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M R O C C       |       2 0 2 4       |       #2


MROCC Lifetime Achievement Award Recipient

 JAMES FERGUSON, DO
Medical Director, RMS
Vault Workforce Screening, A Sterling Company AND Kristine Pasciak
MROCC Executive Director

At the recent MRO training course in Orlando, MROCC was proud to recognize Dr. Donna Smith with the MROCC Lifetime Achievement Award for her many years of tireless work for and contributions to the fields of occupational health, workplace safety, and substance misuse prevention and testing. As an MRO certification organization, we are not in the business of giving awards. This award was the first of its kind and very much deserved by Dr Smith.

Dr. Smith is currently the Regulatory Compliance Officer at WorkforceQA, a full-service Third Party Administrator for workplace safety and compliance programs. She is also the Quality Assurance Officer at Recovery Trek, a Third Party Administrator focused on Professional Health Monitoring.

She has over 35 years' experience and expertise in drug-free workplace program regulatory compliance. Dr. Smith has served in policy and regulatory positions with the U.S. Army, Department of Defense, and the Department of Transportation (DOT). While at the DOT, she was a principal author of the DOT drug and alcohol testing rules. She also served on the anti-doping task force of the International Olympic Committee.

Dr. Smith is a widely acclaimed speaker, educator, and author. She is a nationally recognized expert in the areas of federal drug testing regulations, drug and alcohol testing procedures, drug and alcohol abuse awareness training for employees and managers, medical review officer (MRO) procedures, drug-free workplace policy and procedures, and substance abuse prevention and rehabilitation.

Since 1990 she has served on the faculties of the American Society of Addiction Medicine (ASAM), the American College of Occupational and Environmental Medicine (ACOEM), and the American Osteopathic College of Occupational and Preventive Medicine (AOCOPM) for continuing medical education courses for physicians serving as Medical Review Officers (MROs).

Dr. Smith has served on the Substance Abuse and Mental Health Services Administration's (SAMHSA) Federal Drug Testing Advisory Board (DTAB), the Substance Abuse Program Administrators Association (SAPAA) Board of Directors, and currently serves on the Board of the Drug-Free America Foundation.

Dr. Smith also serves as a technical expert in the Professional Health Monitoring arena. Dr. Smith earned a BA in sociology from Capital University, an MSW in clinical social work from Hunter College, CUNY, and a PhD in counseling psychology from Ball State University.

In addition to her other work and contributions, Dr. Smith has also regularly contributed to the MROCC newsletter, has co-authored the MROCC MRO Manual, and has served on our Examination Development committee since the early 1990s.

From the Board Members and staff of MROCC, thank you Dr. Smith for all you have done and the continuous support you give to all.

 
 

DEA Proposes to Reschedule Marijuana from Schedule I to Schedule III

 DONNA SMITH, PhD
LLC Regulatory Compliance Officer
WorkforceQA

On May 21, 2024, the Department of Justice (DOJ) Drug Enforcement Administration (DEA) published a Notice of Proposed Rulemaking (NPRM) to reschedule marijuana from Schedule I to Schedule III of the federal Controlled Substances Act (CSA). If the rule is finalized, marijuana would be considered a drug with "moderate to low potential for physical and psychological dependence" and would be available for medical use only at the federal level.

Under the federal CSA, the DEA classifies drugs into five distinct categories, or schedules, depending on the drug's acceptable medical use and its potential for abuse or dependence. Schedule I drugs are defined as having no currently accepted medical use and a high potential for abuse. Marijuana has been a Schedule I drug since the inception of the CSA in 1970. Schedule III drugs are defined as drugs with a moderate to low potential for physical and psychological dependence, and with accepted medical use. Some examples of Schedule III drugs are Tylenol with codeine, ketamine, buprenorphine, and anabolic steroids.

On October 6, 2022, President Biden released a statement asking the Secretary of the Department of Health and Human Services (HHS) and the Attorney General "to initiate the administrative process to review expeditiously how marijuana is scheduled under federal law". August 29, 2023, HHS recommended to the DEA that marijuana be rescheduled to Schedule III, and in accordance with the CSA, DEA initiated formal rulemaking in the May 21, 2024 NPRM. If the transfer to Schedule III is finalized, any drugs containing marijuana will be subject to the applicable prohibitions in the Federal Food, Drug, and Cosmetic Act, enforced by the Food and Drug Administration (FDA). Additionally, if marijuana is transferred to Schedule III, the manufacture, distribution, dispensing, and possession of marijuana would remain subject to the applicable criminal prohibitions of the CSA.

