AS/NZS 4308:2008 Procedures for Specimen Collection and the Detection & Quantitation of Drugs of Abuse in Urine Compliance & Frustrations in the First Year Sue Nolan DrugFree Sites Ph: 021 877606 sue@drugfreesites.co.nz www@drugfreesites.co.nz Introduction • Legal requirements • History & changes • Relevance to Collecting and “on-site” screening • Compliance & Frustrations • Where to from here Drug Testing Is Lawful Air NZ Employment Court Judgement; April 04 • Random: Safety Sensitive Jobs • Post Incident/ For Cause: All Staff • AS/NZS 4308: Latest Version • Comprehensive programme adopted Drug & Alcohol Free Workplace Model Policy and Procedures EAP, Rehabilitation and Case Management Education and Training Outcome: Testing AS/NZS 4308:2008 Management Commitment & Leadership Change of behaviour leading to a Safer Workplace History AS 4308: 1995 – Screening & confirmation: lab based: same laboratory – Option: duplicate or single samples AS/NZS 4308: 2001 – – – – Joint standard Ambiguities removed Duplicate specimens only Accredited laboratories 2008 Standard AS/NZS 4308: 2008 • Significant changes from 4308:2001 – 5 years/ 15 meetings – Public comment x 2 • On-site screening • Laboratories performing screening only • Screen result: “negative” or “not-negative” • “not-negative” screen must laboratory confirmation • More responsibility on collectors • Some confirmation cut-off concentrations lowered – MA (“P”), MDMA/MDA (“E”), benzodiazepines AS/NZS 4308:2008 • S1: scope & definition • S2: collection, storage, handling, dispatch NZQA • S3: general laboratory requirements • S4: laboratory screening procedures IANZ accreditation • S5: laboratory confirmatory procedures IANZ accreditation • App.A: optional on-site screening NZQA (collection & screening) & IANZ accreditation (agency) • App.B: verification of performance of on-site devices • App.C (& S2.2.4): chain of custody forms What Drug Classes & Substances? • Cannabis metabolites • Opiates: morphine, codeine • Amphetamine type substances: – – – – methylamphetamine (P) methylenedioxyamphetamine (E) pseudoephedrine, phentermine Benzylpiperazine (BZP): not “on site” screen • Cocaine metabolites • Benzodiazepines: diazepam, temazepam, clonazepam Other Drugs The detection & reporting of drugs other than those listed in Table 2 is not precluded – LSD – Other party pills (eg DMAA) – Magic mushrooms (psilocybin) Laboratory testing only Mass spectrometry confirmation detected Laboratory determines cut-offs Compliance and Frustrations Principal Frustration • How do I distinguish expert advice From • Plethora of – Half truths – Non truths – Absolute nonsense fuelled by the avaricious need to make sales of products & services Compliance No.1 NZQA Certification 1.3.14: Collector A person who has successfully completed a course of instruction for specimen collection and on-site screening, handling, storage and dispatch of specimens and who has received a statement of attainment in accordance with NZQA. Frustrations • 9-12 months for units standards to emerge • Another 3-6 months for courses to get authored, moderated, assessed, accepted by training organisations (ITOs, PTEs, polytechs etc) Unit Standards • 25458 : “Perform urine specimen collection in the workplace for drug testing” (level 3, credits 2) • 25511: “Perform urine drug screening in the workplace” (level 4,credits 4) • NZQA Courses run by – DrugFree Sites: Sue Nolan (25458 & 25511) – InScience: Ann-Louise Weaver (25458 & 25511) – ESR (25458 only) Excuses for Non Compliance Compliance No.2 Verified Screening Device • Process, independent of the manufacturer, for ensuring trueness of results with respect to the screen cut-offs & the device is “fit for purpose.” • Performed by accredited AS/NZS 4308 laboratory (or equivalent) Frustrations • No “on-site” devices available in Aus/NZ passed verification BUT • Microcheck :verified Sep 2008 • Proscreen: verified Nov 2008 • Surestep: verified Feb 2009 Excuses for Non Compliance Legal Rights • Company & Donor request – evidence of NZQA certification of collectors & screeners – copy of verification certificate: “on-site” device • Donor can – refuse to have test conducted if NZQA certification and proof of verification of “onsite” device is not evident Compliance No.3 Integrity Tests 2.3.3 Collection Procedure (f) The integrity of the specimen shall be checked I. Visual inspection (colour) II. Temperature measurement (330C & 380C) III. On-site creatinine test Additional integrity testing may be performed (h) If integrity cannot be established, another urine shall be collected and both forwarded to laboratory for drug and