DOT Urine Collection and Breath Alcohol Testing Procedures Mock Demonstrations and Review of Recent...

DOT Urine Collection and Breath Alcohol Testing ProceduresMock Demonstrations and Review of Recent Applicable Rule Changes

Presented by Tiffany Ellefson

2010 UpdatesAlcohol Testing Form (ATF) was

updated◦Technical amendment published Feb.

25, 2010 authorizes use of updated form.

◦Initially, Aug. 1, 2010 was published as the last date to use the old form but it was changed to Jan. 1, 2011.

◦What was changed? Paperwork Reduction Act Burden

Statement on back of Copy1 & 2 Instructions on back of Copy 3

ATF Update – Back of Copy 1&2

ATF Update – Back of Copy 3

2010 UpdatesFederal Custody and Control

Form (CCF) was updated!!DOT authorized the use of the

new form starting Oct. 1, 2010Old forms can be used up to

Sept. 30, 2011After Sept. 30, 2011, if the old

form is used in error, it will be a correctable flaw.

What changed on the CCF?In Step 1, Federal testing

authorities are noted including all of the DOT agencies◦Collectors are required to mark the

agency who is authorizing the testing

In Step 5A (copy 1), new drug analytes and clarifying drug analytes were added◦MDMA, MDA, MDEA (Ecstasy)◦∆9-THCA (Marijuana metabolite)◦BZE (Cocaine metabolite)

What changed on the CCF?In Step 6 (copy 2), line added for

MRO to write on, new line item “other” for refusal to test situations

In Step 7 (copy 2), box was added for MRO to check if the split specimen reported as cancelled

Backside of Copy 5 (Donor Copy), instructions were revised for completing CCF

New CCF

2010 Updates§40.14 What collection information

must employers provide to collectors? (NEW!)

Employers must ensure that the collector has the following information for a drug test:◦Employee’s Full name and SSN/ID◦DER information◦Test reason◦Whether the collection needs to be

observed or not…

§40.14 ContinuedThe following information is also

required but can be pre-printed on the CCF:◦Lab name & address◦Employer name, address, phone & FAX◦MRO name, address, phone & FAX◦DOT agency which regulates the

employee’s duties◦Optional: C/TPA name, address, phone

& FAX

2010 UpdateEffective Oct 1, 2010, the drug

testing panel was updated:◦MDMA, MDA, MDEA (Ecstasy) added◦Screening test of 6-AM (Heroin

metabolite) added◦Cutoff levels for cocaine and

amphetamines were lowered

DOT Urine Collection ProcessDOT Urine Specimen Collection

Guidelines – updated 10/1/2010“The collector has a major role in

the success of the DOT’s drug testing program. The collector is the one individual in the testing process with whom all employees have direct, face-to-face contact.”

The CollectorPart 40 defines a collector as a

trained person who instructs and assists employees at a collection site, who receives and makes an initial inspection of the urine specimen provided by those employees, and who initiates and completes the Federal Drug Testing Custody and Control Form (CCF).

Collector’s TrainingDOT does not provide or require

a “certification” but collector must meet training requirements:◦Basic Information◦Qualification training◦Initial proficiency demonstration

(mock collections)◦Refresher training◦Error Correction Training

The Collection SiteTwo types: single toilet restroom

and multi-stall restroomSite must have:

◦Restroom or stall with toilet◦Source of water to wash hands ◦Suitable clean surface for area to

complete paperwork and collection steps

Collector must secure water sources and other possible adulterants

Security of Collection SitePrevent unauthorized access to site

during collectionPrevent employee or any other person

from gaining unauthorized access to collection materials/supplies

Ensure that all authorized person are under supervision of collector or site personnel

Provide for secure handling and storage of specimens

Security and Integrity

Security and Integrity

Collection SuppliesCollection kitFederal Drug Testing Custody and

Control Form (CCF)Bluing agent to add to toilet

bowl/water tankSingle use disposable gloves are

recommendedTamper-evident tape for securing

faucets, toilet tanks, etc. and signs to prevent entry to collection area

Collection StepsEmployee reports for testCollector verifies identity - photo ID

◦Acceptable methods vs. Unacceptable methods

Collector explains basic collection procedures to employee◦Ex. Backside of CCF (copy 5), posters

displayed at site, checklists used by collector

Collector reviews CCF and completes Step 1

Pre-collection stepsCollector directs the

employee to remove unnecessary outer garments

Collector directs the employee to empty pockets and display items

Collector directs the employee to wash and dry their hands

Instructions to employeeCollector must inspect the restroom before

(& after) every specimen collectionThe collector gives a collection kit to the

employee or the employee is allowed to select a kit

Collection kit is opened in the presence of both collector and employee

Collector directs the employee to go into restroom, provide a specimen of at least 45 mL, do not flush the toilet and return the specimen to the collector as soon as possible

