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DOT COLLECTOR QUALIFICATION TRAINING and PROFICIENCY DEMONSTRATION (In accordance with 49 CFR Part 40). 6 th Annual FTA Drug & Alcohol Program National Conference St. Louis, MO April 5, 2011. FMCSA. FAA. FTA. PHMSA. FRA. USCG*. *HSA. COURSE MATERIALS.

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slide1

DOT COLLECTOR QUALIFICATION TRAININGandPROFICIENCY DEMONSTRATION(In accordance with 49 CFR Part 40)

6th Annual FTA Drug & Alcohol Program

National Conference

St. Louis, MO

April 5, 2011

slide2

FMCSA

FAA

FTA

PHMSA

FRA

USCG*

*HSA

course materials
COURSE MATERIALS
  • DOT 49 CFR Part 40 (revised effective 10/1/2010)
  • DOT Urine Specimen Collection Guidelines(revised effective 10/1/2010)
  • DOT Agency Rules (e.g., Part 655 for FTA)
  • DOT video on Collection Site Security & Integrity
  • Collector checklists (courtesy of Lorri Smith)
resources
RESOURCES
  • DOT - Office of Drug & Alcohol Policy & Compliancewww.dot.gov/ost/dapc(202) 366-3784
  • FTA - Drug & Alcoholhttp://transit-safety.fta.dot.gov/DrugAndAlcohol/default.aspx

(617) 494-6336

course objective
COURSE OBJECTIVE

To provide DOT urine specimen collectors with basic information and qualification training required under 49 CFR Part 40, and prepare them for the proficiency demonstration that will follow.

slide6

ASD

DER

IO

KSA

NOPE

ODAPC

OST

PIE

SVT

acronyms abbreviations
ACRONYMS &ABBREVIATIONS
  • CCF - Custody and Control Form
  • CDL - Commercial driver’s license
  • DAPM - Drug and Alcohol Program Manager
  • DER - Designated Employer Representative
  • DOT - Department of Transportation
  • GAO - Government Accountability Office
acronyms abbreviations cont d
ACRONYMS &ABBREVIATIONS (cont’d.)
  • HHS - Health and Human Services
  • MFR - Memorandum for the Record
  • MRO - Medical Review Officer
  • ODAPC - Office of Drug and Alcohol Policy Compliance
  • SAP - Substance Abuse Professional
  • SVT - Specimen validity testing
slide9

IMPORTANT TERMS/DEFINITIONS

  • Collector: A trained person who instructs and assists individuals at a collection site, who receives and makes an initial inspection of the urine specimens provided by those individuals, and who initiates and completes the Federal Drug Testing Custody and Control Form (CCF).
slide10

IMPORTANT TERMS/DEFINITIONS (cont’d.)

  • Adulteratedspecimen: A specimen that has been altered, as evidenced by test results showing either a substance that is not a normal constituent for that type of specimen or showing an abnormal concentration of an endogenous substance.
slide11

IMPORTANT TERMS/DEFINITIONS (cont’d.)

  • Dilutespecimen: A specimen with creatinine and specific gravity values that are lower than expected for human urine. The specimen is considered dilute when the creatinine is > than or = to 2 mg/dL but < than 20 mg/dL, and specific gravity is > than 1.0010 but < than 1.0030.
slide12

IMPORTANT TERMS/DEFINITIONS (cont’d.)

  • Invalid Drug Test: The result reported by an HHS-certified laboratory in accordance with the criteria established by HHS Mandatory Guidelines when a positive, negative, adulterated or substituted test result cannot be established for a specific drug or specific validity test.
slide13

IMPORTANT TERMS/DEFINITIONS (cont’d.)

  • Substitutedspecimen: A specimen with creatinine and specific gravity values that are so diminished or so divergent that they are not consistent with human urine. A specimen is considered to be substituted when the creatinine is < than 2 mg/dL, and the specific gravity is < than or = to 1.0010 or > than or = to 1.0200 on both the initial and confirmatory tests.
slide14

IMPORTANT EVENTS IN

2007-2008

  • News reports and other investigations have raised concerns about significant vulnerabilities in DOT’s drug testing program. (e.g. FOX 9 undercover investigations of five DOT collection sites in Minnesota).
slide15

IMPORTANT EVENTS IN

2007-2008 (cont’d)

