Transcript FAA/DOT Regulatory Overview & Update

Drug and Alcohol Testing Programs
Updates for FTA-regulated Employers
Dr. Donna Smith
FirstLab, Inc.
[email protected]
February 2009
RECENT PART 40 REVISIONS
August 2008
Part 40 Amendments
• Final Rule June 08; effective 08-25-08
− Specimen validity testing mandatory
− Direct observation procedures for specimen collection
modified
− Changes for MRO interpretation and reporting of
multiple invalid specimen results; multiple specimens
collected at one testing event; multiple results on a
specimen
Specimen Validity Testing (SVT)
• Mandatory for all DOT drug testing
• Minimum SVT requirements for laboratory
− Creatinine (if less than 20 must also measure Specific
Gravity)
− pH
− One or more oxidizing agents
• Criteria for adulterated, substituted and invalid
remain the same
Invalid Specimens
 DOT has adopted the DHHS guidance to
laboratories for what they report as “invalid
Specimen”
 12 circumstances that require laboratory to report a
specimen as invalid
 MRO has responsibility for discussing an invalid
result with the certifying scientist before
interviewing the donor
 Purpose of this discussion is to determine if additional
testing of the specimen at another laboratory is
beneficial
Invalid Specimen
 Donor interview is to determine if there is a medical
explanation for the circumstances that rendered the
specimen invalid
 If there is no medical explanation, the test is cancelled and an
immediate re-collection under direct observation procedures is
required
 If there is a medical explanation for the invalid specimen (e.g.
medication interference), the test is cancelled and there is no
recollection of a specimen
 If donor admits to drug use, the MRO must write and
sign a statement documenting the donor’s admission
and report same to DER
 Test is cancelled
 If donor admits to attempting adulteration, the MRO will
report the result as a refusal to test
Direct Observation Collections
 Required in the following circumstances:
 Donor presents a specimen with temperature out of range
 Donor presents a specimen that collector believes was adulterated or
substituted
 MRO cancels a test and requires a re-collection of a specimen
because Specimen creatinine was 2-5 mg/dL
 Specimen was invalid and there was no medical explanation
 Split specimen was requested and was not available for reconfirmation
 Direct observation procedure provides for more visual scrutiny
by observer/collector
 Donor must position clothing so that the observer can view the donor’s
body from chest to mid-thigh (front & back)—to check for a urine
substitution or adulteration devise.
 After inspection, the donor may reposition clothing and provide
specimen with observer directly observing the urine leaving the body
into the collection container
Multiple Results on a Specimen
 If specimen is both positive and adulterated or
substituted, MRO reports both positive and
refusal to test determinations for the test
 If specimen is verified as positive and/or refusal
to test and is also invalid, MRO does not cancel
test or report specimen invalidity
 Positive dilute is reported to DER, however no
re-collection is authorized
Resources from DOT’s
Office of Drug & Alcohol Policy & Compliance
• Best Practices for DOT Random Drug and
Alcohol Testing
• Employer Guide to DOT Testing
• Employee Booklet (What Employees Need To Know About
DOT Drug & Alcohol Testing)
• DOT Specimen Collection Guidelines
All of the above are available at
www.dot.gov/ost/dapc
DESIGNATED EMPLOYER REPRESENTATIVE
(DER)
DUTIES, PROGRAM COMPONENTS, BEST PRACTICES
Designated Employer
Representative (DER)
- Serves as point of contact for the testing program
- Receives test results from the Medical Review
Officer and Breath Alcohol Technician (BAT)
- Ensures that employees who violate the policy are
removed from safety-sensitive duties and meet
return to duty requirements, if they return to work
- Ensures that all eligible employees are in a random
testing pool
- Serves as the custodian for all records required by
the DOT rules
Reasonable Suspicion Training
• Required for all supervisors
• Minimum of 2 hours
− Signs and symptoms of drug/alcohol misuse
