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From: Anonymous FAA Employee - Not a Pilot
Password: orange
Date: 20 Nov 2006
Time: 13:49:41 -0800
Remote Name: 65.244.107.206
I'm in a designated safety/security-sensitive position in a DOT agency. I was prescribed Marinol (10mg) by my physician for persistent weight loss and stimulation of appetite. These symptoms are attributable to depression (now in remission) and stress. I use this medication on an as-needed basis so I have a bottle of 30 pills that has lasted me quite some time. The bottle I have is a little less than a year old, but I have a new prescription, as yet unfilled, from about 6-7 months ago. Recently, I took some Marinol numerous times during a week and had a random urine drug test at the end of the week. So, there is good chance the test will return positive. At the time I obtained the prescription, I discussed with my doctor. what if any effect my intermittent use of Marinol would have on my DOT position. My doctor provided me with a written statement indicating that my dosage/usage is too low to affect my central nervous system and therefore would not have any effect on the performance of my safety/security-sensitive duties. As such, and due to the irregular use, I did not think it necessary to disclose the occasional medication use to the agency.
1. Based on the above, would the MRO have to downgrade a positive test?
2. In your opinion, would the letter discussing the lack of central nervous system effect preclude disclosure of any medical info to the agency as required for safety/security-sensitive positions?
3. How would you treat this case if you were the MRO?
4. As a matter of practice, when a valid Marinol prescription is established, does the agency require any additional testing (ie THC-V) that would require notification to the agency and or a removal duties pending such further tests?
5. Is there anything you've read here that would cause an MRO to lean toward any adverse findings?
6. Do you know of any cases similar to mine? Any precedent decisions in this area? I work for an especially bureaucratic agency and I want to be prepared for each question should any arise.
Thanks for your comments.