April 11, 2011

FLIGHTLINE BRIEFS

INSPECTION UPDATE

Many clients are experiencing their biannual FAA drug testing audit this year, some with and some without notice. The inspection can happen at any time, which was the case when snowbound inspectors up north came south in the cold months and inspected as many Part 121, 135, 145 and Contractor drug testing programs as possible.

Through our continuous training we are finding that many of you are complying with "Pre-Hiring Employment Testing." At the time of hiring, a pre-employment test must be done, even if the employee is going to spend time in training or doing non-safety-sensitive work for some time.

However, the FAA found an issue with one situation where a client paid the employee for taking the day off from his regular full time job to interview and orient himself with the new company. The FAA argued that he worked that day and this is still going back and forth on the final outcome.

The Inspectors are finding that some programs are not being diligent in completing random testing. This mostly happens with smaller operators that do not have enough staff to review the information.

If a D.E.R. is selected and opens mail at the beginning of the quarter, that is their notice of a random test and to take the test as soon as practical. One ongoing situation is a company that had a D.E.R. selected twice in one year and neither test was completed!!!

RETURN TO DUTY AND FOLLOW UP TESTING

You may experience the fact the one of your employees has a positive, or refuses to test. They have to submit themselves to the Substance Abuse Professional program and receive a RTD test and complete a Follow Up testing program. The SAP program is required by regulation if the employee wants to remain in a safety sensitive position.

This follow up program might be ongoing when a new employee is hired. Your background investigation will reveal that the Follow Up testing is still "in progress" and being completed. In either case, it is the D.E.R.'s responsibility to closely monitor and coordinate these tests according to the schedule that the Substance Abuse Professional dictates.

We have seen several instances during review of these Rehabilitation Programs by the FAA Drug Abatement Division that found the schedule was not closely adhered to and the FAA made a decision to begin the entire program over again. Some of these Rehabilitation Programs take up to two (2) years to complete. This can happen even if one scheduled test is missed!

LEGAL UPDATE

DRUG TESTING INDEXES

The new federally mandated urine testing process for safety-sensitive workers involves initial testing for the 6-AM heroin marker. In the past, safety sensitive worker urine testing for heroin was performed only after a positive morphine test result, because heroin metabolizes to 6-AM, and then to morphine.

In addition to lowering the cutoffs for amphetamines and cocaine, the U.S. DOT requires urine testing for heroin marker specifically. This newly mandated testing process revealed a nearly 20% jump in positive results – 0.011% in the fourth quarter of 2010 vs. 0.009% in the same period in 2009.

The government also requires testing for Ecstasy (MDMA). During the first three months of testing under the new requirements, the additional test yielded a positivity rate (0.004%) consistent with expected rates based on historical non-regulated testing data.

DRUG ALERT

MANDATORY REPORTABLE DRUGS WITH RESTRICTIONS

We are providing you with a listing of drugs that must be reported to your company, if you are licensed Part 61, 63, 65, 67 and in a safety sensitive position, whether taken alone or in combination with other drugs.

All safety sensitive employees should report prescriptions to the D.E.R. that may affect their safety sensitive work. You may want to remind your safety sensitive employees that they have a duty to report prescription medicines that they believe may affect their work.

The drug is to be named, then the times between when you take the drug and the times you will be performing safety sensitive work. How long the prescription typically lasts, should also be listed.

• Antivert – 24hrs – 1mo
• Atarax – 8hrs. – 1mo.
• Benedryl – 6hrs – 6mos.
• Codiene – 6hrs. – 1mo.
• Compazine – 8hrs – 1mo.
• Darvocet – 6hrs. – 1mo.
• Darvon – 6hrs – 1mo.
• Demerol – 8hrs. 1mo
• Empirin w/Cod – 6hrs – 1mo
• Equagesic/Meprobamate
• 8hrs – 1mo
• Flexeril – 8hrs – 1mo
• Hydrocodone – 8hrs – 1mo
• Hyphen – 8hrs – 1mo
• Levsin – 12hrs – 1yr
• Lioresal – 8hrs – 1mo
• Lomotil – 6hrs – 1mo
• Lortab – 8hrs – 1mo
• Meperdine – 8hrs – 1mo
• Mepergan – 8hrs – 1mo
• Meprobamate – 8hrs – 1mo
• Morphine – 8hrs – 1mo
• Naldecon – 6hrs – 1mo
• Norgesic – 8hrs – 1mo
• Parafles – 8hrs – 3mo
• Parafon – 8hrs – 3mo
• Percocet – 8hrs – 1mo
• Percogesic – 6hrs – 1mo
• Phenergan – 8hrs – 1mo
• Probamate – 8hrs – 1mo
• Promethazine – 8hrs – 1mo
• Pyridium – 6hrs – 1mo
• Reglan – 12hrs – 1yr
• Robaxin – 8hrs – 1mo
• Rutuss – 8hrs -1mo
• Skelaxin – 6hrs – 3mo
• Soma – 8hrs – 3mo
• Stadol – 8hrs – 1mo
• Talwin – 8hrs – 1mo
• Tigan – 8hrs – 1mo
• Torecan – 8hrs – 1mo
• Tylenol w/Cod – 8hrs – 1mo
• Tylox – 8hrs – 1mo
• Valium – 48hrs – 1mo
• Vicodin 8hrs – 1mo
• Vistaril – 8hrs – 1mo
• Wygesic – 8hrs – 1mo

This is a partial listing and not all inclusive. Any category of Analgesics, Anti-Motion Sickness, Tranquilizers & Sedatives, Antidepressants, Barbiturates, Skeletal Muscle Relaxants or Non-Prescription Cough & Cold Remedies and Antihistamines are medications of concern and are provided as a starting point for consideration.

For more information, or answers to questions you may have, please feel free to contact Flightline Drug Testing at the numbers below.