Comment from Philip Kemp

Philip KempOtherIndividual
Summary: The commenter, who has experience working with county, state, and federal postmortem toxicology laboratories, highlights the technical challenges of data compatibility between different Laboratory Information Management Systems (LIMS). They argue that the variety of systems used by different agencies could create a significant barrier to electronic submission of toxicology data.
The comments thus far have stressed the burdens of funding, staffing, and training that will facilitate the obtaining and testing the biological samples from fatal drug impaired driving cases. These are indeed valid concerns and should be addressed per commenters' recommendations. My contribution has to do with confidentiality. During my time with county, state, and federal postmortem toxicology laboratories, the release of toxicology data carries with it the burden to secure the transfer of data from agency to agency. Depending on their funding capacity of the laboratory, different agencies across the country use different means to generate and store data. A variety of Laboratory Information Management Systems (LIMS) systems are used with differing platforms. This issue may be a significant barrier with so many forms of electronic submission. I am sure this barrier can be overcome with the sophisticated systems available today. However, it may hinder submission by a significant number of offices who have data management methods incompatible with the receiving system.

View on Regulations.gov