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  • ACOEM Asks That Provision Allowing Hair Testing for Screening Commercial Drivers Be Reconsidered

    November 20, 2015

    The Honorable James Inhofe, et al.
    Chairman
    Senate Committee on Environment and Public Works
    Washington, DC 20510

    The Honorable Bill Shuster, et al.
    Chairman
    House Committee on Transportation and Infrastructure
    Washington, DC 20515

    Dear Chairmen Inhofe, Shuster, and Thune, and Ranking Members Boxer, DeFazio and Nelson:

    On behalf of the American College of Occupational and Environmental Medicine (ACOEM), I write to respectfully urge the Surface Transportation Conference Committee to reconsider the provision that would allow hair testing for screening of commercial drivers.

    ACOEM is an organization of more than 4,000 occupational physicians and other health care professionals that provides leadership to promote optimal health and safety of workers, workplaces, and environments. Employee drug testing programs are an integral part of the safety programs of many employers. Occupational medicine physicians play an important role as medical review officers (MROs) in drug testing programs, ensuring integrity in the entire process: specimen collection, shipping and receiving, analysis, and reporting. All federal agencies require that drug-testing results must be reviewed by a certified MRO to ensure a positive result is not due to a legitimate medical use, and truly represents use of the drug by the applicant or worker being tested.

    Currently, the federal drug testing programs only allow urine drug testing, but the Department of Health and Human Services (DHSS) has been studying the appropriateness of using alternative matrices, such as oral fluid (saliva), and hair.

    Our concern with the pending bill is that it bypasses the usual process the federal programs have had in place since their inception during the Reagan administration. That is, the DHHS promulgates the new rules (or changes in the current testing programs) after diligent examination of the applicable scientific principles, scientific literature and practicalities of implementing the changes. The Department of Transportation (DOT) and its agencies then adopt the DHHS policies agency-wide. The DHHS has been studying hair testing for several years, and it is ACOEM’s understanding that DHHS is considering a proposal for using hair testing for federal agency drug testing. The current legislation proposes a rather radical change in this established process and would separate the trucking industry from the other DOT-covered agencies and from DHHS. We therefore advocate that introduction of hair drug testing for commercial vehicle drivers be initiated only after DHHS completes its review through its time-honored process of rigorous scientific examination described above and not through this proposed legislation.

    Thank you for your consideration of these comments.

    Sincerely,

    Mark A. Roberts, MD, PhD, MPH, FACOEM
    President