The Department of Transportation (DOT) has approved the use of oral fluid testing in their drug testing program, effective June 1, 2023. However, implementation is subject to the certification of at least two labs by the Department of Health and Human Services (HHS). Employers now have the choice between urine and oral fluid samples for drug testing, and they can switch between the two if a second sample is needed. This approval signifies a significant shift in drug testing methods, recognizing the benefits of oral fluid testing in terms of convenience, accuracy, and shorter detection windows.
Oral fluid testing offers advantages that make it an attractive alternative to urine testing. It is non-invasive and can be easily done on-site, eliminating the need for specialized collection facilities. With a shorter detection window, it provides a more real-time assessment of impairment, enhancing workplace safety. The testing will be required for observed collections involving transgender and non-binary individuals.
Let’s take a look at some of the steps that need to be taken to get prepared for this new type of DOT testing:
- Consortium/Third Party Administrators (C/TPAs) need to update their guidelines to reflect the employer’s policy on sample type selection for different situations. Each collection site should have specific instructions for the employer’s preferred testing method. The decision on the type of testing lies with the employer, but employees should always be informed about the procedures. Collectors will also be required to obtain their DOT Oral Fluid Collector Certification, as well as receiving training on the oral fluid devices which will be used for testing.
- Employers will retain the responsibility of determining refusals based on information provided by collectors. Not showing up for a pre-employment test or leaving before providing a sample should not be considered a refusal. DOT collectors must undergo proficiency training and obtain certification for oral fluid collections. This ensures they understand proper specimen collection, including obtaining a split sample, and accurately completing required forms. Using expired oral fluid devices will result in a Fatal Flaw. Collectors should also have the Designated Employer Representative’s (DER) information available to address any uncertainties regarding specimen collection.
DOT Oral Fluid tests will go through the same MRO process as a DOT urine test, with an interview taking place with the donor if there is a non-negative result. The interview process gives the donor the opportunity to provide any medical documentation which could explain the result. When the MRO receives the documentation (such as a prescription) they will assess whether it appropriately explains the metabolite found within the specimen, and informs whether or not the MRO will turn over the result to a Negative. Donor’s will also always have the ability to request that the split specimen be tested, just as they are with urine samples being tested through the DOT program.