everyone. We'll just wait a few minutes to make sure everyone is in who wants to be in. Okay, I think I think participation login looks stable to me, so we'll go ahead and get started. Welcome, everybody. My name is Doug Martin, and I'm one of the faculty that is involved with teaching ACOM MRO courses, joined this evening by Drs. Peterson, Smith, and Peet, and open for any questions that you might have, and you can put those in the chat. You can raise your hand if you want to, a couple different ways that you can go about doing that. We also have some previously submitted topics, one in particular that we want to cover that was a subject of a recent thread in the MRO listserv email. So, if anybody has any questions, don't shy away. You want to start with the one that was in the forum? Go right ahead. Okay, I'm going to share my screen, and Donna, you have not seen this, so I'll ask you to read through it. You may want to read it out loud, and I understand you've had no time to prepare, but you're the expert, and this is an area of confusion among a lot of new MROs. You want to read it out loud? Oh, okay. So, there's a commercial driver with a positive DOT test, and he obviously went through the substance abuse professional program and successfully completed that, and then the substance abuse professional recommended a five-year follow-up testing program, and apparently, he is in year two of that program, and then he left the employer. He is not working in a CDL position, but is maintaining his CDL license. I understand that a future employer will have to check his drug testing history and continue any return-to-work program, and by that, I guess they're referring to any follow-up testing that was not completed on the original substance abuse professional's evaluation. My question is, when a driver is no longer employed or doing safety-sensitive work, that is CDL driving, but is under a SAP program for randoms, under a SAP program, I'm not sure what that means, does the driver have to continue with the testing while not in a safety-sensitive position, or is the, okay, the follow-up testing put on hold? If has to continue the program, who does the scheduling of the tests usually done by the employer? Okay, I think I've got the picture here. So, he's calling this a SAP program, but it's not a SAP program, it's a follow-up testing program. Yes, that was prescribed or that was ordered by the substance abuse professional when they completed the return-to-work process. Okay, so here's the response, somebody's response, all DOT testing is on-duty testing. I don't like that phrase, but we'll go with that for now. When a driver is not in a DOT safety-sensitive driving position, his follow-up testing plan goes on hold, that is true. He can't be tested when he is not driving a commercial motor vehicle because he is not a threat to public safety. Well, that's an opinion. Okay, when he returns to driving a commercial motor vehicle for a DOT employer, the follow-up testing plan picks up where it left off. His follow-up testing plan must be extended by the length of time he was not subject to testing. So, if he was in a non-DOT covered position for 16 months, his follow-up plan gets extended 16 months. It's up to his employer to figure out how to make that work. The SAP's plan is for follow-up tests only, not for random tests. Follow-up tests and random tests are different and are recorded differently on a CCF. Well, where do I start, Dr. Martin? I think I would give that a C grade. There's some things in that that are probably close to being accurate, but there's other things that, how should I put this, probably are not as clear as they should be. Okay, I'll take that as a start. So, let's start with the first thing is that the follow-up testing plan, it is true, it can only be satisfied in terms of the tests that are required when the driver is in a commercial driver's license position. So that's correct. He left that employer and he had had the follow-up tests for the two years that he was working for that employer after completing his substance abuse professional evaluation. That counts as two of the five years for which the substance abuse professional ordered that he would be subject to follow-up testing. What we don't have in the question is, normally, the substance abuse professional is not going to just say follow-up testing for five years. The substance abuse professional is going to say, in the first year, the driver must have six follow-up tests, or maybe the FAP says 12, but has to have at least six tests. And then the plan goes on to say, it can stop there, but obviously, from this question, the SAP wanted the follow-up testing to go for five years. So then the SAP would have said in year two, three, four, and five, at least three tests per year, six tests per year, whatever he or she decided. Now, when the driver left the employee and was no longer working in a CDL position, the follow-up testing stops. He can't go out and order those tests on his own, right? He can't go back to the SAP and say, you know, tell me when to go for a follow-up test. And that counts toward fulfilling his follow-up testing plan obligation. So if and when he is hired, again, in a CDL position, the asker or the response on the question is correct. That new employer will have to do a query or a search of the database, right, at the clearinghouse, and to determine when he had his return to duty testing, that he had completed the SAP process, and that he was in a follow-up testing program. The difficulty here is that there is no way to know from just the clearinghouse query how many follow-up tests were conducted. That's one