1. FTA DRUG AND ALCOHOL PROGRAM NATIONAL CONFERENCE How to Review Your Collection Site for Compliance Atlanta, GA 2015

2. Why Inspect? Central Role Collection Sites are final and central component to D&A program Highest likelihood of technical flaws (most regs to follow) Cheating Many sites fail basic security/integrity procedures Users have most to lose, always a step ahead Oversight Thousands of sites Millions of tests per year

3. Why Inspect? FTA’s Clandestine Collections FTA maintains a full-fledged clandestine collection site inspection program How will your site do? FAIL STATS 7% have failed to identify donor 36% have failed to check pockets 31% have failed to require hand washing Bad Sites 9% reviewed showed critical failures Your employees deserve better

4. Why Inspect? Includes 691 inspections through Dec. 2014

5. Traveling Public US Congress US DOT FTA DAPM Collector

6. Collection Site Visits – FTA Method  Scheduled  Open Process  Instructional  Identity & Purpose clearly stated  Includes discussion of “problem” collections/scenarios  Water sample

7. Pros  Questionnaire  Thorough understanding of policies, practices, knowledge  Can openly inspect equipment, facility  Can openly inspect credentials

8. Cons  The Ringer  Dynamic can compound collector mistakes  “Rest of process” missing  Some errors fixed by nature of mock

9. Collection Site Visits  Begin with:  FTA Collection Site Questionnaires (http://transit- safety.fta.dot.gov/DrugAndAlcohol/tools)  Both Urine and Breath-Alcohol questionnaires available  Set a date  Familiarize yourself with the questionnaire  (Call us if you have questions!)  A review of CCFs/ATFs from site beforehand is extremely helpful

10. Collection Site Visits  There are two components to collection site inspection: 1.Mock collection 2.Unusual (“problem”) collections discussion

11. Collection Site Visits  Mock Collection  A demonstration of procedures used during normal/uneventful collections  Corrections should be conveyed after the mock  Collector should perform mock just as he or she normally would

12. Collection Site Visits  Unusual collections review  A discussion covering scenarios specifically described in 49 CFR Part 40 Shy Bladder Refusals Direct Observation And More!  Does not usually include demonstrations

13. The Breath Alcohol Test §40.211-§40.279

14. Does the Breath Alcohol Technician (BAT):  Request photo ID (if not done already)  Use a Federal Alcohol Testing Form (ATF)?  Complete the form correctly and in order?  1-2-3-(4)  Use a NHTSA-approved EBT (breath device) or ASD (saliva testing device)?

15. Does the BAT/Site:  Have training/qualification records?  Keep regular accuracy checks recorded?  Maintain their equipment as required?

16. Does the BAT/Site:  Have a copy of the Quality Assurance Plan (QAP) for the device (EBT) used?  Have a current copy of 49 CFR Part 40?  Understand how to load and troubleshoot problems with the device?

17. Does the BAT/Site:  Have an EBT for confirmation tests if they use saliva test or non- evidential breath testing device?  Have any experience with positive tests?  Understand special circumstances, such as refusals, fatal flaws, etc.?

18. The Urine Drug Collection §40.31-§40.73 & §40.191- §40.209

19. Does the collector:  Request photo ID (if not done already)?  Instruct donor to remove outer garments?  Instruct donor to empty pockets?  Allow the donor to keep wallet?  Explain the procedures? Including showing the donor the instructions printed on the back of the form

20. Does the collector:  Ask donor to wash hands?  Secure all internal water sources?  Open sealed kit in front of donor  Give donor a 55ml container?

21. Once in the enclosure:  Concealment areas secured or removed?  Chemicals and fluids removed?  Ceiling tiles secured? Twelve pieces of paraphernalia found at this major US airport collection site. >

22. Once in the enclosure:  Are there windows, doors, panels, or pass-through ports?  Is the toilet tank lid secured?  Is the water off?

23. Does the collector:  Check the temperature strip?  Check the quantity?  Distribute the specimen into each of 2 bottles?

24. Does the collector:  Provide a clean and suitable writing surface?  Use a Federal CCF?  Ensure all steps completed correctly on the CCF?  Don’t forget: 1, 2, 3, 5, 4 !

25. Demonstration of Correct CCF Steps

26. Steps 1 & 2

27. What’s Wrong/Missing?

29. 29

30. 30

31. Does the collector:  Place specimen label seals on bottle?  Date the seals?  Instruct the donor to initial the seals?  And verify initials?

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33. Does the collector:  Seal the specimens into a shipping bag?  Monitor only one donor at a time?

34. Discussion Topics  Shy Bladders  Uncooperative donor  Direct Observation

35. Shy Bladder  Donor must make initial attempt, even if:  Waiting for representative, or  “Just doesn’t have to go”  Donor has 3hrs to provide specimen  beginning with QNS cup  Donor may have up to 40 ounces of fluid over 3hrs  Doesn’t have to drink  Measurements must be:  Consistent  Accurate

36. Uncooperative Donors  If a donor is uncooperative:  Terminate test  Record actions in “Remarks” section  Call DER  This is a refusal to test  This goes for being uncooperative for directly observed or monitored tests as well… Collector is in Charge!

37. Direct Observation  If donor:  Removes tampering materials from pockets  Behaves in a way that “clearly indicates an attempt to tamper with a specimen”  Provides a specimen out of temp  Provides an adulterated/tampered specimen  Collector must require Direct Observation

38. Direct Observation Cont.  D.O. collection must occur immediately  No provision for waiting period, fluid intake  Same-gender observer  Need not be a collector or medical professional  Observer must: Require that donor disrobe (to chest, knees) and rotate to display absence of devices Watch urine travel from body to cup Record name on CCF (if not collector)

39. Discussion Topics  Frequency of courier Daily  Security of stored specimen No access by “civilians”  General facility security & privacy Back doors, lock boxes  Fixing Flaws Immediate or next business day  Collector training and retraining Mock collections in training 30 days to retrain after a Fatal Flaw

40. Does the Site:  Have your correct contact information?  Transmit Copy 2 of the CCF directly to the MRO after each collection?  Afford donors confidentiality and privacy before, during, and after the collection?

41. Does the Site:  Welcome your visits?  Perform other USDOT-regulated tests?  Understand the importance of the collection process as relates to your compliance?

42. Next steps:  Get questionnaires  http://transit-safety.fta.dot.gov/DrugAndAlcohol/tools http://transit-safety.fta.dot.gov/DrugAndAlcohol/tools  Make an appointment  Visit & evaluate  Require corrective actions  Give them a due date!  Re-visit

43. Remember: Your collection site should be…  Consistent and accurate  Your partner in the process  Willing to respond to your request for compliant practices

44. FTA Drug and Alcohol Program NATIONAL CONFERENCE THANK YOU Atlanta, GA 2015