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Qualification Training

DOT Urine Specimen Collectors must be knowledgeable about the DOT’s drug and alcohol testing regulations (49 CFR Part 40), the current copy of the Office of Drug and Alcohol Policy and Compliance’s Urine Specimen Collection Guidelines as well as specific agency requirements. Collector Qualification Training must include:

  • The necessary steps to complete a valid collection, including completing and distributing Custody and Control
  • How to handle shy bladder situations, attempted specimen tampering and other problem collections.
  • Fatal and correctable flaws and how to correct problems in collections.
  • The Collector’s critical role in the collection process. As the collector, you are responsible for ensuring the integrity of the collection process, the privacy of the donor and the security of the specimen.

After completing Qualification Training, collectors must complete an initial proficiency demonstration. The demonstration must include five, consecutive error-free mock collections. The mock collections, which are monitored and evaluated by a qualified collector trainer, must cover the following situations:

  • Two “Uneventful” scenarios
  • One “Insufficient Quantity of Urine,” or Shy Bladder, scenario
  • One “Temperature Out-of-Range” scenario
  • One scenario in which the donor refuses to sign the CCF and initial the tamper-evident bottle seals

STTs and BATs must be knowledgeable about the alcohol testing procedures in 49 CFR Part 40 as well as all current DOT guidance concerning alcohol testing. STT and BAT Qualification Training must consist of a DOT Model BAT and STT Course or its equivalent, and include:

  • Training to proficiency in the DOT’s alcohol testing procedures and the specific alcohol testing devices to be used.
  • An emphasis on the STT’s/BAT’s role in maintaining the integrity of the testing process, ensuring the privacy of the employees being tested and avoiding conduct or statements that could be viewed as offensive or inappropriate.

 

  • Refresher Training

    Collectors, BATs and STTs must complete Refresher Training a minimum of once every five years. The required training is to include a regulation review and update as well as a Qualification Training review. In conjunction with each Refresher Training, collectors, BATs and STTS must once again complete the mock collections or tests that were required as part of their initial proficiency demonstration.

  • Error Correction Training

    When a collector or alcohol technician makes a mistake that causes a drug or alcohol test to be cancelled, he or she must complete Error Correction Training within 30 days of being notified of the error. The Error Correction Training is only required to cover the subject matter relating to the error that caused the test to be cancelled, but must include a proficiency demonstration. The required demonstration must include one uneventful scenario and two scenarios related to the area or areas in which the error occurred.

Agencies that Require DOT Testing

Designed to protect the safety of employees, co-workers and the general public, the DOT’s drug and alcohol testing regulations cover the more than 12 million people who perform DOT-designated safety-sensitive functions. These employees include pipeline workers, truck drivers, ferry operators, train engineers, bus drivers, airline crew, mechanics and many others, and work for employers regulated by the Federal Aviation Administration, Federal Motor Carrier Safety Administration, Federal Railroad Administration, Federal Transit Administration, Pipeline and Hazardous Materials Safety Administration, and the United States Coast Guard.

Collectors and alcohol technicians who perform DOT collections must familiarize themselves with the drug and alcohol regulations governing the employers that they perform collections for. Below are brief descriptions of the six agencies that require DOT drug and alcohol testing along with drug and alcohol testing regulation references.

  • Federal Aviation Administration

    The Federal Aviation Administration (FAA) regulates and oversees all aspects of civil aviation in the United States. The FAA agency regulations cover flight crews, flight attendants, flight instructors, air traffic controllers, air craft dispatchers, aircraft maintenance personnel, ground security coordinators and aviation screeners.

    For more information, see FAA regulations at 14 CFR Part 121.

  • Federal Motor Carrier Safety Administration

    The Federal Motor Carrier Safety Administration (FMCSA) is responsible for the safety of commercial motor vehicle operations on U.S. highways. The FMCSA drug and alcohol testing regulations cover commercial drivers license holders who operate commercial motor vehicles that are 26,000 pounds or greater, or operate a vehicle that carries 15 passengers or more, or are required to display a DOT placard in the transportation of hazardous material.

    For more information, see FMCSA regulations at 49 CFR Part 382.

  • Federal Railroad Administration

    The Federal Railroad Administration (FRA) regulates railroad safety. The agency develops and enforces rail safety regulations, conducts research and development in support of improved railroad safety and administers railroad assistance programs. The FRA drug and alcohol testing regulations cover employees, employers, owners, manufacturers, lessors or lessees of railroad equipment, track or facilities, and independent contractors providing goods or services to a railroad.

    For more information, see FRA regulations at 49 CFR Part 219

  • Federal Transit Administration

    The Federal Transit Administration (FTA) administers Federal funding for a variety of locally planned, constructed and operated public transportation systems throughout the United States. Mass transit regulated by the FTA includes buses, subways, light rail, commuter rail, streetcars, monorail, ferry boats, inclined railways and people movers. The FTA drug and alcohol testing regulations cover vehicle operators, controllers, mechanics and armed security personnel.

