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From: g woodall
Password: orange
Date: 24 Nov 2006
Time: 10:12:56 -0800
Remote Name: 216.231.162.9
First I appreciate the diligence and concern shown in your questions. Your plan, as under 49 CFR 40.195, to have the donor examined is sound and a hair test as part of the exam is optional but certainly allowed. (Some argue for blood because the std reads "e.g. blood," but I don't think it precludes other technologies.) But please note that a "positive" on exam or alternative testing is an MRO "test cancelled," not a MRO "positive." (Aside: equals No SAP remedy?) Note also that 49 CFR 40.195 does not apply to randoms but only to testing where a negative is required, i.e., pre-employment, follow-up, or return to duty. For a random, the individual waits his three hours, provides evidence to the MRO of anuria, and receives a report of "test canceled, recollection not required." Some argue that if you know for sure in advance (you're are collection site and MRO), you might fudge the wait and skip to the anuria - - at your own peril.
Your concern as to DOT fitness might prompt a call to the examining provider, but certainly should prompt a notation on the MRO report of "underlying medical condition may be a safety concern." Hopefully the employer would revisit that aspect with the examiner or seek another verifying opinion.