Observed collections in DOT urine drugs testing

Under some circumstances, collection of urine specimens for drugs screening must be observed directly by collection personnel. Observation must be by a person of the same gender as the testing subject. This is an important factor in choosing a collection facility. See related post Selection of Specimen Collection and Testing Sites.

For commercial drivers and other federal employees, observation is required if the DER (Designated Employer Representative) directs the collector to do so. The DER is required to have the collection observed for the following situations. Otherwise, the DER is not allowed to have the collection observed.

Observation is required (and so, authorized) ONLY

  • for Return to Duty after completing Substance Abuse Professional (SAP) requirements following a positive test or refusual
  • for Follow-up after Return to Duty, as require by SAP
  • If ordered by the MRO ( Medical Review Officer )

In the course of the collection, if the following apply, the collector must proceed with a directly observed collection

  • The collector “observes materials brought to the collection site or the employee’s conduct clearly indicates an attempt to tamper with a specimen” (see §§40.61(f)(5)(i) and 40.63(e) );
  • The temperature on the original specimen was out of range (see §40.65(b)(5) ); or
  • The original specimen appeared to have been tampered with (see §40.65(c)(1) ).

The procedures for observed collection are specified in http://www.dot.gov/odapc/dot-direct-observation-procedures.