    For more information, see FTA regulations at 49 CFR Part 655

  • Pipeline and Hazardous Materials Safety Administration

    The Pipeline and Hazardous Materials Safety Administration (PHMSA) protects the American public and environment by regulating the movement of hazardous materials. The PHMSA regulations cover operators, maintenance and emergency response personnel.

    For more information, see PHMSA regulations at 49 CFR Part 199

  • United States Coast Guard

    The United States Coast Guard (USCG) regulates boat crews who operate in commerce. Although it became an agency of the U.S. Department of Homeland Security in 2003, it still follows the 49 CFR Part 40 drug testing procedures. The USCG regulations cover all crewmembers that operate commercial vessels.

    For more information, see USCG regulations at 46 CFR Parts 4 and 16

Forms Used in DOT Drug and Alcohol Testing

Federal Custody and Control Form(CCF)
Federal Custody and Control Form(CCF)
The Federal Custody and Control Form is used to document all urine specimen collections for DOT drug tests. This form follows the specimen from the time the donor is identified and provides an initial specimen until the testing has been completed.

The initial steps of the five-part carbonless form are completed by the collector and donor at the collection site. Additional steps are completed at the laboratory and by the Medical Review Officer. This DOT-required form helps ensure that the specimen is accurately tracked and the donor is positively identified.
Alcohol Testing Form (ATF)
Alcohol Testing Form (ATF)
The DOT Alcohol Testing Form is used to document DOT alcohol tests. It is a three-part carbonless manifold form used to record the results of an alcohol test. Steps one and three are completed by the alcohol technicians, who also either affixes printed test results to the form or records the result with a ballpoint pen. In step two, the employee certifies that the identifying information provided on the form is true and correct. Step four is completed by the employee if the result is 0.02 or higher.

Refusal-to-Submit to DOT-required Drug and Alcohol Testing

There are several instances that the DOT defines as Refusals-to-Submit. Many of these situations relate directly to the urine specimen collection procedures used in drug testing or the alcohol testing process. So, it is critical for collectors and alcohol technicians to be aware of Refusl-to-Submit scenarios and be prepared to deal with these problem collections.

  • Controlled Substances Testing

    A DOT-regulated employee refuses a required drug test when he or she…

    • Fails to appear for any test (except a pre-employment test) within a reasonable time, as determined by the employer, consistent with applicable DOT agency regulations, after being directed to do so by the employer. This includes the failure of an employee (including an owner-operator) to appear for a test when called by a Third Party Administrator (TPA).
    • Fails to remain at the testing site until the testing process is complete. Exception: An applicant who leaves the testing site before the testing process commences for a pre-employment test is not deemed to have refused to test.
    • Fails to provide a urine specimen for any drug test required by regulation. Exception: An applicant who does not provide a urine specimen because he or she left the testing site before the testing process began for a pre-employment test is not deemed to have refused to test.
    • In the case of a directly observed or monitored collection for a drug test, fails to permit observation or monitoring.
    • Fails to provide sufficient quantity of urine within the time limit under then-current regulations and it has been determined, through a required medical evaluation that there was no adequate medical explanation for the failure.
    • Fails or declines to take a second test the employer, Medical Review Officer (MRO), or collector has directed the driver to take.
    • Fails to undergo a medical examination or evaluation, as directed by the MRO as part of the verification process, or as directed by the DAPM/DER as part of the “shy bladder” procedures.
    • Fails to cooperate with any part of the testing process (e.g., refuses to empty pockets when so directed by the collector, behaves in a confrontational way that disrupts the collection process, fails to wash hands after being directed to do so by the collector, etc.).
    • Fails to remain readily available for post-accident testing or fails to report, without a valid reason, that he or she was in a post-accident situation that required testing.
    • If the MRO reports to the driver that he or she has a verified adulterated or substituted test result.
    • For an observed collection, fails to follow the observer’s instructions to raise the employee’s clothing above the waist, lower clothing and underpants, and to turn around to permit the observer to determine if the employee has any type of prosthetic or other device that could be used to interfere with the collection process.
    • Possesses or wears a prosthetic or other device that could be used to interfere with the collection process.
    • Admits to the collector or MRO that he or she has adulterated or substituted the specimen.

  • Breath Alcohol Testing

    A DOT-regulated employee refuses a required alcohol test when he or she…

    • Fails to appear for any test (except a pre-employment test) within a reasonable amount of time, as determined by the employer, after being directed to do so by the employer. This includes the failure of an employee (including an owner-operator) to appear for a test when called by a TPA.
    • Fails to remain at the testing site until the testing process is complete. Exception: An individual who is there for a pre-employment test and leaves before the testing process begins is not deemed to have refused to test.
    • Fails to provide a saliva or breath specimen, as applicable, for any DOT required test. Exception: An individual who does not provide a saliva or breath specimen because he/she left the testing site before the testing process began for a pre-employment test is not deemed to have refused to test.
    • Fails to provide a sufficient breath specimen and a physician has determined through a required medical evaluation that there was no adequate medical explanation for the failure.
    • Fails to undergo a medical examination or evaluation, as directed by the employer as part of the insufficient breath procedures.
    • Fails to sign the certification at Step 2 of the alcohol testing form (ATF).