Drug Testing, MRO Review, and Collection Procedure Disputes

Representative facts: An employee subject to random workplace drug testing produced a urine specimen that tested positive for codeine at 2,400 ng/mL and negative for other drugs. The Medical Review Officer certified the result as positive, and the employee was terminated. The employee claimed that poppy seed ingestion explained the result and alleged collection flaws, including that the courier’s name was not printed on the custody and control form.

Issues for expert review:

· Did the MRO conduct an appropriate review before verifying the codeine result as positive?

· Was poppy seed ingestion a medically plausible explanation under the applicable testing rules and cutoff levels?

· Were the collection procedures substantially compliant, and did any alleged deviations compromise the integrity or fairness of the test?