Update on DOT Drug &
Alcohol Testing Programs
FL DOE Meeting
February 2011
Dr. Donna Smith
FirstLab, Inc.
dsmith@firstlab.com
DOT Final Rule
 Final Rule published Aug 16, 2010; Interim
Final Rule published Sep 27, 2010
 Changes to Part 40 effective Oct 1, 2010
 Part 40 changes necessary to conform to
revisions in the DHHS Guidelines published
in Nov 2008.
 OTETA requires DOT to follow the DHHS
requirements for testing procedures/protocols
and the drugs tested for in the DOT programs
 Most of the changes relate to the DHHS
certified laboratory procedures
Summary of Part 40 Changes
 Testing for MDMA (Ecstasy)—MDMA is added as a
target analyte in the amphetamines screening assay,
with confirmation testing for MDMA, MDA, and
MDEA.
 Lower cutoff levels for cocaine and amphetamines;
 Mandatory initial testing for heroin—The target
analyte 6AM is added to the opiates screening test.
 Certain definitions in-§40.3 were revised or added to
conform to definitions in the DHHS Guidelines
Adding MDMA To Drug Test Panel
 DOT adopted the HHS laboratory testing
requirements of conducting initial testing for MDMA,
conducting confirmatory testing for MDMA (Ecstasy),
MDA (hug drug), and MDEA (Eve).
 MDMA Screening cut-off 500 ng/mL
 MDMA, MDA, MDEA confirmation cut-offs 250ng/mL
 MDMA is readily available on the US illicit drug
market
 MDMA is no longer exclusively viewed as a ‘‘rave’’ or club
drug, which aids distributors in selling it to nontraditional
abusers
Lower Cut-offs for Amphetamines and Cocaine
 DOT projects that the lower cut-off levels for cocaine and
amphetamines will produce a 30% increase in laboratory
confirmed positive tests for both cocaine and
amphetamine/methamphetamine
 Based on DOT data for confirmed cocaine and amp/methamp positives, the
lower cut off levels will result in approximately 4,000 additional cocaine
positives, and 4,000 additional amp/methamp positives per year.
Initial Test
Analyte
Current
Screening
Cut-off
New
Screening
Cut-off
Confirmatory Test
Analyte
Current
Confirmatory
Cut-off
New
Confirmatory
Cut-off
Cocaine
metabolites
300 ng/mL
150 ng/mL
Benzoylecgonine
150 ng/mL
100 ng/mL
Amphetamines
1000 ng/mL
500 ng/mL
Amphetamine
Methamphetamine
500 ng/mL
500 ng/mL
250 ng/mL
250 ng/mL
Initial Testing for 6 AM (Heroin metabolite)
• Prior to 2010 6-AM testing was only conducted
when morphine was detected at or above 2000
ng/mL on the opiate screening test
• Now all specimens will be tested for 6-AM,
regardless of whether morphine is detected in the
screening test
• DOT estimates only 30-40 additional 6-AM
positives per year
No Change in Part 40 Provisions
• Specimen Collection procedures remain the same
• Record keeping requirements for employers,
MROs, collectors, etc. remain the same
• DOT did not adopt the use of “instant drug tests”
or the use IITF’s (screening only testing facilities)
for DOT drug testing programs
• Alcohol testing procedures remain the same
New Custody and Control Form
• The DHHS revised the federal custody and control form (CCF)
• Effective date for the new CCF is Oct 1, 2010
• DOT-regulated employers may use the “old” federal CCF until
Sep 20, 2011
• Major changes to the federal CCF include:
− Collector/employer must identify the testing authority in Step 1 of the
CCF
- DOT: FMCSA, FAA, FRA, FTA, PHMSA, & USCG
- All CDL testing is marked DOT-FMCSA
− Step 4 includes blocks for use of IITF (will not apply to DOT testing)
− Specimen container seals/labels more narrow
− Laboratory and MRO sections will include additional drug analytes
(MDMA, MDA, MDEA)
Employer Instructions to Collector
• In the IFR DOT requires that employers provide collectors with
information about the donor and the drug test when the
employee presents for a specimen collection
1.
2.
3.
4.
5.
6.
7.
8.
9.
Name of employee (or applicant) being tested
Employee SSN or other ID number
SAMHSA laboratory name and address
Employer name, address, phone number, fax number
DER name and telephone number
MRO name, address, phone number, and fax number
The DOT agency (e.g. FMCSA) which regulates the employee’s
safety-sensitive duties
Test reason (e.g. pre-employment, random, etc.)
Whether the test is to conducted under direct observation or not
NOTE: # 3, 4, 5, 6, 7 can be preprinted on CCF
New Federal CCF
Reminder About “Annual” Drug Test
• Any drug test conducted on Florida school bus
drivers as part of physical examination or other
annual exam is not a federal DOT drug test.
• Drug test should be conducted using a nonfederal custody and control form or other form
issued by the State
• Even though Florida has adopted the FMCSA
standards for physical qualifications of school bus
drivers, the drug test is not a test conducted
under Part 382.
New Craze in Illegal Drugs
• K2 or "Spice" is a mixture of herbs and spices that is
typically sprayed with a synthetic compound
chemically similar to THC.
• Chemical compounds typically include HU-210, HU211, JWH-018, and JWH-073.
• Commonly purchased in head shops, tobacco shops,
various retail outlets, and over the Internet.
• Often marketed as incense or "fake weed.“ or
synthetic cannabis
• Street names--Bliss, Black Mamba, Bombay Blue,
Fake Weed, Genie, Spice, K-2, Special K
Spice, K-2
• K2 is typically sold in small, silvery plastic bags of
dried leaves and marketed as incense that can be
smoked.
• Resembles potpourri.
• Usually smoked in joints or pipes, but some users
make it into a tea.
• Psychological effects are similar to those of
marijuana and can include paranoia, panic
attacks, and giddiness
Spice, K-2
• DEA listed the major components in Spice and K2 as Schedule I illicit drugs in December 2010
• No medical or licit use for the compounds found in
K-2/Spice
• Use is not detected in drug test for marijuana
• Several laboratories have developed assays to
detect Spice/K-2 in urine.
− Has not been added to DOT drug panel
Bath Salts?? What Next?
• Mephedrone (4-MMC) is a drug that has a chemical
lineage that blends amphetamine and cathinone
structures together to create a hybrid psychedelic
stimulant.
• Cathinone is the psychostimulant that powers the
drug khat, a plant that is grown in Africa and
smuggled to the United States.
• Mephedrone has obvious addictive potential.
• Anecdotal information indicates that the drug can
cause an amphetamine-like constellation of effects,
including all the onerous symptoms of paranoia,
anorexia, and hyper-vigilance.
Bath Salts & Plant Food-Mephedrone
• Ivory Wave, Red Dove, and Vanilla Sky are the more common
forms of these products.
• Nominally marketed and sold as bath salts, these substances
are not intended for human consumption.
• Are packaged as bath salts and are relatively easy to prepare
and ingest to get high.
• The white bath powders can be snorted or smoked. Preparation
is quite similar to preparation of powdered methamphetamine or
cocaine for "snorting."
• 4-MMC also appears as a product in certain brands of foreign
made plant food. Coming from Russia and Cameroon, these
substances are typically packaged in small plastic baggies for
individual use. They are prepared and snorted in a fashion
identical to ingestion of cocaine and methamphetamine.
Bath Salts