− Criteria for reasonable suspicion testing
− Procedures for documenting R/S testing and
getting employee tested
• Training can be classroom, video,
computer-based
Employee Drug and Alcohol
Awareness Information
• Educational materials or training classes should be provided to all
employees subject to testing
• Information should include:
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Prohibited conduct
Testing requirements and procedures
Consequences and disciplinary actions
Employee rights and responsibilities in testing program
Alcohol and drug abuse awareness information
Information on getting help with a substance abuse problem
• Employee should sign acknowledgment of receipt of
information/materials
Hiring or Transferring to a DOT
Position
• Pre-employment/post-offer testing with a negative result
before person is hired or transferred
• Employee put in random pool immediately after
hiring/transfer
• Prior employer Drug and Alcohol violations check
• Documentation that question concerning a previous positive
or refusal to test on a DOT pre-employment test is asked on
application or at time of offer
Reasonable Suspicion Testing
• Based on the observations of a supervisor who has completed R/S
training
• Supervisor’s observations must be documented on a form or written
report
• R/S tests must be completed ASAP after decision to test is made
− If both alcohol and drug tests are indicated, the alcohol test should be
conducted first
• Employee should be escorted to testing site
• Employee should not be permitted to return to work after testing;
transportation home should be offered
− RTW only after test results are received
Post-Accident Testing
• Understanding of FTA criteria for post-accident testing
− FTA created a quick reference guide that provides information on
FTA post-accident thresholds, who should be tested and limitations
for testing. The 3 x 2 laminated cards can be ordered on-line from
the Publications tab of the FTA, Office of Safety and Security
website
• Records for DOT post-accident and non-DOT or
company authority post-accident testing must be
separate and distinct
• Thorough documentation of all DOT post-accident
testing incidents
• Time constraints for accomplishing testing
• Procedures in place for accomplishing post-accident
testing during “non-business” hours
RANDOM TESTING
• Ensure all eligible employees are in testing pool and that
pool is updated as needed
• Random selection process meets DOT requirements
• Documentation of reasons why selected employees are
not tested
• Tracking to ensure that minimum percentage is achieved
• Tracking to ensure that there is no predictable pattern to
when random tests are conducted
• Remember that cancelled random tests do not count
toward required annual percentage
Random Testing Basics
• Updating of pool
− Safety-sensitive employees should be placed in pool immediately upon
hire or transfer into position
− Pool should be reviewed and made current before each random
selection is made
• Random selections must be made at least quarterly and both the
selection dates and the testing dates should be unpredictable
and shown no identifiable pattern
• Each eligible employee must have an equal chance of being
selected and of being tested
• Use of “alternates” is discouraged; use “over selection” criteria
instead
- Alternates can only be tested if all “primary” selectees have either been
tested or are not available for the entire testing cycle
• Once notified of selection for testing, employee must proceed
immediately to testing site
Random Testing Best Practices
• Random testing dates must demonstrate an
unpredictable pattern and be reasonably applied to
all shifts or work cycles
• If DER selects random testing dates, selected
employees who are absent or otherwise not available
on the selected date are not “excused” from testing
for the selection period
• Once a new random selection is made, employees
selected for the previous period cannot be tested
• Random alcohol testing is limited to just before,
during or just after performing safety-sensitive duties
Return to Duty and Follow-up Testing
• Occur only when there has been a DOT violation (positive, refusal to
test, etc.)
