BACKGROUND INFORMATION ON ALCOHOL AND DRUG TESTING
BARBARA BUTLER & ASSOCIATES INC.
This backgrounder is not intended to discuss the merits of drug testing, or go into extensive details on the scientific considerations in setting up a program. It is simply intended to provide an overview of the main issues so that employers considering including testing as part of their alcohol and drug policy have a better understanding of the key issues.
TESTING AS PART OF A COMPREHENSIVE POLICY
Companies need to make a careful assessment of whether alcohol and drug testing should or should not be included in their overall policy. The introduction of testing in any workplace is a controversial decision, and should be made with full understanding of the role of testing in a comprehensive policy, and consideration of whether it is justified for certain employee groups.
Decisions are needed on who to test, under what circumstances, for what substances, using what technology, and what will be the consequence for failing a test, or refusing to be tested (including confirmed tampering with the sample).
WHO IS SUBJECT TO TESTING: UNDER WHAT CIRCUMSTANCES
Circumstances for testing can include:
Some companies may conclude testing will not play a role in the implementation of their policy. Others may conclude testing should be triggered for all employees under certain circumstances, or for certain groups of employees (e.g. high risk) under other circumstances. Each policy must be absolutely clear on when testing applies, and the procedures which will be used, as well as the justification for its introduction.
WHAT TO TEST FOR
Existing technology has developed methods to accurately test for the presence of a wide range of drugs. Workplace testing programs authorized through the United States Department of Health and Human Services (DHHS) and accepted throughout North America, focus on six specific drug classes most commonly associated with abuse in the general population.
The standard testing panel is marijuana, opiates, amphetamines, phencyclidine (PCP), cocaine, and alcohol.
Programs are not limited to these substances if there are problems and grounds to "expand" the slate. Many Canadian companies are adding oxycodone to their opiate panel because of the significant problems with it's use and abuse across the country. The U.S. Secretary of DHHS has signed off on the requirement for adding oxycodone to the regulated slate of drugs (January 2012). For the most part, however, additional drugs are generally only tested for in post treatment situations on the advice of the substance abuse specialist.
TEST PROCEDURES - DRUGS IN URINE
There are three stages to the testing process: sample collection, laboratory analysis, and medical review and reporting of results. All three stages have been strictly regulated in the United States, and these procedures have been accepted in Canada as meeting the highest standard of accuracy and integrity of the process.
The positive levels for the five classes of drug tests are indicated in the table below:
* A ng/ml means nanograms per millilitre. A nanogram is one billionth of a gram.
A millilitre is one thousandth of a litre.
Tests results provide qualitative and quantitative information indicating whether a specific substance is present in the urine. The concentration of a drug in urine is influenced by several factors: dose of the drug taken, how it is taken, frequency of use, time lapse from drug use to urine collection, amount of liquid consumed recently, time elapsed since last urination, time of day and any recent dehydrating exercise.
For drugs other than alcohol, a confirmed positive test simply indicates that the drug was ingested recently. Tests for alcohol use (breath) are more specific on the degree and timing of impairment, and can identify whether the person was under the influence of alcohol when the sample was collected through standard calculations equating test results to blood alcohol content.
A positive test confirms that laboratory analysis found the drug at or above the prescribed cut-off level. A negative test either confirms the drug was not found in the sample, or that it was present below the cut-off level.
On-Site Testing Devices: Undertaking an initial screen at the collection site (point of collection test or POCT) is becoming increasingly available and are particularly of interest for companies with remote operations where laboratory turn-around time could be longer because of distances. The test device is a "screen" in that it can screen out negative results. However, any result indicated by the screen as "not negative" must be forwarded to a lab for confirmation using the same chain of custody procedure, and a lab positive must be reviewed by an MRO before any employment action is taken.
In addition, companies should only use devices that have adulteration checks; otherwise, tampered samples could never be identified for further analysis at the lab. The U.S. government has approved the use of "mini labs" to do the screening step, but has not yet finalized approval for test cups.
For the most part in Canadian programs, test cups are being used in reasonable cause and post incident testing situations. Normally split sample urine testing is being used for all other testing situations except random, where in non-regulated random testing situations, oral fluid is often collected for analysis in the lab (see below). Some programs in northern Alberta are allowing POCT for site access testing when large numbers of people must have negative test results before getting on a site, and the laboratory process can not turn the volumes around quickly.
