Best Practices in Drug Testing Programs

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Best Practices in Drug Testing Programs

• Specimen Collection
• DOT non-DOT Testing
• Policy Considerations
• Arkansas Public Transportation Conference
• October 2008
• Dr. Donna Smith, FirstLab, Inc. Regulatory
  Affairs Officer
• dsmith_at_firstlab.com

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Urine Drug Testing ProgramsAn Overview

• DOT mandates urine drug testing programs for
  applicants to, and employees in, safety-sensitive
  positions in the transportation industry
• This includes testing of people who have a
  Commercial Drivers License and who work as
  operators, dispatchers, and mechanics for public
  transit authorities/agencies
• DOT regulations specify that drug testing must be
  conducted using a urine specimen--collected from
  the donor by a trained and qualified collector,
  tested at a federally certified laboratory, and
  the test result reviewed and interpreted by a
  Medical Review Officer (MRO)
• Because the drug testing process begins with the
  collection of the urine specimen, that process is
  key to ensuring the integrity of the process,
  protection of employees rights and privacy, and
  the validity accuracy of the test result.
• One of major concerns about urine drug testing is
  measures to prevent or deter cheating on the test
  by adulterating or substituting the urine
  specimen when it is collected

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Urine Specimen Collection Process

• The urine specimen collection process is designed
  to meet 3 objectives
• Ensure the proper identification of the specimen
  with the donor
• Ensure the security of the specimen and maintain
  an intact chain of custody throughout the process
• Protect integrity of the testing process by
  deterring cheating (e.g. adulterating,
  substituting, manipulating the specimen)
• The collection process has 3 main components
• Preparation of the collection site the donor
• Custody and Control Form (CCF) documentation
• Specimen collection, packaging and shipment

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Specimen Donor Identification

• Photo ID of donor
• Donor ID number (e.g. SSN, DL, Passport, other
  photo ID number)
• Specimen ID number on custody and control form
  (CCF) and on each bottle label
• Donors initials on bottle seal
• Collector certification statement signature
• Donor certification statement signature
• Donor is provided copy of CCF

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Specimen Security

• Specimen is processed packaged in the donors
  presence
• No testing or analysis conducted on specimen at
  collection site
• Specimen bottle tamper-evident seals
• Specimen and CCF placed in plastic bag with
  pressure active seal
• Specimen and CCF shipped via laboratory courier
  or express carrier (tracking )

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Protecting Specimen Integrity

• Elements of the specimen collection process
  designed to deter and detect attempts to
  adulterate, substitute, dilute or otherwise
  defraud the drug test
• Preparation of the specimen collection site
• Deterrent actions with the donor
• Specimen integrity checks by the collector

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Preparation of the Collection Site

• Water sources in toilet enclosure are disabled so
  there is no access to add water to the specimen,
  mix or prepare solutions, etc.
• Bluing placed in toilet bowl, tank lid taped or
  tank water blued
• Access/exits restricted or secured
• Cleaning supplies, materials, other possible
  contaminants removed
• Collection supplies discarded/removed
• Inspect storage areas or hidden spaces for
  urine specimens, bottles, adulterants, etc.
• Post public restroom against unauthorized entry
• Prepare one stall for use collector remains
  inside restroom

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Everyday Products Used as Adulterants
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Deterrent Actions with Donor

• Have donor remove all outer garments (jackets,
  coats, coveralls, hats, etc.)
• Require donor to leave all hand carried items
  outside toilet enclosure (bags, purses, cell
  phones, IPods, etc.)
• Donor may retain only wallet, money clip, money,
  credit cards, etc.)
• Require donor to empty all pockets and display
  contents
• Donor must leave all items from pockets, except
  money, outside the toilet enclosure
• Require donor to wash dry hands in presence of
  collector before entering the toilet enclosure
  (refusal to do so is a Refusal to Test)
• Provide donor with only the collection
  containernot the specimen bottles to take into
  the toilet enclosure
• Accompany donor to door of toilet enclosure
• The collector may set a reasonable time for the
  donor to remain in the toilet enclosure
• Pay close attention to the donor and his actions
  in this preparation process

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Specimen Integrity Checks by the Collector

• Specimen temperature check
• Within 4 min. of the donor presenting the
  specimen
• Acceptable temperature range 90-100F
• If temperature is out of range, a 2nd immediate
  collection under direct observation must be
  conducted
• Specimen volume check
• Must be at least 45 mL( for split specimen 30 mL
  if only a single specimen) in collection
  container
• If less, specimen must be discarded (unless
  specimen is suspect)
• Specimen color, odor, physical properties check
• If specimen is green/blue or other color
  inconsistent with voided specimen, specimen is
  suspect
• If specimens odor yields bleach, ammonia,
  vinegar or other common adulterant, specimen is
  suspect
• If specimen appears to have visible residue or
  sediment, is excessively frothy or bubbly,
  specimen is suspect

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Additional Deterrent Actions

