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DOT Urine Collection and Breath Alcohol Testing ProceduresMock Demonstrations and Review of Recent Applicable Rule Changes
Presented by Tiffany Ellefson
2010 UpdatesAlcohol Testing Form (ATF) was
updated◦Technical amendment published Feb.
25, 2010 authorizes use of updated form.
◦Initially, Aug. 1, 2010 was published as the last date to use the old form but it was changed to Jan. 1, 2011.
◦What was changed? Paperwork Reduction Act Burden
Statement on back of Copy1 & 2 Instructions on back of Copy 3
ATF Update – Back of Copy 1&2
ATF Update – Back of Copy 3
2010 UpdatesFederal Custody and Control
Form (CCF) was updated!!DOT authorized the use of the
new form starting Oct. 1, 2010Old forms can be used up to
Sept. 30, 2011After Sept. 30, 2011, if the old
form is used in error, it will be a correctable flaw.
What changed on the CCF?In Step 1, Federal testing
authorities are noted including all of the DOT agencies◦Collectors are required to mark the
agency who is authorizing the testing
In Step 5A (copy 1), new drug analytes and clarifying drug analytes were added◦MDMA, MDA, MDEA (Ecstasy)◦∆9-THCA (Marijuana metabolite)◦BZE (Cocaine metabolite)
What changed on the CCF?In Step 6 (copy 2), line added for
MRO to write on, new line item “other” for refusal to test situations
In Step 7 (copy 2), box was added for MRO to check if the split specimen reported as cancelled
Backside of Copy 5 (Donor Copy), instructions were revised for completing CCF
New CCF
2010 Updates§40.14 What collection information
must employers provide to collectors? (NEW!)
Employers must ensure that the collector has the following information for a drug test:◦Employee’s Full name and SSN/ID◦DER information◦Test reason◦Whether the collection needs to be
observed or not…
§40.14 ContinuedThe following information is also
required but can be pre-printed on the CCF:◦Lab name & address◦Employer name, address, phone & FAX◦MRO name, address, phone & FAX◦DOT agency which regulates the
employee’s duties◦Optional: C/TPA name, address, phone
& FAX
2010 UpdateEffective Oct 1, 2010, the drug
testing panel was updated:◦MDMA, MDA, MDEA (Ecstasy) added◦Screening test of 6-AM (Heroin
metabolite) added◦Cutoff levels for cocaine and
amphetamines were lowered
DOT Urine Collection ProcessDOT Urine Specimen Collection
Guidelines – updated 10/1/2010“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.”
The CollectorPart 40 defines a collector as a
trained person who instructs and assists employees at a collection site, who receives and makes an initial inspection of the urine specimen provided by those employees, and who initiates and completes the Federal Drug Testing Custody and Control Form (CCF).
Collector’s TrainingDOT does not provide or require
a “certification” but collector must meet training requirements:◦Basic Information◦Qualification training◦Initial proficiency demonstration
(mock collections)◦Refresher training◦Error Correction Training
The Collection SiteTwo types: single toilet restroom
and multi-stall restroomSite must have:
◦Restroom or stall with toilet◦Source of water to wash hands ◦Suitable clean surface for area to
complete paperwork and collection steps
Collector must secure water sources and other possible adulterants
Security of Collection SitePrevent unauthorized access to site
during collectionPrevent employee or any other person
from gaining unauthorized access to collection materials/supplies
Ensure that all authorized person are under supervision of collector or site personnel
Provide for secure handling and storage of specimens
Security and Integrity
Security and Integrity
Collection SuppliesCollection kitFederal Drug Testing Custody and
Control Form (CCF)Bluing agent to add to toilet
bowl/water tankSingle use disposable gloves are
recommendedTamper-evident tape for securing
faucets, toilet tanks, etc. and signs to prevent entry to collection area
Collection StepsEmployee reports for testCollector verifies identity - photo ID
◦Acceptable methods vs. Unacceptable methods
Collector explains basic collection procedures to employee◦Ex. Backside of CCF (copy 5), posters
displayed at site, checklists used by collector
Collector reviews CCF and completes Step 1
Pre-collection stepsCollector directs the
employee to remove unnecessary outer garments
Collector directs the employee to empty pockets and display items
Collector directs the employee to wash and dry their hands
Instructions to employeeCollector must inspect the restroom before
(& after) every specimen collectionThe collector gives a collection kit to the
employee or the employee is allowed to select a kit
Collection kit is opened in the presence of both collector and employee