  • Continuing use of products designed to “beat” the drug test brazenly marketed on the internet. (Examples: Whizzinator, Urinator, the Wedge)
  • Congressional hearings on challenges to establishing an effective drug testing program.
slide16

IMPORTANT EVENTS IN

2007-2008 (cont’d)

  • GAO undercover investigations (May - September 2007) of DOT collection sites around the country focused on the motor carrier industry
  • GAO released report to Congress on options to improve drug testing programs and better identify illegal drug users and keep them off the road (May 2008).
slide17

IMPORTANT EVENTS IN

2007-2008 (cont’d)

  • October 14, 2008: Federal prosecutors won a 19-count indictment against Puck Technology, maker of the Whizzinator and Number 1, and its owners (Gerald Wills and Robert Catalano) for fraud and selling drug paraphernalia.
slide18

IMPORTANT EVENTS IN

2007-2008 (cont’d)

  • November 24, 2008: Wills and Catalano pleaded guilty to one count of conspiracy to defraud the federal agency that administers federal workplace drug testing programs, and one count of conspiracy to sell drug paraphernalia.
slide19

Results of GAO Investigations

Applicable to all Transportation Modes

  • Lack of compliance with specimen collection protocols (22 out of 24 were not in compliance with some of the protocols)
  • Subversion of the drug test is possible
    • Small vials in socks or undergarments containing synthetic urine or drug-free urine
    • Use of adulterants
slide23

Results of GAO Investigations

Applicable to all Transportation Modes(cont’d)

  • Limitations to the test itself (DOT only tests for 5 illegal drugs)
  • Lack of disclosure of past positive drug tests
slide24

Options Identified by GAO(May 2008)

  • Providing and publicizing information regarding drug testing requirements through promotional materials, website, conferences
  • Increasing oversight and enforcement authority over service agents
slide25

Options Identified by GAO(May 2008) (cont’d)

  • Strengthening the enforcement of safety audits for new carriers (FMCSA)
  • Adopting federal legislation prohibiting the sale, manufacture, or use of drug testing subversion products
slide30

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slide32

Options Identified by GAO(May 2008) (cont’d)

  • Testing for additional illegal drugs or some prescription drugs
  • Developing a national database reporting requirement and authority to suspend a CDL for a positive drug test result or test refusal
slide33

2009 – 2010 UPDATES

  • DOT made available the Collection Site Security & Integrity poster and 10 Steps Video
  • H.R. 858 (Drug Testing Integrity Act of 2009) was introduced in Congress on 2/4/09
  • S. 3638 (Public Transportation Safety Act) was unanimously approved by the Senate Banking Committee on 6/29/10
  • DOT made revisions to 49 CFR Part 40 effective 10/1/2010
fta drug alcohol testing circumstances
FTA DRUG & ALCOHOL TESTING CIRCUMSTANCES
  • Pre-employment
  • Post-Accident
  • Reasonable Suspicion
  • Random
  • Return-to-Duty
  • Follow-up
dot drug panel
DOT DRUG PANEL

Confirmatoy Cut-off (ng/mL)

  • Marijuana 15
  • Cocaine 100*
  • Opiates

Morphine/Codeine 2000

6 –AM (heroin 10*

  • Amphetamines 250*

Methamphetamine 250*

MDMA, MDA, MDEA 250*

  • Phencyclidine (PCP) 25
drug testing process
DRUG TESTING PROCESS

Step 1 Employer orders test

Step 2: Collector collects urine specimen

Step 3 HHS laboratory analyzes urine sample provided by employee and confirms test result(s)

Step 4: MRO verifies lab test result

Step 5: Employer (through DER) receives verified test result and takes action, as necessary.

slide37

“THE COLLECTOR HAS A MAJOR ROLE IN THE SUCCESS OF THE DOT’S DRUG TESTING PROGRAM. THE COLLECTOR IS THE ONE INDIVIDUAL IN THE TESTING PROCESS WITH WHOM ALL EMPLOYEES HAVE DIRECT, FACE-TO-FACE CONTACT.”

