DOT Drug Testing Now Includes Semi-Synthetic Opioids

The Federal Department of Transportation (DOT) issued a new ruling mandating the inclusion of four new semi-synthetic opioids (pharmaceutical pain medications) as part of federally mandated drug testing beginning January 1, 2018. These new drugs are in addition to the existing panel that are already including in testing, which includes marijuana, cocaine, amphetamines, phencyclidine (PCP), and opiates.

The four opioids are oxycodone, oxymorphone, hydrocodone and hydromorphone. Some common brand names for these semi-synthetic opioids include OxyContin®, Percodan®, Percocet®, Vicodin®, Lortab®, Norco®, Dilaudid®, Exalgo®.

FAQs

What if I have an active/current prescription for one of these semi-synthetic opioids?

Be proactive in ensuring that your prescribing physician knows what type of safety-sensitive work you currently perform. This is important information for your prescribing physician to consider when deciding whether and what medication to prescribe for you. It is important for you to know whether your medications could impact your ability to safely perform your work.

For example, don’t just provide your physician a job title, but describe your exact job function(s) or ask your employer for a detailed description of your job function that you can give to your prescribing physician.

What if I test positive while holding a current prescription for an opioid?

According to DOT Rule 49 CFR Part 40 Section 40.135 subpart G:

After getting results of the drug test the Medical Review Officer (MRO) must:

Tell the employee if the test was positive and for which drug(s) the specimen tested positive.
Allow five business days for the employee’s physician to contact the MRO to see if the prescription can be changed to one that won’t make the employee medically unqualified or does not pose a safety risk.

What if I have an old/inactive prescription for one of these semi-synthetic opioid medications?

If your prescription is not active, speak with your physician and alert them ASAP to the fact that you perform safety-sensitive work. If you test positive with an inactive prescription it will be considered a positive test, and you will be subject to your employer’s existing drug and alcohol policy; possibly including discipline. Your physician may be able to issue you a new prescription or alter the prescription to one that will not make you medically unqualified to perform safety-sensitive work.

What if I have a current prescription for Medical Marijuana?

The Department of Transportation’s Drug and Alcohol Testing Regulation – 49 CFR Part 40, at 40.151(e) – does not authorize “medical marijuana” under a state law to be a valid medical explanation for a transportation employee’s positive drug test result.

For PG&E employee members:

PG&E DOT-covered employees include Commercial (Class A and B) Drivers, Aviation employees and Gas operations, call center and dispatching operations, maintenance and emergency response personnel.
The November 13, 2017 DOT ruling includes testing for these four opioids: oxycodone, oxymorphone, hydrocodone and hydromorphone.
Some common names for these semi-synthetic opioids include: OxyContin®, Percodan®, Percocet®, Vicodin®, Lortab®, Norco®, Dilaudid®, Exalgo® .
Beginning January 1, 2018, PG&E will begin testing for these four opioids in addition to the current panel of THC, cocaine, PCP, opiates, and amphetamines as part of its DOT Compliance random drug testing protocol.
For DOT-covered PG&E employees that have a current prescription for one of these new opioids, this test will be a verified negative test, with a safety concern to the company.
For DOT-covered employees that do NOT have a prescription, this will be treated as a positive test and the current process for a DOT positive test outlined in LA 04-16 would apply.

If you test positive with a valid current prescription, the test will be considered a verified negative test with a safety concern.

This safety concern means that PG&E will not let you do safety-sensitive work (for up to five days) until your prescribing physician has changed your prescription to one that won’t make you medically unqualified to do safety-sensitive work. That is why it is important to be proactive and speak with your physician in advance of a random DOT drug test.

Additional Resources

PG&E 5 minute meeting announcing new opioid inclusion into DOT testing program

PG&E’s DOT anti-drug/alcohol misuse prevention program, 2016 version

Current DOT drug and alcohol testing Letter of Agreement (La 04-16) between IBEW 1245 and PG&E

Department of Transportation (DOT) FAQs: