MISTAKES PEOPLE MAKE BY: JOE REILLY, JOE REILLY & ASSOCIATES, INC.
This is the fourth of a series of articles that will highlight actual mistakes that occur during the process of workplace drug & alcohol testing. The intent of these articles is to alert folks as to the importance of taking the time to perform drug and alcohol testing services correctly and without flaws. Of course proper training and consistent re-training is the key to preventing the mistakes that are discussed.
of Transportation (DOT) drug test collections were not adhering to the proper DOT collection protocols. Te U.S. Government Accountability Office (GAO) was asked to perform an undercover operation to determine whether (1) urine collectors followed DOT protocols at selected collection sites and (2) commercially available products could be used to defeat drug tests. Twenty-two of the twenty-four selected urine collection sites did not adequately follow the DOT collection protocols. Additionally, it was found that cheating was in fact very possible at the majority of these sites. As a result of the media exposure and
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GAO findings in 1997, DOT asked the industry to pay more atention to the training requirements and protocols for drug test collections. With a major emphasis on prevention of cheating on the drug test; DOT produced training tools for the industry—a poster and a video entitled “DOT’s 10 Steps to Collection Site Security and Integrity”
Best Practices to Avoid these Mistakes
1. Collectors should review all copies of the CCF prior to distributing them to ensure that they are legible. In regards to copies that are to be faxed, if the writing is light then collectors should make a darker copy to be sent via fax.
2. Always fax MRO and Employer copies immediately after collection or no later than the end of the business day.
3. When faxing copies of CCFs, maintain a copy of the fax transmittal form with the CCF.
4. Post a notice in the collection site regarding the new step 1D on the CCF to indicate the transportation mode that the collection is for.
5. Post a notice that specimen bottle labels not to be dated or initialed until the labels are on the bottles.
6. Use remarks line to indicate donors are informed of consequences of leaving the collection site (a refusal).
38 datia focus
ack in 1997 media accounts indicated that some collection sites performing Department
both available on the web site of the Office of Drug & Alcohol Policy & Compliance (ODAPC)—
www.dot.gov/odapc/. Four years later, mistakes continue to
occur in the collection process. Millions of drug test collections are performed each year; many by well trained collectors without error. But many are also performed by collectors who have not kept up with required DOT training for DOT urine drug test collections. Recently, DOT again emphasized
that many collectors and collection sites continue to make mistakes and errors during the collection process. Here is a listing of some of the recent errors pointed out by DOT officials with DATIA’s suggestions on how to avoid these errors: Custody and Control Forms (CCFs)
received are illegible. Collectors should review all copies of the CCF prior to distributing them to ensure that they are legible. In regards to copies that are to be faxed, if the writing is light then collectors should make a darker copy to be sent via fax. MROs and Employers are reporting
that they are not receiving their respective copies of the CCFs despite multiple requests. Per DOT regulations, collectors must send the CCFs within 24 hours or the next business day and must keep their copies of CCFs for at least 30 days. Collectors are not marking step 1D in
the CCF to indicate the transportation mode that the collection is for (FAA, FR, FTA, FMCSA, etc.). Tis is a new step for the CCF and collection sites should be sure to post notices within the collection area reminding collectors to mark this information on the CCF. Te donor initialing of the specimen
botle labels is being done while the labels are on the CCF contrary to DOT regulations that require the labels be signed on the specimen botle. Collectors are not adequately informing
donors that leaving the collection site prior to the completion of the collection
winter 2012
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