Mandatory Guidelines for Federal Workplace Drug Testing Programs using Oral Fluid (OFMG) (Revised)
2022-04-13 2022-04-26 2022-04-19 2022-04-19 2022-04-19 2022-04-19 2022-05-05 2022-05-05 2022-06-14 2022-06-14
SAMHSA-2022-0001-0007 SAMHSA-2022-0001-0023 SAMHSA-2022-0001-0022 SAMHSA-2022-0001-0019 SAMHSA-2022-0001-0021 SAMHSA-2022-0001-0011 SAMHSA-2022-0001-0027 SAMHSA-2022-0001-0030 SAMHSA-2022-0001-0041 SAMHSA-2022-0001-0043
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https://api.regulations.gov/v4/comments/SAMHSA-2022-0001-0007 https://api.regulations.gov/v4/comments/SAMHSA-2022-0001-0023 https://api.regulations.gov/v4/comments/SAMHSA-2022-0001-0022 https://api.regulations.gov/v4/comments/SAMHSA-2022-0001-0019 https://api.regulations.gov/v4/comments/SAMHSA-2022-0001-0021 https://api.regulations.gov/v4/comments/SAMHSA-2022-0001-0011 https://api.regulations.gov/v4/comments/SAMHSA-2022-0001-0027 https://api.regulations.gov/v4/comments/SAMHSA-2022-0001-0030 https://api.regulations.gov/v4/comments/SAMHSA-2022-0001-0041 https://api.regulations.gov/v4/comments/SAMHSA-2022-0001-0043
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This is completely absurd and unjust! It is time to move past these destructive policies. If a persons physician believes it is in ones best interest to use a medicine, then the federal government should not be able to hold this against the person due to a failed test. This is very un-American! Cannabis is a very safe, and effective medicine. We should embrace it as such. Although I believe Oral Fluid testing is a good thing for quick non dot testing, I think it is offering many opportunities for Cheating for DOT testing.  There will be more and more companies that will begin to do their own testing with their Employees which leaves the opportunity for friends and colleagues testing each other and promotes collaboration between Staff and Employee I believe that medical cannabis users should be exempt from fedral drug screen failures. his is slightly insane but a logical outcome of the federal governments continued refusal to change its outdated, disproven, and harmful categorization of cannabis as a Schedule I drug. This rule is founded on completely archaic ideas about cannabis and how it affects an individual. There is no science backing up the non-legitimacy of medical use cases for cannabis where in many circumstances, actually improves the life of the person who uses it. Personally I have suffered from high anxiety/depression and PTSD and using cannabis before bed helps me immensely to calm down and get good rest. Without it I typically have night sweats/terrors that severely affects my performance the next day. Using cannabis before bed however allows me to function fully the next day and show up to work and other responsibilities with a clear and balanced mind. The harmless nature of this drug truthfully should allow it to be legal federally. Even for non medical patients, it is far safer to be taken recreationally than something like alcohol. Having cannabis be a schedule 1 drug is completely erroneous but while states have laws allowing it to be used medically, we should honor that and not move retroactively. Progress needs to be made here to establish facts about cannabis instead of digging in our heels based off assumptions made by politicians from decades ago. More and more research is coming out showing the benefits of cannabis and how truly harmless it can be. We need to be a country that creates rules based off these facts in order to maintain the sense of freedom that we cherish here.  SAMHSA 2022-0001 is a throwback to a relic of reefer-madness legislature. All of this is the politically neurotic outcome of the federal governments continued refusal to change its outdated, targeted, and medically harmful categorization of cannabis as a Schedule I drug. Please look yourself in the mirror and explain this, a physicians authorization or medical recommendation for a Schedule I substance is not an acceptable medical explanation for a positive drug test. Ill help, its a back asswards loophole to apply to try to regulate an innoxious substance. Its also funny how the most addictive substances known to man are considered safe enough to assign to Schedule II; live with yourself knowing that you helped fuel a crisis that ruins lives and kills people because of a nonsensical mindset of ignorance, greed, and fear. You wont read it but heres to you, cheers; https://www.npr.org/2022/02/25/1082901958/opioid-settlement-johnson-26-billion, https://www.newsnationnow.com/health/where-do-us-opioid-trials-settlements-stand/. As a qualified SAP from 05 to present I am in support for Oral Fluid Testing but with the following caveats: 1) ONLY Urine Testing should be used for the RTD Return to Duty test. 2) There should be no change to the SAP being the sole author of any employees mandatory Follow up Testing Plan. The SAP is the one in the entire RTD process who is spending up to hours of time providing a clinical assessment and applying diagnostic criteria with backend recommendations for education or treatment or both. Thus, upon any employee compliance the SAP should be the only Service Agent type deciding the amount of Follow-up Tests but also if they recommend ORAL or URINE for Follow-up tests. I would advise that all Follow up Tests are URINE TESTS only. The Oral Test appear from what I read to be the way to go for Pre-employment Test, Randoms, Reasonable Suspicion, Post Accident etc but the RTD and Follow up Test should ALWAYS be Urine based. If there is a choice on either for Oral and Urine testing for RTD and Follow-up Testing this call should ONLY be for the contracted SAP to make and never the employer or 3rd party TPA.  