The NPRM set forth the following eight factors that are used when considering rescheduling. The conclusions reached by HHS and DOJ suggest that they do not agree on all of these issues and in its NPRM the DEA requests additional data through public comments.

  1. The drug's actual or relative potential for abuse. HHS concluded that marijuana does not lead to substance use disorder as frequently as other substances such as heroin, oxycodone, fentanyl, cocaine, alcohol and others. In 2016, DEA found that marijuana had a high potential for abuse and now recommends gathering additional data to assess marijuana's actual or relative potential for abuse.
  2. Scientific evidence of its pharmacological effect, if known. In the past 30 years, the potency of marijuana's delta-9 THC has increased dramatically. While HHS noted that marijuana use can produce pleasurable effects, it may also induce sedation and anxiety responses. Abuse can lead to addiction and the need for medical attention. DEA believes that additional data is necessary to assess this factor.
  3. The status of current scientific knowledge regarding the drug or other substance. HHS found that inhaling marijuana produces immediate effects while oral administration produces a slower onset of psychological effects. DEA noted that additional data regarding routes of administration of marijuana and the impact on delta-9 THC potency may be appropriate for consideration.
  4. Its history and current pattern of abuse. HHS concluded that the prevalence of marijuana is less than that of alcohol and significantly more than that of other drugs. DEA found in 2016 that marijuana is the most widely used illicit drug and anticipates that additional information arising from this rulemaking will further inform the findings.
  5. The scope, duration, and significance of abuse. HHS concluded that drugs other than marijuana, such as alcohol, heroin, and cocaine, are more likely to lead to substance use disorder. DEA found in 2016 that the abuse of marijuana was widespread and one of the primary drugs leading to admission for substance abuse treatment.
  6. What, if any, risk there is to the public health. HHS found that the risks posed by marijuana use to public health are low compared to other drugs. For overdose deaths, marijuana always is ranked lowest. DEA concluded in 2016 that marijuana poses a number of risks to public health, including impaired driving and physical and psychological dependence. DEA requests additional data on public safety risks that may be appropriate for consideration.
  7. Its psychic or physiological dependence liability. HHS found that marijuana can produce both psychic and physical dependence, although the symptoms are usually mild. In 2016, DEA found that long-term heavy use of marijuana can lead to physical and psychological dependence and that this dependence is underdiagnosed and undertreated in the medical setting. DEA requests additional information that may be appropriate for consideration.
  8. Whether the substance is an immediate precursor of a substance already controlled. HHS and DEA both concluded that marijuana is not an immediate precursor of another controlled substance.

Rationale for Schedule III

  1. HHS and DOJ both agree that marijuana has a potential for abuse less than other drugs and substances listed in Schedules I and II.
  2. HHS recommended a finding that marijuana has a currently accepted medical use in the United States, specifically for medically supervised treatment of anorexia related to a medical condition, nausea and vomiting (e.g., chemotherapy-induced), and pain. DOJ concurs with HHS's conclusion for purposes of the initiation of the rulemaking process.
  3. DOJ agrees with HHS's conclusion that the abuse of marijuana may lead to moderate or low physical dependence, depending on the frequency and degree of marijuana exposure.

Impact on Employers and MROs

Comments on the NPRM may be submitted up until July 22, 2024 at the federal register website. The DEA may hold administrative hearings on matters of fact and law related to the rulemaking; notices of such hearings would be published in the Federal Register. It will likely take months for DEA to review the comments submitted, so it is unclear when or if a final rule may be issued.

 
 

Yes, We Do Things Differently "Up North": The Uniqueness of Drug and Alcohol Testing in Canada vs the US

 Nadine Wentzell, BSc(Pharm), PhC, MAdEd Workplace Substance Use Consultant
Nadine Wentzell Consulting Inc.
nadine@nadinewentzell.com

What follows are some of the key areas where testing in Canada differs from the US. Of note, the information provided here is relevant to drug and alcohol testing in Canada and not related to the US Department of Transportation (US DOT) testing, other than where identified as follows.

