So what are we finding on current Government
Accountability Office (GAO) 2007 Undercover Investigation Findings
75%
67% 42%
19% 17%
10
failed to restrict access to items that could be used
to adulterate or dilute the urine specimen; individuals had ac- cess to soap, air freshener, and other potential adulterants in the privacy enclosure.
had access to run- ning water in the privacy enclosure.
failed to ask the employee to empty his/her pockets and
display items to ensure no items were present that could be used to adulterate the specimen. The GAO Investigators brought drug masking agents and synthetic urine (bought over the Internet) into the collection sites and mixed them with their specimen without being detected by trained collec- tion site personnel.
failed to check the temperature of the specimen.
failed to add bluing agent in the toilet water or secure the
tank with tape.
Source:
http://www.gao.gov/products/ GAO-08-225T
audits? You might be surprised at some of these findings. • Very commonly, prior to the collection, the collector fails to explain collection procedures or show the instructions on the back of the CCF. It is important to review 49 CFR Part 40 Section 40.61 with your collectors—(e) Explain the basic collection procedure to the employee, including showing the employee the instruc- tions on the back of the CCF.
• A collector becomes familiar with the donor aſter 12 follow up tests and neglects to check the donor’s ID. In ad- dition the procedures for direct observa- tion are not followed properly. Familiar- ity does not grant the collector a pass to not follow strict collection procedures. Always perform the collection the same way every time with every donor.
• A collector throws away the first temper- ature out-of-range specimen and all pa- perwork when a frustrated donor leaves stating “I don’t have time for this” in the face of the Shy Bladder process. Tis, of course, is a major issue because now there is no documentation of anything that occurred. Te correct process would be for the collector to retain the CCF paperwork with complete documenta- tion of what happened, distributing the Medical Review Officer (MRO) Copy and employer copy to the MRO and to the employer. With only one specimen collected that is out-of-temperature range, nothing would be sent to the lab.
• In another temperature out-of-range situation, the collector starts the second collection process immediately aſter re- ceiving the first specimen. Upon receiving the second specimen, the collector pours off the specimen into the four speci- men vials and fills out the Custody and Control forms (CCF) simultaneously. Of course what happens is that the specimen seals are put on the incorrect botles and at the lab the specimen ID numbers on
datia focus
the botles do not match the specimen ID numbers on the CCF forms.
• Te practice of altering a form when the correct form is not available seems to come up oſten in our audits. Some collectors think that the Department of Transportation (DOT) does not allow the form to be altered. 49 CFR Part 40 Section 40.45 clearly states that you can. Other collectors, when altering forms, do not alter the forms properly. DOT is clear that when the collector has no “blank” CCFs and the CCFs on-hand contain inaccurate pre-printed employer, MRO, collection site, and/or laboratory information, the collector is permited to “line through” the inaccurate infor- mation and insert legibly the proper information. I always advise collectors to be as neat as possible when altering a form and provide the correct account number for the test. Te collector should also “line through” barcodes on the form so that at the laboratory the new printed information is utilized.
• Pre-filling out the CCF was very common in our auditing as well. Collectors like to pre-date the specimen security seals, pre- print the collector name, date and time on Step 4; and in some cases pre-sign on Step 4. In one large mobile collection event I audited, the two collectors handed out the CCF forms to 35 donors and asked them to initial the specimen security seals and complete Step 5 in its entirety. I cannot tell you how messed up this collection became with 4 fatal flaws and 12 correctable errors.
• Several audits revealed collection sites that do not properly secure the bath- room to be used for the collection. Some sites have made a half-hearted atempt at this with partial security and integrity measures, and some simply do not make any atempt at all. One collector used bleach as the bluing agent for the toilet. I always highly recommend the DOT 10 Steps to Collection Site Security and Integrity Video and the DOT 10 Steps
summer 2014
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