Comment from Martha Deering

I served as a DOT SAP from 2004-2026, only recently relinquishing that credential due to my age. However, my interest in retaining as many safety measures as possible for all administrations under the DOT remains an important issue to me. I am concerned about the proposed changes to The Food and Drug Administration (FDA)'s announcement on its intent to remove the 510(k) Clearance requirement for federally regulated drug testing programs. Before relinquishing my DOT SAP credential, the majority of the cases I handled involved cannabis and drivers, most of whom were school bus drivers. In addition, we continue to have serious and often deadly crashes/accidents involving vehicles of the FAA, FMCSA, PHMSA, FRA, FTA, and to a lesser extent the USCG. In my work, I often found non-DOT companies utilizing drug testing services that were poorly administered and often ended with seriously deficient results. Removing the 501(k) requirement opens up DOT administrations to this type of poor, deficient and dangerous testing, allowing individuals with substance problems to continue to be a danger to the public. I strongly recommend that this requirement remain and even be strengthened to be able to identify newer drugs and identify false positives from appropriately prescribed and used medications. In conclusion, I strongly recommend retaining the 501(k) requirement in order to maintain and hopefully increase safety.