Source: DOT Urine Specimen Collection Guidelines

authorized collection personnel
AUTHORIZED COLLECTION PERSONNEL
  • Only collectors meeting Part 40 training requirements can collect DOT specimens
  • No certification required by DOT; but collector must have documentation of training completed to show to DOT agency representatives (e.g., FTA auditors) and to employers and TPAs when requested
who may not serve as collectors
WHO MAY NOT SERVE AS COLLECTORS?
  • Immediate supervisor of the employee being tested
  • A safety-sensitive employee subject to DOT testing
  • An individual who works for a DHHS lab and can link the employee with a urine specimen, drug test result, or lab report
  • The employee himself/herself cannot collect his/her own specimen
  • Relatives, spouses, friends of the employee
collector training requirements
COLLECTOR TRAINING REQUIREMENTS
  • Basic Information: DOT Part 40, Urine Specimen Collection Guidelines, and applicable DOT agency regulations (e.g. Part 655)
  • Qualification training must include instruction on:
    • all steps necessary to correctly complete and transmit the Custody and Control Form (CCF)
    • problem collections (e.g. shy bladder, attempts to adulterate, insufficient volume, etc.)
collector training requirements cont d
COLLECTOR TRAINING REQUIREMENTS (cont’d.)
  • “fatal flaws” and “correctable flaws” and how to correct them
  • Responsibility for maintaining the integrity of the process; ensuring the privacy of the employee and the security of the specimen; and avoiding offensive or inappropriate conduct or comments
collector training requirements cont d42
COLLECTOR TRAINING REQUIREMENTS (cont’d.)
  • Initial Proficiency Demonstration
  • Refresher Training
  • Error Correction Training
proficiency demonstration
PROFICIENCY DEMONSTRATION
  • Consists of five consecutive error-free mock collections (two uneventful, one insufficient volume, one temperature out-of-range, and one refusal to sign the CCF and/or initial the seal)
  • Monitored and evaluated by a qualified collector who has demonstrated the necessary knowledge, skills and abilities
refresher training
REFRESHER TRAINING
  • At least every five years
  • Must include elements of Qualification Training and Proficiency Demonstration
slide45

ERROR CORRECTION TRAINING

  • Required after amistake that results in a canceled test.
  • Conducted within 30days of error notification
  • Covers only the subjectmatter area(s) where error(s) occurred
error correction training cont d
ERROR CORRECTION TRAINING (cont’d.)
  • Completion of three error-free mock collections including one uneventful scenario and two related to the subject area(s) where error(s) occurred
  • Training and proficiency demonstration to be monitored and documented by person providing training.
collection supplies
COLLECTION SUPPLIES
  • Collection kit (collection cup, specimen bottles, leak-resistant plastic bag, absorbent material, shipping container)
  • Federal Custody & Control Form (CCF)
  • Bluing or coloring agent
  • Single-use disposable gloves (recommended) Tamper-evident tape
  • Signs to prevent entry into the collection area (if necessary)
collection site requirements
COLLECTION SITE REQUIREMENTS
  • Must be secure at all times that collections are taking place
  • Must have all necessary personnel, materials, equipment, facilities, supervision, temporary storage of specimen, suitable clean surface for writing
  • Must have a facility for urination (e.g., restroom) that affords privacy. Can be a single-toilet restroom with a full length privacy door, or a multi-stall restroom with a partial length door
collection site requirements cont d
COLLECTION SITE REQUIREMENTS (cont’d.)
  • Must have a source of water for washing hands, preferably external to the restroom
  • Can be in a medical facility, a mobile facility (e.g., a van) a dedicated collection facility, or any other facility meeting above requirements.
slide51
The following appeared in the 3/3/08 Caledonian-Record of St. Johnsbury, VT

2/29/2008

Police: Man Gets Shot to Avoid Work

Associated Press

PASCO, Wash. (AP) - What happened to faking a cough? Sheriff's detectives in Franklin County said a man had his friend shoot him in the shoulder so he wouldn't have to go to work.

When he first spoke with deputies, Daniel Kuch, of Pasco, told them he'd been the victim of a drive-by shooting while he was out jogging Thursday.

But detectives told KONA radio that Kuch later acknowledged that he asked his friend to shoot him so he could get some time off work and avoid an upcoming drug test.

The friend, Kurtis Johnson, of Burbank, has been arrested for investigation of reckless endangerment.

Kuch was booked into the county jail and is expected to be charged with false reporting.

Detectives declined to say where Kuch works, or whether he still has a job.

