Premium on Safety - Issue 42 2021 - 2
BEST PRACTICES
SMS isn't that manual sitting on a shelf.
Ideally, it's a process that's been carefully
woven into every aspect of your operation.
It's something that rightfully receives
consistent attention. Like managing
maintenance or operations, you will never
be 'finished' with it. Space is hard. So is
SMS if you try to take it on in aggregate.
My suggestion: break it down into pieces
and schedule recurring sessions to evaluate
your SMS status. Refine and fortify the
capabilities you already have in your
operation, one element at a time. Do a
thorough review of your organization's
safety risk profile, then examine your
suggestion and hazard reporting policy
and its use rate, follow up with a check on
the currency and appropriateness of your
internal evaluation process. When you get
confident the key parts are working, review
and focus your performance metrics.
These are some possible milestones, but
yours can (and should) be customized to
your operation. The key is to get SMS into
the flow of your 'important stuff' because
that's where it belongs!
There are regulatory changes in the works
that will soon push SMS requirements
beyond commercial carriers, into Part
135, Part 145, air tour, and possibly other
operations. Even if you're not directly in
the path of those oncoming mandates, the
drive to advance, innovate and thrive-so
prevalent in aviation's history-should be
a powerful motivator. That, coupled with
a better appreciation that this represents
a next 'Giant Leap' for our industry might
simply be grounds to shift us collectively
into high gear. It's time to get smarter, get
involved and get busy with the hard work
of having and running an SMS. Take a cue
on how to get started from Henry Ford,
who said, " nothing is particularly hard if
you divide it into small jobs. "
Stay well, fly smart and fly safe.
In June 2018, the FDA approved cannabidiol (Epidiolex®) for the treatment of seizures.
The active ingredient in this medication is CBD. In December of 2018, the Farm Bill was
signed into law. It removed hemp, defined as cannabis and derivatives of cannabis with
extremely low concentrations of the proactive compound delta-9-tetrahydrocannabinol
(THC) with no more than 0.3% THC, from the definition of marijuana in the Controlled
Substances Act (FDA July 25, 2019). The Departments of Agriculture in each state are
responsible for the establishment, operation procedures, and industrial hemp licensing
programs. Twelve states have laws that delineate THC levels in cannabidiols (CBD).
CBD products are not considered psychoactive. There is some preclinical work at this
time showing CBD may be psychoactive based on some preliminary data in patients with
anxiety and addiction (Neurotherapeutics. 2015;12(4):825-836). This is the same CBD,
only in lower concentration, that is used in products found in CBD stores, health food
stores, and airport shops. CBD products are not regulated by the FDA. The amount of
THC in some products may be falsely reported. There has been some anecdotal data of
pilots who have used CBD products with a low THC component, and who had a random
drug level show up positive for THC. A newly hired Colorado pilot was fired in 2017 due
to accidentally eating a marijuana edible from a friend. He tested positive for THC before
starting his job. THC is fat soluble and will stay in the body for weeks. The pilot did
receive his certificates back through working with the FAA.
Medications that could potentially cause a false positive for THC include proton pump
inhibitors, omeprazole (Prilosec®), pantoprazole (Protonix®), and esomeprazole (Nexium®).
Proton pump inhibitors will block the stomach acid (hydrochloric acid) completely.
This will prevent backup of the stomach acid into the esophagus, the main cause of
gastroesophageal reflux disease (GERD).
Non-steroidal anti-inflammatory drugs (NSAIDs) are medications used for pain. Typical
uses of NSAIDs are for people with osteoarthritis and general muscle pain. NSAIDs block
the inflammatory process to stop or decrease pain. Ibuprofen (Motrin®) and naproxen
(Aleve®) have been reported to cause a falsely elevated THC level. An HIV medication,
efavirenz (Atripla®, Sustiva®) is also on the list of medications that could possibly cause
THC to be detected.
It has been shown in studies that the type of immunoassay technique used can make
a difference of showing a false positive THC test versus a negative test (Clinical Tox,
Vol. 58 2020: Issue 6). The package insert for pantoprazole (Protonix®) recommends
that an alternative confirmatory method should be considered to verify positive results.
The time span the patient is taking these medications could also play a role in false
positive findings. It has been postulated that chronic administration of these particular
medications may lead to a higher false positive THC urine level.
Paul Ratté
Director of Aviation Safety
Programs, USAIG
HOW URINE TESTING WORKS
Urine testing for drugs is common in the outpatient clinic setting and outside laboratories.
The reason for urine testing in the outpatient setting is for initial screening purposes. It is
faster and cheaper but has a higher false positive rate than blood testing or other more
technologically advanced tests. The urine drug tests are immunoassays, a biochemical
test that detects a drug or a drug concentration in solution through the use of an
antibody (most common) or an antigen. The antibody seeks out the drug the clinician is
looking for and attaches to it. The immunoassay is interpreted as positive or will report
a concentration of the drug. The immunoassays can cross-react with commonly used
medications or its metabolites and show a false positive level for substances that are
banned by an employer. A drug metabolite is a remnant of the drug after being broken
down by the body, and the most common metabolizer of a medication is the liver. The
metabolite can be active and have an effect on the body or be inactive and not have an
effect. Immunoassays will also react with medications that are chemically similar to the
banned substances, but are not pharmacodynamically related, or how the medication
affects the body.
2
https://www.fda.gov/news-events/congressional-testimony/hemp-production-and-2018-farm-bill-07252019
http://www.usaig.com
http://www.usaig.com
https://www.aopa.org/training-and-safety/air-safety-institute
Premium on Safety - Issue 42 2021
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