of the, I think, the loop, not loopholes, really, but just- It's a sticky wicket. Yeah, it's a sticky wicket, okay? So therefore, that new employer is going to have to contact the subsequent employers and ask them, right, for the number of follow-up tests that were completed after the individual came back to work for them until they left. They don't really necessarily have to have the dates of those or whatever, but just how many of those follow-up tests. The new employer will also have to obtain a copy, either from the previous employer, from the driver himself, or the driver can request it from the substance abuse professional to find out how many tests were recommended or were ordered, okay? So then they know how many is left, and in fact, if there are three years left in which the driver has to be subject to follow-up testing. And then the new company is responsible for carrying out the remainder of that substance abuse professional's follow-up plan for that driver. And it will go about it just like any other follow-up testing plan. So if, again, once they get that SAP plan and see that in years three, they were to have three follow-up tests, in year four, they were to have three follow-up tests, and in year five, they were to have two follow-up tests, then that's the plan that the new employer will impose. As far as do those tests have to be evenly spaced, three in 12 months, does that mean they have to have a test every four months? No, they can do one in January, and they can do another one in March, and then they can do the third one in October, but it will still mean that the individual is subject to that testing for three more years. So the 16 months has nothing to do with it. It doesn't figure into the formula at all. Does that clarify most of it, Dr. Martin? I don't have a question. I think you got it. I think the most important takeaway that I got from the LISTSERV discussion was you hit the head on the nail as far as trying to figure out how many previous tests had already been done. I think that's the key to the whole thing, and I think that's where, frankly, a lot of the problems exist because trying to track that information is, in many cases, difficult. I know I can tell you one experience that I had is what happens when you have a trucking company that goes out of business? Okay, well, trying to track down that record is not easy. In theory, they're supposed to have records transferred someplace and all this sort of thing, but in reality, that can be much more difficult than what you might think. And then let's say that you have a driver that, how should we put this, doesn't necessarily keep the greatest records in the world, so you're sitting there trying to get corroborating information from a bunch of sources to try to figure that stuff out. Yeah, and I have pointed out to FMCSA, as I'm sure others have from the regulatory standpoint, that there is no requirement placed on the driver that he or she should keep a copy of the substance abuse professional evaluations or to keep copies, even if that's the custody and control form, of any follow-up tests that he or she undergoes. And so, again, how many times do drivers keep that information? No. I mean, it behooves them to do so because it's very difficult otherwise. I do want to mention one thing, and this may be too much detail, but I do not believe that it is incumbent upon the new employer to determine if the number of follow-up tests that were ordered in those two years were all accomplished. I don't find anything in the rule, and it's almost impossible, especially if that trucking company's gone out of business or whatever, there's really no way to substantiate that. So I think that it is an acceptable practice, and I've talked with some folks at the Clearinghouse about this and at FMCSA. So this new employer, once they find that the driver was employed for two years after the substance abuse professional status, and they find out that what the SAP has ordered in terms of the number of years that the driver is subject to testing, then they start from year three. So even if the SAP had ordered six tests in year one and six tests in year two, and maybe that employer only did nine of them or ten of them, there is not any going back and adding those on. Is that making sense? So you would start from what year three is, which may be three tests, it may be six tests, it may be whatever. Right, there's no, as we say in the NFL, no video review. There is not. That's right. So one other element, and that is when the driver now starts working for a new employer, they will probably have to undergo an employment test and have a negative urine. That will not count. But then after they've been accepted as an employee, then the follow-up testing program will begin. That's true. So the pre-employment drug test does not count toward meeting the follow-up testing plan requirements, nor does any... Don't forget that driver is also going to go in the random pool for this company on the day that he is hired. And so let's say he is selected for a random test the first go-round, in the first quarter that he's working for them, or the first month that he's working for them. That random test does not count as a follow-up test. Right. I had a scenario one time, believe it or not, with a guy that, of course, we did his exam, right? So the pre-employment test was done on that date. And sure enough, he got drawn for the random for the next day. And sure enough, they found out about his follow-up testing need. And on the third day, he had to have that test done. So he had three different tests done three days successively for different reasons. Correct. And