Agency Information Collection Activities; Proposals, Submissions, and Approvals: Barriers and Solutions for Submitting Toxicology Data to the Fatality Analysis Reporting System Pursuant to Recommendationsfor Toxicological Investigation of Drug-Impaired Driving and Motor Vehicle Fatalities

The National Safety Council (NSC) supports the proposed action to address barriers in submitting toxicology data for drug-impaired driving investigations. They argue that improving data collection is critical for roadway safety, addressing the drug overdose epidemic, and providing a holistic view of the DUID problem.

The National Association of Mutual Insurance Companies (NAMIC) expresses support for federal and state efforts to identify and treat alcohol- and drug-impaired drivers. They advocate for funding for innovative countermeasures, such as expanding toxicology lab capacities and promoting safe driving programs and consumer education.

A representative from the Idaho Transportation Department (ITD) supports the initiative to improve toxicology data submission by identifying state-level statutory barriers and suggesting ways to streamline sample collection. They also propose creating a shared database of validated testing methods to help other laboratories meet the federal recommendations for tier II drugs.

The commenter highlights significant barriers to toxicology testing, including a lack of standardized procedures, insufficient funding for forensic labs, and a lack of integration with the criminal justice system. They argue for a standardized model similar to DNA testing, the adoption of existing National Safety Council recommendations, and the implementation of legislation to mandate consistent sample collection and testing standards.

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 Washington State Toxicology Coordinator (WTSC) supports the proposed action but argues that the current FARS system is over-comprehensive and lacks specific fields for drug levels and screening vs. confirmatory results. They recommend aligning the FARS drug list with the 2021 Update Tier 1 and 2 recommendations and specifically request the inclusion of cannabinoid levels and screening indicators.

The commenter provides a list of recommended focus areas for improving drug-impaired driving investigations. They suggest funding for testing devices, training, salary increases for toxicologists, and procedural improvements like electronic warrants and consolidated court days.

The commenter identifies several logistical and systemic barriers to submitting toxicology data, including BAA restrictions on equipment, staffing shortages, and the difficulty of validating comprehensive testing panels. They do not explicitly state a position for or against the proposed action, but rather provide a list of challenges related to the topic.

The commenter, who works in a major metro area, argues that current barriers to collecting toxicology data are significant due to lack of statutory requirements, funding, and training. They support the proposed action by advocating for mandates on sample collection, increased lab funding, and specific training for coroners and law enforcement.