Page 22 - OHS, March 2020

DRUG TESTING
Regarding drug test cheating, SAMHSA states:
All unobserved specimen collections are at risk for substitu- tion and adulteration. Studies conducted by the drug testing industry indicate that 0.05 to 3 percent of urine specimens col- lected for drug use detection are determined to be substituted or adulterated. Oral fluid collections will occur under obser- vation, which should substantially lessen the risks of specimen substitution and adulteration that has been associated with urine specimen collections, most of which are unobserved.
On the subject of cutting time and costs, SAMHSA offered the following: “Oral fluid collection can require less time than urine collection, reducing employee time away from the workplace and, therefore, reducing costs to the...employer.”
In the OFMG, SAMHSA also emphasized that oral fluid collec- tions do not require a facility that provides visual privacy during the collection and that the agency anticipates that “many oral fluid collections will occur at or near the workplace, and not at a dedi- cated collection site, thereby reducing the amount of time away from the workplace.”
Employers will have the option to collect a urine specimen when a donor is unable to provide an oral fluid specimen (and vice versa), which will “reduce both the need to reschedule a collection and the need for the MRO to arrange a medical evaluation of a donor’s inability to provide a specimen.”
Perhaps, the greatest time and cost savings cited by SAMHSA was the reduction in the overall time needed to administer an oral fluid test.
Administrative data for urine collections indicates it takes, on average, about four hours from the start of the notification of the drug test to the actual time a donor reports back to the worksite... The Department estimates the time savings to be more than 2 hours. Using OPM’s estimate for the average an- nual salary of Federal employees converted to an hourly wage, the savings generated for the Federal Government would be roughly $400,000 to $1.2 million a year, or $38 to $114 per test.
In the Federal Register announcement, SAMHSA stated:
The scientific basis for the use of oral fluid as an alternative specimen for drug testing has now been broadly established and the advances in the use of oral fluid in detecting drugs have made it possible for this alternative specimen to be used in federal programs with the same level of confidence that has been applied to the use of urine.
SAMHSA added:
The OFMG provide the same scientific and forensic supportability of drug test results as the Mandatory Guidelines for Federal Work- place Drug Testing Programs using Urine (UrMG).
That’s quite an acknowledgement. And phrases like “scientific basis... has been broadly established” and “the same scientific and forensic supportability” as urine testing will likely have a powerful
Figure 1: Oral fluid provides a shorter window of detection than other testing methods combined with non-invasive collections.
impact on employers, mandated or not, who are considering lab- based oral fluid testing. It will force many service providers from a passive marketing position of simply making oral fluid testing available to clients to more aggressive and outward efforts to not only offer this alternative testing method but to differentiate them- selves from their competition.
For the typical buyer, as well as many sellers of drug testing, it’s more about authorization than it is about science: “If it’s good enough for the government, it must be good enough for me.” That may be a gross oversimplification of an otherwise complex issue, but it applies, generally. Some people must now, at the very least, become knowledgeable about lab-based oral fluid testing, while others—such as lab professionals, collectors, certain employees at companies that conduct drug testing, and medical review officers (MROs)—must become experts, at least in the specific duties they will be responsible for in an OFMG-compliant testing program.
SAMHSA is allowing a 12- to 18-month implementation period to give employers and service providers ample time to learn the regulations, get trained in how to fulfill their responsi- bilities per the guidelines, and in some cases (such as with labo- ratories), become certified. Fortunately, the OFMG are written in the same concise, easy-to-understand style as the manda- tory guidelines for urine testing, which is a good thing because there’s a lot to know going forward. Following are just a few highlights of the OFMG.
What Must Collectors Know?
Collectors are significantly affected by the OFMG. First, with oral fluid collections, employees, in addition to professional technicians, can conduct the collection. There are two key parts to collector training: the OFMG and the specific collection device being used. The OFMG define a collector as someone “who has been trained to collect oral fluid specimens in accordance with these Guidelines and the manufacturer’s procedures for the collection device.”
Second, collections can take place at the workplace in addition to an approved, offsite facility. The site being used may be a perma- nent or a temporary facility if the site meets all the requirements of an approved collection site. SAMHSA anticipates that many employers will choose to collect oral fluid samples at the work site in order to save time and boost productivity. Collectors, including employees who conduct collections, will be responsible for ensur- ing the portion of a worksite being used for collections qualifies, according to the OFMG. Citing Subpart E of the guidelines, collec- tion site requirements include:
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Provisions to ensure donor privacy during the collection
A suitable and clean surface area not accessible to the donor