BEST PRACTICES BY JOE REILLY, JOE REILLY & ASSOCIATES DOT Collection Site Audits W
hat can you expect when the Department of Transportation (DOT) or a mystery shopper
audits your collection site for urine specimen and breath alcohol testing? Audits might be conducted with a visit
to your collection site, a phone interview, or a questionnaire to be faxed or e-mailed. A visit to your site might be announced, or it might be a surprise visit. Audits can be for DOT collections or for Department of Health and Human Services (HHS) collections, so be prepared. Some common procedure questions for
the audit include: • Does the collector prepare the restroom to deter the dilution or substitution of a specimen?
• Does the collector begin the collection without delay once the donor arrives at the collection site?
• Does the collector perform only one specimen collection at a time?
• Does the collector properly verify donor identity?
• Does the collector describe the basic collection procedures to the donor, and instruct the donor that he or she may read the instructions for completing the Federal Custody and Control Form (CCF), on the back of the Federal CCF? Te answers to the above questions should be YES. Now, let’s go through some additional audit questions:
1. How do you stay current with regulations? You must be knowledgeable about 49 CFR Part 40, the current DOT Urine Specimen Collection Procedures Guidelines, and DOT agency regulations applicable to the employers for whom you perform collections. You must keep current on any changes to these materials. Visit oſten and subscribe to the listserv at the DOT Office
16 datia focus
of Drug & Alcohol Policy & Compliance (ODAPC) web site.1 You can also get involved with industry
organizations like: Drug & Alcohol Testing Industry Association (DATIA)2
and
Substance Abuse Program Administrators Association (SAPAA).3
Tese
organizations offer regular trainings and an annual conference with great information. Finally, you should atend any Quest
Diagnostic training programs and webinars that are available to you.
2. Do you have documentation of completing Qualification Training and your Initial Proficiency Demonstration? Where are your certificates for Qualification and for Initial Proficiency Demonstration as a DOT urine specimen collector, and also as a breath alcohol technician? Do you have easy access to these certificates? DOT requires Qualification Training and Initial Proficiency Demonstration every five years. Do you have documentation of both?
3. Who provides the training for collectors at your collection site? What are the qualifications of your trainer? Is someone in your organization a trainer? What are the qualifications of your trainer? Is your trainer a DATIA- Certified Professional Collector Trainer? Your trainer must meet the qualifications outlined in 49 CFR Part 40—regularly conducting DOT drug test collections for a period of at least a year; conducting collector training under this part for a year; or successfully completing a “train the trainer” course.
4. Is your supervisor the trainer or do you use an outsourced trainer? Make sure that the qualifications listed above in number three are met for the trainer.
5. Have you had any fatal flaws in the past two years? If you have had fatal flaws, go back and review the guidelines so you avoid any additional fatal flaws. Te fatal flaws in the DOT urine collection process include: a. specimen ID number on CCF does not match specimen ID number on botle’s seal
b. insufficient quantity of urine collected and the specimens cannot be re-designated
c. the specimen botle seal is missing, broken, or shows signs of tampering
d. no printed collector’s name and no collector’s signature on CCF
6. Have you completed the required error collection training after a fatal flaw? If you make a mistake in the collection process that causes a test to be cancelled (i.e., a fatal or uncorrected flaw), you must undergo error-correction training. This training must occur within 30 days of the date you are notified of the error that led to the need for retraining. Error correction training must be provided, and your proficiency documented in writing, by a person who meets the trainer requirements outlined in number three above. As part of the error correction training, you must demonstrate your proficiency in the collection procedures by completing three consecutive error-free mock collections. The mock collections must include one uneventful scenario and two scenarios related to the area(s) in which
spring 2017
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