It wasn't known if he had obtained a lawyer.

protecting security integrity of process
PROTECTING SECURITY & INTEGRITY OF PROCESS

Before EACH collection:

  • Secure all water sources. Tape or secure shut any movable toilet tank, or put bluing agent in the tank
  • Ensure that water in the toilet is blue
  • Ensure that no soap, disinfectants, cleaning agents, or other possible adulterants are present
protecting security integrity of process cont d
PROTECTING SECURITY & INTEGRITY OF PROCESS(cont’d.)

Before EACH collection (cont’d.):

  • Ensure that undetected access is not possible
  • Ensure that no foreign or unauthorized substances are present
  • Secure areas and items (ceiling tiles, trash cans, paper towel dispensers, under-sink areas, etc.) that can be used to hide contaminants

Re-check all of the above following EACH collection to ensure continued integrity

quality control measures cont d
QUALITY CONTROL MEASURES (cont’d.)
  • Restrict access to collection materials and specimens
  • If restroom is used for other purpose, post sign during collection process
  • Conduct only one collection at a time. If one employee is in a waiting period in a “shy bladder” situation, you may conduct a collection for another employee
  • Keep the collection container in yours and the employee’s view until the specimen is sealed
quality control measures cont d56
QUALITY CONTROL MEASURES (cont’d.)
  • Restrict handling of the specimen before it’s sealed to the collector and the employee
  • Maintain personal control over each specimen and CCF throughout the process. Collector must remain within the collection site
  • Implement a policy to prevent unauthorized personnel from entering any part of the site where specimens are collected or stored
preliminary steps
PRELIMINARY STEPS
  • Collector must notify the DER if employee is unreasonably late
  • Begin the testing process without undue delay. Example: Do not wait until the employee says he or she is ready to provide sample
  • If employee is at the site for both drug and alcohol tests, complete alcohol test first
  • If necessary, provide emergency medical attention prior to specimen collection
preliminary steps cont d
PRELIMINARY STEPS (cont’d.)
  • Do NOT collect by catheterization or by other means
  • Require employee to provide a photo ID issued by the employer or the government. Contact DER to verify identity of employee if he or she cannot produce positive ID
  • If employee asks, provide collector ID
  • Explain the basic collection procedure; showthe employee the instructions on the back ofthe CCF
preliminary steps cont d60
PRELIMINARY STEPS (cont’d.)
  • Ensure that the required info is provided at the top of the CCF (lab name and address and pre-printed specimen ID # which matches the ID # on the bottle seals)
  • Direct employee to remove outer clothing (including hats or head covering) that could be used to conceal items that could be used to tamper with a specimen. Must provide receipt when asked and allow employee option to keep wallet after inspection. Advise employee that failure to comply with your directions constitutes a test refusal
preliminary steps cont d61
PRELIMINARY STEPS (cont’d.)
  • Direct the employee to empty pockets and display contents. Use own judgment to determine whether or not a directly- observed collection is necessary.
  • Instruct employee not to list on the CCF medications he/she is currently taking,except on the back of his/her copy

(Copy 5).

before the employee provides the specimen
BEFORE THE EMPLOYEE PROVIDES THE SPECIMEN...
  • Complete Step 1 of the CCF. Eff. 10/1/10, must specify the federal testing authority, e.g. DOT-FTA.
  • Instruct employee to wash and dry his or her hands under collector’s observation. No further access to water until after specimen is presented.
  • Either the collector or the employee can select an individually wrapped collection container and unwrap in both individuals’ presence. Give the employee only the collection container
before the employee provides cont d
BEFORE THE EMPLOYEE PROVIDES…(cont’d.)
  • Direct employee to provide at least 45 mL of urine, NOT to flush the toilet, and return container to you
  • Collector may set a reasonable time limit for voiding ( 2 – 3 minutes)
  • Pay careful attention to the employee and note any conduct that clearly indicates an attempt to tamper with a specimen. If such a conduct is detected, enter in the “Remarks” line of the CCF and immediately require a directly-observed collection.
when the specimen is presented to the collector
WHEN THE SPECIMEN IS PRESENTED TO THE COLLECTOR…
  • Check the temperature within 4 minutes after employee presents the specimen
  • Check for sufficiency (at least 45 mL)
  • Check for signs of adulteration or substitution (Examples: color, odor, excessive foaming)
preparing the specimen
PREPARING THE SPECIMEN
  • Check the appropriate boxes on Step 2 of the CCF ( temperature, split specimen collection, and whether or not it was observed)
  • First pour 30 mL into the primary specimen bottle (Bottle A) and then 15 mL into the second bottle (Bottle B)
  • Place and secure the lids/caps on the bottles

