Implementation Guidelines - Federal Transit Administration - U.S. ...

authorized individuals are under the
supervision of the collector at all times when
in the collection area. The collector may
remove any person who obstructs, interferes
with, or causes a delay in the collection
process.
Collection Site Personnel. A collector
is a trained person who instructs and assists
employees at a collection site, receives and
makes an initial inspection of the urine
specimen provided by those employees, and
initiates and completes the Federal Drug
Testing Custody and Control Form (CCF).
Only individuals that meet the minimum
requirements for collectors defined in
Subpart C of 49 CFR Part 40 are authorized
to collect urine specimens for DOT drug
testing.
The minimum requirements that a
collector must have in order to perform their
duties include basic information,
qualification training, initial proficiency
demonstration, refresher training, and errorcorrection
training. These requirements are
discussed in Chapter 5, Section 6 of this
document. The DOT does not require or
provide collector certification, but instead
requires that collectors have documentation
that they have met the appropriate training
requirements.
If an individual becomes a collector after
August 1, 2001, he/she must meet the
training and proficiency demonstration
requirements prior to performing any DOT
collections. Individuals who served as
collectors prior to August 1, 2001, but have
not met the minimum training requirement
have until January 31, 2003 to be trained.
All collectors must have refresher training
within 5 years from the date they completed
their initial qualifications training and every
5 years thereafter.
Recommendation
Mobile Collectors Have Limitations
Many transit systems and state consortia
use mobile collectors to collect urine and
breath specimens for the FTA drug and
alcohol testing program. Mobile collectors
are often associated with or under contract to
third party administrators who provide all the
testing services as part of a turnkey package.
The mobile collectors are often considered an
economical method for obtaining collection
services in areas, times, or situations that
have limited collection site alternatives. In
most cases, mobile collectors notify the transit
system when they will be on-site for random
test collections. Many transit systems and
statewide consortia find this arrangement
convenient as the mobile collector takes over
many of the administrative responsibilities
associated with the program.
In most cases, mobile collectors provide a
collection services that are compliant with the
FTA drug and alcohol testing regulations.
However, FTA-regulated employers must
carefully monitor the policies and practices of
mobile collectors. A primary concern is the
predictability and pattern of testing that is
often characteristic of mobile collectors. To
economically provide testing services, mobile
collectors typically attempt to schedule
collections in the most cost-efficient manner
possible. Subsequently, collectors often ride a
circuit from transit system to transit system,
and so patterns develop. Additionally, mobile
collectors that are not close to the transit
system cannot respond in a timely manner for
post-accident or reasonable suspicion tests.
Since an incident triggers the need for a test,
and the transit system must respond
immediately, prior arrangements for a
collector within close proximity is necessary.
The immediate or direct supervisor of an
employee may not serve as a collector for
that employee (§655.53). Additionally, the
employee may not be the collector of his or
her own urine specimen. The Urine
Specimen Collection Guidelines also
recommends that a collector should not be
related to the employee (e.g., spouse, ex-
Chapter 7. Drug Testing Procedures 7-4 August 2002