he thought he was being picked on, of course, but there you go. I don't see any questions in the chat or the Q&A, but Donna, we recently talked about the implications of the HHS change in the opioid cutoff levels and where DOT is. That might be worth your talking about. What do you think? Well, it could be a short conversation. Basically, things are at a kind of an impasse, if you will, between the federal agencies right now. It's true that HHS did say that the cutoff level for morphine, for confirmatory cutoff level, would be raised from 2,000 to 4,000. What is the date for that? February 24th? What is that date? Mike, do you remember? Yeah, it's around about now. Right about now, right. About a week from now, I think. Yes, when the labs were for any test that is being done under HHS authority, that they needed to change the confirmatory cutoff level. Well, DOT was apoplectic when that final rule came out, and they didn't feel that they had been consulted, and they further believed that they had to do a full rulemaking process in order to make that happen for DOT testing, drug testing. When the final rule came out from HHS, DOT said that there was no way that they could get a rulemaking done, including a NPRM and a final rule, in time for the implementation effective date of the change to the HHS panel by mid-February. Some of us suggested that they could do an interim final rule that would not require months of comments and months of delay and months of whatever, but the people in charge of DOT right now said that they did not want to exercise that option for rulemaking. They were going to go through the NPRM process and the final rule and the proposed rule process. Secondly, there were several of us who believed that because of the Omnibus Transportation Employee Testing Act, OTETA, that DOT really didn't have any choice but to do what HHS said because of the way that the original legislation was written. I was a strong supporter of that approach, but I don't work there anymore and they told me no, that they do have the obligation to issue a conforming rule. We are now at impasse. I know that ODAPC, the Office of Drug and Alcohol Policy and Compliance at DOT, was asking HHS to delay the effective date of the confirmatory cutoff change for morphine. However, that has not happened yet and so we are now at a circumstance where, which is going to be a disaster, where the laboratories will be forced to have different confirmatory cutoffs and reporting for DOT testing as opposed to for HHS testing. HHS testing, of course, applies to only federal employees and the only way that the laboratory will know which morphine cutoff to use is by what is marked on the custody and control form because it's a federal form and so if it's marked HHS, they will on February, I think it's 24th, whatever, they will use 4000 as a morphine cutoff level. If it's marked with one of the DOT agencies, they will mark it with, they will test it under the old or the cutoff level of 2000 for morphine. NRC, the Nuclear Regulatory Commission, I have talked to two people there and they've said they are going to go with the HHS change at 4000. They don't have to do a rulemaking. That's a good thing because NRC's last rulemaking took them 13 years so that probably wouldn't happen. So that's where we're at. I think that the laboratories are just apoplectic about it, as you can imagine, Mike, because of the thousands of specimens, federal specimens that come in on a given day, Mike, what, less than 1% of them are HHS tests? Yeah, it's a little fortunate in that those 1% are concentrated in less than five labs. Yeah, right. It's not spread over the 25 or so that are certified. And to do a 2000 and a 4000 cutoff, it's really going to be extra work, but not backbreaking. They're just going to have to add more controls. That's what they've got to do. But you've still got to pick them out when they come through the back door. Yeah, right. So Doug, what is a student in this MRO course trying to master the basics do when they're thinking about taking the test? Any strategies for dealing with that? Well, we did at the exam development committee, we made sure that there would be nothing on the test this year that was specific to the confirmatory cutoff for morphine. So we went through questions and made sure that there were no questions that would be impacted by the fact of the morphine level going to 4000. Yeah, I can't just add to that. I know a little bit about psychometrics just to get myself in trouble. And what I've learned from those professionals that understand testing science, and how individuals take tests, look at tests, whether there's bias in the questions, not bias in the questions, you know, how you come up with foils that make sense or don't make sense is that one of the things that standardized testing should never do is to introduce test questions that have not been validated or thought about. So any standardized test, I don't care if it's a board recertification, you know, I just took the NRCME test again, just a couple of weeks ago. And I can tell you that there was nothing in those tests that are reflective of things that have just come out within the last six months. That would be unfair. The psychometricians would tell you that that's a bias error, and they would not allow those questions anyway. So I think that although MRO students obviously need to know about what's going on, that's something that's important. I don't think they need to worry so much about getting tripped up on that in the course of an exam. But I see we have a couple of questions. Julie, do you want to read the first one? Of course. So Dr. Schwartz has