In this module, we'll briefly discuss hair testing for drugs of abuse with particular emphasis upon the status of hair testing from a federal regulatory perspective and then some issues related to the collection of hair specimens for drugs of abuse testing. Generally the appeal of using hair testing for drugs of abuse prevention and control in workplaces is the period of detection. While oral fluid testing and urine testing can pick up recent drug use, it is really only the hair or the nail specimen that can pick up repetitive drug use that has occurred over a period of weeks or months. So let's take a look at where we are with hair testing, particularly in the federally mandated drug testing arena. So back in 2004, 2003, there was an attempt by the Department of Health and Human Services to gather information about whether or not hair testing for drugs of abuse would be applicable for federal drug testing programs, for federal employees, for Department of Transportation, etc. There were consensus studies done, there were several panels and meetings held to take a look at the technology, at the matrix, and what would be involved for using hair testing or incorporating hair testing into federal drug testing programs. Not much occurred for about a decade, if you will, and then in 2014, Congress actually put language in a trucking authorization bill that said that truck companies would be able to use hair testing for pre-employment testing of commercial drivers, and that in order to do so, they needed the Department of Health and Human Services to finalize some technical guidelines and standards for hair testing for drugs of abuse, and they should do so no later than December 16, 2015. Well, that has not happened. In the interim, the Drug Testing Advisory Board, which is that advisory council made up of experts in the field of drug and alcohol testing, did make a recommendation to SAMHSA, to the Substance Abuse Mental Health Services Administration in the Department of Health and Human Services, that they should proceed with development of mandatory guidelines for hair testing in federal workplace drug testing programs. This was partly driven by the language in the legislation. So where we are now, five years later, essentially, the draft hair testing mandatory guidelines were written by SAMHSA, by the Office of Drug-Free Workplace, and they have been submitted to OMB, the Office of Management and Budget, for approval and release, we had thought, in 2019, but that has not happened. So here we are in 2020, with no proposed mandatory guidelines to date. No DOT action on hair testing can take place until HHS issues hair testing mandatory guidelines, and DOT then follows with its rulemaking. Without any federal standards for hair specimen collections, we have to rely at this point on what is the standard of practice in the industry where hair testing is used extensively, particularly for pre-employment testing. So the supplies that are a part of hair testing collections are disposable gloves, scissors, a hair clip of some type to separate the hair on the head of the donor, alcohol wipes, a collection kit that is supplied by one of the hair testing laboratories. It consists of a foil packet, a specimen envelope, a plastic bag, and a custody and control form along with an envelope seal that helps to document the chain of custody for the specimen being obtained from the donor and shipped to the drug testing laboratory. Most of the hair testing laboratories that do workplace hair testing have specimen collection procedures that they have developed for collecting and processing and sending specimens to their laboratories for analysis. Some of these training programs for hair specimen collectors are on the laboratory websites, and in general, the procedures are as follows in terms of what's on this particular slide. Using clean scissors to cut the hair, single use or disposable scissors, or clean with an alcohol wipe prior to use. Head hair length should be at least one and a half inches. Approximately 120 strands of hair are needed for adequate sample. The cutting of the hair for the sample is to be cut near the rear of the crown of the head as close to the scalp as possible. Put the hair sample in a foil packet, which is provided as part of the collection kit. You keep the root ends out just about a quarter of an inch from the slanted end of the foil. If the hair sample is longer than the piece of foil, which is generally maybe three inches at the most, you do not cut the hair sample, but simply wrap excess length around the foil packet. Place a security seal from the CCF on the bottom of the envelope or indicated. Instruct the donor to initial and date the seal and the envelope after the collector has placed the seal on the envelope. The collector initials and dates the seal in the envelope and then places the sealed specimen bag into an overnight shipping package and sends the specimen to the designated laboratory for testing. So you can see some parallels here. There is a custody and control form. There are security seals, if you will. And there is identification of this specimen with the individual. Some of the issues that are involved with hair testing in a workplace setting certainly have to do with the collection of an adequate sample. If a person does not have hair on the crown of their head or on other places on their head, then other body hair may be used, but it may be difficult to obtain in adequate quantity, and there are privacy concerns. And don't forget that there's a big difference, if you will, in detection window from head hair versus body hair. So with head hair looking at an approximate one and a half centimeter length of head hair growth, you'll be looking at maybe 90 days of the past 90 days of hair of drug use being incorporated into the hair shaft. But with body hair, particularly depending on what site it is taken from, such as the arms, the chest, the legs, the back, et cetera, that window of detection can extend out many months, six months or beyond. It's also difficult for a collector sometimes to detect human hair wigs, hair pieces or extensions, weaves, et cetera. So it does take some experience and just some learning on the fly, if you will, for the collector to be able to make sure that they are collecting a sample from the person's head. There is a difficulty with determining an adequate specimen for very closely cropped hair or curly hair, very wiry hair, and oftentimes you can't do that as easily in terms of knowing that you have enough strands of the hair in order to do the analysis. So sometimes you may have to actually weigh the hair if it is not in one and a half inch lengths. Difficulty in handling and placing the hair while wearing gloves. It does take something. I mean, a hairstylist may be able to cut hair while wearing gloves, but for most collectors, this is not something that they are trained to do. And so it is sometimes difficult to make sure that you are not cutting too much of the hair and therefore leaving a, quote, bald spot, end quote, on the donor, but also getting an adequate sample. Closely braided or plaited hair should be unbraided before cutting the sample. So again, this raises issues with regard to what extent can a donor who is presenting for a hair test be told to undo their hairstyle or how their hair is currently configured. So those have been some issues that employers have had to work through when they decide to use hair testing for pre-employment or other testing reasons under their policy.

hair testing

federal regulatory perspectives

specimen collection

detection windows

workplace drug prevention