MRO Modifications & Change Orders 2 — Questions and Answers
Question 1: An employer wants to modify their DOT drug testing policy to add a pre-employment alcohol testing requirement. What must the employer do before implementing this change?
- Notify employees and update the written policy (Correct answer)
- Obtain MRO approval before changing the policy
- Submit the change to SAMHSA for review
- Wait 90 days after notifying employees
Correct answer: Notify employees and update the written policy
Employers must update their written drug and alcohol testing policy and notify employees before implementing changes, but do not need MRO or SAMHSA approval.
Question 2: A collector makes an error on the Federal CCF during a DOT urine collection. Under which circumstance can the MRO accept the specimen without a corrective statement?
- The error is a fatal flaw that cannot be corrected
- The error is a correctable flaw and the collector provides a sworn statement (Correct answer)
- The error involved the wrong specimen ID number
- The error occurred on Copy 1 of the CCF
Correct answer: The error is a correctable flaw and the collector provides a sworn statement
Correctable flaws on the CCF can be remedied when the collector provides a signed statement explaining the error and attesting to the correct information.
Question 3: A laboratory reports a specimen as substituted. The employee provides documentation of a medical condition causing low creatinine. What action should the MRO take?
- Immediately report the result as negative to the employer
- Evaluate whether the condition could plausibly cause the substituted result (Correct answer)
- Cancel the test and order an immediate recollection
- Accept the medical explanation without further evaluation
Correct answer: Evaluate whether the condition could plausibly cause the substituted result
The MRO must evaluate whether the employee's medical explanation is plausible and consistent with the substituted specimen criteria before making a final determination.
Question 4: Under DOT 49 CFR Part 40, when may an MRO change a verified positive result to a negative after reporting to the employer?
- Only if the employee requests reanalysis within 72 hours
- If the MRO obtains new information indicating the result was incorrect (Correct answer)
- Never — once reported, a verified result cannot be changed
- Only if the employer requests a correction within 10 business days
Correct answer: If the MRO obtains new information indicating the result was incorrect
An MRO may change a verified result after reporting it to the employer if new, legitimate medical information or a lab reanalysis demonstrates the original result was incorrect.
Question 5: A split specimen (Bottle B) reanalysis fails to confirm the primary specimen's positive result. What must the MRO report?
- The result stands as positive because Bottle A was confirmed
- The MRO must cancel the test and report it as cancelled (Correct answer)
- The MRO reports the result as negative
- The MRO orders a third specimen collection immediately
Correct answer: The MRO must cancel the test and report it as cancelled
When a split specimen reanalysis fails to reconfirm the primary specimen result, the MRO must cancel the test.
Question 6: Which of the following represents a change in MRO reporting that requires documentation of the reason for the change?
- Changing a 'test not performed' to a cancelled result
- Correcting the spelling of an employee's name on the report
- Changing a verified negative to a positive after new lab findings (Correct answer)
- Updating the collection date on the final report
Correct answer: Changing a verified negative to a positive after new lab findings
Any change to a verified result — such as from negative to positive — requires the MRO to document the reason in the record.
Question 7: An employee's specimen is initially reported as negative dilute. The employer's policy requires a recollection under direct observation for all dilute results. The recollection also comes back negative dilute. What does the MRO report?
- The result is cancelled pending a third collection
- The MRO reports the second result as negative and that is final (Correct answer)
- The MRO reports positive because two dilute results indicate tampering
- The employee is permanently disqualified from safety-sensitive duties
Correct answer: The MRO reports the second result as negative and that is final
When a second negative dilute result is obtained following an employer-directed recollection, the MRO reports the final result as negative, ending the process.
MRO Modifications & Change Orders 2
An employer wants to modify their DOT drug testing policy to add a pre-employment alcohol testing requirement.
What must the employer do before implementing this change?