• Donor is not permitted to leave collection site
  control at any time during collection process
• Including while waiting because of a shy
  bladder or waiting for a second observed
  collection
• Collector must keep specimen under his/her
  control and sight at all times after presentation
  by the donor
• Closely monitor and control access to fluids
  during shy bladder procedure and at any time
  while donor is waiting to provide specimen
• Decrease time donor is kept waiting after
  signing in and beginning collection process

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Direct Observation Collections

• Direct Observation collections provide further
  deterrent to adulterating or substituting a
  specimen
• Direct observation procedures are only used when
  donor has engaged in conduct indicating an
  attempt to adulterate or substitute a specimen or
  when ordered by the MRO
• Direct observation must always be done by a
  person the same sex as the donor
• Direct observation is different from monitoring
  a collection
• Actual visual sighting of urine coming from
  donors body into the collection container
• DOT recently revised direct observation
  collection procedures to include a requirement
  for donor to position clothing so that observer
  can inspect the donors body front back from
  mid-chest to mid-thighs without clothing
• Purpose of this procedure is for observer
  /collector to inspect for any prosthetic device
  used to adulterate or substitute a urine specimen

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DOTs 10 Steps to Collection Site Security and
Integrity Office of Drug and Alcohol Policy and
Compliance U.S. Department of Transportation
1. Pay careful attention to employees throughout
the collection process. 2. Ensure that there is
no unauthorized access into the collection areas
and that undetected access (e.g., through a
door not in view) is not possible. 3. Make sure
that employees show proper picture ID. 4. Make
sure employees empty pockets remove outer
garments (e.g., coveralls, jacket, coat, hat)
leave briefcases, purses, and bags behind and
wash their hands. 5. Maintain personal control
of the specimen and CCF at all times during the
collection. 6. Secure any water sources or
otherwise make them unavailable to employees
(e.g., turn off water inlet, tape handles to
prevent opening faucets, secure tank lids).
7. Ensure that the water in the toilet and tank
(if applicable) has bluing (coloring) agent in
it. Tape or otherwise secure shut any movable
toilet tank top, or put bluing in the tank. 8.
Ensure that no soap, disinfectants, cleaning
agents, or other possible adulterants are
present. 9. Inspect the site to ensure that no
foreign or unauthorized substances are present.
10. Secure areas and items (e.g., ledges, trash
receptacles, paper towel holders, under-sink
areas, ceiling tiles) that appear suitable for
concealing contaminants.
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Specimen Validity Testing (SVT) at the Laboratory

• Since all attempts to adulterate or substitute a
  urine specimen may not be detected when the
  specimen is collected, the laboratory must
  conduct SVT on all DOT-regulated drug tests
• Laboratory SVT Procedures
• Determine the creatinine conc. on every specimen
• Determine the specific gravity on every specimen
  for which the creatinine conc. is less than 20
  mg/dL
• Determine the pH on every specimen
• Perform one or more tests for oxidizing
  adulterants on every specimen
• Perform additional validity tests when the
  following conditions are observed
• Abnormal physical characteristics
• Reactions or responses characteristic of an
  adulterant
• Possible unidentified interference or adulterant

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DOT and non-DOT Drug Testing

• DOT drug testingtesting conducted by the
  employer when required to by Federal regulations
  (e.g. FMCSA and FTA)
• Non-DOT testingtesting conducted by the employer
  based on its own policy and authority, even when
  required by the state or contract conditions
• An employer may have both DOT and non-DOT testing
  programs
• Must use different forms (custody and control
  forms) for DOT-mandated testing and for non-DOT
  testing
• Can use the same procedures for DOT and non-DOT
  testing as long as the appropriate CCF is used at
  the collection
• DOT-covered employees (e.g. CDL holders, public
  transit operators, dispatchers, etc.) may be
  subject to additional testing based on the
  employers policy, but that testing must be
  identified as non-DOT
• DOT-covered employees and employees subject to
  random testing under the employers authority
  cannot be in the same random pool for selection

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Best Practices--Random Testing

• Ensure all eligible employees are in testing pool
  and that pool is updated as needed
• Random selection process is fair and equitable
  and every person is eligible for selection each
  time selections are made
• Random selections should be made at least
  quarterly
• Person selected for random test can be tested at
  anytime during that quarter
• Selected employee should not have advance notice
  that he/she is selected for testing
• Documentation of reasons why selected employees
  are not tested during the quarter (i.e.
  terminated, on leave of absence, etc.)
• Tracking to ensure that minimum annual percentage
  is achieved
• Tracking to ensure that there is no predictable
  pattern to when random tests are conducted
• Remember that cancelled random tests do not count
  toward required annual percentage under DOT rules

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Best Practices--Substance Abuse Policy

• Identify prohibited drug and alcohol-related
  conduct
• Explain drug and alcohol testing requirements and
  testing procedures
• Address procedural issues
• Medications and safety concerns
• Dilute specimens, shy bladder, fitness for duty
  other medical examinations
• EAP SAP referrals, last chance agreements
• Define safety-sensitive duty and positions
  subject to testing
• State consequences and disciplinary actions for
  violation of policy
• Provide a copy of the policy to each employee and
  maintain documentation that employee has received
  and understands the policy

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