• RTD test conducted after SAP has provided follow-up evaluation report
stating that employee has complied with treatment requirements
• Follow-up testing determined by SAP
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Begins when employee returns to safety-sensitive duties
Minimum of 6 FU tests in first 12 months after return to duty
FU testing may extend for up to 60 months as ordered by SAP
Number of tests and duration of testing determined by SAP
Employer sets schedule for “no notice” FU tests
Employee is also in random pool
MRO Drug Test Results
• Negative—No drugs present above cut-off level
• Negative Dilute—No drugs present above cut-off level and
low specific gravity & creatinine
• Positive—Drugs present and no medical explanation
• Refusal to Test—Adulterated (contains exogenous
substance or excessive level of endogenous substances) or
Substituted (SG & creatinine not consistent with human
urine)—or no medical explanation for inability to provide a
urine specimen
• Canceled Test—Invalid specimen, flawed
collection/specimen, Shy bladder with medical explanation
Alcohol Test Results
• Reported to you by the BAT if result is above
0.020 BrAC
• May be reported directly to your TPA if result is
less than 0.020
• A result less than 0.020 is a Negative
• 0.020-0.039 result requires temporary removal
from duty but is not a positive
• 0.040 or greater is a positive alcohol test—a
violation of DOT rules
EAP & RETURN TO DUTY
• Procedures for SAP contact information being provided to
employees/applicants
• Company policy on EAP , if available
• Last chance agreements, return to duty after treatment,
etc.
• Ensuring employee is returned or continued in random
pool, in addition to a follow-up testing program
Records
• The records shall be maintained in a secure location
with controlled access.
• §655.71 specifies the records to be maintained and
the periods of retention
• Types of records to be maintained include records
related to:
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Collection process
Test results
Referral and return to duty and follow-up testing
Employee training
• §40.333 also specifies records employers must keep
Documents needed for record maintenance under
40.333
• Keep the following records for five years:
− Records of alcohol test results indicating an alcohol concentration of
0.02 or greater;
− Records of verified positive drug test results;
− Documentation of refusals to take required alcohol and/or drug tests
(including substituted or adulterated drug test results);
− SAP reports; and
− All follow-up tests and schedules for follow-up tests.
• Keep records for three years of information obtained from
previous employers under §40.25 concerning drug and alcohol
test results of employees.
• Keep records of the inspection, maintenance, and calibration of
EBTs for two years.
• Keep records of negative and cancelled drug test results and
alcohol test results with a concentration of less than 0.02 for one
year.
Additional Records Required under Part 655
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Documents relating to the random selection process.
Documents generated in connection with decisions to administer reasonable suspicion
drug or alcohol tests.
Documents generated in connection with decisions on post-accident drug and alcohol
testing.
MRO documents verifying existence of a medical explanation of the inability of a covered
employee to provide an adequate urine or breath sample.
The employer's copy of the custody and control form.
Documents related to the refusal of any covered employee to submit to a test required by
this part.
Documents presented by a covered employee to dispute the result of a test administered
under this part.
Training materials on drug use awareness and alcohol misuse, including a copy of the
employer's policy on prohibited drug use and alcohol misuse.
Names of covered employees attending training on prohibited drug use and alcohol
misuse and the dates and times of such training.
Documentation of training provided to supervisors for the purpose of qualifying the
supervisors to make a determination concerning the need for drug and alcohol testing
based on reasonable suspicion.
Certification that any training conducted under this part complies with the requirements for
such training
Copies of annual MIS reports submitted to FTA.
Record maintenance—Best Practices
• Maintain paper records in secure, controlled access filing
cabinet
− Drug & alcohol testing records should not be maintained as part
of employee personnel file
− Filing by date within record type categories is generally most
efficient
• If records are maintained electronically, including pdf or
other images of CCFs, ATFs, etc., they must be capable
of being printed/reproduced as paper documents
• Records maintained at employer’s principal place of
business should not be transferred or transported off-site
− Audits by FTA and state oversight agencies are conducted at
employer’s place of business
− Statistical and data summary reports may be required/requested
by oversight agencies for ongoing compliance monitoring
SPECIMEN COLLECTION PROCESS
ENSURING INTEGRITY OF THE TESTING PROGRAM
Specimen Collection
• The DOT, DHHS and other government entities have identified
the specimen collection process as the “weak link” in the federal
drug testing programs
• Program integrity, deterrence and detection of illicit drug use, and
ultimately safety, are affected by collection procedures that give
opportunities for donors to, adulterate, substitute, and manipulate
their urine specimens
• The original specimen collection procedures emphasized the
proper identification of the specimen with the donor, the security
of the specimen through chain of custody documentation, and the
donor’s privacy rights.