asked, for correctable error, how much effort does MRO have to extend to get correction? I'm assuming he's meaning correctable error in federal systems, right? So things like chain of custody, correctable errors, and that sort of thing. Boy, what a subjective question. You know, enough work to try to get the job done? That sounds like a flippant answer, but you know, it sort of depends on what the correctable error is. If it's something real easy, like maybe the collector forgot to do something or what have you, that's relatively easy. As MROs, I always remember the section of the code that says that we're the gatekeepers of the process, something I always like to reference too. And sure enough, we are the gatekeepers of the process. So that is involved in that process as well. You will run into times, and I certainly have had this happen to me multiple times, where trying to get those correctable errors taken care of are difficult because collector isn't there, gone on vacation, been fired, we don't know where they are, etc., etc. Well, I mean, the only thing that you can do in those situations is document those facts. I mean, you don't have to call the National Guard to go track a collector down. That's not what this is about. So I think what I'm trying to say is it depends. Dr. Peterson, I don't know if you have other comments about that. I'm sure you probably do. Well, the students of the MRO, I would go through the presentation on the custody and control form, identify for yourself each and every correctable flaw, and think about how much effort it would take. For example, well, I won't even give an example. Donna, you are involved in dealing with correctable flaws. Do you have a response to that? Yeah. I mean, I think from the MRO perspective, as long as you make a good faith effort, and again, a correctable flaw would be something like you've got a positive, and one example would be, and this is probably one of the easiest ones, you've got a non-negative test, and for whatever reason, the certifying scientist did not get a signed copy one to you, okay? Well, obviously, you don't want to cancel that test, and you need to make every effort to contact the laboratory certifying scientist and get the signature. I mean, and I think that what is that I have always found, I don't know about you, Doug, when that's happened, the laboratories are very responsive to getting that done, okay? I mean, they understand the impetus and implication of that, too, and a lot of times, it's just somebody forgot or hit the button too soon or whatever, yeah. Exactly, exactly. Now, with the collector flaws, like in terms of a collector's signature is missing, but the collector's name is there, and you've made, what we do, we make two attempts to get that information, an affidavit or a signed statement from the collector, and then guess what? Then we say, okay, then we're going to cancel this test, and error correction training will be required of that collector, and that collection site will be held responsible, if you will, for a canceled DOT test because of a collector error, and usually that works to get the statement. Very good. Julie, other questions? Yeah, so we have another question. For temp not recorded, is it okay for the lab to process? Yeah, the lab always processes that, yes. Yeah, I assume the temperature not recorded on the chain of custody is what's being asked, yeah. Yes, right, and then, of course, they will attempt to get that corrected, and then they will wait five days, and if they have gotten nothing, then they will go ahead and report out the result. Now, the question is, do you, as the medical review officer, have to try to get that corrected? No, you do not. We have a question about shy bladder. I had an elderly CDL bus driver have a shy bladder. She did not provide enough specimen within three hours. I MRO interviewed her. She refused shy bladder referral. She says she has nothing wrong with her physically and mentally. I ruled her refusal to test. A backstory is this elderly driver missed the urine cup during attempts because my collector said there was urine all over bathroom. Is this really a refusal to test because her technique of urinating in the cup was not effective? I wouldn't want to go to court and defend that refusal to test, I'll tell you that. First of all, why was the MRO interviewing that her as opposed to her being sent for an examination by a referral physician? Yeah, that's exactly right, Dr. Smith. The premise here is backwards. The MRO would not get involved with this until the shy bladder evaluation has been completed and reviewed by the MRO, and then at that point, the MRO interview would occur. So I'm not quite sure I'm understanding the course of events here. I guess- Let me just amend one thing, maybe. If in fact, the elderly CDL driver refused to go for the shy bladder evaluation, that becomes a refusal to test, but it is a refusal to test from the employer because the employer is the one that has to tell the driver you have to go for this examination. And so then it becomes the employer that documents that she would not go for that shy bladder evaluation. I can tell you that of all the litigation that MROs have been dragged into, 85% of those cases are shy bladder cases where the MRO's determination was a refusal to test. And it ends up to be a, right? I mean, they are- You want to make really, really sure that the entire criteria have been met before you put your name on that test results or that CCF that it's a refusal to test for a shy bladder. Yeah, I don't know. I mean, the anecdotal information about having urine all over the floor is interesting information. Probably