For context, the US DOT 49 CFR Part 40 provides regulations on how to conduct required drug and alcohol testing and what procedures to use. These regulations apply to transportation employers, safety-sensitive employees — including self-employed individuals, contractors and volunteers covered by the DOT agency — and service agents. The sectors covered under these regulations are all federal aviation, motor carriers, railroad, transit, and pipeline and hazardous materials, as well as the US Coast Guard.

There are several overarching differences in workplace drug and alcohol testing between Canada and the US. The focus on testing in Canada is related to employer due diligence in providing safe workplaces. Any workplace testing is based on that goal and premise.

In Canada, there is no differentiation between legal and illegal substance use. An employer's responsibility is not enforcement or policing. Substance use that impacts safety is not influenced by the regulatory status of a drug; it is the action of the substance that negatively impacts the ability to work safely that is the concern. In Canada, employers are required to accommodate an employee confirmed to have a substance use disorder (SUD), as this is a protected ground from discrimination under Canada's federal Charter of Human Rights. As such, voluntary disclosure of an SUD is an integral component of drug and alcohol policies in Canada.

For the past 50 years, the alcohol level for criminality in Canada is 0.08% Blood Alcohol Concentration (BAC). However, it is scientifically recognized impairment with some individuals can occur at lower levels of alcohol. In recognition of this, many jurisdictions have reduced this level to 0.05%, and most workplaces follow 0.04% as per the US DOT. Unlike alcohol, there is not a consensus for any drug, from lab-based specimen analysis, at or above which will provide assurance of impairment. Positive test results for Oral Fluid (OF) are indicative of safety risk, not impairment.

  1. What are the regulations governing workplace drug testing in Canada?
    It may surprise you to know that there are no regulatory requirements that provide employers with direction or guidance on drug and alcohol testing in Canada. In particular, with cannabis, despite all the fanfare surrounding legalization in October 2018, the only legislative change was to the Canadian Criminal Code which was revised to include "Blood Drug Concentration" (BDC) prohibitions for driving. This is not to be confused with a definitive level equated with "impairment"* the new criminal offenses are referenced as being at, or over, a prohibited BDC for certain impairing drugs, including THC and cocaine.

  2. What are the standard reference sources for an employer who wants to conduct drug and alcohol testing?
    For over 30 years, the US has had comprehensive programs in place for the transportation industry under the regulations of US DOT 49 CFR Part 40. It is imperative for Canadian companies who have employees working in the US in any of the identified sectors to follow these regulations. The most common situation where this may apply to Canadian employers is in trucking, where the specifics of the Federal Motor Carrier Safety Administration (FMCSA) must be followed by those conducting business in the US.

    The standards for many processes under Part 40 are routinely referenced in Canada, such as collection protocols for specimens, which are valuable and ensure consistency with protocols to protect all involved in the process and ensure consistency in application. However, there are several significant differences. As an example, it is highly unlikely that observed collections would ever be permitted or conducted in Canada. Word-for-word duplication of US program elements is not recommended and inconsistent with many Canadian protocols.

    The Canadian Model for Providing a Safe Workplace (the Model), current version 6.1, was created from a need that arose in the oil and gas industry in Alberta, because of the absence of any federal regulatory requirements for drug and alcohol testing. It was a collaborative initiative by the Construction Owners Association of Alberta (COAA) and Energy Safety Canada. The intent was to create a general best-practices guideline for industry use, particularly for heavy industrial construction and maintenance. The Model has evolved over the years and is commonly referenced by many working in the field of drug and alcohol testing and occupational health and safety. However, a working knowledge of the Model details and its corresponding application is inconsistent and often inaccurate. The Model was never intended for application across all sectors and work environments. It is not a regulatory document and does not have that weight of application. This is important from the perspective that many employers are under the misunderstanding that it is the required standard in Canada, which is not the case.

    Third-Party Administrators (TPAs) are often a source of information for employers seeking guidance when creating their policies and/or providing direction on drug and alcohol testing. TPAs have certified collectors who collect specimens. They do not conduct drug and alcohol testing, which is a common misunderstanding. There are very few, if any, TPAs who are owned by, or operated under the guidance of, a licensed health care professional. Therefore, they are not bound to a strict ethical code, or necessarily employ anyone with the depth of knowledge to advise employers on the specifics of drug and alcohol testing. TPAs can best serve their clients by providing references to the previously noted resources and associated companion documents.