integrity tests Ways to cheat ? • Drinking excessive fluid – Dilute specimen: creatinine test mandatory • Adding fluid to specimen • Substitution Temperature mandatory • Dehydrated urine • In vivo: diuretics, herbal: PH, creatinine • In vitro: bleach, detergents, nitrite • Collection: PH, nitrite, oxidant tests recommended • Artificial bladders Artificial Bladders Frustrations • Setting up collection site to minimise cheating • Mandatory to test creatinine extra step • Sometimes colours on integrity panels or dipsticks difficult to distinguish Principle: When in doubt, collect another specimen both to laboratory Excuses for Non Compliance Compliance No.4 Chain of custody & forms • 1.3.9: A series of procedures to account for the integrity of each specimen by tracking its handling and storage from the point of specimen collection to final disposal of the urine. • 1.3.10: A form to be used from time of collection of the specimen to its receipt by the laboratory. Thereafter, appropriate documentation accounts for the urine or aliquots within the laboratory. Chain of Custody Minimal Information (2.2.4) • Verification of donor’s ID (photo not essential) – Unequivocal and independent • Two unique identifiers • Date & time of collection • Name & signature of collector • Requesting authority details • Results of specimen integrity checks • Declaration by collector: compliance with Standard – Specimen collected & Tested on-site (if applicable) • Signature from donor confirming – Their own specimen & correctly taken – NB: This is the last step Chain of Custody Other Information • Reason for the test • Drug classes • Medications : Must not be on employer/ collector copy • On-site screen results: Must not be on employer copy Frustrations • Previous COC forms out of date • Requirement for single COC set covering – – – – – On-site collection & screening Dispatch to laboratory if required Laboratory receipt Risk of error too high with two forms Time consuming • Companies must address “verification of donor identity” issue Excuses for Non Compliance Compliance No.5 Quality Controls +ve and –ve QCs conducted – each day prior to 1st urine screen – after each batch of 25 tests (alternate) – at each testing site QC failure – remaining collections sent to laboratory – corrective action Frustrations • QCs: only recently available • Still questions around reliability • Need to match QCs to “on-site” device – Advice from supplier – Dont shop around for best deal • Adds cost Confusion • Physical control line on device vs QC Excuses for Non Compliance Compliance No.6 Language & Reporting • Screen result – Negative or “Not Negative” – Word “positive” prohibited • “Adulteration” replaced by “specimen integrity” • Screen not negative or specimen integrity ?? – Interim report may be issued that can only advise that the specimen requires further testing Frustrations • Adopting the new language • Changing reporting practices • Educating companies of compliance requirements • Reviewing company policies Excuses for Non Compliance Compliance 7 Accreditation 1.3.12: Collecting agency An organisation assuming professional, organisational, educational and administrative responsibility for collection, on-site screening (if applicable), storage and dispatch of the urine specimen – If on-site screening is performed, the collecting agency shall be accredited against AS/NZS 4308 (by IANZ). – Where the collecting agency does not perform on-site testing it should seek accreditation when such accreditation exists. – The requesting authority also may operate as a collecting agency. Frustrations • • • • Final process to be put in place IANZ accreditation: just established Initial inspection advice on “what to do?” Accreditation assessment (initial and 4 yearly) – – – – 1 day $2500-3000 (+travel costs) $500 annual fee Annual inspection • Laboratories – 2008 accredited: CHL, A+ ESR (assessed) Excuses for Non Compliance Compliance 8 Proficiency Tests A3.2 (j): The collecting agency shall participate in an external proficiency program. Where such a program is not available, the CA shall arrange a program with a laboratory to demonstrate ongoing reliability of the screening process. – 5% urine negatives Laboratory – Program available from Australia ??? Frustrations • Establishing proficiency program with Lab • Cost built in to operation • Managing proficiency variances Excuses for Non Compliance Conclusion Compliance Yes 1 NZQA Certification 2 Verified screening devices 3 Integrity tests Possible 4 Chain of custody forms 5 Quality controls 6 Language & reporting 7 Proficiency tests 8 Accreditation In Progress