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Association of Flight Attendants-CWA United Master Executive Council

Flight Attendant Alert: Changes to DOT Testing Effective January 1, 2018

Date: December 5, 2017
Type: AFA Article

Background


DOT has issued a final notice that four (4) commonly prescribed medications will be added to the DOT testing program effective January 1, 2018.  These 4 medications fall under a category of drugs known as opioids.  They include:

  • Hydrocodone (example: VicodinLortabLorcetMaxidoneNorcoZydone)
  •  Hydromorphone (example: Diluadid, Exalgo, Hydromorph Contin, Palladone)
  •  Oxycodone (example:Percocet, Percodan, OxyContin, Roxicodone, Endocet, Xtampza, OxylR)
  •  Oxymorphone (example: Opana, Numorphan).

Opioid medications are typically prescribed for the management of pain after injury, surgery, dental procedures and diagnosis of a medical illness with painful symptoms. 

Important Regulatory Clarifications

  •  Starting January 1, 2018, DOT testing will now for the very first time detect the use of these specific medications.
  •  If the testing lab confirms the presence of these medications in a Flight Attendant’s drug test, the Flight Attendant will be contacted by a Medical Review Officer (MRO) to determine if the Flight Attendant has a legally valid prescription within the overall meaning of the Controlled Substance Act (CSA).
  •  DOT has made it clear that it will not issue guidance to the MROs on how long a prescription may be considered valid for the purpose of providing a legitimate medical explanation for a laboratory positive.  Specifically, DOT states “it would not be appropriate for the Department to substitute its judgement for that of the Drug Enforcement Administration which is the Federal agency with the authority to determine what constitutes a valid prescription under the CSA. The DEA has not set a maximum duration for the length of time a prescription can be considered to be legally used by the person to whom it was prescribed…consequently, DOT will not create a time limit on the use of a legally valid prescription. Instead, MROs will make individualized determinations for each donor.”
  •  Regardless of whether medical marijuana is prescribed by a physician, it cannot be the basis of a legitimate medical explanation. IT WILL VERIFIED BY THE MRO AS A TEST POSITIVE.
  •  When verifying the prescription an employee provides to the MRO, the DOT is now recommending that “MROs should speak with the pharmacy and not simply rely on a photograph of the prescription label”.
  •  If an MRO has concerns about an employee’s ability to safely perform her/his duties while taking a prescription, a new process has been put in place by DOT to ensure that “an employee is not caught off guard by the MRO’s decision to report the medical information regarding a legally valid prescription to a third party”. Effective January 1, 2018, the MRO must give the employee five (5) business days to have her/his prescribing physician contact the MRO to determine if the medication(s) can be changed to one that does not make the employee medically unqualified or that does not pose a significant safety risk BEFORE reporting the safety concern to a third party.  If the MRO does not receive such information from the prescribing physician, the MRO would then report to third parties.   Previously, the MRO would report to the third party and then engage with the prescribing health care provider. 

Resources to Help You Balance Safety and Medication

There are a number of resources under the Flight Attendant Drug and Alcohol (FADAP) Website (www.FADAP.org) to help you balance safety and the use of prescription medications including the 4 new medications for which DOT will test effective January 1, 2018. 

Medication Safety Film for Flight Attendants: Preview this short film to understand the safety issues and best practices around medication use by Flight Attendants.  

Medication and Flying Article “What Medications Can I Take While Flying? Read this 3 page article to get a more rounded understanding of the issues surrounding medication use by Flight Attendants and best practices. 

“Flight Attendant Essential Job Functions” Wallet Card: There is no list of DOT banned prescriptions for flight attendants, other than prescription marijuana. The decision of what medications (including dosage, frequency and timing of use in relation to your work schedule) which you can take and safely perform your Flight Attendant duties is generally determined by your health care provider. To help you inform your provider of your safety sensitive duties, provide your health care provider with your job description for incorporation into your medical file. You can also download wallet size lists of Flight Attendants’ essential job functions for your provider’s quick reference each and every time a medication is discussed.  

Health Care Provider’s Medication Note: Should your health care provider prescribe a medication containing an opioid or amphetamine (both of which are detectable under DOT testing) have your provider sign this note for your submission just in case you are challenged about the safe use of the medication.

Your AFA EAP: Have more Questions? Contact us at 800-424-2406.

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