ABSTRACT

A Medical Review Officer (MRO) has come to be defined in U.S. Department of Transportation (DOT) regulations (i.e., 49 CFR Part 40) as a licensed physician (Doctor of Medicine or Osteopathy) who is knowledgeable about and has clinical experience in controlled substance abuse disorders, including detailed knowledge of alternative medical explanations for laboratory confirmed drug test results. The MRO has become an integral part of the workplace drug testing process as federal regulations for workplace drug testing have been developed and implemented, at first for drug testing of federal employees, and then for millions of other workers in private industry for which drug testing was mandated by federal agencies such as the U.S. DOT, The U.S. Coast Guard, and the Nuclear Regulatory Commission. Beginning in the mid-1980s the MRO has been involved in an ever-growing number of drug tests. Federal regulatory requirements for workplace drug testing have expanded and these regulations have further defined and broadened the role of the MRO in the process. Programs for workplace drug testing requiring medical review have been implemented by various states (e.g., Florida, Georgia, others) in connection with worker compensation programs. Some states have required medical review of all workplace drug test results collected in those states (e.g., Oklahoma and New York). Increasing numbers of private employers have been implementing drug testing programs that include medical review of results absent any regulatory requirement to

do so. Although originally all workplace drug testing programs involved the collection of urine drug testing specimens, and most still do, other sampling media including hair, blood, saliva, and sweat, and others are beginning to be accepted and used in workplace drug testing programs. All of these factors have led to the emergence of the MRO as the “gatekeeper” of the workplace drug testing process.