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Observed collections in DOT urine drugs testing

(Revised for readability Nov 10 2018)

Observation is either required, or not allowed, in mandated 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.

The employer is responsible to assure observation is done always, and only, when required.

For commercial drivers and other federal employees, observed collection 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 WHEN:

  • 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 )
    • invalid specimen reported from lab
    • dilute specimens meeting certain criteria

Irregularities during specimen collection

In the course of urine specimen 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

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Selection of Specimen Collection and Testing Sites

In urine drugs testing, collection of the specimen is critically important . If drivers are in Northern California and able to have testing and specimen collection performed at our parent company, Occupational Health Services, you can be assured that all collectors and alcohol testing technicians are qualified, experienced, and certified. However, if testing might be needed at another location, you should evaluate possible collection and testing sites in advance.

In selecting a collection and testing site, consider the following:

  • Be sure to know the facility’s specimen collection hours.
    • There will generally be a cut off time for collections, earlier than the closing time of the clinic. This is to allow up to three hours for provision of a specimen, as required by DOT/FMCSA regulation.
    • At OHS, collections must begin before 3:00 PM
  • Determine if there are collectors available of appropriate gender, in case an observed collection becomes necessary.
  • Assure collectors have been trained and alcohol testers are certified.
  • Set up an account or otherwise make advance arrangement for payment. Specimen collection and alcohol testing is free of additional charge at our Lodi location only.
  • Make arrangements Custody and Control Form (CCF) to reflect laboratory and MRO information for Central Medical Review. The driver may carry a preprinted copy from us, or the collection site may store some copies for you, or alter some of their own to reflect CMR data.
  • Designated Employer Representative (DER)  information should be provided to the site.
  • Notify the collection site and CMR when the employee is expected to arrive at the collection site. Remember, once informed of a follow-up or random drugs test to be taken, the employee must proceed immediately and directly to the collection site.
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CMR: New site, updated mission

In an effort to provide timely and authoritative information to my clients and the public in general, I am developing this system to create articles of interest and assemble them into newsletters. Please register for the newsletter if you wish to receive occasional and irregular updates on topics of interest to commercial drivers and their employers regarding drugs and alcohol testing of these and other federally regulated employees.

I welcome your comments, but shall publish them. I may respond directly, or with an article to reflect concerns and questions, or I may not respond.  At some point in future we may open up to public dialogue.