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From: Robert Swotinsky MD
Password: orange
Date: 14 Mar 2008
Time: 05:09:06 -0800
Remote Name: 4.154.214.161
The MRO or MRO's assistant is supposed to check the negative box in Step 6 of the MRO Copy (#2) of the CCF and sign and date the report. Karen, you're asking, What if no-one at the MRO's office is doing that? Is it a violation of the rule?
Yes, it is a violation of the rule. It doesn't seem to me an extremely serious violation of the rule, but nevertheless the rule clearly directs the MRO or MRO assistant to complete CCF2 as described in section (e) below. If you're working with an MRO/MRO's office who is not doing this, you might want to reeducate the MRO/MRO's office accordingly.
Subpart G - Medical
Review Officers and the Verification Process
§ 40.127 What are the MRO's functions in
reviewing negative test results?
As
the MRO, you must do the following with respect to negative drug test results
you receive from a laboratory, prior to verifying the result and releasing it to
the DER:
(a) Review Copy 2 of the CCF
to determine if there are any fatal or correctable errors that may require you
to initiate corrective action or to cancel the test (see §§40.199 and 40.203).
(b) Review the negative
laboratory test result and ensure that it is consistent with the information
contained on the CCF.
(c) Before you report a
negative test result, you must have in your possession the following documents:
(1) Copy 2 of the CCF, a
legible copy of it, or any other CCF copy containing the employee's signature;
and
(2) A legible copy (fax,
photocopy, image) of Copy 1 of the CCF or the electronic laboratory results
report that conveys the negative laboratory test result.
(d) If the copy of the
documentation provided to you by the collector or laboratory appears unclear,
you must request that the collector or laboratory send you a legible copy.
(e) On Copy 2 of the CCF,
place a check mark in the “Negative” box (Step 6), provide your name, and sign,
initial, or stamp and date the verification statement.
(f) Report the result in a
confidential manner (see §§40.163–40.167).
(g) Staff under your direct,
personal supervision may perform the administrative functions of this section
for you, but only you can cancel a test. If you cancel a laboratory-confirmed
negative result, check the “Test Cancelled” box (Step 6) on Copy 2 of the CCF,
make appropriate annotation in the “Remarks” line, provide your name, and sign,
initial or stamp and date the verification statement.
(1) On specimen results that
are reviewed by your staff, you are responsible for assuring the quality of
their work.
(2) You are required to
personally review at least 5 percent of all CCFs reviewed by your staff on a
quarterly basis, including all results that required a corrective action.
However, you need not review more than 500 negative results in any quarter.
(3) Your review must, as a
minimum, include the CCF, negative laboratory test result, any accompanying
corrective documents, and the report sent to the employer. You must correct any
errors that you discover. You must take action as necessary to ensure compliance
by your staff with this part and document your corrective action. You must
attest to the quality assurance review by initialing the CCFs that you review.
(4) You must make these CCFs
easily identifiable and retrievable by you for review by DOT agencies.
[65 FR 79526,