more interesting to me as a federal motor carrier safety administration certified examiner, I begin to have questions about, is the person's vision okay? Is their judgment okay to even hold a commercial driver medical certificate? But that's not what we're here for. We're here for the MRO part of this. So that just reminds me to tell everybody that make sure you understand which hat you're wearing in what situation, because many of us often wear many different hats and it's tough sometimes to make sure that you understand what you're doing in any particular situation and not overstep what your role is. Okay, Julie. So I know you were talking a little bit about tests, so I'm not sure if you answered this one, but I'll be taking tests next week. What initial and cutoff levels will be on test and other changes I should be aware of? Assume I can use the level in the course manual? Definitely. Yes, that is for sure. You bet. And you will be asked about initial and cutoff levels. If that was part of the question, I wasn't quite sure, but yes, that is subject to test questioning. Yep, something you have to memorize. What are the initial cutoff levels on the federal panel and what are the conformatory cutoff levels? Cutoffs. Okay, Julie. Those are all I'm seeing in the queue. Kent, you're muted. You didn't miss anything. If you're taking the online exam, it's important in preparing for it to have available to yourself the key tables and documents that you will use not only to pass the exam, but to function as an MRO on a day-to-day basis. So that table with the cutoff levels for both the initial tests and the confirmation tests, you will memorize those, you will know them, and you'll also have that sheet there for you. You'll also have the sheet with the creatinine and specific gravity, and Donna and I carefully put together a table on that. You'll also have available the list of medications that can cause positive drug tests and which medication can test positive for what drug, because as an MRO, you need to have a working knowledge of pharmacology. And so it's not just studying for the test. It's really studying to be an effective MRO. Everything you do to be able to quickly pass the exam will also allow you to be an efficient and effective MRO. There's a follow-up question regarding the temperature. If temp not recorded, I thought it could be done. Yes, I think that's what we said. Even though the temperature is not recorded, the laboratory goes in with the testing process. And of course, they try to correct it, but they go through with it. Dr. Schwartz, hopefully that answered your question, but if not, please feel free to. If I could just bring up one point, and again, it's because I get some phone calls from medical review officers that maybe have taken the course six years ago or seven years ago. And so the past month, I've been getting a number of inquiries that start out with, Dr. Smith, the California and the Washington laws changed effective January 1, and you can't test for marijuana in California on any drug test. You can't do a urine test for THCA, which is a non-psychoactive metabolite of THC. And in Washington for pre-employment tests, you can't even, as an MRO, you can't even report a marijuana positive to an employer. And let me say that that has absolutely nothing to do with the review of federal drug tests. So that if you're reviewing a DOT test for marijuana in California, in Washington, it does not matter. Okay. You have to follow the DOT guidelines, which have very limited medical, acceptable medical explanations for marijuana positive. I recently attended a webinar called 2024, the year of oral fluid testing. And my first reaction was, I don't think so, because 2024, we're not going to have an acceptable federal collection device. And we may not have two laboratories that have been certified, I think, you know, maybe 2025 or 2026. But they went on to say that the reason is because of these laws in California and Washington. And the key phrase was in the laws that a person may not be excluded from work for the presence of quote, non-psychoactive cannabis metabolites. So they're talking about the non-psychoactive metabolites, but THC is psychoactive. So I think that the federal program will of course be unchanged. And I think that most employers who say in their policy that they may not have the presence of THC and its metabolites, that will will still permit companies to do testing. But that's where the state laws is dividing the head of the pin into psychoactive metabolites and non-psychoactive metabolites. We did receive one more question. Dr. Cochran works for a medical center as the MRO for pre-employment testing. I understand that this is not federally regulated testing. I inherited a policy that says that marijuana positive is not a disqualifier for hire, and an organizational cutoff of 100 was established in policy. But I often see levels quite a bit higher, and the candidate gives a story about usage pattern that sounds plausible. I don't have a specific question, but would appreciate your expert thoughts on how I should be thinking about marijuana levels. I think when you say 100 nanograms per mil, that is probably the initial test cutoff. Because way back, there were kits that were used that had 100 nanogram per mil cutoffs. I don't know of a marijuana drug testing program that would use 100 nanograms per mil as a confirmation cutoff. I've never come across that. So I think there's some confusion in that policy that you've inherited about what 100 nanograms per mil is. It's probably the screening cutoff, because there were kits available to do that cutoff. And it