• Products and instructions for “beating a drug test” have become
readily available via the internet and other media.
• DOT collection procedures have been refined and revised to
place more emphasis on preventing cheating on the test
Protecting Specimen Integrity
 Elements of the specimen collection
process designed to deter and detect
attempts to adulterate, substitute, dilute
or otherwise defraud the drug test
 Preparation of the specimen collection
site
 Deterrent actions with the donor
 Specimen integrity checks by the
collector
Preparation of the Collection Site
• Water sources in toilet enclosure are disabled so there is
no access to add water to the specimen, mix or prepare
solutions, etc.
• Bluing placed in toilet bowl, tank lid taped or tank water
blued
• Access/exits restricted or secured
• Cleaning supplies, materials, other possible contaminants
removed
• Collection supplies discarded/removed
• Inspect storage areas or “hidden spaces” for urine
specimens, bottles, adulterants, etc.
• Post public restroom against unauthorized entry
− Prepare one stall for use; collector remains inside restroom
Deterrent Actions with Donor
• Have donor remove all “outer garments” (jackets, coats, coveralls, hats,
etc.)
• Require donor to leave all hand carried items outside toilet enclosure
(bags, purses, cell phones, IPods, etc.)
− Donor may retain only wallet, money clip, money, credit cards, etc.)
• Require donor to empty all pockets and display contents
− Donor must leave all items from pockets, except money, outside the toilet
enclosure
• Require donor to wash & dry hands in presence of collector before
entering the toilet enclosure
• Provide donor with only the collection container—not the specimen bottles
to take into the toilet enclosure
• Accompany donor to door of toilet enclosure
• The collector may set a reasonable time for the donor to remain in the
toilet enclosure
• Pay close attention to the donor and his actions in this preparation
process
Specimen Integrity Checks by the Collector
• Specimen temperature check
− Within 4 min. of the donor presenting the specimen
− Acceptable temperature range 90-100°F
- If temperature is out of range, a 2nd immediate collection under
direct observation must be conducted
• Specimen volume check
− Must be at least 45 mL in collection container
- If less, specimen must be discarded (unless specimen is “suspect”)
• Specimen color, odor, physical properties check
− If specimen is green/blue or other color inconsistent with voided
specimen, specimen is “suspect”
− If specimen’s odor yields bleach, ammonia, vinegar or other
common adulterant, specimen is suspect
− If specimen appears to have visible residue or sediment, is
excessively frothy or bubbly, specimen is suspect
Additional Deterrent Actions
• Donor is not permitted to leave collection site
“control” at any time during collection process
− Including while waiting because of a “shy bladder” or
waiting for a second observed collection
• Collector must keep specimen under his/her control
and sight at all times after presentation by the donor
• Closely monitor and control access to fluids during
shy bladder procedure and at any time while donor is
waiting to provide specimen
• Decrease time donor is kept waiting after “signing in”
and beginning collection process
Additional Specimen Integrity Measures
• Direct Observation collection procedures required when:
− Collector believes donor brought item(s) to collection site intended to defraud
test or impact specimen integrity
− Specimen temperature is out-of-range
− Specimen color, odor, physical appearance is unusual
− MRO has ordered a direct observation because previous test was:
- Cancelled-Invalid (no medical explanation)
- Cancelled because there was no split available
- Dilute with Cr. 2-5
• Direct Observation procedures modified to include inspection of donor for
adulterant/substitution apparatus
− Donor must adjust clothing so that observer can view the donor’s body (front
and back) from chest to mid-thigh to inspect for adulteration/substitution
paraphernalia
- Donor may reposition clothing after the visual inspection and proceed to provide
specimen in observer’s presence
DOT’s 10 Steps to Collection Site Security and Integrity
Office of Drug and Alcohol Policy and Compliance
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1. Pay careful attention to employees throughout the collection process.
