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From: g woodall
Password: orange
Date: 19 Mar 2009
Time: 15:03:14 -0800
Remote Name: 199.227.125.3
I'm not familiar with NRC nuances but if allowed:
1) you might report the "problematic ones" as "negative using federal levels / positive at limit of detection". Keeps you and the employer happy and the record keeping clear.
2) see #1 - the MRO process otherwise remains the same but including the limit of detection (LOD) results means some results are below the federal cutoffs and at or above the LOD. That is, the MRO makes the usual calls and asks the usual question.
3) Testing to LOD gives more positives but not false positives
4) EAP sounds good to me and reduces the risk of litigation for these cases.
Finally, to expand on #2 and #3, opiates and poppy seeds will become a MAJOR issue. I suggest you and the employer address it ahead of time. (I vote to exclude the opiates at LOD, but include opiates >2,000 and <15,000 in the LOD group.)