(Step 3)

  • Seal the bottles by placing the tamper-evident seals over the caps and down the sides
preparing the specimen cont d
PREPARING THE SPECIMEN (cont’d.)
  • Discard any urine left over in the collection container after both bottles have been appropriately filled and sealed
  • Collector must write the date on the tamper-evident seals
  • Have the employeeinitial the seals
procedures for broken seals cont d
PROCEDURES FOR BROKEN SEALS (cont’d.)
  • If seals break while on CCF, transfer info to a new CCF and use seals from the second CCF
  • If seals break while on bottle, initiate a new CCF. Place new seals perpendicular to the original without obscuring info on the original seals; have employee initial both seals; draw a line through the specimen ID number and bar code on the original seals.
procedures for broken seals cont d68
PROCEDURES FOR BROKEN SEALS (cont’d.)
  • Provide comments in “Remarks” line on CCF
  • Destroy all copies of the original CCF
slide69

COMPLETING THE PROCESS

  • Direct employee to read and sign certification statement on Copy 2 (Step 5) of the CCF and provide date of birth, printed name and telephone numbers
  • Complete Step 4 of the CCF
  • Ensure that all copies of the CCF are legibleand complete
  • Remove Copy 5 and give to employee.
completing the process cont d
COMPLETING THE PROCESS (cont’d.)
  • Place the specimen bottles and Copy 1 of the CCF inside the appropriate pouches
  • Secure both pouches of the plastic bag
  • Advise the employee that he or she may leave at this time
shipping procedures
SHIPPING PROCEDURES
  • Place the sealed plastic bag in a shipping container designed to minimize the possibility of damage during shipment
  • Seal the container as appropriate
  • Send Copy 2 of the CCF to the MRO and Copy 4 to the DER within 24 hours or next business day. Keep Copy 3 for at least 30 days.
  • Ensure that each specimen collected is shipped to the lab ASAP, or within 24 hours or next business day
shipping procedures cont d
SHIPPING PROCEDURES (cont’d.)
  • While awaiting pick-up or shipment, ensure that the specimen containers are relatively secure and are not subject to damage, theft or other actions that could impact the integrity of the specimens.
drug test refusal cont d
DRUG TEST REFUSAL (cont’d.)
  • Failure to appear within a reasonable time after notification, as determined bythe employer. (Except pre-employment)
  • Failure to remain at the testing siteuntil the testing process iscomplete
  • Failure to provide a urinespecimen required by DOT or anyDOT agency
drug test refusal cont d76
DRUG TEST REFUSAL (cont’d.)
  • Failure to permit the observation or monitoring of specimen collection when it is required
  • Failure to provide a sufficient amount of urine without an adequate medical explanation for the failure
  • Failure or refusal to take a second test the employer or collector has directed the individual to take
drug test refusal cont d77
DRUG TEST REFUSAL (cont’d.)
  • Failure to undergo a medical evaluation as directed by the MRO as part of the verification process, or by the DER as part of the “shy bladder” procedures
  • Failure to cooperate with any part of thetesting process
  • If the MRO reports a verified
  • adulterated or substituted testresult.
drug test refusal cont d78
DRUG TEST REFUSAL (cont’d.)
  • For an observed collection, failure to follow the observer’s instructions to raise clothing above the waist, lower clothing and underpants, and to turn around to permit the observer to determine if donor is wearing a prosthetic or any device that could be used to interfere with the collection process.
drug test refusal cont d79
DRUG TEST REFUSAL (cont’d.)
  • Possession or wearing of a prosthetic or other device that could be used to interfere with the collection process
  • Admitting adulteration or substitution of the specimen to the collector or the MRO
drug test refusal cont d80
DRUG TEST REFUSAL (cont’d.)
  • Leaving the scene of the accident without just cause prior to submitting to a test

Note: A test refusal carries the same consequences as a positive test and depending on the employer policy, it may result in employee termination

insufficient volume aka shy bladder cont d
INSUFFICIENT VOLUME (aka “SHY BLADDER” – cont’d.)
  • Discard the insufficient sample (unless it is also

out of temp range)

  • Explain to employee the

“shy bladder” process and

urge employee to drink upto 40 ounces of fluids within3 hours. If employee refusesto complete the test, this is arefusal. Immediately notifythe DER.

