In an attempt to keep up with constantly changing trends in drugs of abuse and individuals’ tricks to the drug testing system, the Drug Testing Advisory Board (DTAB) never has a shortage of work to be done. The DTAB conducts research and advises the administrator, the Substance Abuse and Mental Health Services Administration (SAMHSA), on the agency’s drug testing activities and the drug testing laboratory certification program. The latest project for the DTAB is the evaluation of hair specimens for possible use in the Federal Workplace Drug Testing Program.
Since 1988, organizations that are required to perform federal workplace drug testing have been limited to the use of urine specimens. However, concerns and data have emerged that point up some of the limitations of traditional urine-based testing.
On July 15, the DTAB convened in Rockville, Md., and opened its meeting to the public to present information on the supportability of the hair specimen for federal workplace drug testing and the historical perspective on hair as a drug testing matrix. The meeting also addressed the current thinking on hair specimen drug testing as it relates to:
- Specimen characteristics;
- Collection, preparation and stability;
- Drug analytes, analyte stability;
- Best practices and experiences;
- Proficiency testing; and,
- Hair drug testing data.
Ron Flegel, Chair of DTAB, says, “We tried to present an unbiased rationale of the science that hair testing provides as well as what other alternate matrices provide.” He says with hair testing, there is a longer window of detection. Entities such as the Federal Motor Carrier Safety Administration and trucking companies pointed out in public comments that it is important for them to be able to look at longer windows of detection when it comes to pre-employment testing.
The technical aspects, as well as the legal aspects – some cases that had been concluded and some that are still ongoing around hair testing – were also discussed.
The presentations also addressed specifics surrounding the various hair colors and hair color bias, contamination, physiological characteristics of hair and how individuals can adulterate a hair specimen. Research has found that hair testing is very difficult to adulterate, but one presentation showed that bleaching or using a flat iron may affect the results of a hair specimen drug test.
Another benefit is the elimination of collection issues associated with urine. According to a press release from Omega Laboratories, “hair testing has consistently identified over three times as many illegal substance users as urine testing in regulated industry pre-employment trial programs.”
Essentially, the July meeting set out to answer questions that had previously been asked by professionals and the public.
In 2004, the administrator of DTAB, SAMHSA, published Mandatory Guidelines for Federal Workplace Drug Testing Programs that included alternate matrices to drug testing. These were urine, hair, oral fluid and sweat. In 2008, after receiving comments from both the public and the federal agencies, officials at SAMHSA decided that there was a great deal of scientific knowledge that still had to be gained on some of the alternate matrices and therefore only put out the urine mandatory guidelines, which were completed in 2008.
In 2010, the implementation of the changes in the urine program had begun and additionally it was stated in the preamble for public knowledge that the alternate matrices would be assessed individually based on field and public comments received.
In 2011, oral fluid testing began to be assessed and discussed at board meetings and open session. As a result, there were two mandatory recommendations given in 2012:
- To include oral fluid as an alternate matrix
- To include synthetic opiates in all testing whether it be urine or any of the alternate matrices that would exist in the future for the Federal Drug-Free Workplace Programs.
Those oral fluid mandatory guidelines are now in the process of being reviewed by the Department of Health and Human Services (HHS). “Oral fluid, hair, and sweat pads, were three of those alternate matrices that were proposed in 2004. Since we have completed, or at least the mandatory guidelines for oral fluid are in progress, the next alternate matrix would be hair,” says Flegel, director of the Division Workplace Programs for SAMHSA.
As was done with oral fluid and will be done with hair testing, the DTAB will give a recommendation to the administrator of SAMHSA, that it would or would not suggest that hair testing be included in the Federal Drug-Free Workplace Programs.
The administrator will then agree or disagree with the recommendation and based on that the Division of Workplace Programs would begin to write the mandatory guidelines for hair testing. From that point, the guidelines would be reviewed by HHS for final draft, go to the federal agencies for their comments and suggested edits, be taken back to account for those suggested edits and then would go out to the public. Flegel says generally this process takes anywhere between a year and 18 months.