Interpretation Response #PI-97-004
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Interpretation Response Details
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Department of Transportation
Office of Drug and Alcohol Policy and Compliance
49 CFR Part 40 Interpretation Notice
Question: In the event that a split specimen arrives at the laboratory and specimen A appears to have leaked out of its sealed bottle, can specimen B be redesignated as specimen A so that the primary laboratory can test the specimen?
Response: Because the vast majority of urine specimens sent to laboratories will test negative, the Department believes that if split specimens arrive at the primary laboratory and the sealed bottle A has lost its contents, the laboratory can -- upon believing sufficient urine exists in bottle B to conduct all appropriate primary laboratory testing -- redesignate the bottles. The bottles must be redesignated prior to the opening of either bottle. On the appropriate bottle, the laboratory shall mark through the "A" and write "B," then initial and date the change. A corresponding change shall be made to the other bottle by marking through the "B" and writing "A," and initialing and dating the change. A notation shall be made on the original chain of custody (Copy 1) and on the split-specimen copy (Copy 3).
If this situation occurs, the laboratory should not bring this split specimen deficiency to the attention of the MRO (at this time) but should simply test the specimen and report the result to the MRO. Consequently then, an MRO, honoring a donor"s request to have the split specimen tested following a confirmed positive test result, must manage the situation the same as for specimens when the split sample is not available for testing.