insufficient volume aka shy bladder cont d82
INSUFFICIENT VOLUME (aka “SHY BLADDER” – cont’d.)
  • Document time of attempts, quantity of specimen provided and amount of fluids consumed
  • In pre-employment and return-to-duty situations where the individual must have a verified negative test result and the individual has a legitimate medical condition for the inability, the physician may use alternative testing methods, including, but not limited to blood testing, to determine any clinical evidence of drug abuse
insufficient volume aka shy bladder cont d83
INSUFFICIENT VOLUME (aka “SHY BLADDER” – cont’d.)
  • Employee must be monitored during the waiting period and not be allowed to leave the collection site
  • If employee is unable to provide sufficient sample within 3 hours of the first attempt, discontinue the process, and note it on the “Remarks” line of the CCF and immediately notify the DER. If none was provided, check the appropriate box under Step 2.
insufficient volume aka shy bladder cont d84
INSUFFICIENT VOLUME (aka “SHY BLADDER” – cont’d.)
  • Send/fax Copy 2 of the CCF to the MRO and Copy 4 to the DER to notify them of the problem within 24 hours
  • Within 5 days, DER must refer employee to an examining physician acceptable to the MRO. The physician will provide his/her written recommendations to the MRO, who will, in turn, report his/her determination to the DER in writing.
temperature out of normal range 90 100 f
TEMPERATURE OUT OF NORMAL RANGE (90 – 100 F)
  • Check the “No” box under Step 2 of the CCF and note it in the “Remarks” line
  • Complete the collection process for the first specimen and immediately begin a second collection under direct observation. Use a new CCF and a new collection kit
  • On the CCFs, cross reference the two collections (e.g., 1st of 2 or 2nd of two, the specimen ID numbers, reason for 2nd collection, and that it was observed)
temperature out of range
TEMPERATURE OUT OF RANGE…..
  • Send both specimens to the lab
  • Inform the collection site supervisor and the DER that a collection took place under direct observation and the reason for doing so

NOTE: Do NOT introduce any other object (e.g., litmus paper, testing strip, etc.) into the collection container or specimen bottles

catheterization
CATHETERIZATION
  • Not authorized by DOT unless employee normally voids through self-catheterization
  • Not authorized from an unconscious employee
external urine bag
EXTERNAL URINE BAG
  • Urine specimen should be freshly voided
  • Instruct employee to empty the bag in the privacy of a bathroom, show the empty bag to the collector, drink sufficient fluids to provide 45 mL of urine, and pour the specimen from the bag into the collection container in the privacy of the bathroom
adulteration or substitution
ADULTERATION OR SUBSTITUTION
  • If signs of tampering or substitution is apparent, immediately conduct a second collection under direct observation
  • Send both specimens to the laboratory for testing
  • If specimen shows sign of tampering, the 1st specimen is always sent to the lab even though it may have had an insufficient volume
directly observed collections
DIRECTLY-OBSERVED COLLECTIONS
  • Previous specimen was invalid and there was no adequate medical explanation. (E)
  • Previous collection was verified positive, adulterated or substituted, but the test had to be canceled because the split specimen test could not be performed. (E)
  • Previous specimen was negative-dilute with creatinine level between 2 – 5 mg/dL.(E)
  • If test is a Return-to-Duty or Follow-up. (E)
directly observed collections cont d
DIRECTLY-OBSERVED COLLECTIONS (cont’d)
  • Collector observed materials or conduct clearly indicating an attempt to tamper with a specimen. (C)
  • Temperature was out of range. (C)

Note: Refusal by the employee to have the specimen collection directly-observed when required by either the employer or the collector is a refusal to test.