was, in some cases, deliberately raised that high to prevent any positives being detected. Dr. Cockrum said, no, the 100 is after the lab has confirmed on their normal cutoff. As the confirmation cutoff? Wow, that's really unusual. Yeah, that's almost unheard. I have not heard of that. Me either, never. I mean, you wouldn't see any positives. So, I haven't seen that policy you're referring to either, obviously. And certainly, if you wanted for me to review it, I could do that for you. But I've got to believe that's the initial test cutoff at 100 nanograms per mil. And remember, as an MRO, in a non-federally regulated test, you're the agent of the employer and you're following their policies. It's a good idea when you get a client to look at their policies and give them suggestions and critiques if you think the policies are bad. And that's certainly a common role of MROs. And it helps them to get to know their client and cement the relationship with the client. I'd like to add something to that. And that has to do with, I believe, you were saying, Dr. Crawford or whoever was submitting this, that in interviewing either candidates for these positions or employees, that the information about their usage of cannabis or their exposure to cannabis or to marijuana products often seemed that they could, in fact, have 100 nanograms or more from CBD or from passive exposure or from whatever. And that was a concern to you. And I thought you were also trying to indicate or ask a question about what our experience was with regard to what does a specific level, whether that's 110 nanograms of THCA per mil versus 80 nanograms of THCA per mil in a urine specimen. What does that say about how much they used, when they used it, or their history, or even, God forbid we go there, whether or not there could have been any impairment or whatever associated with that use. And again, Dr. Pete has taught me from when I was just 18 years old, I think, that you can't tell anything about the quantitation in a urine specimen. You want to say that more eloquently, Mike? No, there's no correlation between a urine concentration of a drug or drug metabolite to the way the drug was used, the amount of drug used, the time the drug was used. God forbid any degree of impairment correlation, because that is not the case. Even under very controlled studies, they can't relate a urine level to impairment. So, you know, it's just a finding to show you that the donor, at some prior time, used that particular drug, in this case, marijuana. I have one other comment about Dr. Cochram's initial post. And this kind of gets at what Dr. Peterson said about understanding your policy. I do a fair number of MRI reviews in the non-regulated, non-federal world. And it is true that you really have to understand what the individual drug policy says, and more importantly, what it doesn't say sometimes. But in his narrative that he put in, I think it's interesting that he says that he inherited a policy that marijuana positive. I want to stop right there. What that tells me is, is that in this particular drug testing process, the MRO still has the ability to report the test out as marijuana positive. And I don't think that's something that we should ignore in his description, because I think that's different than saying, well, you just can't report it if it's positive. That's a whole different ballgame. So I would look at this from the perspective that MRO work in this would be like it normally is. You're looking at the result. You're going to do an interview, find out if there's a legitimate medical explanation. If there's not a legitimate medical explanation, you're going to report it as positive. Let the company human resources person figure out whether this particular marijuana positive either fits within the policy so that they can be hired, or doesn't fit within the policy so that they can't be hired. I would be real cautious and suggest to Dr. Cochram that you don't become a human resources officer. That so many times has been asked of me during my career, and I backtrack away from that as fast as I possibly can. I will do everything for a company to try to help them create their drug testing policy. I'll do everything to try to point out the pluses and the minuses. I'll sit down with their corporate attorneys. I'll sit down with HR people and tell them, OK, here's the pluses and the minuses. But I did not go to school. I did not become certified as an MRO to be a HR specialist. OK, Julie, anything else? I don't see any. Are there any other questions? Yeah, you're muted. Oh, there is one more that just came in. OK. Is hair testing reliable for THC? That sounds like a toxicology question to me. Yes, it's reliable for THC. However, like urine, it's not THC that you detect in hair. It's the THC acid metabolite. And you have to have a very low cutoff in a hair specimen to detect that. Whether it's detectable after single use in hair, the answer to that is probably no. It does take time for any drug or drug metabolite to build to a concentration that's detectable in hair. But you can detect THC use through the detection of the THC metabolite in hair specimens. And most labs who do testing for hair do that test. Very good. All right. Well, any other comments, questions for the good of the order? All right. Seeing none, I want to thank the participants tonight. Thank you, faculty, for joining us tonight. Everybody have a good rest of your evening and Valentine's Day. Thank you, everyone for joining. Thank you.

drug testing

workplace

follow-up testing

commercial drivers

substance abuse professional

DOT testing

HHS guidelines

federally regulated testing