The MRO (Medical Review Officer) is responsible for reviewing all drug test results and verifying them with the donor. Here’s what the process looks like:

Reviewing Results:

1. Negative Results: Can be delegated to staff for processing.
2. Non-Negative Results: Must be reviewed directly by the MRO, who is required to conduct a personal interview with the employee.

The Verification Interview:

1. The MRO explains the purpose of the interview and identifies themselves and their role.
2. They notify the employee of the lab results and request an explanation for any non-negative results.
3. The burden of proof is on the employee to provide valid explanations, such as prescriptions or medical conditions.

Refusal to Cooperate:
If an employee declines to speak with the MRO, the test result will not disappear. Most employees choose to engage in the interview process.

When Employees Say, “I Only Used Once”

When an employee claims they “only used once” after testing positive, SAPs should approach this assertion critically:

Why It’s Unlikely:

1. Random testing uses a 50% selection rate, so not all employees are tested even when selected.
2. For most drugs, the detection window is only three days (except cannabis).
3. The odds of someone using just once and getting caught in a random test are approximately 1 in 89,000.

Key Insight:
Statements like “I only used once” often indicate a deeper pattern of substance use. SAPs should use clinical judgment to assess these claims carefully.

Prescription Medications and DOT Compliance: What Employers and Employees Need to Know

For employees in safety-sensitive positions regulated by the Department of Transportation (DOT), the use of prescription medications is a critical topic. While these medications may be necessary for certain conditions, DOT regulations require that they are legally valid, medically necessary, and safe for performing safety-sensitive functions. Here's what you need to know about prescription compliance, the role of the MRO, and best practices for avoiding issues.

The Role of the MRO in Prescription Verification

The MRO plays a central role in verifying positive test results involving prescription medications.

Determining Legitimacy:
The MRO confirms the prescription is legally valid, meaning it was issued by a licensed physician.

Assessing Medical Necessity:
The MRO checks if the prescription is being used for the condition it was originally intended to treat.

1. Valid Use: Tylenol #3 taken shortly after being prescribed for dental work.
2. Misuse: Using that same prescription a year later for back pain may not meet DOT standards.

Checking Prescription Age:

1. DOT doesn’t define how long a prescription remains valid.
2. Common Practice: Many MROs consider prescriptions over 12 months old invalid unless justified.

Contacting Relevant Parties:
If the MRO has doubts, they may confirm the prescription with the dispensing pharmacist or treating physician.

PRN Medications and Safety Concerns

“PRN” (as needed) medications can complicate compliance:

1. If a PRN prescription is over 12 months old or used outside its original intent, it may be deemed invalid.
2. If there are concerns about safety risks (e.g., dosage, side effects), the MRO may request more information.
3. Employees have up to five days to provide supporting documentation or have their physician speak with the MRO.

Key Insight:
The MRO’s decision is final unless new information is provided within 30 days.

Best Practices for Employees

Check Your Medicine Cabinet:

1. Dispose of expired or unused medications through a Drug Take Back Day or at a local fire station.
2. Avoid using medications older than 12 months.

Stay Proactive About Valid Prescriptions:

1. Keep prescriptions current and use them only for their intended purpose.
2. Discuss any PRN use with your physician to ensure DOT compliance.

Be Ready to Verify:
If you test positive for a controlled substance, be prepared to provide proof that the prescription is current, valid, and medically necessary.

What About Over-the-Counter Medications?

DOT rules also apply to OTC medications. While not banned, they must not impair the employee’s ability to perform safety-sensitive duties.

Key Requirement:
The treating physician must confirm that the OTC or prescription medication does not interfere with safe job performance.

Final Thoughts: Ensuring Compliance with Prescription Medications

Prescription medications can create compliance challenges, but with the right precautions, issues can be avoided.

For Employers:
Educate employees on the importance of having valid, medically necessary prescriptions. Encourage them to stay current with their medications.

For Employees:
Don’t rely on expired prescriptions. Stay informed, seek updated medical advice when needed, and be ready to verify your medications.

By following best practices and understanding DOT requirements, employees can maintain compliance and protect their roles in safety-sensitive positions.

Need help navigating prescription rules under DOT? Let me know how I can assist!