• Public Affairs

  • ACOEM Comments on DOT Drug Testing Procedures for 6–AM

    May 10, 2012

    Docket Management Facility
    U.S. Department of Transportation
    1200 New Jersey Ave. SE.,
    West Building Ground Floor
    Room W12-140
    Washington, DC 20590-0001;

    Dear Sir or Madam:

    The American College of Occupational and Environmental Medicine (ACOEM) welcomes the opportunity to provide comments to the Interim Final Rule (IFM) concerning changes to the Procedures for Transportation Workplace Drug and Alcohol Testing Programs with respect to the issue of procedural changes for certain laboratory results involving 6-AM.  As our organizational membership consists of a number of physicians who are Medical Review Officers (MRO), we are keenly aware of the issues that have been brought forth in this IFM. 

    We agree that there was skepticism and ambiguity with the rule that required the MRO to confer with the laboratory when a urine result showed the presence of 6-AM without the presence of a morphine marker.

    It was frequently brought to our attention that MROs approached this issue with the thought process and scientific understanding consistent with the available research data that shows that the presence of 6-AM indicates a specific marker for heroin use, regardless of the presence of morphine at the laboratory’s LOD (limit of detection).  Furthermore, MROs thought it an unnecessary and tedious process to go through this step and then to additionally contact ODAPC for instruction when this situation occurred.  Almost always when this happened, the ultimate result was an MRO verified positive result.

    ACOEM is therefore in full support of the Interim Final Rule and applauds the Department for removing this requirement of laboratory and ODAPC contact and consultation, with the specific instruction to the MRO to consider a test positive when 6-AM is present but with or without a morphine marker.  Furthermore we support and understand fully that there can be no legitimate medical explanation for the presence of 6-AM and that when this situation arises, it demands a positive MRO determination.

    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

    Douglas W. Martin, MD, FACOEM
    Chair, ACOEM Medical Review Officers Section