Latest ODAPC Update, Approved Devices, and What It Means for Employers
The U.S. Department of Transportation is taking significant steps toward implementing oral fluid drug testing as part of its regulated drug testing program. While the final rule allowing oral fluid testing became effective on June 1, 2023, there are still key steps that must be completed before DOT-regulated employers can fully implement this new testing method. This article addresses where we are in the process, and what is still outstanding.
Current Status: Can Oral Fluid Be Used Yet?
As of now, oral fluid testing cannot yet be used for DOT testing because at least two HHS-certified laboratories must be approved to process oral fluid specimens. The Department of Health and Human Services (HHS) has not yet certified the required number of labs under the National Laboratory Certification Program (NLCP). Until these certifications are granted, DOT drug tests must still be conducted using urine testing.
However, in a crucial step forward, the Oral Fluid Specimen Collection Guidelines were officially released. These guidelines establish the proper procedures for collectors, laboratories, and Medical Review Officers (MROs) when handling oral fluid specimens. It also addresses the training requirements, problem collections, what to do in a dry mouth situation and many other processes. It is recommended that anyone who will be collecting oral fluid collections read this document and be ready and prepared once testing is officially available.
Approved Oral Fluid Collection Device
The Quantisal II Oral Fluid Collection Device has been approved for use and meets both HHS and DOT guidelines. This device allows for the simultaneous collection of A and B specimens, ensuring compliance with federal split-specimen testing requirements. Collection sites and employers preparing for oral fluid testing should become familiar with this device and its procedures. The regulations also indicate that the collector follows the manufacturer’s instructions for collecting the specimen. It is recommended that you read the instructions and become familiar with the correct use of the device.
How This Impacts Employers, Collection Sites, and C/TPAs
The introduction of oral fluid testing represents a major shift in DOT drug testing. Here’s what you need to know:
Employers
• Oral fluid testing cannot be used yet but employers should prepare for the transition.
• Policies should be reviewed and updated to include oral fluid testing once it becomes available.
• Oral fluid testing will be particularly useful in post-accident and reasonable suspicion testing, as it detects recent drug use more effectively than urine testing.
• Oral fluid testing will also be required for all observed collections for circumstance of transgender or non-binary.
• Employers must have a “Standing Order” that outlines pre-authorized instructions.
Collection Sites & Service Agents
• Collectors will need specific device training to properly administer oral fluid tests under DOT regulations.
• Sites should prepare to stock and use the approved Quantisal II collection device.
• Understanding the new Oral Fluid Specimen Collection Guidelines.
C/TPAs (Consortia/Third-Party Administrators)
• Educate clients about the upcoming changes and ensure they are ready for implementation.
• Update procedures to include oral fluid testing once it becomes available.
• Assist employers in ensuring compliance with new training and collection requirements.
What’s Next?
The approval of two certified laboratories remains the final hurdle before oral fluid testing can officially be implemented under DOT regulations. Once that happens, employers and service providers will need to be ready to train staff, update policies, and ensure compliance with the newly released Oral Fluid Specimen Collection Guidelines. To view the list of oral fluid drug testing laboratories that are certified by HHS, you can visit ODAPC’s website. You can also sign up to receive DOT updates by subscribing to the ODAPC List Serve Notices.