    Case law in Canada is what guides us in best practices regarding the "when" and the "how" of testing. Familiarity with recent trends in drug use, regionally and geographically, is also an important indicator of what to include on your testing panel.

  3. What certification/accreditation is required for a laboratory's analysis to be legally defensible?
    Laboratories in Canada that analyze drug specimens are not required to have Substance Abuse and Mental Health Services Administration (SAMHSA) certification. This is another area of confusion and misunderstanding. The most important aspect of lab-based analysis is that laboratories conducting drug testing follow strict protocols and analytical processes that follow industry standards of best practices, which will withstand legal rigor if ever challenged. The standard acceptable accreditations are ISO 17025 for substances of abuse, or the College of American Pathologists (CAP) Accreditation Certification.

  4. What drug panels are acceptable?
    There is no standard testing panel, or group of panels. Many employers will follow the US DOT "panel 5". Reference to any panel number is irrelevant to anyone other than a lab or a TPA who collects specimens to send to an accredited lab for analysis. It can be very confusing for employers and has no meaning or relevance to them.

    It is important for employers to know exactly what they need to be testing for and why. It is not uncommon for employers to identify a 12 panel, under the assumption that more is always better, and not realize that in addition to other concerns, several of the drugs on this panel list are no longer available or on the market in Canada, while others on this panel are not substances of abuse, and the employer has no authority or rationale to be testing for them.

    The generally accepted panel includes cannabis, cocaine, amphetamines, 6-acteylymorpohine (6-AM, heroin) and other opiates, more recently including fentanyl, even though at least one Canadian TPA has been in the practice of advising employers that it's not necessary, because it's a street drug and not a problem in the workplace. In my 20+ years experience of helping employers manage substance use in the workplace that assertion is not supported. Benzodiazepines are an important addition to the panel that many employers have made. These drugs are highly misused, abused, over-prescribed, and the "go-to" option to mitigate alcohol withdrawal. As alcohol continues to be the most common substance of abuse in Canada, their use is much more common than may be recognized.

  5. What are the most appropriate specimen types for testing?
    Until relatively recently urine testing remained the gold standard in Canada. Cannabis legislation has changed all that. Urine testing in the US and Canada is currently only for an inactive metabolite. With cannabis in particular, presence of THC metabolites can exist for several weeks after consumption. Urine testing equates with expensive "pee". In Canada, urine testing is generally reserved for return-to-work and ongoing follow-up testing, because in these circumstances, abstinence from substance use is frequently a requirement. Lab-based urinalysis will provide confirmation of inactive metabolite, when present, which is indicative of substance use.

    Testing in most workplaces is "event" testing, as sometimes referenced, in situations of post-incident and reasonable cause. In these circumstances, case law is focused on safety risk at the time of testing, and therefore a requirement to prove use of substance at the time. Other than blood — which is not an option in Canadian workplaces — the best indicator of current substance use is oral fluid. Lab-based oral fluid testing will provide confirmation of active or "parent" drug, on which disciplinary — and legal action, if necessary — can be taken.

    Hair testing is generally not accepted in Canada because there is no opportunity to test for active substance, nor differentiate as to whether the substance use was during work time or outside of works hours. It is generally considered an invasion of an individual's privacy. Exceptions to this are in circumstances of legal cases, such as child custody matters, where complete abstinence is a court-ordered requirement.

  6. What is the position on Point of Collection Testing (POCT) vs laboratory testing?
    Use of POCT devices in isolation, without any follow-up lab-based specimen analysis, is not an accepted best practice. There are several reasons for this, primarily because of the subjectivity of the interpretation of the results, which varies with the experience and confidence of the "reader" of the results. It is important to remember that POCT results are a screen only and are not reviewed by a Medical Review Officer (MRO). There is no confirmatory analysis. As such, the results of a POCT device testing are not legally defensible.

    In some situations, employers may choose to use a POCT for risk mitigation and returning an employee to work versus placing them in a "stand down" situation pending lab-based test results. This is not consistent with best practices and not recommended, for several reasons, not the least of which are the limitations of POCT devices regarding drug panels and levels. It is known that up to 50% of the drugs of concern will not be detected using this method. The Model directs that any POCT use is required to be followed by lab-based specimen analysis.

    Laboratory analysis and confirmation of positive testing is the only legally defensible result in situations of reasonable cause and post incident.

