What are the occupational medicine guidelines for conducting BATs in light of the COVID-19 pandemic?

Breath Alcohol Testing
Alcohol testing is mandatory for some employees in industries regulated by the Department of Transportation (DOT). It is also performed under non-regulated drug testing programs, per employer policy. Initially, screening is performed by a trained screening test technician (STT) or evidential breath testing or breath alcohol technician (BAT). An alcohol screening device (ASD) device is used, which measures alcohol in saliva or breath. Employees who exceed the screening threshold (0.02% breath alcohol) must undergo breath alcohol testing using an evidentiary breath alcohol testing device (EBT) within 15 to 30 minutes. Most use single-use disposable plastic breath tubes. Alcohol testing may be performed in a clinic facility, or by personnel who travel to a test site at a workplace or another designated location.

When saliva is used as the matrix for alcohol screening, 49 CFR Part 40.245(a)(3) requires that the STT “offer the employee the opportunity to use the device. If the employee uses it, you must instruct the employee to insert it into his or her mouth and use it in a manner described by the device’s manufacturer.” If the employee chooses not to use the device, the STT “must insert the device into the employee's mouth and gather saliva in the manner described by the device's manufacturer. [The STT] must wear single-use examination or similar gloves while doing so and change them following each test1.” 

Saliva collection, itself, should not generate significant respiratory droplets or bio-aerosols. However, the single use testing materials should be considered contaminated, and must be handled accordingly. Skin contamination is possible.

Breath alcohol testing requires a forced exhalation by the evaluee for at least six seconds. This procedure may generate bio-aerosols. It is performed by a trained BAT. While the technician can use PPE to reduce the risk of viral exposure, to the extent that aerosols containing virus are produced vs. large droplets, any contamination introduced to the testing room may linger. The DOT model course states the BAT holds the instrument, but to allow for social distancing we recommend that during the COVID-19 pandemic the employee does so. Some opportunity for skin and surface contamination exists. Advice for use, cleaning, and sanitizing of breath testing instruments in the pandemic period is available from at least some manufacturers.2,3,4

Specific advice for performance of breath alcohol testing during the pandemic

The clinic operator must determine whether or not testing can be safely scheduled based on the factors noted above. It may be possible to provide testing as usual, or there may be some limitations on the clinic’s ability to provide services. Nothing in statute or regulation compels a clinic to provide alcohol screening or testing. However, some alcohol testing is required by regulation and/or company policy. Contracts with clients may obligate a provider to continue services when possible. 

For federally regulated testing, the Office of Drug and Alcohol Programs and Compliance (ODAPC) and each of the DOT Modal Agencies, has provided guidance on which examinations must be performed as usual, which can be deferred, and the nature of the latitude granted the employer. This information is briefly summarized in the table below. The designated employer representative (DER) for client companies should be well aware of what is required. However, it is also desirable for service providers to be familiar with current guidance. ODAPC has made it clear it hopes service agents, including STTs and BATs will:

“continue to provide services to DOT-regulated employers if it is possible to do so in accordance with State or local mandates related to COVID-19.  Should you have concerns about COVID-19 when testing or interacting with employees, please follow your company policy, directions from State and local officials, and guidance from the Centers for Disease Control and Prevention (CDC).5"

When breath alcohol screening and testing is performed, the following is recommended:
  1. The BAT and STT should obtain and familiarize themselves with COVID-19 specific guidance for their cleaning and sanitizing their testing equipment, if this is available. Non disposable portions of the instruments should be cleaned and sanitized using approved methods before and after each test.
  2. Regulation already requires the STT to don a fresh pair of disposable gloves for each test. This is also essential for BATs as both the BAT and the employee handle the testing device to some extent.
  3. Testing personnel should wear N95 masks if available to them, or surgical procedure masks if N95s are unavailable. Employees should be given surgical procedure masks upon arrival to the clinic and should be expected to wear them during their visit, except during testing.
  4. When performing alcohol screening, use of saliva testing equipment is strongly preferred as this is unlikely to increase production of respiratory droplets or aerosols.
  5. The DOT model course states the BAT holds the instrument, but to allow for social distancing we recommend that during the COVID-19 pandemic the employee does so. 
  6. When breath alcohol testing is performed, whether in screening or testing, the employee should point the open end of the disposable breath tube away from the STT or BAT. 
  7. A face shield or other eye protection is recommended.

Appendix: MODAL Agency Guidance on BAT 05/11/2020

Citations

1) https://www.transportation.gov/odapc/part40/40-245
2) https://3gxou93ihow7rltj72rrjmb1-wpengine.netdna-ssl.com/wp-content/uploads/2020/03/Infection-Control-Cleaning-and-Disinfecting-Intoximeters-Desktop-Instruments.1.pdf
3) https://3gxou93ihow7rltj72rrjmb1-wpengine.netdna-ssl.com/wp-content/uploads/2020/03/Infection-Control-Cleaning-and-Disinfecting-Intoximeters-Handheld-Instruments.4.pdf
4) https://www.lifeloc.com/covid 
5)  https://www.transportation.gov/odapc/compliance-with-dot-drug-and-alcohol-testing-regulations
6) https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/2020-03/FMCSA%20COVID-19%20Drug_%26_Alcohol_Testing_Guidance.pdf
7) https://www.faa.gov/about/office_org/headquarters_offices/avs/offices/aam/drug_alcohol/media/FAA%20COVID-19%20Drug%20and%20Alcohol%20Testing%20Guidance.pdf
8) https://www.phmsa.dot.gov/news/phmsa-issues-stay-enforcement-pipeline-operators-due-covid-19-outbreak
9) https://www.dco.uscg.mil/Portals/9/DCO%20Documents/5p/CG-5PC/INV/docs/documents/MSIB-10-20_Novel_COVID-19_Drug-Testing_Requirements.pdf?ver=2020-03-27-144839-417
10) https://railroads.dot.gov/elibrary/fra-guidance-drug-and-alcohol-testing-requirements-during-covid-19-public-health-emergency

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Disclaimer:
The Forum does not necessarily represent an official ACOEM position. The Forum is intended for health professionals and is not intended to provide medical or legal advice, including illness prevention, diagnosis or treatment, or regulatory compliance. Such advice should be obtained directly from a physician and/or attorney. Questions are answered with the best available data or recommendations at the time.