Before an organization recruits a person, they need to screen the individual for any drug abuse. The procedures of such tests are guided by the DOT standards. These are DOT drug tests and are mandatory for all organizations.
DOT Test Procedure
Employees are tested for use of drugs and alcohol. Urine samples of employees are collected by an authorized DOT agency and subsequently sent to the laboratory.
Special collection kits are used to collect urine samples from employees. These kits should be in strict compliance with DOT regulations. There is a separate collection site in an organization, which is demarcated for urine collection. Only this site may be used to collect urine samples from employees.
Sometimes the collection site may be situated outside of the office premises. Independent collection site owners need to ensure appropriate security measures, have the requisite personnel, facilities, materials, supervision, and equipment to conduct collection of urine samples as per the DOT guidelines. Only the employee is allowed to be at the collection site at the time of urine collection.
The Custody and Control Form (CCF) is issued by the Federal Drug Testing department, and this is used to accurately document all urine collections from employees of an organization. The form should not have crossed its expiry date and needs to be in a carbonless five-part, manifold format. No part of the CCF can be revised or modified by the collector.
Relevant information for billing or associated situations can be mentioned out of the border in the CCF. Details like name, telephone number, address, fax number of the organization employer should be mentioned on the CCF.
Refusal to test
In certain instances, an employee may fail to turn up for a urine collection at the scheduled date and time. There is a prescribed time limit to wait for the employee’s attendance. If this timeframe is crossed, the employee is notified that he or she has refused to test.
Urine collections for DOT drug tests need to happen without any delay. Once an employee arrives for the test, the procedure needs to begin right away. If alcohol tests are also being conducted the urine samples should be collected after the alcohol tests. The collector needs to ensure this at all times.
Once the urine sample has been collected the employee is required to sign the certification on CCF. The employee also needs to mention his or her name, birth date, date of urine collection as well as contact information (i.e. phone number, etc.). In case an employee refuses to sign the certification or does not want to furnish contact information, the collector should mention this in the remarks section of the CCF.
DOT Workplace Drug Testing Errors
The Department of Transportation (DOT) has a strict drug and alcohol testing policy for all agencies operating under them. The policy defines rules and regulations like which employees are covered, when to administer testing, up to the procedure to follow in case an employee has a positive drug test result.
The DOT is dedicated to ensuring that all tests are properly administered to guarantee the quality of results. That is why only trained collectors are allowed to administer DOT drug and alcohol testing.
However, there are still instances when collectors commit errors during testing. In 1997, the U.S. Government Accountability Office (GAO) performed an undercover operation and found that a majority of the collection sites they visited did not follow proper DOT procedures and that cheating was possible in these testing areas. The GAO findings led the DOT to provide training solutions that emphasized prevention of cheating on drug tests.
Years later, DOT still reports that collectors and collection sites still commit errors during the collection process. Here are some of the reported errors found by DOT officials and DATIA’s suggested solutions to avoid these errors:
Custody and Control Forms (CCF) received are illegible: It is important that collectors check the forms and ensure that the writing is legible before sending them out. Documents that have light writing must be darkened before sending them through fax.
MRO and Employers not receiving their respective CCF copies, even after multiple requests: DOT regulations state that collectors must send a copy of the CCF within 24 hours or the next business day after collection. They must also keep copies of the CCF for at least 30 days.
Collectors fail to mark the 1D in the CCF indicating which mode of transportation the sample is for (FAA, FMCSA, etc.): Collection sites are advised to post reminders and notices for collectors to see since this is a new step in the process.
Donor specimen labels are signed while still on the CCF: According to DOT rules, labels must be signed while on the specimen bottle.
Collectors are not properly informing donors about regulations upon leaving the collection site: Donors who leave the collection site after the test has begun will be considered as refusing the test (except for pre-employment testing).
Let these mistakes be a reminder that it is important to facilitate proper training and re-training of DOT collectors to ensure that they do all the necessary steps properly. Collection sites must ensure that testing areas follow DOT guidelines and regulations to guarantee the quality of tests and results.
About DOT Saliva Alcohol Testing
Safety-sensitive positions typically refer to the operation of heavy machinery or vehicles. Some of the organizations who employ safety-sensitive workers include:
Employers must read and understand industry-specific regulations as published on the DOT website.1 The Designated Employer Representative (DER) plays a key role in understanding these regulations and ensures the company’s compliance with the DOT Drug and Alcohol Testing Program.
DOT saliva alcohol tests can only be conducted by trained professionals called screening test technicians (STT). They are responsible for transmitting the test results to the employers, all the while observing timeliness and confidentiality.2
Note: If you are the immediate supervisor of an employee, you may not act as the STT of that employee when he/she is tested even if you are STT-qualified, except when no other STT is available and if you are not prohibited by DOT agency regulations. Also, if the employee being tested for alcohol is also being tested for drugs, the STT must ensure that the alcohol screening and confirmation are completed first before the employee submits any samples for the drug test.
Site - This subpart lists the requirements for a designated DOT alcohol testing laboratory, including security; visual and aural privacy for the test subject; availability of authorized personnel, equipment, materials and facilities needed for the collection and analysis of saliva samples.