There are additional areas where drug and alcohol testing in Canada differ from the US. What has been identified here is a high-level overview. There are benefits to lack of regulation for employers conducting drug and alcohol testing in Canada primarily related to autonomy and flexibility. The downside to this is that in the absence of regulatory direction, there is much inconsistency and confusion. The result is a wide variance in employer policies and procedures, and a frequent lack of adherence to best practices. The best way to ensure drug and alcohol programs meet employer goals and are legally defensible is to stay current and informed through access to reputable and credible references and resources.

 
 

Evaluating educational needs in urine drug test interpretation

Christine Snozek, PhD Co-director of Chemistry
Mayo Clinic Arizona, Phoenix, AZ

Recently, MROCC and other professional societies were invited to participate in a survey evaluating case scenarios related to urine drug test (UDT) interpretation. The survey was sponsored by the Association for Diagnostics and Laboratory Medicine (ADLM), with the goal of identifying educational needs in a diverse group of healthcare professionals. Interpretative questions were developed by volunteers from ADLM's Toxicology and Therapeutic Drug Monitoring division, and vetted by independent expert laboratorians. The questions covered a variety of topics ranging from basic knowledge of immunoassay screen cross-reactivity to more advanced case scenarios such as simulated compliance.

Over 900 clinicians and laboratorians responded to the survey during 2020-2023. The largest respondent group comprised 'MD or equivalent' participants (n=510), 126 of which were from MROCC. Physician respondents reported a broad range of specialties, training/experience, and confidence in UDT interpretation. Respondents from MROCC reported notably more experience and confidence in UDT interpretation compared to physicians from other organizations, and compared to the full group of respondents (Table 1).

Table 1. Self-reported training/experience and confidence in urine drug test interpretation.

Training/experience in UDT interpretation
 NExtensiveModerateLittle/None
MROCC (MD & APP)12948 (37.2%)65 (50.4%)16 (12.4%)
Other MDs38368 (17.8%)112 (29.2%)203 (53.0%)
All respondents909194 (21.3%)296 (32.6%)419 (46.1%)
Confidence in UDT interpretation
 NExtremelyGenerallySomewhat/
Not at all
MROCC (MD & APP)12838 (29.7%)74 (57.8%)16 (12.5%)
Other MDs38253 (13.9%)118 (30.7%)211 (55.2%)
All respondents907156 (17.2%)324 (35.7%) 427 (47.1%)
APP: advanced practice professional; MD: medical doctorate; UDT: urine drug testing

Each respondent answered 6 out of 11 interpretative questions developed by the project team (the number of questions each participant saw was limited to reduce the time required to complete the survey). The mean number of correct responses for all respondents was 4.04 out of 6 possible. Physician respondents on average answered 4.14 questions correctly, ranging from 4.82 for MD toxicologists to 3.66 for primary care and internal medicine (PCIM) physicians (Table 2). Respondents from MROCC averaged 4.05 correct answers.

Table 2. Survey responses by physician specialty.

MD respondents, by specialtyN (% of MDs)Mean Correct (SD)p (vs Toxicology)
Clinical or medical toxicology28 (5.5%)4.82 (1.31)Ref.
Addiction medicine39 (7.6%)4.56 (0.94)n.s.
Psychiatry22 (4.3%)4.55 (1.06)n.s.
Pain management23 (4.5%)4.39 (1.03)n.s.
Emergency medicine121 (23.7%)4.26 (1.29)0.02
Pathology43 (8.4%)4.19 (1.28)0.03
Occupational medicine73 (14.3%)4.18 (0.98)0.01
Primary care and internal medicine132 (25.9%)3.66 (1.22)<0.0001
n.s.: not significant; SD: standard deviation.

The survey results highlighted areas of UDT where additional education could benefit respondents from all backgrounds and specialties. The full study, entitled 'Assessing Knowledge Gaps and Educational Needs in Urine Drug Test Interpretation Among Healthcare Professionals' will be published this summer in American Journal of Clininical Pathology. The following case scenarios from the survey are of particular relevance to MROCC.

CASE 1: A patient prescribed Ativan (lorazepam) has a negative urine immunoassay screen for benzodiazepines. Which response is correct?

