Factors Required for Reliable Workplace Drug Testing
A. COLLECTION SITE
(Permanent/temporary facility used to collect a specimen)
1. Preparation of Collection Site
An appropriate site can be established to permit the collection of a valid specimen and ensure confidentiality
2. Security
Restrict access to collection site personnel and restrict access to specimens, collection materials, supplies, and records
3. Privacy
Facility constructed to ensure the privacy of the donor during specimen collection
4. Observed Collection
Capability to observe donor during specimen collection if there is any suspicion that the donor may attempt to tamper with or adulterate the specimen
B. COLLECTOR
(Individual who obtains the specimen from the donor)
1. Training
Can document appropriate training has been given to the collector
2. Certification
A certification program can be established to ensure that a collector is fully trained to properly collect and handle the specimen
C. COLLECTION DEVICE
1. Collection container
Allows for collection of a valid specimen, safe handling of specimen, and integrity and identity of specimen during transport
2. Capability to secure device
Able to prevent/indicate unauthorized access to specimen
3. FDA clearance (if required)
Container/kit cleared by FDA
4. Impact of device on specimen
Device alters or affects the specimen/drug/metabolite
D. SPECIMEN
(Hair, saliva, sweat, urine)
1. Body Site
Identify a specific body site to collect valid specimen
2. Multiple Testing
Volume/size of specimen is sufficient to conduct several tests
3. Potential to Split Specimen
Single specimen can be divided into two identical (split) specimens
4. Stability and Storage Evaluated
Effects of environment, storage, and shipment on specimen have been evaluated
E. COLLECTION PROCEDURE
(Procedure used to collect specimen)
1. Donor Identification
Procedure to ensure identification of donor
2. Prepare Donor for Specimen Collection
Procedure to ensure that a valid specimen can be collected
3. Chain of Custody
Can document the handling of the specimen from the time that the donor provides the specimen until the collector sends the specimen to the laboratory
4. Chain of Custody Form
Standard form can be designed to properly document all essential information (i.e, specimen custody, validity, and identity)
5. Specimen Integrity Evaluation
Procedure/tests available to ensure that a valid specimen is provided by the donor
6. Deter Tampering/Adulteration
Procedures to prevent donor from tampering with or adulteration the specimen
7. Transportation of Specimen
Can be packaged to protect specimen from damage/loss during transit
F. ON-SITE TESTING
(Refers to initial tests of urine specimens performed at collection site)
1. FDA clearance (if required)
The test kit has been cleared by the FDA
2. Specific for drug class
The test kit has documented specificity for the drug class of interest
3. Permit documentation of collection
Procedure allows appropriate documentation of specimen collection (see specimen collection A, B, C, D, and E)
4. Documentation of on-site testing
Procedure allows documenting the test result and chain of custody during testing
5. Documentation of results
A procedure can be established to document test result
6. Defined testing level
Uses HHS testing levels
7. Target analyte
Detects HHS target analytes
8. Objective differentiation of positive and negative
Test provides an objective discrimination between positive and negative results
9. Includes appropriate controls
Controls available to ensure on-site test is working correctly
10. Training/certification of on-site test analysts
Procedure available to train and certify analysts
11. Analysts do not know donor identity
Individual conducting on-site test is unable to determine donor identity
12. Result verified by second analyst
Ability to have results confirmed by a second analyst on-site
13. Procedure to detect adulterants
Ability to determine if the specimen has been adulterated and ability to determine if the test is effected by the adulterant
G. LABORATORY TESTING
1. Criteria for accessioning specimens
Can appropriate criteria be established to determine the acceptability of specimens received by the laboratories
2. Short term storage to ensure specimen integrity
Specimens can be stored to ensure that analytes are not affected by environmental or physical factors during normal handling procedures
3. Can identify adulterated/substituted specimens
Tests are available to determine the presence of adulterants and/or if the specimen is a valid specimen
4. Initial Test
(First test conducted to identify presumptive positive specimens for each drug class tested)
a. FDA cleared test
The test kit should be cleared by the FDA as a diagnostic medical device
b. Detect HHS target analytes
The test kit detects the target analyte
c. Use HHS established testing levels
The test kit performance has been optimized around the HHS testing cutoff level
d. Acceptable performance around the cutoff
Test kit performance around the cutoff is acceptable, i.e., samples 25% above and below the cutoff can be discriminated and are correctly reported as positive or negative
e. Ability to repeat initial test
Procedure allows the initial test to be repeated
5. Confirmatory Test
(A chemical test using a principle differing from the initial test that can uniquely identify a specific analyte)
a. Uses mass spectrometry for identification and quantitation
The technique provides a positive identification of a specific analyte (if present) and an accurate quantitative result of the analyte
b. Use HHS established testing levels
Capable of calibrating the procedure around the HHS testing cutoff level
c. Acceptable performance around the cutoff
Procedure is linear around the cutoff
6. Cutoffs reflect drug use
The cutoff can be related to drug use while minimizing potential endogenous, chemical, and electronic interferences
7. Internal quality control program
An internal quality control program can be established that includes calibrators, drug-free controls, and blind samples
H. QUALITY CONTROL AND QUALITY ASSURANCE
1. Certified laboratory program
A certification program can be established for laboratories conducting the testing
2. External PT samples
Performance testing samples can be prepared that challenge the ability of the laboratories to identify analytes and determine their concentration
3. Laboratory inspection program
An inspection program can be established to inspect and evaluate all aspects of a laboratory
4. Blind samples
Possible to submit negative/positive samples as if they were donor specimens
I. REPORTING
(Refers to the laboratory reporting results to the Medical Review Officer)
1. Certifying scientist review of lab results before reporting
A comprehensive final review can be conducted by one individual who reviews the technical data, chain of custody, and all other records associated with the specimens before the results are reported to the MRO
2. Results reported by specific drug
Laboratory report can list results for each specific drug detected
3. Confidential and timely written lab reports
There is a reasonable turn-around-time to report results and results are reported such that the identity of the donor and the results are kept confidential
4. Standard report form
A standard report form can be used to ensure that results are reported as required
J. MEDICAL REVIEW OFFICER
(Refers to a physician reviewing a laboratory result, discussing positive results with donor, and making a final determination regarding substance abuse)
1. Interpreting results
Scientific information is available to allow an MRO to properly interpret a positive test result
2. Alternative medical explanations
Alternative medical explanations been properly described/established
3. MRO Training
Appropriate training is available to ensure that MROs can properly interpret drug test results
K. MISCELLANEOUS ISSUES
1. Result related to dose/time response
Concentration of drug/metabolite related to the time and dose when drug use occurred
2. Specimen contamination
Specimen may contain drug from external exposure rather than through metabolic process