The following procedures are to be followed by the STT when conducting the alcohol screening test using the saliva ASD:
Check the device expiration date and show it to the employee. Do not use an expired device.
Open the device package in front of the employee.
Instruct the employee on how to insert the device into his mouth properly to ensure that he uses it in accordance to manufacturer specifications.
If an employee chooses not to use the device or if a new test becomes necessary because the device did not activate, the STT must insert the device in the employee’s mouth and collect saliva according to manufacturer instructions. STT must wear single-use gloves while doing the test.
Follow manufacturer instructions to ensure the device is activated.
If for any reason something goes wrong like if the device breaks or is dropped on the floor, the STT must discard this device. Conduct a new test with a fresh device.
The replacement device must have been under the STT’s or the employee’s control before the test.
DOT Drug Testing FAQs
In the publication “What Employees Need to Know about DOT Drug and Alcohol Testing”, the U.S. Department of Transportation aims to help employees address their safety concerns regarding workplace drug and alcohol testing in line with what has been required by certain parts of the DOT Agency regulations. Reading through this handbook, one will find out about all the answers to many of their questions regarding drug and alcohol testing in DOT.
In relation to this, here are some FAQs on DOT Drug and Alcohol Testing:
A: Safety – this is the top priority of the U.S. DOT and for this reason, the department has deemed it necessary to put drug and alcohol testing in place throughout the agency. Part of the program is to ascertain that transportation providers across road, over land, in the air or all models employ 100% drug-free and alcohol-free operators.
A: All safety-sensitive employees assigned under the DOT are required to undergo the test. This would include people from the: aviation department (flight crews, air traffic controllers, aircraft dispatchers etc.); commercial motor carriers who are Commercial Driver’s License holders; maritime crewmembers operating any type of commercial vessel; pipeline operations, emergency response and maintenance; railroad men; and transit department including vehicle operators, armed security, mechanics and controllers among others.
A: Employers are expected to provide their employees with a company policy as well as educational materials that include all the necessary explanations related to the need to undergo DOT drug and alcohol testing. This should also include how the procedure goes and how one will be able to comply with it.
A: The DOT makes use of a specific drug testing tool, that is, urine drug testing. The urine specimen will then be analyzed with certain types of drugs or metabolites like cocaine, marijuana/THC, amphetamines, opiates, and phencyclidine.
A: For a post-accident test, blood specimen collection will be required. The same applies for Serious Marine Incident (SMI) testing.
A: The use of OTC or prescribed medications is allowed provided the medicine has been prescribed by a licensed physician. The physician must also truthfully swear that the use of such medications will be safe to use by an employee in the performance of his duties.
A: DOT drug and alcohol testing are performed during pre-employment in most cases. However, several situations can also call for the performance of a test like for reasonable cause or suspicion, return-to-duty, post-accident, follow-up and even for random purposes.
A: Urine drug testing follows a series of three important steps including: (1) the collection; (2) testing at an authorized laboratory; and (3) a corresponding review by the Medical Review Officer of the DOT or the DOT-related agency.
A: Federal or DOT drug and alcohol tests are performed by completing the so-called Federal Drug Testing Custody and Control Form or CCF. This form contains specific instructions as to who and how the form will be filled up. Any other drug test performed without the CCF is conducted by a private entity.
A: The DOT spearheads the test in such a manner that the test’s validity will be ensured at all times. It also reserves the confidentiality of the employee’s testing details.
A: The first thing one should do is comply with the requirement, that is, to submit oneself to the test. From there, he can make a timely complaint on the matter. This can be done by addressing the concern through the employer’s dispute resolution office. Any complaint should be made in writing. An issue can also be coursed through DOT’s drug and alcohol program office.
A: He will be removed by the company official and will be restricted from performing safety-sensitive functions as defined by the DOT. He will be allowed to return to duty though provided he has dutifully completed the evaluation administered by a Substance Abuse Professional (SAP) and has completed counseling, education or treatment for his dependence. Likewise, he should provide a negative result for drugs and a less than 0.02 alcohol test result.
A: Substance Abuse Professionals or SAPs are persons who play a critical role when it comes to workplace drug testing. They take charge of evaluating individuals who have violated rules of the DOT drug and alcohol testing program. They are tasked to recommend education, counseling or treatment for concerned employees. They too can determine whether or not a person is safe to return to his safety-sensitive duty.
A: Employers would provide employees with a list of SAPs with their corresponding address or contact information.
A: The DOT will not in any way take charge of the firing of the person who has found to have violated the drug and alcohol rules set by the agency. Employers have a hand on the matter and are expected to provide a course of action for the benefit of the industry as a whole. Employees though should expect immediate removal from office in case of violations.
A: Yes, it will definitely affect employment history. This can be carried on from one employer to another most especially if the next employer is also subject to the DOT Agency’s regulations.
A: The Office of Drug and Alcohol Policy and Compliance (ODAPC) will help answer any other questions a person has when it comes to DOT’s drug and alcohol program regulations.