June 27, 2019
U.S. Department of Transportation
1200 New Jersey Avenue, S.E.
West Building Ground Floor, Room W12–140
Washington, DC 20590–0001
RE: Docket Number FMCSA–2019–0108
Dear Sir or Madam:
The American College of Occupational and Environmental Medicine (ACOEM) welcomes the opportunity to provide comments to the Federal Motor Carrier Safety Administration (FMCSA) regarding its Information Collection Request regarding the Commercial Driver Drug and Alcohol Clearinghouse. As our organization’s membership consists of many physicians who are Medical Review Officers (MRO), we are keenly aware of the issues that have been brought forth in the Final Rule.
We wish to reinforce our support for a National Clearinghouse as we believe that this will improve the process of identifying those commercial drivers who should not be performing safety-sensitive functions because of a violation of agency drug and alcohol testing regulations. We have long advocated for measures that increase stakeholder communication with the goal being to improve safety of both the public and commercial drivers, and the Clearinghouse process will no doubt make that goal easier to accomplish.
We would specifically like to comment on the requirement for MROs to report verified positive, adulterated, substituted, and refusal test results within a two-business-day timeframe. Although we have heard from a minority of members about a potential concern of low-volume MROs who might be challenged with having the necessary staffing requirements to meet this portion of the rule, the overwhelming response we have received from our MROs is that this is a reasonable timeframe to accomplish this reporting requirement.
Thank you for the opportunity to comment. We are available to discuss the issues further at your request.
Stephen A. Frangos, MD, MPH, FACOEM
Douglas W. Martin, MD, FACOEM
Chair, ACOEM Medical Review Officers Section