DOT Urine Collection and Breath Alcohol Testing Procedures Mock Demonstrations and Review of Recent Applicable Rule Changes Presented by Tiffany Ellefson

2010 Updates Alcohol Testing Form (ATF) was updated Technical amendment published Feb. 25, 2010 authorizes use of updated form. Initially, Aug. 1, 2010 was published as the last date to use the old form but it was changed to Jan. 1, 2011. What was changed? Paperwork Reduction Act Burden Statement on back of Copy1 & 2 Instructions on back of Copy 3

ATF Update – Back of Copy 1&2

ATF Update – Back of Copy 3

2010 Updates Federal Custody and Control Form (CCF) was updated!! DOT authorized the use of the new form starting Oct. 1, 2010 Old forms can be used up to Sept. 30, 2011 After Sept. 30, 2011, if the old form is used in error, it will be a correctable flaw.

What changed on the CCF? In Step 1, Federal testing authorities are noted including all of the DOT agencies Collectors are required to mark the agency who is authorizing the testing In Step 5A (copy 1), new drug analytes and clarifying drug analytes were added MDMA, MDA, MDEA (Ecstasy) ∆9-THCA (Marijuana metabolite) BZE (Cocaine metabolite)

What changed on the CCF? In Step 6 (copy 2), line added for MRO to write on, new line item “other” for refusal to test situations In Step 7 (copy 2), box was added for MRO to check if the split specimen reported as cancelled Backside of Copy 5 (Donor Copy), instructions were revised for completing CCF

New CCF

2010 Updates §40.14 What collection information must employers provide to collectors? (NEW!) Employers must ensure that the collector has the following information for a drug test: Employee’s Full name and SSN/ID DER information Test reason Whether the collection needs to be observed or not…

§40.14 Continued The following information is also required but can be pre-printed on the CCF: Lab name & address Employer name, address, phone & FAX MRO name, address, phone & FAX DOT agency which regulates the employee’s duties Optional: C/TPA name, address, phone & FAX

2010 Update Effective Oct 1, 2010, the drug testing panel was updated: MDMA, MDA, MDEA (Ecstasy) added Screening test of 6-AM (Heroin metabolite) added Cutoff levels for cocaine and amphetamines were lowered

DOT Urine Collection Process DOT Urine Specimen Collection Guidelines – updated 10/1/2010 “The collector has a major role in the success of the DOT’s drug testing program. The collector is the one individual in the testing process with whom all employees have direct, face-to- face contact.”

The Collector Part 40 defines a collector as a trained person who instructs and assists employees at a collection site, who receives and makes an initial inspection of the urine specimen provided by those employees, and who initiates and completes the Federal Drug Testing Custody and Control Form (CCF).

Collector’s Training DOT does not provide or require a “certification” but collector must meet training requirements: Basic Information Qualification training Initial proficiency demonstration (mock collections) Refresher training Error Correction Training

The Collection Site Two types: single toilet restroom and multi-stall restroom Site must have: Restroom or stall with toilet Source of water to wash hands Suitable clean surface for area to complete paperwork and collection steps Collector must secure water sources and other possible adulterants

Security of Collection Site Prevent unauthorized access to site during collection Prevent employee or any other person from gaining unauthorized access to collection materials/supplies Ensure that all authorized person are under supervision of collector or site personnel Provide for secure handling and storage of specimens

Security and Integrity

Security and Integrity

Collection Supplies Collection kit Federal Drug Testing Custody and Control Form (CCF) Bluing agent to add to toilet bowl/water tank Single use disposable gloves are recommended Tamper-evident tape for securing faucets, toilet tanks, etc. and signs to prevent entry to collection area

Collection Steps Employee reports for test Collector verifies identity - photo ID Acceptable methods vs. Unacceptable methods Collector explains basic collection procedures to employee Ex. Backside of CCF (copy 5), posters displayed at site, checklists used by collector Collector reviews CCF and completes Step 1

Pre-collection steps Collector directs the employee to remove unnecessary outer garments Collector directs the employee to empty pockets and display items Collector directs the employee to wash and dry their hands

Instructions to employee Collector must inspect the restroom before (& after) every specimen collection The collector gives a collection kit to the employee or the employee is allowed to select a kit Collection kit is opened in the presence of both collector and employee Collector directs the employee to go into restroom, provide a specimen of at least 45 mL, do not flush the toilet and return the specimen to the collector as soon as possible

