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Changes made to CDL Drug Testing Policies
Updated On: Oct 22, 2010
The Department of Transportation has amended provisions for drug testing as it concerns the testing of urine specimens and training for Medical Review Officers (MROs) and certain procedures that must be used by MROs.  These changes are effective 10/1/2010 and will affect members who possess a valid Commercial Driver's License (CDL) and are required to participate in government mandated drug testing programs.  Other members may be affected by the regulatory provisions if required by their respective collective bargaining agreements
 Expanded Drug Testing Panel and Revised Cutoff  Levels
 The Department of Health and Human Services expanded the number of drugs for which testing must be conducted and revised the cutoff levels for certain drugs. The table below provides an updated list of drugs and their rnetabolites for which testing must be conducted and their corresponding cutoff levels.


Initial Test Analyte
Initial Test Cutoff Concentration
Confirmatory Test Analyte
Confirmatory Test Cutoff Concentration
Marijuana Metabolites
50 ng/mL


15 ng/mL
Cocaine Metabolites*
150 ng/mL
100 ng/mL
Opiate metabolites

Codeine/Morphine 2

2000 ng/mL
2000 ng/mL
10 ng/mL
10 ng/mL
25 ng/mL
25 ng/mL


500 ng/mL
250 ng/mL


250 ng/mL
500 ng/mL
250 ng/mL
250 ng/mL
250 ng/mL
·         Adulterated Specimen - A specimen that has been altered, 8S evidenced by test results showing either a substance that is not a normal constituent for that type of specimen or showing an abnormal concentration of an endogenous substance.
·         Confirmatory Drug Test - A second analytical procedure performed on a different aliquot of the original specimen to identify and quantify the presence of a specific drug or drug metabolite.
·         Initial Drug Test (Screening Test) - The test used to differentiate a negative specimen from one that requires further testing for drugs or drug metabolites.
·         Initial Specimen Validity Test - The first test used to determine if a urine specimen is adulterated, diluted. substituted, or invalid.
·         Invalid Drug Test - The result reported by an HHS-certified laboratory in accordance with the criteria established by HHS Mandatory Guidelines when a positive, negative, adulterated, or substituted result cannot be established for a specific drug or specimen validity   test.
·         Laboratory - Any U.S. laboratory certified by HHS under the National Laboratory Certification Program as meting the minimum standards of Subpart C of the HHS Mandatory Guidelines for Federal Workplace Drug Testing Programs; or, in the case of foreign laboratories, a laboratory approved for participation by the DOT under this part.
·         Limit of Detection (LOD) - The lowest concentration at which a measurand* can be identified, but (for quantitative assays) the concentration cannot be accurately calculated.
·         Limit of Quantitation - For quantitative assays, the lowest concentration at which the identity and concentration of the measurand can be accurately established.
·         Negative Result - The result reported by an HHS-certified laboratory to an MRO when a specimen contains no drug or the concentration of the drug is less than the cutoff concentration for the drug or drug class and the specimen is a valid specimen.
·         Positive Result - The result reported by an HHS-certified laboratory when a specimen contains a drug or drug metabolite equal to or greater than the cutoff concentrations.
·         Reconfirmed - The result report for a split specimen when the second laboratory is able to corroborate the original result reported for the primary specimen.
·         Rejected for Testing - The result reported by an HHS-certified laboratory when no tests are performed for a specimen because of a fatal flaw or a correctable flaw that is not corrected.
·         Split specimen collection - A collection in which the urine collected is divided into two      separate specimen bottles. the primary specimen (Bottle A) and the split specimen (Bottle B).


* A physical quantity, property, or condition which is measured.

1 Delta-9-tetrahydrocannabinol-9-carboxylic acid (THCA)


2Morphine is the target analyte for codeine/morphine testing


3Either a single initial test kit or multiple initial test kits may be used provided the single test kit detects each target


independently at the specified cutoff


4Methamphetamine is the target analyte for amphetamine/methamphetamine testing


5 To be reported positive for methamphetamine, a specimen must also contain amphetamine at a concentration equal


to or greater than 100 ng/mL


6 Methylenedioxymethamphetamine (MDMA)


7 Methylenedioxyamphetimine (MDA)

8 Methylenedioxyethylamphetamine (MDEA)
New Requirements for Medical Review Officers

Medical Review Officers have been notified that the DHHS has determined that there are no legitimate explanations for positive test results for MDMA, MDA, MDEA, PCP, and 6-AM. In addition, if an MRO receives a confirmed positive test result for an opiate that is not codeine or morphine, he/she must very a confirmed positive test result only if the MRO determines that there is clinical evidence, in addition to the urine test, of unauthorized use of any Opium, opiate, or opium derivative, (i.e., morphine, heroin or codeine).

To make the determination, as described above, the MRO must use their best professional
judgment and discretion to determine whether such clinical evidence exists. For example, the
MRO may determine if there are:
1. Recent needle tracks
2. Behavioral or psychological signs of acute opiate intoxication or withdrawal
3. Clinical history of unauthorized use recent enough to have produced the laboratory test
result, or
4. Use of medication from a foreign country.
Therefore, the MRO must either conduct, or cause another physician to cond\1et a face-to-face examination of the employee. If the MRO is unable to establish sufficient clinical evidence or history, the test result must be verified as negative.

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