2. Ensure that there is no unauthorized access into the collection areas and that
undetected access (e.g., through a door not in view) is not possible.
3. Make sure that employees show proper picture ID.
4. Make sure employees empty pockets; remove outer garments (e.g., coveralls, jacket,
coat, hat); leave briefcases, purses, and bags behind; and wash their hands.
5. Maintain personal control of the specimen and CCF at all times during the collection.
6. Secure any water sources or otherwise make them unavailable to employees (e.g.,
turn off water inlet, tape handles to prevent opening faucets, secure tank lids).
7. Ensure that the water in the toilet and tank (if applicable) has bluing (coloring) agent
in it. Tape or otherwise secure shut any movable toilet tank top, or put bluing in the
tank.
8. Ensure that no soap, disinfectants, cleaning agents, or other possible adulterants are
present.
9. Inspect the site to ensure that no foreign or unauthorized substances are present.
10. Secure areas and items (e.g., ledges, trash receptacles, paper towel holders,
under-sink areas, ceiling tiles) that appear suitable for concealing contaminants.
Employer Responsibilities
• Ensure all collectors meet DOT training qualification
standards
• Request that “DOT’s 10 Steps to Collection Site Security
and Integrity “ posters be displayed at collection sites
− Available on ODAPC website www.dot.gov/ost/dapc
• Encourage the use of a collector checklist for each
collection
• Ensure that collection sites are aware of direct
observation procedures and conduct same as required
• Review employer copies of CCFs to ensure they are
complete and accurate
• Visit collection sites frequently; conduct audits or
administer questionnaires to reinforce use of correct
specimen collection procedures
PRESCRIPTION & OTC MEDICATIONS
IMPLICATIONS FOR SAFETY & PERFORMANCE
Legal vs. Illegal Drugs
• NTSB, ONDCP, SAMHSA and other government agency
studies indicate that abuse and misuse of prescription
controlled substance medications is more prevalent than
“illicit” drug use.
• Dramatic increase in past decade in use of medications
for chronic pain, anxiety, sleep disorders, & attention
deficit disorders.
• Inappropriate use of medications takes several forms:
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Non-medical use
Misuse
Abuse
Physiological dependence
Psychological dependence
Inappropriate Use-Definitions
• Non-medical use is when use of the medication is not prescribed
by a medical professional and is used for the experience or
feeling it causes.
• Misuse is the incorrect use of a medication by not following
prescribed dosage levels, frequency of use, or use for a purpose
other than for which it was prescribed.
• Abuse is when the pattern of use leads to clinically significant
impairment or distress that manifests itself in the individual’s
behavior.
• Physiological dependence is when the individual experiences
increasing tolerance for a drug and experiences withdrawal when
the medication is discontinued.
• Psychological dependence or addiction is when the individual
experiences an overall loss of control, seeks medication
compulsively, and continues use of the medication in spite of
negative consequences.
DOT Drug Testing Limitations
• DOT drug testing is limited by OTETA to Schedule I
& II drug classes
• Most painkillers, anxiety drugs, sleep aids, etc. are
Schedule III, IV & V drugs
• Largest class of painkillers, synthetic opioids, are not
detected in DOT testing:
− Oxycodone, hydrocodone, hydromorphone, oxymorphone, methadone
• Benzodiazepines, barbiturates, and propoxyphene
are also not detected in DOT testing
• Urine drug test does not indicate impairment, nor can
it determine abuse or misuse of prescribed
medications
NTSB Directives to FTA
• Educate transit systems
- Potential safety risks of Rx and OTC
− 2002 publication of FTA’s Prescription & OTC Medication Tool Kit
• Require notification of Rx/OTC use by safety-sensitive employees
• Incorporate qualified medical personnel in Fitness for Duty
Assessment
• Train employees on roles and responsibilities
• FTA should establish a comprehensive toxicological testing
requirement for a sample of fatal transit accidents to identify the
role played by common Rx/OTC medications
− FTA is undertaking a study to assess the current status of
Rx/OTC policies within the transit industry and to determine the
extent to which transit systems collect and maintain data
regarding the role Rx/OTC medications play in fatal accidents.
All transit systems were asked to complete online
questionnaires by Jan 30, 2009
MRO Safety Concern on DOT Drug Test
• Issued by MRO when laboratory positive drug
test is due to use of a prescribed or medically
administered drug and MRO believes:
− Use of prescribed medication poses a significant
safety risk, or
− Medical condition for which medication is prescribed
may pose a significant safety risk
• Test result will be reported as “Negative” with
MRO comment of a safety concern
• Employee is informed by MRO that safety
concern is being reported to employer
MRO Notice to Donor
• MRO notifies donor that he/she can submit
(within 5 days) documentation from prescribing
physician that demonstrates:
− Medication has been discontinued, or
− changed to one that does not cause concern
• If MRO receives such documentation, employer
will be notified that safety concern is removed
MRO Safety Concern Notification
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The medical review officer is required by 49CFR Part 40.327 to provide to third parties, drug test results and medical information affecting the
performance of safety-sensitive duties which are obtained during the verification process.
Employee
Social Security or ID
Date of Specimen Collection
Date of MRO determination
As a result of the MRO verification process, the MRO has determined that in addition to the drug test result there is a:
Safety Concern – Medication –Employee has reported the use of medication(s) that may pose significant safety risk or may make the employee
medically unqualified for a safety-sensitive position.
In accordance with §40.135 (c) the employee has been notified that they have 5 days for the prescribing physician to contact the MRO to determine if the
medication can be changed to one that does not make the employee medically unqualified or does not pose a significant safety risk. Employer will be
notified if this information is provided. If you do not receive an amended report, additional information that the medication was discontinued or changed
was not provided
Additional information obtained from the treating provider on
present a safety concern
, that medication of concern has been discontinued or changed to one that does not
Additional information obtained from the treating provider on
concern
, that medication of concern has been changed, but to one that also presents a safety
Safety Concern – Medical Condition – Employee has disclosed a medical condition that may have an adverse impact on the safe performance of safetysensitive duties--Recommend evaluation by Occupational Health professional
Safety Concern – Medical Condition – Employee has disclosed a medical condition that may result in the employee not meeting Federal medical
standards - Recommend evaluation by Occupational Health professional/Medical Examiner.
Medical Review Officer Name:
Medical Review Officer Signature:
Date:
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Employer Actions on MRO Safety Concern
• Options for resolving safety-concerns
− Have prescribing physician provide statement that
employee is able to perform safety-sensitive duties
while taking medications
− Have employee undergo “fitness for duty” evaluation
by employer designated physician
• Important for transit employer to have medication
policy and procedures in place
• MRO cannot make “fitness for duty”
recommendation based on donor interview and
urine drug test result
Medication Safety Issues
• Possible “impairing” effects
• Risks associated with medical conditions for
which meds are being used
• Interactions with other medications and OTC
products
• Compliance with recommended dosing
− Dosage amounts
− Timing of taking meds
• Therapeutic course; acute vs. chronic
• Employee lack of awareness of impairing effects
Medication Use
Side effects of concern
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Somnolence
Fatigue
Impaired judgment
Hypotension
Sedation
Erratic performance
• Impaired reflexes
• Dyskinesias and other
neurologic dysfunction
• Headaches
• Muscle weakness
• Visual disturbance
FTA Prescription and OTC Toolkit
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Policies
Procedures
Training Aid
Post-Accident Procedures
Several lists of Rx and OTC medications used by
various federal and private agencies
• References and Resources
• http://transit-safety.volpe.dot.gov/Publications
• http://transit-safety.volpe.dot.gov/safety/datesting/Presentations
Policy Options
• Responsibility is placed on the employees to report &
determine their own ability to safely perform their
duties while using medications
• Requiring authorization by medical practitioners that
employee can safety perform duties while using
prescribed medications
• Use of a list of medications to guide employees and
medical practitioners on which medication may or
may not be used, and those medications that must
be approved for use
• Evaluation of employee’s fitness for duty based on
prescribed medications by employer designated
physician
Policy Considerations
• Employees often under-report medications used
• Reporting medical information to supervisors may
place inappropriate level of responsibility and liability
on them
• Lists of acceptable and unacceptable medications
are difficult to keep updated and all inclusive
• Prescribing physicians are often unaware of
employee’s duties or unwilling to risk their patient’s
not being able to work
• If having employee’s physician authorize employee
working while taking prescribed meds, statement
must be specific and include understanding of
employee’s duties
Policy Considerations
• Use of DOT driver medical standards or equivalent
with biennial physical examinations
• Fitness for duty examinations by employer
designated physician
• Review of employee medication reports or personal
physician statements by employer designated
medical consultant
• Annual review of employee’s medications/medical
history
• Ongoing employee education and awareness efforts,
emphasizing new medications, medical facts, etc.