Comment on SAMHSA 2022-06884I am an operations manager at a public transit authority and think adding the ability to conduct drug testing using oral fluids will be a benefit felt across the board. Our organization would certify staff to be able to self administer oral fluid testing as well as use a clinic. Drivers would still have to go to a clinic for BAC testing, so we would not self administer that test. It takes a lot of planning and resources to pull drivers off route for random testing, send them to the clinic, wait at the clinic, then coordinate getting them back on route. Being able to self administer random testing will simplify the process and make it more convenient to test at all times of service. Our practice would be to use urine tests for pre-employment, return to duty, and follow up. In the cases of shy bladders or the inability to produce a large enough specimen, we would be open to transitioning from urine to oral fluids before exhausting the time limit. We prefer pre, return, and follow-up to be more structured through a clinic and to use urine, especially for return and follow-up. In response to the question of whether or not to allow opposite gender techs to observe urine collection, our team was split. The male point of view was it makes no difference. The human resources and female recommendation was to have it observed by the same gender. Past experiences show female staff were already stressed about being observed. To have the collection observed by a male would further exacerbate the situation. Just because someone is going through the follow up process doesnt mean they should lose their dignity. We understand in smaller communities it may be harder to find same gender techs to observe urine collections, but we dont have the issue in our area. In response to the question of whether or not refusing an opposite gender observer constitutes a refusal to test, we assumed that the regulation wouldnt require same gender observers. We would recommend calling that a refusal to test. If your test requires observing, you must have already tested positive. We cannot give someone the ability to cheat the system if they know there arent many same gender techs. In summary, lets get oral fluid testing up and running and relieve some of the burden placed on organizations to maintain compliance with drug testing. A separate soap box issue I would like to see movement on is THC levels testing to remove the current zero tolerance policy that can last for up to 60 days after last contact/consumption. Safety sensitive industries need a better answer than zero tolerance when cannabis products and marijuana use are rising as fast as they are now. Zero tolerance is hurting staff retention and recruiting.   This suggested language should be stricken: The Department also proposes to add a new item iii to this section stating that a physicians authorization or medical recommendation for a Schedule I substance is not an acceptable medical explanation for a positive drug test. Under the CSA, a Schedule I substance is defined as a drug, chemical, or other substance with no currently accepted medical use in the United States, a lack of accepted safety for use under medical supervision, and a high potential for abuse. (Ref. 13) The DEA maintains the current listing of controlled substances on their website.The government should not meddle in health-related decisions made by a medical professional.  You are relying upon an executive order that is nearly 36 years old to justify invasive urine testing for huge numbers of employees.  Please vote to remove this added language and respect the recommendations of medical professionals.  Just keep adding rules and adding rules and you will deplete the already suffering transportation sector,when you dont have food on the the grocery store shelves or gas to put in your car or toilet paper to wipe your but because you have no truck drivers to bring it to you,when you cant get food to feed your children,then I suppose you will second guess yourselves and all these nonsense rules you are making.Why dont you just sit back and keep getting that salary that you do nothing to earn and stop making up rules.....Just remember that trucks move America and if trucks are not moving neither are you!!!