Post collection steps Collector accepts specimen from employee Collector must check the following: Temperature of specimen – within 4 minutes Specimen volume – 45 mL Signs of adulteration/substitution Collector completes Step 2 of CCF

Accepting/securing specimen Collector will open specimen bottles Collector will pour 30 mL into one specimen bottle (primary/A) then at least 15 mL into other specimen bottle (split/B)

Sealing specimen bottles Collector will remove seals from CCF and place on appropriate bottles Collector will date each seal Collector will direct the employee to sign their initials on each seal

Completing collection Collector directs the employee to read, sign, and date certification statement in Step 5 of Copy 2 Collector completes Step 4 of Copy 1 – printing & signing their name, noting time, date, and courier

Completing collection Collector reviews CCF then provides Copy 5 to the employee Collector places specimen bottles and Copy 1 in leak-resistant plastic bag Collector dismisses employee Collector prepares specimen for shipment to the laboratory Must ship within 24 hrs or next business day Must secure specimens prior to pickup by courier

Distributing paperwork Collector sends Copy 2 to the MRO and Copy 4 to the DER(usually by FAX) Collector must retain Copy 3 for at least 30 days

Shy Bladder Protocol Occurs when employee isn’t able to provide 45 mL on initial attempt Employee will be allowed up to 3 hours to provide a valid specimen Employee will be allowed to drink up to 40 oz of fluids – must be monitored If unable to provide after 3 hrs, next step will be a medical evaluation

Direct Observation Collections Collections under direct observation are required when: Temperature out of range Specimen shows signs of tampering Collector finds item intended for adulterating or substituting specimen Directed by MRO Test reasons are Return to duty and Follow- ups Specific protocol – lift, lower, turn around

Refusal to test (involving collector) Failure to report for required test Failure to remain at the collection site until testing process is completed Failure to allow a direct observed collection or monitored collection Failure to cooperate with the testing process – ex. Refuse to empty pockets, fail to wash hands, behave in a confrontational manner

Refusal to test continued For a direct observed collection, failure to follow collector’s instructions Possessing or wearing a prosthetic or other device that could be used to interfere with testing process Admission to collector (or MRO) that employee adulterated or substituted specimen

Beating the drug test Three common methods: Dilution – adding water (less common) or drinking large quantities of fluids (more common) Adding adulterant to specimen – designed to breakdown drug metabolites or interfere with laboratory instruments Substituting a “clean” specimen

DOT Alcohol Testing Who can conduct an alcohol test? STT – Screening Test Technician BAT – Breath Alcohol Technician Both have training requirements – same as collector What instruments can be used? ASD – Alcohol Screening Devices EBT – Evidential Breath Tester Must be on NHTSA CPL (Conforming Products List)

Testing Steps Employee provides ID Explain testing procedures Technician completes step 1 of Alcohol Testing Form (ATF) Employee signs Step 2 of ATF Technician performs alcohol test (individual steps will vary depending on device utilized)

Testing Steps continued If screening test results indicate reading: <0.02 - test is negative (no further testing needed) >=0.02 – Confirmation test is required If negative, technician completes Step 3 then provides employee their copy of ATF If confirmation required, technician provides instructions to the employee

Confirmation Alcohol testing Must be completed with an EBT Must be completed within 15 – 30 minutes of the screening test If confirmation test result reading is: <0.02 – negative test 0.02 – 0.039 – removal from duty >0.04 – positive test Technician will sign & complete Step 3 Employee will be instructed to sign Step 4 if result is greater than 0.02

Refusal to test In addition to the applicable ones described in the collection section, if the employee refuses to sign Step 2 of the ATF, this will be a refusal to test.

Problems in alcohol testing Shy Breath – unable to provide sufficient breath (or saliva) sample for testing Employee will be directed for a medical evaluation Calibration of instruments Availability of trained BATs/STTs

Questions…Contact Information Tiffany Ellefson, Vice President Midwest Toxicology Services, Inc. 603 E Washington St, Ste 200 Indianapolis, IN 46204 tiffany.ellefson@midwesttox.com 317/262-2205 (office) 317/501-1617 (cell)