The DOT has made some updates to their DOT Urine Specimen Collection Procedures Guidelines. Many of the changes are simply the addition of greater detail regarding the procedure being specifically written out, rather than an actual change to how it should be done. 

This first change is a great example of this, it was always suggested by ODAPC and the DOT that the training for collector certification be completed within a 30 day period though it was not specifically stated in the guide. However, now the documentation specifically indicates that the DOT recommends that the training and the required mock be completed within a 30 day period. 

Here are some of the other updates which are not changing anything, they have simply added specific verbiage to clarify and confirm actions which were previously expected, but not explicitly defined.

• They added specific notation confirming that if a collector does not provide a required MFR for a correctable flaw, in the appropriate timeframe, then Error Correction Training will be required. 
• For ECCF use there are now specific instructions on how to deal with the situation of an authoritative copy (printout of Copy 1 of the ECCF) not printing out, see below:
  • Collector should sign reprinted Copy – in presence of donor, using a wet-ink signature in Step 4 to designate this as the authoritative copy – and document what occurred in the remarks
• The document now specifies what is NOT acceptable ID to be used by a donor, which is:
  • Id by coworker
  • Id by another employee being tested
  • Use of non-photo ID card (SSN, credit card, membership card etc.)
  • Faxed or photocopies of ID docs
• The section regarding the need for hand washing prior to a collection now indicates that hand sanitizer is acceptable as an option.
• The chart in the Refusal to test section has been updated to include which events cause a refusal, as well as who would be making the decision in that case ie. MRO, DER, Collector etc. 

Observed Collection Updates

The observed collections section sees a big update, as required by the US government’s executive order to only recognize two “unchangeable” sexes, male and female, and mandating that federal agencies use the term “sex” rather than “gender”. For clarity, this means the DOT does not want to allow a transgender person the ability to choose who the observer is, they are mandating that the observer be the same sex as the donor’s birth sex, regardless if they have transitioned. 

The observed collections section was also updated to now include the ability to switch specimen type to oral fluid for an observed test requirement – as an oral fluid collection is always considered an observed collection. 

Lastly, this section added more specific guidance regarding the required immediacy of an observed collection and that collectors should always be prepared to conduct an observed collection. The guidance now also speaks directly to collection sites, advising that they should always have an observer available, and should this NOT be the case that they should let all of their DOT-regulated clients know ahead of time so arrangements can be made.

The DOT also reminds us that the CFR Part 40 requires all service agents involved in drug testing (collectors, laboratories, Medical Review Officers (MRO), Substance Abuse Professionals (SAP), and C/TPAs) to be on the ODAPC Listserve to ensure that they receive notification of any and all updates or changes being made to the CFR Part 40. If you haven’t already, subscribe HERE.