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

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

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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

spouse, relative) or a close personal friend. The guidelines go on to suggest that to avoid any potential appearance of collusion or impropriety, a safety-sensitive employee subject to the DOT drug testing rules should not be a collector, an observer, or a monitor for co-workers who are in the same testing pool or who work together with that employee on a daily basis. Each collector must maintain documentation of their initial qualifications training, proficiency demonstration, refresher training, and error-correction training and provide this documentation upon request to DOT agency representatives (i.e., auditors, triennial reviewers), and to employers and/or C/TPAs using their services. The collection site personnel are responsible for maintaining the integrity of the specimen collection and transfer process, ensuring the security of the specimen, and ensuring the dignity and privacy of the donor. Collectors should conduct their duties with professionalism and avoid any remarks that may be construed as accusatory or otherwise offensive or inappropriate. To deter donors from tampering with their specimens, the specimen collector must perform the following tasks prior to each and every collection: 1. Secure water sources by turning off water or taping handles to prevent opening faucets. 2. Put bluing agent in the toilet bowl and swish to ensure dispersion throughout the bowl. 3. Remove all soap, disinfectants, cleaning agents, or other possible adulterants. 4. Inspect the site to ensure that no foreign or unauthorized substances are present. 5. Secure toilet tank top or put bluing agent in the tank water. 6. Ensure that undetected access is not possible. 7. Secure areas and items that can be used to conceal contaminants (i.e., vanities, trashcans, paper towel holders). 8. Recheck each collection facility following each collection. Collectors may only conduct one test at a time (unless the donor is in an extended wait time associated with the insufficient volume procedure described later in this chapter). The collector must, to the greatest extent possible, keep the donor’s specimen within full view of the donor and the collector until the specimen is sealed. Only the collector and the donor are allowed to handle the specimen before it is sealed. The collector must remain at the collection site and be in personal control of the specimen throughout the collection process. As the employer, you are ultimately responsible for the collection process and as such you should monitor collection sites closely and require documentation that collectors have met the minimum requirements. Contracting for this service removes your staff from direct involvement in the collection and testing process and turns these functions over to impartial, outside technical persons who have no direct relationship with your employees. Contracting for collection services, however, does not relieve you from responsibility for ensuring that the complete collection process meets all applicable regulatory requirements established by FTA and DOT (§40.15(c)). Chapter 7. Drug Testing Procedures 7-5 August 2002

spouse, relative) or a close personal friend.<br />

The guidelines go on to suggest that to avoid<br />

any potential appearance of collusion or<br />

impropriety, a safety-sensitive employee<br />

subject to the DOT drug testing rules should<br />

not be a collector, an observer, or a monitor<br />

for co-workers who are in the same testing<br />

pool or who work together with that<br />

employee on a daily basis.<br />

Each collector must maintain<br />

documentation of their initial qualifications<br />

training, proficiency demonstration,<br />

refresher training, and error-correction<br />

training and provide this documentation<br />

upon request to DOT agency representatives<br />

(i.e., auditors, triennial reviewers), and to<br />

employers and/or C/TPAs using their<br />

services.<br />

The collection site personnel are<br />

responsible for maintaining the integrity of<br />

the specimen collection and transfer process,<br />

ensuring the security of the specimen, and<br />

ensuring the dignity and privacy of the<br />

donor. Collectors should conduct their<br />

duties with professionalism and avoid any<br />

remarks that may be construed as accusatory<br />

or otherwise offensive or inappropriate.<br />

To deter donors from tampering with<br />

their specimens, the specimen collector must<br />

perform the following tasks prior to each<br />

and every collection:<br />

1. Secure water sources by turning<br />

off water or taping handles to<br />

prevent opening faucets.<br />

2. Put bluing agent in the toilet<br />

bowl and swish to ensure<br />

dispersion throughout the bowl.<br />

3. Remove all soap, disinfectants,<br />

cleaning agents, or other possible<br />

adulterants.<br />

4. Inspect the site to ensure that no<br />

foreign or unauthorized<br />

substances are present.<br />

5. Secure toilet tank top or put<br />

bluing agent in the tank water.<br />

6. Ensure that undetected access is<br />

not possible.<br />

7. Secure areas and items that can<br />

be used to conceal contaminants<br />

(i.e., vanities, trashcans, paper<br />

towel holders).<br />

8. Recheck each collection facility<br />

following each collection.<br />

Collectors may only conduct one test at<br />

a time (unless the donor is in an extended<br />

wait time associated with the insufficient<br />

volume procedure described later in this<br />

chapter). The collector must, to the greatest<br />

extent possible, keep the donor’s specimen<br />

within full view of the donor and the<br />

collector until the specimen is sealed. Only<br />

the collector and the donor are allowed to<br />

handle the specimen before it is sealed. The<br />

collector must remain at the collection site<br />

and be in personal control of the specimen<br />

throughout the collection process.<br />

As the employer, you are ultimately<br />

responsible for the collection process and as<br />

such you should monitor collection sites<br />

closely and require documentation that<br />

collectors have met the minimum<br />

requirements. Contracting for this service<br />

removes your staff from direct involvement<br />

in the collection and testing process and<br />

turns these functions over to impartial,<br />

outside technical persons who have no direct<br />

relationship with your employees.<br />

Contracting for collection services, however,<br />

does not relieve you from responsibility for<br />

ensuring that the complete collection<br />

process meets all applicable regulatory<br />

requirements established by FTA and DOT<br />

(§40.15(c)).<br />

Chapter 7. Drug Testing Procedures 7-5 August 2002

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