68
FOGHORN
The bottleneck has been the Food 
and 
Drug 
Administration(FDA). 
Its 510(k) medical device clearance 
requirement was built for hospital 
diagnostic equipment, and it has 
blocked the laboratory infrastructure 
that federal drug testing programs 
need. This spring the FDA finally 
moved. On May 1, it published a 
Notice of Intent at Docket No. FDA-
2026-N-4268 to exempt these devices 
from the 510(k) requirement. On June 
29, I signed PVA’s formal comments 
backing the proposal and pushing 
FDA to finish the job: cover the full 
federal testing panel including PCP, 
cover the oral fluid collection devices 
themselves, make existing inventory 
usable immediately, exercise enforce-
ment discretion in the interim, and 
formally recognize SAMHSA and the 
National Laboratory Certification 
Program as the governing authorities 
for this forensic testing framework. 
The American Waterways Operators 
filed parallel comments the next day. 
FDA faces a statutory 120-day dead-
line, so a final determination is due by 
the end of August.
One more point. This is a deregu-
latory initiative. We are asking the 
federal government to eliminate a du-
plicative clearance requirement that 
forces manufacturers to prove device 
performance twice, to two different 
agencies, under a framework never 
designed for workplace drug testing. 
PVA will always push for less regu-
lation and more operator flexibility. 
This effort fits squarely within the 
administration’s own regulatory re-
form agenda.
The federal government has already 
decided that oral fluid testing is sci-
entifically valid. Our job is to make 
sure the last barrier comes down. If 
outdated testing rules have cost you a 
good candidate, tell us. Those stories 
are the most persuasive advocacy we 
have, and PVA’s Legislative Commit-
tee will continue to advocate for this 
member flexibility. 
Safe sailing.
Sincerely,
Andrew Sargis
PVA President, 2026
Continued from page 4: Letter from the President
AT THE HELM

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