RESULTS: 67.2% of all respondents and 41.7% of MROCC respondents correctly identified that benzodiazepine immunoassay screens can have falsely negative results for lorazepam, and that confirmation testing is warranted. 33% of MROCC participants incorrectly responded that the negative screen proves noncompliance.

EDUCATIONAL EMPHASIS: All immunoassay drug screens have the potential for both false positive and false negative results, and should never be considered definitive. Benzodiazepine screens in particular are often poorly sensitive for conjugated metabolites such as lorazepam-glucuronide, the predominant form of lorazepam in urine. Although some assay manufacturers have recently incorporated enzymatic removal of glucuronide conjugates to improve benzodiazepine detection, individuals interpreting UDT screening results should recognize the potential for poor cross-reactivity and the importance of confirmation testing by mass spectrometry to resolve unexpected results.

CASE 2: A patient prescribed oxycodone is positive on her urine confirmation test for oxycodone (40,000 ng/mL) and hydrocodone (5000 ng/mL). What is the best interpretation?

RESULTS: 54.9% of all respondents and 64.1% of MROCC respondents correctly recognized that these drug concentrations are most consistent with co-ingestion of oxycodone and hydrocodone. 30.1% of MROCC respondents incorrectly answered that hydrocodone is a metabolite of oxycodone.

EDUCATIONAL EMPHASIS: Hydrocodone and oxycodone are distinct semi-synthetic opiates that do not share a common metabolic pathway. The primary metabolites of oxycodone are noroxycodone and oxymorphone (active); oxymorphone is further metabolized to noroxymorphone and oxymorphone-glucuronide. Hydrocodone metabolites include norhydrocodone, dihydrocodeine, and hydromorphone (active); the latter two compounds can also form glucuronide conjugates.

CASE 3: Your patient has a history of heroin use. A urine opiate screen is positive and confirmation shows 250 ng/mL of morphine. 6-monoacetylmorphine (6-AM) is undetectable. Which response is correct?

RESULTS: 73.5% of all respondents and 73.8% of MROCC respondents correctly recognized that 6-AM is not always present after remote heroin use. 23.3% of MROCC respondents incorrectly answered that undetectable 6-AM rules out heroin use.

EDUCATIONAL EMPHASIS: Short half-life compounds such as heroin, 6-AM, and cocaine are eliminated shortly after use, even with relatively concentrated matrices such as urine. Downstream metabolites such as morphine (for heroin/6-AM) and benzoylecgonine (cocaine) might be the only remaining evidence of substance use. Detection windows vary depending on the compound, dose, and individuals' clearance, but in general the parent drugs heroin and cocaine will be undetectable within hours and 6-AM may only be detectable within 1 day of heroin use.

CASE 4: A patient prescribed Suboxone (buprenorphine/naloxone) has urine confirmation results (in ng/mL): 10,000 buprenorphine, 50 norbuprenorphine, 2,500 naloxone. What is the best interpretation?

RESULTS: 39.5% of all respondents and 38.5% of MROCC respondents correctly identified sample adulteration with Suboxone to simulate compliance. 42.3% of MROCC respondents incorrectly answered that the norbuprenorphine to buprenorphine ratio indicates compliance.

EDUCATIONAL EMPHASIS: Addition of prescribed medications to urine samples to simulate compliance can occur with any high-risk therapeutic including opioids and medication-assisted therapies. Presence of metabolites, while suggestive of at least partial compliance, does not rule out addition of medication directly to the sample. Very low metabolite to parent ratios are a potential indicator of sample adulteration, although the expected ratios vary depending on the parent compound and metabolite(s) tested. In this scenario, a metabolite:parent ratio of 0.005 is well below the published threshold of 0.02 for suspecting buprenorphine adulteration. An additional clue in this scenario is the presence of naloxone in a 1:4 ratio with buprenorphine; naloxone is poorly absorbed orally but present in Suboxone at 1/4th the concentration of buprenorphine.

 
 

The ACOEM Occupational Toxicology Special Interest Section

John W. Downs MD MPH Medical Toxicologist, Virginia Commonwealth University Health System, Richmond, Virginia

The Occupational Toxicology Section of the American College of Occupational and Environmental Medicine (ACOEM) is a newer special interest section within ACOEM. Following the American Occupational Health Conference (AOHC) in spring 2022, ACOEM members Dr. Beth Baker and Dr. John Downs (both medical toxicologists) felt that toxicology-related content at AOHC could be improved and that ACOEM members with a background in medical toxicology or general toxicology would be interested in having a forum where clinical occupational toxicology topics could be discussed. Further, Dr. Baker and Dr. Downs recognized that occupational and environmental medicine (OEM) physicians had a role in establishing the specialty of medical toxicology, but that the vast majority physicians now training in medical toxicology come from an emergency medicine background. A special interest section for occupational toxicology could be helpful to reinvigorate physicians with an OEM background to pursue additional training in toxicology, or to develop unique curriculum for training in occupational toxicology.

