Submission comment for AS/ANZS: 4308 2022 is 3rd August 2022

Good afternoon WDTA Members,

Cut off for comment submission on the final AS/ANZS: 4308 2022 is 3rd August.

The WDTA has significant concerns around 4 key points. The board believes the 4 items listed below have the potential to negatively impact our industry and on-site workplace urine drug screening.

I would urge all members to log on to the standard site and, at a minimum, enter the 4 comments below.

2.2 Collection Site: 2.2.2 Privacy

  • supervised vs observed
  • Observed samples can be collected if “there is a risk”. How is this defined and what is deemed acceptable and unacceptable risk?
  • The WDTA has concerns that some workplaces may decide that all urine samples may be “at risk” and then all samples need to be observed.
  • That then raises the potential for issues with the unions and perhaps then ongoing problems with the collection of samples for workplace testing.
  • There is the potential that a worksite may just cease testing as it becomes too difficult.

 2.5 Transportation to the laboratory Note 1. Where transportation is facilitated by commercial couriers, and chain of custody is not practical, the risk of not maintaining COC should be assessed.

  • How is this possible if commercial couriers are used? The large laboratories have a comprehensive in house courier network.
  • This doesn’t exist for the smaller organisations who are reliant on commercial couriers.
  • Previously the seals on the sample containers/tubes have been considered sufficient to ensure the sample has not been tampered with.
  • Why is there a requirement to changes this?

4.5.2 General Acceptance Criteria.

Laboratories can reject samples from worksite testing companies, without any recourse from the collection organisations.

The WDTA position is that the laboratory does not have the right to summarily refuse to perform testing without engagement and an explanation to the worksite testing company.

B.2 Collection, transportation and storage devices

“Evidence of verification shall be provided, if required, that collection, transportation and storage devices are fit for purpose in that drugs are stable and recoverable during collection,…….manufacturers specifications”

  • This is not the testing device but the transport device- for example the yellow cap
  • This potentially would require for each analyte/drug to be verified (potentially a stability study time/temp/recovery) in collection containers like 70ml yellow top containers.
  • This would be prohibitively expensive and if a company had multiple collection/transportation devices (ie. Yellow caps from different manufacturers), each of these would require verification.
  • There is then the issue of how do you determine one yellow top container from another? In theory, every single yellow top brand would require verification.
  • This seems to be an example of looking for a solution for a problem that doesn’t exist.

The WDTA board will lodge comments on the above 4 points. For weight of comment, we would urge our members to add the 4 WDTA highlighted comments to your submission comments plus any other concerns your team has.

In order to be effective we need as many responses as possible.