general rules
GENERAL RULES
  • Collector or employer must explain to employee the reason for direct observation
  • Observer must be the same gender, but need not be a trained collector. If other than the collector, write observer’s name on the “Remarks” line of the CCF.
  • Complete a new CCF; mark the reason for test (same as first); check “Observed” box (Step 2); enter the reason in “Remarks” line and cross-reference the two specimens.
general rules cont d
GENERAL RULES (cont’d.)
  • Prior to specimen collection, observer must request the donor to raise his/her shirt, blouse, or dress/skirt, as appropriate, above the waist, lower clothing and underpants to about mid-thigh, and to turn around to show that he/she is not wearing a prosthetic or other device that could be used to interfere with the collection process
  • Observer must view the urine stream from the employee to the collection container
monitored collections
MONITORED COLLECTIONS
  • If a multi-stall restroom is used
  • Use of an opposite-gender monitor is allowed as long ashe/she is a medical professional
  • Should be same gender as theemployee if monitor is not amedical professional
  • Must not watch the employee void into the collection container
  • Refusal by employee to be monitored is a refusal to test
fatal flaws in drug testing
“FATAL FLAWS” IN DRUG TESTING
  • No printed collector’s name and no collector’s signature
  • The specimen ID numbers on the specimen bottle and the CCF do NOT match
  • The specimen bottle seal is broken or shows evidence of tampering and the split specimen cannot be redesignated
  • There is an insufficient amount of urine in the primary specimen bottle because of leakage or other causes
problems that result in canceled tests
PROBLEMS THAT RESULT IN CANCELED TESTS
  • The lab reports an “Invalid Result”
  • The lab reports the result as “Rejected for Testing”
  • The lab reports that the split specimen failed to reconfirm all of the primary specimen results because the drug(s)/drug metabolites) were not detected; adulteration criteria were not met; and/or substitution criteria were not met
problems that result in canceled tests cont d
PROBLEMS THAT RESULT IN CANCELED TESTS (cont’d.)
  • The lab reports that the split specimen failed to reconfirm all of the primary specimen results, and the split specimen was invalid.
  • The lab reports that the split specimen failed to reconfirm the primary specimen results because the split specimen was unavailable for testing.
problems that result in canceled tests cont d98
PROBLEMS THAT RESULT IN CANCELED TESTS (cont’d.)
  • The examining physician has determined that there is an acceptable medical explanation for the employee’s failure to provide a sufficient amount of urine
correctable flaws cont d
CORRECTABLE FLAWS (cont’d.)
  • The collector’s signature or printed name is omitted on the certification statement on the CCF
  • The specimen temperature was not checked and the “Remarks” line did not have any entry regarding the temperature being out of range
  • The employee’s signature is omitted from the CCF, unless refusal to sign is noted on the “Remarks” line
correctable flaws cont d100
CORRECTABLE FLAWS (cont’d.)
  • The certifying scientist’s signature is omitted on the laboratory copy of the CCF for a positive, adulterated, substituted, or invalid test result
  • The collector uses a non-Federal form or an expired Federal form for a DOT test
correcting drug test problems
CORRECTING DRUG TEST PROBLEMS…
  • Regarding use of a non-Federal form or expired Federal form: Provide a signed statement (MFR) stating that the incorrect form contains all the information needed for a valid DOT drug test, and that the incorrect form was used inadvertently or as the only means to conduct a test, in circumstances beyond your control. List steps taken to correct the problem. Transmit the info to the lab on the same business day by fax or courier. Keep documentation of correction with CCF. (See Section 40.205(b)(2)).
correcting drug test problems cont d
CORRECTING DRUG TEST PROBLEMS… (cont’d.)

Make it obvious on the face of the CCF that you have corrected the flaw.

  • If problem concerns omission of required info: Supply missing info in writing and a statement that it is true and accurate. Do this on the same business day you were notified of the problem and transmit the info by fax or courier.
  • Take all actions necessary to correct the problem. If correction does not take place, MRO must cancel the test.
effect of a cancelled drug test
EFFECT OF A CANCELLED DRUG TEST
  • It is neither positive nor negative.
  • Employer must not attach to the cancelled test the consequences of a positive test or other DOT drug testing violation (e.g., removal from S/S position)
  • Unless directed by the MRO, employer must not require employee to undergo recollection
effect of a cancelled drug test cont d
EFFECT OF A CANCELLED DRUG TEST (cont’d.)
  • Does not count toward compliance with DOT requirements (e.g., being applied toward the minimum random testing rate)
  • Does not provide a valid basis for an employerto conduct a non-DOT test ( i.e., a test under company authority)
procedural problems that do not result in cancellation
PROCEDURAL PROBLEMS THAT DO NOT RESULT IN CANCELLATION...

Any error that does not affect employee protections under Part 40, but may subject collector to DOT enforcement action. Examples are:

  • A delay in the collection process
  • Transposition of the social security numbers
  • Failure to directly observe or monitor a collection
  • Name of the courier omitted on the CCF