In a discussion with DATIA staff earlier in late October Department of Transportation (DOT) officials noted a large number of errors in DOT specimen collections. The following are the errors DOT identified, and our recommendations for best practices to ensure compliance with collection procedures.
Custody and Control Forms (CCFs) received are illegible.
Best Practice: Collectors should review all copies of the CCF prior to distributing them to ensure that they are legible. If the writing is light then collectors should make a darker copy to be sent via fax.
MROs and Employers are reporting that they are not receiving their respective copies of the CCFs despite multiple requests.
Best Practice: Collection site managers should make clear assignments about which collection site personnel are responsible for sending copies of the CCF to employers and MROs. Per DOT regulations, collectors must send the CCFs within 24 hours or the next business day and must keep their copies of CCFs for at least 30 days. A best practice is to review the fax transmittal form to ensure successful delivery of the fax, and to maintain the fax transmittal form with the CCF.
Collectors are not marking step 1D in the CCF to indicate the transportation mode (FAA, FRA, FTA, FMCSA, etc.) for the collection.
Best Practice: Collection sites should post notices within the collection area reminding collectors to mark this information on the new CCF.
Donors are initialing the specimen bottle labels while the labels are on the CCF, contrary to DOT regulations that require the donor to initial the labels after they are attached to the specimen bottle.
Best Practice: Managers should ensure that collection personnel follow correct procedures and provide additional training if appropriate. Failure by collection site personnel to follow correct procedures may warrant disciplinary action as covered by company personnel policies.
Collectors are not adequately informing donors that leaving the collection site prior to the completion of the collection process (with the exception of pre-employment tests) is considered a refusal to test.
Best Practice: Train collectors to include in the instructions they give every donor that leaving the test site prior to completion of the collection is considered a refusal to test. Train collectors to give the same instructions with every collection. Provide a script for collectors to follow that has all the necessary instructions to donors.