Post collection stepsCollector accepts specimen from

employeeCollector must check the

following:◦Temperature of specimen – within 4

minutes◦Specimen volume – 45 mL◦Signs of adulteration/substitution

Collector completes Step 2 of CCF

Accepting/securing specimenCollector will open specimen

bottlesCollector will pour 30 mL into one

specimen bottle (primary/A) then at least 15 mL into other specimen bottle (split/B)

Sealing specimen bottlesCollector will remove seals from

CCF and place on appropriate bottles

Collector will date each sealCollector will direct the employee

to sign their initials on each seal

Completing collectionCollector directs the employee to

read, sign, and date certification statement in Step 5 of Copy 2

Collector completes Step 4 of Copy 1 – printing & signing their name, noting time, date, and courier

Completing collectionCollector reviews CCF then provides

Copy 5 to the employeeCollector places specimen bottles and

Copy 1 in leak-resistant plastic bagCollector dismisses employeeCollector prepares specimen for

shipment to the laboratory◦Must ship within 24 hrs or next business

day◦Must secure specimens prior to pickup by

courier

Distributing paperworkCollector sends Copy 2 to the

MRO and Copy 4 to the DER(usually by FAX)

Collector must retain Copy 3 for at least 30 days

Shy Bladder ProtocolOccurs when employee isn’t able

to provide 45 mL on initial attempt

Employee will be allowed up to 3 hours to provide a valid specimen

Employee will be allowed to drink up to 40 oz of fluids – must be monitored

If unable to provide after 3 hrs, next step will be a medical evaluation

Direct Observation Collections

Collections under direct observation are required when:◦Temperature out of range◦Specimen shows signs of tampering◦Collector finds item intended for

adulterating or substituting specimen◦Directed by MRO◦Test reasons are Return to duty and

Follow-upsSpecific protocol – lift, lower, turn

around

Refusal to test (involving collector)Failure to report for required testFailure to remain at the collection

site until testing process is completed

Failure to allow a direct observed collection or monitored collection

Failure to cooperate with the testing process – ex. Refuse to empty pockets, fail to wash hands, behave in a confrontational manner

Refusal to test continuedFor a direct observed collection,

failure to follow collector’s instructions

Possessing or wearing a prosthetic or other device that could be used to interfere with testing process

Admission to collector (or MRO) that employee adulterated or substituted specimen

Beating the drug testThree common methods:

◦Dilution – adding water (less common) or drinking large quantities of fluids (more common)

◦Adding adulterant to specimen – designed to breakdown drug metabolites or interfere with laboratory instruments

◦Substituting a “clean” specimen

DOT Alcohol TestingWho can conduct an alcohol test?

◦STT – Screening Test Technician◦BAT – Breath Alcohol Technician◦Both have training requirements –

same as collectorWhat instruments can be used?

◦ASD – Alcohol Screening Devices◦EBT – Evidential Breath Tester◦Must be on NHTSA CPL (Conforming

Products List)

Testing StepsEmployee provides IDExplain testing proceduresTechnician completes step 1 of

Alcohol Testing Form (ATF)Employee signs Step 2 of ATFTechnician performs alcohol test

(individual steps will vary depending on device utilized)

Testing Steps continuedIf screening test results indicate

reading:◦<0.02 - test is negative (no further

testing needed)◦>=0.02 – Confirmation test is

required If negative, technician completes

Step 3 then provides employee their copy of ATF

If confirmation required, technician provides instructions to the employee

Confirmation Alcohol testingMust be completed with an EBTMust be completed within 15 – 30

minutes of the screening testIf confirmation test result reading is:

◦<0.02 – negative test◦0.02 – 0.039 – removal from duty◦>0.04 – positive test

Technician will sign & complete Step 3Employee will be instructed to sign

Step 4 if result is greater than 0.02

Refusal to test In addition to the applicable ones

described in the collection section, if the employee refuses to sign Step 2 of the ATF, this will be a refusal to test.

Problems in alcohol testingShy Breath – unable to provide

sufficient breath (or saliva) sample for testing◦Employee will be directed for a

medical evaluationCalibration of instrumentsAvailability of trained BATs/STTs

Questions…Contact Information

Tiffany Ellefson, Vice PresidentMidwest Toxicology Services, Inc.603 E Washington St, Ste 200Indianapolis, IN 46204

tiffany.ellefson@midwesttox.com317/262-2205 (office)317/501-1617 (cell)