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From: Robert Swotinsky MD
Password: orange
Date: 28 Apr 2008
Time: 17:42:02 -0700
Remote Name: 71.233.246.147
This thread is about a non-DOT testing program. So, while I cite the DOT rules, I point out that they can be looked to as guidance but they are not requirements for non-DOT tests.
The DOT rule does not allow for MROs to provide concentrations to the designated employer representative [49 CFR 40.163(g)]. In the (non-DOT) question posted in this thread, the employer has designated the EAP as its representative, and this EAP is asking the MRO for concentrations. DOT prohibits MROs from reporting concentrations to designated employer representatives because it fears employers will misinterpret or otherwise misuse the numbers. In the case posted here, the employer is incorrectly trying to use the numbers to guesstimate extent of use or extent of addiction. This is the kind of situation DOT is trying to avoid by prohibiting MROs from routinely reporting concentrations to employers.