That request asked questions such as which analytes should be measured in oral fluid for the initial and confirmatory tests, what initial and confirmation cutoffs should be used for the oral fluid drug tests, and whether the oral fluid drug testing panel should be expanded to include schedule II prescription medications.

The responding companies and organizations weren't unanimous. For example, the Drug & Alcohol Testing Industry Association's executive director, Laura Shelton, recommended using oral fluid tests for the same drugs now tested for in urine tests but also said both types of testing should also include prescription medications -- hydrocodone/hydromorphone and oxycodone/oxymorphone. Michael I. Schaffer, Ph.D., VP of laboratory operations for Psychemedics, wrote that its lab has conducted more than 7 million tests using hair for drugs of abuse since the company was founded in 1987. He, too, supported testing for hydrocodone, hydromorphone, oxycodone, and oxymorphone. However, Pipeline Testing Consortium Inc. VP Mike Neuway and David W. Paine, M.D., FAAFP, of American Medical Review Officers, LLC, both of Hutchinson, Kansas, said questions remain whether testing for prescription medications is reasonable under the 4th Amendment. "Our experience with prescription drugs (in non-regulated testing) is the same as has been shown in previous HHS reports (that over 85% are downgraded because the employee has a valid prescription)," they wrote. Pipeline Testing Consortium has provided drug and alcohol testing to DOT-regulated businesses in the oil and gas industry for more than 20 years, their letter states.

Meanwhile, the Drug Testing Advisory Board of SAMHSA's Center for Substance Abuse Prevention (CSAP) is scheduled to meet Sept. 12-13 in Rockville, Md., to discuss proposed revisions to the Mandatory Guidelines, but its meeting will be closed. (Substantive program information, a summary of the meeting, and a roster of DTAB members will be available after the meeting at this website or by contacting Janine Denis Cook, Ph.D., Designated Federal Official, CSAP Drug Testing Advisory Board, 1 Choke Cherry Road, Room 2-1045, Rockville, MD 20857, phone 240-276-2600, e-mail

Most commenters said they support adding oral fluid testing because workers prefer it to urine testing and direct observation of the test is not a concern. Douglas K. Mullen of the Air Transport Assocation of America submitted comments saying oral fluid avoids the need to have same-gender collectors, "which is a significant challenge to the airline industry."

Some of the key questions were how an oral fluid specimen should be collected and, for an oral fluid split specimen collection, how the collection of the two specimens should be performed.

The testing community responded with detailed comments. LabCorp -- Laboratory Corporation of Ameerica, based in North Carolina and one of the largest U.S. providers of substance abuse testing services -- recommended that SAMHSA implement the panel of analytes and cutoffs for oral fluid testing that it published in the Federal Register in April 2004. They are supported by studies and, absent published scientific data supporting significant changes, shoud be considered acceptable for oral fluid testing, LabCorp's Donald E. Horton Jr., vice president of public policy & advocacy, wrote in comments dated Aug. 4.

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