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From: Robert Swotinsky MD
Date: 06 Nov 2004
Time: 19:23:21 -0800
Remote Name: 68.166.235.44
The federal (e.g., DOT) rules assume that morphine levels up to 15,000 ng/mL may be due to poppy seed ingestion. This is because the scientific literature shows that morphine levels a little higher than 10,000 ng/mL can be due to poppy seed ingestion. True, usual levels after poppy seeds are in the 100's and nowhere near 10,000. But, the federal rules apply to all people and regulators have designed the rules to assure that outliers are not unfairly labelled as drug abusers. As with many thresholds, a margin of safety is added, i.e., we use 15,000 instead of 10,000 or 11,000 ng/mL. Much thought has gone into this threshold and I would recommend taking advantage of that expertise rather than using an ad hoc threshold. Furthermore, in case law involving non-regulated testingm, the federal drug tesitng procedures have been cited as the standard of care. If challenged, I don't know how one could defend use of a significantly different threshold to distingish possible poppy seed ingestion from definite use of prescription medicine.