ASK ALICE
In each issue we will be answering questions submitted by members. If you have a question to be answered, please submit it to info@datia. org with Ask Alice in the subject line. Enjoy.
QUESTION: Generally, only one collec- tor is supposed to supervise a collection for an employee. However, given the time span involved, it is possible that two collectors could be involved in a shy bladder collec- tion (e.g., because of a shiſt change during the three-hour period between the first and second collection atempts). How should this be handled?
ANSWER: In this situation, it is permissible for one collector to turn the process over to another collector to complete the collec- tion. Te first collector would document the start time for the 3-hour period. Te second would provide his or her name and signature aſter the second collection, as the collector of record. Te Remarks line (Step 2 of the CCF) would be used to document the transition (including the first collector’s name and the start time for the shy bladder procedure). §40.193; §40.43
QUESTION: In regards to DOT, FMC- SA requires 50% drug and 10% alcohol. Is the 50% & 10% number (random selections needed) derived from the aver- age number of employees for the year or the highest number of employees for the year for that particular company?
QUESTION: Do collectors sign the CCF in situations in which a urine specimen is not provided during a collection (i.e., a refusal to provide a specimen; a shy bladder situation)?
ANSWER: In any such case, the collector would check the box in Step 2 of the CCF indicating that no specimen was provided and enter an explanatory remark. Te collector would then provide his or her name and signature in Step 4 of the CCF. Te employee’s name and phone number should be included on the MRO copy. Te collector would then transmit the CCF copies to the appropriate parties (e.g., employer, MRO). §40.191; §40.193
48 datia focus
ANSWER: To calculate the total number of covered drivers eligible for random testing through- out the year, as an employer, you must add the total number of covered drivers eligible for testing during each random testing pe- riod for the year and divide that total by the number of random testing periods. Cov- ered employees, and only covered employ- ees, are to be in an employer’s random test- ing pool, and all covered drivers must be in the random pool. If you are an employer conducting random testing more oſten than once per month (e.g., daily, weekly, bi- weekly) you do not need to compute this total number of covered drivers rate more than on a once per month basis. §382.305:(j)(1)
Also, this is a good resource for Ran-
dom Testing from DOT: htp://
www.dot. gov/sites/
dot.dev/files/docs/ODAPC_ Random%20Testing%20Brochure.pdf And this is the FMCSA Q&A for
Randoms specifically: htp://www.
fmcsa.dot.gov/regulations/title49/ section/382.305?guidance
QUESTION: If a company has employees selected in Q3 for a random and test them in Q4 does that count as Q3 testing or do they just receive a shortfall for Q3 and Q4 is pulled at a higher % to meet the testing %?
ANSWER: Employees must be tested in the Quarter (Q3) they are selected from the random testing pool. If not, it must be documented why they were not tested in that Quarter. Te next Quarter (Q4) is pulled at a higher % to make up for the employees not tested, in order to meet the required annual testing rate. As a best practice, you should notify employers of the last date that employees can be tested in the random testing period (each Quarter in your case).
QUESTION: May a DOT urine speci- men be obtained via catheterization from a patient who is catheterized as part of a medical procedure or who is unconscious?
ANSWER: No one is ever permited to obtain a urine specimen for DOT testing purposes from an unconscious individual, whether by catheterization or any other means. No one is permited to catheterize a conscious em- ployee for the purpose of collecting urine for a DOT drug test. However, if a person has been catheterized for medical purposes (e.g., a conscious, hospitalized patient in a post-accident test situation), it is permis- sible to use urine collected by this means for DOT testing purposes. All necessary documentation for a DOT collection must be provided (e.g., the CCF). In addition, an employee who normally voids through self-catheterization is required to provide a specimen in that manner. §40.61 ❚
winter 2015
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