The long awaited DOT 49 CFR Part 40 Final Rule is available in its pre-publication version in PDF format as included with this Advisory. The Final Rule is effective January 1, 2018.
BUT WHAT DOES IT MEAN TO YOU? We are posting this as we are getting many calls around “What does it mean to me?”
Most likely, the labs will just modify their current testing panel on the back end to include the expanded opiates. Since there is no change to the current Custody and Control Form (CCF), other than the panel, it is unlikely that there needs to be a complete reprint and reissue of all CCF’s. As new CCFs are printed the changes will take place. More to follow on this if it changes.
Does that change anything at the MRO in that process? No, there are no changes, and donors do not need to disclose any medications they are on. The current MRO review process accounts for all of this.
ONE NEW POTENTIAL ISSUE
Currently, if an donor has a valid prescription; but in the MRO’s opinion should not be performing safety sensitive duties, he or she will issue a “Safety Warning”. This is not universal so you may want to discuss this with your MRO. In this case, you want to enter into ADA Reasonable Accommodation guidelines to work with the employee’s physician to modify medications to ensure performing in a safe manner, or putting them on light duty until medications can be modified.
Note that if your are our client for MRO services all this will be brought to your attention if it occurs.