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  • ACOEM Comments on Federal Railroad Administration’s Rulemaking to Expand Post-accident Drug Testing

    Docket Management Facility
    U.S. Department of Transportation
    1200 New Jersey Avenue SE., W12–140
    Washington, DC 20590

    Re: Docket No. FRA–2010–0155, Control of Alcohol and Drug Use: Addition of Post-Accident
    Toxicological Testing for Non- Controlled Substances

    To Whom It May Concern:

    The American College of Occupational and Environmental Medicine (ACOEM) is pleased to provide comments on the Federal Railroad Administration’s (FRA) Notice of Proposed Rulemaking to expand post-accident drug testing.

    ACOEM is an organization of occupational medicine physicians and providers that service the nation’s workforce. Many of these physicians interact with the railroad transportation industry and some are medical review officers (MROs). ACOEM has special interest sections of physicians working in the transportation industry and who are MROs. These comments are written from the perspective of ACOEM’s Transportation Section and MRO Section.

    The field of occupational medicine is considered a branch of preventive medicine and the physicians who become certified in this field have certificates from the American Board of Preventive Medicine. Although we commonly treat workplace injuries, our primary focus is on prevention rather than treatment.

    ACOEM appreciates the opportunity to comment on the FRA’s proposal to add non-controlled substances to the post-accident test panel which currently includes only marijuana, cocaine, phencyclidine (PCP), and certain opiates, amphetamines, barbiturates, and benzodiazepines. While we understand that at the current time, the proposal is to only add tramadol and certain sedating antihistamines, we feel it is important to mention that there are many other substances that may also affect safety, but are not currently either part of the current panel or proposed to be added to it.

    In addition to the use of single substances which may impair safe performance of duties, it is important to recognize the increasing issue of polypharmacy in the working public. Not only do workers use OTC anti-histamines, but we would point out that there is a concern with using several different OTC medicines, sometimes for a variety of different ailments at the same time, often on top of potentially impairing prescription medications. Frequently, the worker does not understand the potential interactions that these medications may have, including a host of interactions that can occur with prescription medications and OTC products. There is also a strong concern with respect to the use of other prescription medications with significant sedating side effects such as muscle relaxants.

    Whereas we recognize that it is difficult for FRA to introduce a wide-sweeping drug testing policy to cover all potential OTC and prescription issues, we would like to underscore that these issues are a significant concern to us as occupational medicine physicians who, in part, are entrusted to make reasonable determinations concerning safety sensitive occupations on both a case by case and population basis.

    In regards to tramadol and OTC sedating antihistamines, tramadol is a commonly prescribed analgesic that causes dizziness and vertigo in up to 33% of patients, drowsiness in up to 25% of patients, and a variety of other side effects. Seizures have also been reported in patients taking tramadol since it lowers the seizure threshold. Tramadol has abuse potential in addition to the mentioned side effects. Diphenhydramine and other sedating antihistamines have similar side effects as tramadol with regards to dizziness, drowsiness, and vertigo. Although tramadol and OTC antihistamines are very good medications, our physicians feel that they are contraindicated in workers performing safety sensitive functions.

    While we strongly support the addition of tramadol and OTC sedating antihistamines to the post-accident panel, we believe it is essential to increase the education and awareness of both employers and employees on the safety risk these and similar medications may have, not just waiting to evaluate whether they may have played a role in an incident.

    Thank you for the opportunity to comment upon these proposed rules. We are available to discuss this issue further at your request.


    Karl Auerbach, MD, MS, MBA, FACOEM

    Tony Alleman, MD, MPH
    ACOEM Transportation Section