BY JOE REILLY, FORMER CHAIRMAN, DATIA BOARD MEMBER, JOE REILLY AND ASSOCIATES, LLC
The FAA and FTA often audit collection sites. Audits are a good thing because if you find out what your collectors are doing wrong, you can make the appropriate corrections and get the appropriate training completed. When collectors are appropriately trained, this can eliminate mistakes that cause non-compliance and fatal flaws.
Y
ou might remember in 2007 the media exposed procedural errors in direct violation of the testing procedures defined in 49 CFR Part 40. An NBC Nightly News story, which aired on
November 1, 2007, reported the findings of a Government Account- ability Office (GAO) undercover investigation that found it was sur- prisingly easy to cheat on random drug tests. Te story aired on many other media outlets including FOX news. Tese news reports were aimed specifically at truck drivers. Te box on page 10 lists a summa- ry of those findings. Investigators used bogus identification to initiate the testing process in all (100 percent) of the 24 sites investigated, demonstrating the ease at which safety-sensitive employees can send other (presumably drug-free) individuals to take the tests for them. Only two of the 24 sites correctly followed all of the remainder of the testing procedures tested by the investigators. Te remaining 22 (91.7 percent) had two or more serious protocol violations. Having reviewed over 100 audits performed over the past 12
months, collection sites are doing beter but there are still issues that can certainly be corrected if collection site operators would pay more atention to DOT training requirements. (Note: Te author conducted many of these audits and DATIA Certified Professional Collector Trainers (CPCT) conducted others. Audits have been conducted on fixed-facility collection sites and on mobile collectors performing on-site collections, sometimes during daytime hours and sometimes aſter hours. Audits were conducted in multiple areas around the United States. An audit checklist is utilized to verify that the collection is performed properly.) Qualification training as a DOT specimen collector is not difficult
to obtain, but it is also not a quick and easy process for a new collec- tor. When training new collectors, I find there is a minimum 6-hour training process and mock collections always take at least two hours. Typically collectors that have not been trained properly are the ones we see making errors in our audit situations.
www.datia.org datia focus 9
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