The original federal regulations that governed the early workplace drug testing programs were a blend of medicine, toxicology, and law. These regulations were the birthplace of an industry that now consists of more than 675 thousand employers who drug-test more than 12 million employees every year under the Department of Transportation’s regulatory program alone. This program is only 20% of the entire world of workplace drug testing. More than 6,000 MROs review, verifier, and report the results of this testing back to the employers. In so doing, MROs assume responsibility not only for helping to maintain the safety and well-being of the workplace, but they also assume a direct role in the early intervention of a destructive addictive pathway. As the drug-test world expands in both size and complexity, the role of the MRO evolves as well. Today, the MRO must not only be familiar with federal regulations, but also have clinical experience in the diagnosis and treatment of substance abuse disorders, forensic toxicology, and understand all of the other processes involved in the drug-testing programs including collection, lab testing, and return to duty. MROs must understand how alternative specimens are used in workplace drug testing and the intricacies of the review of drug testing panels containing many more drugs than the original HHS 5. State and local regulations may also be applicable for some non-federal drug testing and the MRO should be aware of these. MROs should have specific written protocols for testing under federal, as well as for non-federal drug-testing programs. Specific agreements with each client employer that clarify the MRO’s relationship with that employer should be created. Legal counsel should always be consulted in the establishment of the MRO/client relationship, and MROs should be certain to have the proper Errors and Omissions insurance to cover their work.
Continuing education is necessary for MROs. DOT regulations require both 12 CMEs every 3 years and the successful completion of an examination administered by a nationally recognized certification organization. Additionally, a rich array of newsletters, textbooks, and e-mail lists exists for the benefit of the MRO. Although there is no physician/patient relationship in medical review of test results, and it is a forensic practice rather than the traditional practice of medicine, the MRO role is essential to the integrity and effectiveness of Drug-Free Workplace Programs. The role of the MRO is interesting, complex, and rapidly evolving thanks to the technical advances, regulatory changes, and the huge bank of knowledge gained from the past 16 years of experience.