Collector directs the employee to go into restroom, provide a specimen of at least 45 mL, do not flush the toilet and return the specimen to the collector as soon as possible
Post collection stepsCollector accepts specimen from
employeeCollector must check the
following:◦Temperature of specimen – within 4
minutes◦Specimen volume – 45 mL◦Signs of adulteration/substitution
Collector completes Step 2 of CCF
Accepting/securing specimenCollector will open specimen
bottlesCollector will pour 30 mL into one
specimen bottle (primary/A) then at least 15 mL into other specimen bottle (split/B)
Sealing specimen bottlesCollector will remove seals from
CCF and place on appropriate bottles
Collector will date each sealCollector will direct the employee
to sign their initials on each seal
Completing collectionCollector directs the employee to
read, sign, and date certification statement in Step 5 of Copy 2
Collector completes Step 4 of Copy 1 – printing & signing their name, noting time, date, and courier
Completing collectionCollector reviews CCF then provides
Copy 5 to the employeeCollector places specimen bottles and
Copy 1 in leak-resistant plastic bagCollector dismisses employeeCollector prepares specimen for
shipment to the laboratory◦Must ship within 24 hrs or next business
day◦Must secure specimens prior to pickup by
courier
Distributing paperworkCollector sends Copy 2 to the
MRO and Copy 4 to the DER(usually by FAX)
Collector must retain Copy 3 for at least 30 days
Shy Bladder ProtocolOccurs when employee isn’t able
to provide 45 mL on initial attempt
Employee will be allowed up to 3 hours to provide a valid specimen
Employee will be allowed to drink up to 40 oz of fluids – must be monitored
If unable to provide after 3 hrs, next step will be a medical evaluation
Direct Observation Collections
Collections under direct observation are required when:◦Temperature out of range◦Specimen shows signs of tampering◦Collector finds item intended for
adulterating or substituting specimen◦Directed by MRO◦Test reasons are Return to duty and
Follow-upsSpecific protocol – lift, lower, turn
around
Refusal to test (involving collector)Failure to report for required testFailure to remain at the collection
site until testing process is completed
Failure to allow a direct observed collection or monitored collection
Failure to cooperate with the testing process – ex. Refuse to empty pockets, fail to wash hands, behave in a confrontational manner
Refusal to test continuedFor a direct observed collection,
failure to follow collector’s instructions
Possessing or wearing a prosthetic or other device that could be used to interfere with testing process
Admission to collector (or MRO) that employee adulterated or substituted specimen
Beating the drug testThree common methods:
◦Dilution – adding water (less common) or drinking large quantities of fluids (more common)
◦Adding adulterant to specimen – designed to breakdown drug metabolites or interfere with laboratory instruments
◦Substituting a “clean” specimen
DOT Alcohol TestingWho can conduct an alcohol test?
◦STT – Screening Test Technician◦BAT – Breath Alcohol Technician◦Both have training requirements –
same as collectorWhat instruments can be used?
◦ASD – Alcohol Screening Devices◦EBT – Evidential Breath Tester◦Must be on NHTSA CPL (Conforming
Products List)
Testing StepsEmployee provides IDExplain testing proceduresTechnician completes step 1 of
Alcohol Testing Form (ATF)Employee signs Step 2 of ATFTechnician performs alcohol test
(individual steps will vary depending on device utilized)
Testing Steps continuedIf screening test results indicate
reading:◦<0.02 - test is negative (no further
testing needed)◦>=0.02 – Confirmation test is
required If negative, technician completes
Step 3 then provides employee their copy of ATF
If confirmation required, technician provides instructions to the employee
Confirmation Alcohol testingMust be completed with an EBTMust be completed within 15 – 30
minutes of the screening testIf confirmation test result reading is:
◦<0.02 – negative test◦0.02 – 0.039 – removal from duty◦>0.04 – positive test
Technician will sign & complete Step 3Employee will be instructed to sign
Step 4 if result is greater than 0.02
Refusal to test In addition to the applicable ones
described in the collection section, if the employee refuses to sign Step 2 of the ATF, this will be a refusal to test.
Problems in alcohol testingShy Breath – unable to provide
sufficient breath (or saliva) sample for testing◦Employee will be directed for a
medical evaluationCalibration of instrumentsAvailability of trained BATs/STTs
Questions…Contact Information
Tiffany Ellefson, Vice PresidentMidwest Toxicology Services, Inc.603 E Washington St, Ste 200Indianapolis, IN 46204
tiffany.ellefson@midwesttox.com317/262-2205 (office)317/501-1617 (cell)