Medications & Fitness for Duty
• A 2005 NTSB report concluded that
− healthcare professionals need improved awareness and training on the adverse
impact medical conditions and medications have on commercial vehicle drivers
− dozens of people have been killed and injured in accidents in which drivers were
impaired due to medical conditions or the use of prescription medications that
diminished their vision, cognitive, and motor skills
− medical professionals need additional training to be adept at recognizing and
evaluating medical conditions that may adversely affect a person’s ability to drive
− increased course work and continuing education in the area of assessing and
counseling medically impaired drivers is needed for medical practitioners
• Physician’s Guide to Assessing and Counseling Older Drivers , 2003
− A discussion on medications addresses the level and type of impairment and the
potential side effects that might affect driving performance. Consideration is
given to dosage and changes over time, particularly after drug initiation and
discontinuance. The categories of medications that are addressed include
alcohol, anticonvulsants, antidepressants, antihistamines, antihypertensives,
antiparkinsonians, antipsychotics, benzodiazepines, and other sedatives, muscle
relaxants, narcotic analgesics, nonsteroidal anti-inflammatory drugs, and
stimulants.
− Available at www.nhtsa.dot.gov
FMCSA Driver Medical Standards
• Specifically disqualifying medications
− Insulin – all forms, unless given exemption
− Seizure medication
− Methadone—increasingly being prescribed for
chronic pain
− Modafinil—stimulant used to increase
wakefulness, alertness
Rx & OTC Drugs and Performance
• Pain medicines – Codeine, Darvocet, Morphine, Vicodin,
oxycontin
Drowsiness
Slower reaction times
Mental confusion
Anxiety
Agitation
Dizziness
Blurred vision
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Tranquilizers and Sedatives – Ativan, Diazepam, Xanax,
Halcion,
Valium,
Drowsiness
Amnesia
Agitation
Dizziness
Weakness
Unsteadiness
Disorientation
Rx & OTC Drugs and Performance (Cont.)
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Muscle relaxers – Flereril, Parafon Forte, Robaxin
Drowsiness
Nervousness
Dizziness
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Fatigue
Confusion
Visual disturbances
Anti-motion sickness – Antivert, Dramimine,
Phenergan
Drowsiness
Restlessness
Hallucinations
Blurred vision
Rx & OTC Drugs and Performance
• Antihistamines – Benadryl
Drowsiness
Slowed reactions
Impaired vision
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Stimulants – Sudafed, ephedrine, Aderall
Jitteriness
Diminished concentration
False sense of alertness
Irritability
Post-high fatigue
Current Issues
• Dramatic increase in use of controlled substance
medications to treat chronic pain, anxiety,
depression, attention deficit disorders, in US
population
• Hundreds of new drugs on the market every year that
have potential “impairing” effects
• Medication interactions are often unknown and not
monitored because people get multiple medications
from several physicians
• Aging population being prescribed more and more
drugs
• Painkillers, tranquillizers, sleep aides readily
available via the internet and “walk-in” clinics