to Collection Site Security and Integrity poster. Both are available from DOT at
www.dot.gov/odapc and both are excel- lent tools to help a facility learn how to properly secure a restroom for a DOT urine specimen collection.
• Lastly, some alcohol testing collection sites did not have an evidential breath al- cohol testing device on hand. An instant alcohol test device was used and when tested positive (with mouthwash); there was no mechanism for the collection site to perform the required confirmation testing. Tis was really a disaster as the collection site sent me on my way in my car aſter their knowledge that I was at a .09 alcohol level. Tey were lost as to how to properly arrange for the required confirmation testing. As mentioned, the incorrect practice of
filling out Step 4 of the CCF prior to starting the collection and pre-dating the security seals is still common in the specimen collec- tion industry. Tere are no shortcuts in the collection process; shortcuts lead to errors. Te steps of the collection process should be followed in order; and, remember, the DOT specimen collection order is 1, 2, 3, 5, and 4. If the steps are filled out properly, and in order, the percentage of mistakes that occur declines significantly. It is important to take your time with a collection and not take shortcuts; tak- ing your time leads to perfect collections. Te Federal Transit Administration
(FTA) is particularly aggressive on collec- tion audits. FTA maintains a full-fledged clandestine collection site inspection pro- gram. Reports from April 2014 from the FTA indicate that 10 percent of collection sites audited showed critical failures. Most common findings included not checking identity of donor, not checking pockets, and not requiring hand washing. Tese are easily correctable errors; review these items with your collectors today. Several large collection services have
begun doing internal audits. Te botom line is proper training of collectors; and, of
www.datia.org
DOT’s 10 Ste
ps to Collecti
on Si
te Security and Integrity
Office of Drug and Alcohol Policy and Compliance U.S. Department of Transportation
1. Pay careful attention to employees throughout the collection process.
2. Ensure that there is no unauthorized access into the collection areas and that undetected access (e.g., through a door not in view) is not possible. 3. Make sure that employees show proper picture ID.
4. Make sure employees empty pockets; remove outer garments (e.g., coveralls, jacket, coat, hat); leave briefcases, purses, and bags behind; and wash their hands.
5. Maintain personal control of the specimen and CCF at all times during the collection.
6. Secure any water sources or otherwise make them unavailable to employees (e.g., turn off water inlet, tape handles to prevent opening faucets, secure tank lids).
7. Ensure that the water in the toilet and tank (if applicable) has bluing (coloring) agent in it. Tape or otherwise secure shut any movable toilet tank top, or put bluing in the tank.
8. Ensure that no soap, disinfectants, cleaning agents, or other possible adulterants are present.
9. Inspect the site to ensure that no foreign or unauthorized substances are present.
10. Secure areas and items (e.g., ledges, trash receptacles, paper towel holders, under-sink areas, ceiling tiles) that appear suitable for concealing contaminants.
course, to take the DOT required refresher training and proficiency demonstration every five years. Why is all of this so important? There
are several reasons. We hear often that the collector or collection site is the weakest link in the drug testing pro- cess—let’s change this. Errors in the collection process can lead to issues with DOT regulators and the employers bring
datia focus 11
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