In summer 2022, Dr. Baker and Dr. Downs surveyed ACOEM membership with reported expertise in toxicology to assess for the desire for toxicology interest section to be created and willingness to participate. The response from ACOEM was positive, and a formal proposal was submitted to, and approved by the ACOEM Board of Directors in November 2022. Initial section members and other interested ACOEM members had the first in-person meeting of the Occupational Toxicology section at AOHC 2023 in Philadelphia.

Goals for the Occupational Toxicology section are to:

  1. Provide a forum for discussion of individual or worker care issues about toxicology and toxic or potentially hazardous exposures in the workplace.
  2. Provide educational offerings for those who care for workers or individuals exposed to occupational toxins or potentially hazardous exposures. This may include sessions at current AOHC meetings and online educational webinars.
  3. Provide a resource to find ACOEM members who are experts in occupational toxicology who can consult on, or advise on, workers' or patients' toxicological or potentially hazardous exposures.

In its short existence, the section has thus far been successful in providing unique educational experiences in occupational and environmental toxicology for ACOEM members. At AOHC 2023, the section sponsored a well-received plenary session regarding the glyphosate cancer controversy. More recently at AOHC 2024, the section sponsored two plenary sessions entitled "Decoding the safety data sheet" and "Anecdotes and Antidotes: evolved thinking for workplace antidotes." Additionally, the section also co-sponsored two additional plenary sessions in conjunction with Veterans Administration physicians on military occupational and environmental exposure hazards.

The section was again able to meet in-person at AOHC 2024 to discuss potential initiatives for the upcoming year. Section members were reminded that ACOEM Connect provides a platform for communications between section members to discuss unique case presentations or new toxicologic questions. Section leadership is already working on developing proposals for educational content for next year's AOHC (April 27 - 30, 2025) in Austin, Texas. Possible future content may include impact of microplastics on human health in conjunction with the ACOEM Environmental Health section, and a review of the literature regarding occupational exposures to Per- and polyfluoroalkyl substances (PFAS). Occupational toxicology section members have also expressed interest in partnering with the ACOEM medical review officer section to discuss novel drugs of abuse.

For those interested in becoming an ACOEM Occupational Toxicology section member, they can simply add section membership when initiating or renewing ACOEM membership. Many current section members are board certified by the American Board of Medical Specialties (ABMS) in medical toxicology or by the American Board of Toxicology (ABT) in general toxicology, but section members need not have formal training or certification in toxicology. As with all other ACOEM special interest sections, the annual membership fee is $25. For questions about the group, please feel free to email Dr. John Downs (email: downsjw2000@gmail.com) for more information.

On June 21, 2024 the Department of Transportation (DOT) published three notices in the Federal Register relating to its May 2, 2023 final rule that, among other items, authorized employers to use oral fluid drug testing as an alternative testing methodology to urine drug testing. Complete information is available on the DOT website. Please note: this link was updated 8/5/2024 to reflect the most recent action on this notification.

The National Laboratory Certification Program (NLCP) sent a reminder of the July 19, 2024 deadline for MROs to submit their semiannual reports on federal agency specimens that were reported as positive for a drug or drug metabolite by a laboratory and verified as negative. Register and submit your report through the NLCP online. Please note that this requirement only applies to HHS-mandated drug testing. It does not apply to DOT or NRC testing.

ODAPC - DOT

SAMHSA - HHS

NRC

CUSTODY AND CONTROL FORMS (CCFs)

 
          
 

Medical Review Officer
Certification Council (MROCC)
3231 S Halsted St, Ste Front ###167
Chicago, IL 60608

Tel: 847.631.0599
Email: mrocc@mrocc.org

 

Editor: James Ferguson, DO
Managing Editor: Kristine Pasciak
©2024 Medical Review Officer Certification Council

ISSN: 2833-0870

 

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