While not personally affected by the EtG/EtS test have been researching for about three years.

It is my advice that there is renewed federal interest in EtG testing. Currently being reviewed for further action by SAMHSA (nothing published yet). A meeting was held in March this year.

Accordingly, I am filing a complaint through CLIA (initially against 3 labs) with the assistance of both my Senators and Congressman via introduction and follow up.

The labs subject of my public interest complaint carry a CLIA certification but have never been inspected by the agency. The office defers to a secondary accreditation agency i.e. CAP or one of 5 others. CLIA however must perform an inspection upon receipt of a complaint and report back to complainant on the results. The involvement of the elected officials places them in the response CLIA must also report back to them. The complaint is directed against EtG/EtS testing with focus on the reliability of same with specific emphasis on the instability of the metabolites in urine post-collection.

Per information of San Francisco Regional Office CLIA, EtG testing was mis-classified in their computer system as "forensic" therefore not within their jurisdiction. That issue has been clarified as the test is lab based, high complexity, used in diagnostics and squarely within the responsibilities of their office. The classification will be changed. I believe this may have led to complainants being turned away. As example the office of Drug Free Workplace receives many complaints on EtG but that office neither uses the test nor is empowered to act on same.

Have also spoken with the office of Chemistry and Toxicology, FDA. There are components of the initial screen, immunoassay, I believe should be FDA regulated and are not. We'll see. For some reason this office has high interest in EtG testing though currently lack jurisdiction.

I have also requested the federal legislators ask HHS to explain how they issue Advisory against use of the test through one of their subordinate divisions and CLIA another subordinate division of HHS fails to make any effort to supervise use of same.

Amazingly, I have spoken with 21 CLIA representatives in 5 separate offices with responsibility for lab supervision. Not a single one even knew what EtG testing was. Grocery clerks have better knowledge.

It is my understanding primarily through inside information that HHS is attempting to bring this test under federal supervision. That would mean it would be subject to all of the rules and regulations as currently apply to DOT testing or more likely, the end of EtG tests.