At the beginning of the summer, the Substance Abuse and Mental Health Services Administration (“SAMHSA”) published their most recent Request For Information in order to solicit comments from professionals and experts about potential hair testing for drugs. Rather than focusing on overall policy at this point in time, the request is part of an effort to revise and update standards for laboratory drug testing procedures for federal workers. Hair testing is able to detect past drug use significantly further back in time than urinalysis.

Tasked by the Department of Health and Human Services, SAMHSA is looking to improve the federal government’s best practices in regards to the use of the top technology available. The main goal is to apply these standards to federal workers in the Department of Transportation where being under the influence potentially poses the greatest immediate risk to the general public.

The goal of the request is to ensure the reliability and accuracy of drug tests in the Mandatory Guidelines For Federal Workplace Drug Testing Programs. SAMHSA seeks information and comments on a variety of issues related to hair specimen drug testing. What is significant about SAMHSA’s approach is a willingness to work with outside experts, thus gauging the research and opinions of the treatment professional and addiction research community as a whole.

Although too detailed to capture in full, the Request For Information includes the following 5 question sets:

1. What are the acceptable body locations from which to collect hair for workplace drug testing? What should be done if head hair is not available for collection?
2. What hair treatments (i.e., shampoo, conditioning, perm, relaxers, coloring, bleaching, straightening, hair transplant) influence drug concentration in hair and to what degree?
3. Should the hair collection protocol be standardized, including specific instructions on how close to cut the hair specimen to the skin, how to determine the authenticity of the hair specimen, what cutting instruments to use, how to ensure the cutting instruments are decontaminated, and whether the use of collection kits should be required?
4. What is the minimum amount of hair that should be collected?
5. What technologies are available to perform initial and confirmatory testing on hair specimens?

Once SAMHSA’s final testing guidelines are issued, it will be up to the Department of Transportation and other federal departments to decide whether to adopt these new guidelines and publish new testing rules for regulated employees.