Oral Fluid (saliva) testing technology is now available which will allow efficient collection of a sample and analysis in a laboratory following similar security procedures as those for urine drug testing. Although not widely used in Canada at this time, employers are increasing looking at introducing this alternative technology because it is perceived as less intrusive, provides a tighter window to recent use of a drug, and has less potential for tampering as collection is observed. Although not currently approved for cross border regulated programs, the Secretary of DHHS has approved a plan to add oral fluid testing to the regulations.
The only accurate testing devices are those that collect samples for analysis in the laboratory. That is also the system that the DHHS is proposing in its regulations. There have been scientific studies undertaken over the past 6 to 8 years looking for devices that are specific enough to detect the drugs in oral fluid. These studies are being done to support the drugged driving legislation around the world, including under Canada's Criminal Code. To date, the researchers have not found a point of collection oral fluid device that is sufficiently accurate for use in these programs, and therefore none they would recommend for roadside or workplace programs.
TESTING PROCEDURES - BREATH ALCOHOL
Breath analysis for alcohol use is a widely used and accepted technology because breath is the most easily obtained bodily substance and the results are known within minutes of testing. Current-generation breath-alcohol analyzers have excellent accuracy, precision, sensitivity and selectivity or specificity for ethanol in breath specimens.
The concentration of alcohol in end-expiratory breath accurately reflects the alcohol level in the blood and can appropriately interpret the presence and degree of intoxication or impairment at the time the sample is taken.
Specific training and quality control measures are needed to ensure proper administration of the procedure and calibration of the device. Test results are displayed and confirmation results are printed using an Evidential Breath Testing Device. Collection is handled by a trained Breath Alcohol Technician, generally through an external collection agency; a company representative can be trained to operate the equipment if necessary because of unusual circumstances.
If after a reasonable number of attempts the employee is unable to provide a sufficient sample to register a breath test result, the company will be notified, and arrangements are made for a medical assessment. If there is a medical reason for the situation, the test will be cancelled; if there is no medical reason, this is considered a refusal to test.
TESTING PROCEDURES - ORAL FLUID ALCOHOL
In those situations when a breath analyzer is not available within a reasonable time period, alternative technology can be considered. Usually an alcohol saliva screen is used to "screen out" negative results. If a donor screens above the cut-off level, an oral fluid sample can be collected, sealed and sent to the laboratory for analysis. The device that can be used for this purpose is the one commonly used for oral fluid drug testing (noted above), called Quantisal and is approved by Health Canada. The Canadian laboratory testing oral fluid has developed the proper conversion process for a blood alcohol equivalent.
The process to collect and analyze breath alcohol samples is fully accurate provided an Evidential Breath Testing Device is used by a fully trained breath alcohol technician (BAT). The science on which urine drug testing rests is equally solid provided the process is handled by trained collectors, there is no break in the chain of custody, a screen positive is confirmed by GC/MS analysis and a qualified Medical Review Officer (MRO) reviews all lab positive, adulterated, substituted, or invalid results with the employee.
Although there has been considerable discussion about false positive test results (where a sample is reported to contain a drug that is not actually present above the cut-off level), any possible error in the sample analysis is eliminated through the two-stage screening process and regular calibration of equipment. To avoid any problem, companies should only contract with labs that meet the highest possible standards and are certified by the U.S. Department of Health and Human Services, with trained and qualified collectors, and with an experienced MRO who is fully independent of the laboratory.
CRITICAL ROLE OF THE MRO
It is the Medical Review Officer's job to determine if the laboratory result should be verified as positive, adulterated, substituted, invalid or cancelled after dialogue with the donor. Some the issues they must deal with are:
Tampering can take place when a person knows in advance that he/she will be asked to provide a sample (e.g. primarily in pre-employment/assignment or regular medical situations) where an attempt to substitute a clean sample is used, or in any situation with the help of an additive to "mask" presence of the drug.
Collection agencies and labs are aware of most, if not all, of the methods used to tamper with a sample (e.g. dilute it to move the drug level below the cut-off, use additives to mask the drug, substitute other samples or substances) and take appropriate steps to minimize or eliminate this possibility through the collection procedures and analysis checks. Therefore, there is no requirement for observation at the initial collection stage. However, in the event of confirmed tampering, some companies exercise the option to require observed collection on the next test, and in the case of companies complying with U.S. transportation regulations, there are requirements for observation in certain circumstances.
Additional information on testing programs can be found at: