Compliance Management and Training: Drug Testing – Save Your Money! Part II "What Happens At Collection Sites"

By Sandra Brakstad, President of Midwest Compliance Inc.,
Sauk Rapids Minnesota
800-656-1396
http://www.midwestcompliance.com/

Let’s assume, after reading last month’s article, that you took the necessary steps to enroll your driver(s) in a random drug and alcohol testing program. Then, one day, you receive notice that our friend, “Joe Schmo” has been selected for a random drug and alcohol test.

Because Joe was selected for both tests, the alcohol test requires that you notify him while he is either performing a safety-sensitive job function, is just about to perform, or has just finished performing this function, (see the Drug Testing -- Save Your Money article for the definition of a safety sensitive job.) If he had been selected for just a drug test you could notify him at any time, even if he is off duty, as long as the test is accomplished before the next random selection.

Once Joe has been notified, as his employer you must ensure that he proceeds directly to the test site, he cannot pass “GO,” and he may not collect $200.00, (sorry). It is a good idea to work with your collection sites, to ensure that there are no large gaps of time, from driver notification to the actual collection time. You might also choose to familiarize yourself with the amount of time it takes to travel to the site, and ask the collector to notify you if the driver has not arrived in a “reasonable” amount of time.

Make certain that Joe knows whether he will be tested for drugs, alcohol, or both. Most service agents of large consortiums will provide a written notice to send with the driver. The correct test is imperative because it impacts the required testing percentages of the pool. If the driver takes the wrong test, he/she will be required to take the correct test selected. Knowing which test is required will save you time and money.

Okay, Joe arrived at the collection site on time. Because he was selected for both drug and alcohol testing, it is recommended, in the regulations, that the alcohol test be conducted first.

The Breath Alcohol Technician, (BAT) selects, or allows Joe to select a sealed mouthpiece, and inserts the mouthpiece into the testing device. Then the BAT instructs Joe to blow steadily and forcefully into the mouthpiece for at least six seconds. The BAT will show Joe the test results displayed on the testing device. The results will be recorded, and typically the testing device will print out the results. Joe will receive the printout and must give it to you, once he has returned from testing.

Because Joe was also selected for a controlled substance test, he will be required to provide a urine specimen. The person attending Joe is called the collector. The collector’s job is to ensure that Joe removes any outer clothing; jacket, coat, hat, etc. that could be used to conceal items or substances that could be used to tamper with a specimen. He will also be asked to empty his pockets so the collector can inspect the items to ensure that nothing could be used to adulterate the specimen. Once the pocket items have been checked, they can go back into Joe’s pocket. He will also be required to check any personal belongings, like a briefcase, lunch box, or purse – huh? Tell Joe not to take this as a personal attack on his character, this is just the regulated procedure. If Joe refuses these requests, the collector will notify him that his refusal will constitute a refusal to test. All refusals to test are treated as positives, (more on positives next month).

Next, the collector will instruct Joe to wash and dry his hands. Joe will either break the seal on the collection container, or watch the collector do this. He will be sent into the room used for urination and must provide at least 45mL of urine; he must not flush the toilet. During this process, the collector will be noting the amount of time it takes Joe.

The collector checks the container to ensure it has at least 45mL of urine, that the temperature is with a normal range, that the color and odor are consistent with urine, and that there is no presence of foreign objects or any tampering. The collector must prepare the specimen for testing in Joe’s presence. The preparation includes completing the Custody Control Form (CCF), pouring the urine from the collection container into the split specimen containers, and sealing the shipping envelope.

Occasionally, collectors make errors in the preparation process. If this occurs, the Lab will attempt to get the error corrected. If a correction is not possible, the Lab will cancel the test. If this happens, Joe will have to go through the collection process again, (with a different collector). In this situation, make sure that the clinic does not charge you for the collection process they screwed up!

Barring any delays, due to errors or further testing, the Lab sends their findings to the Medical Review Officer, (MRO) who in turn reports the results to you, the Designated Employee Representative, (DER) – or if you use a service agent, they receive the results from the MRO and report them to you.

In Joe’s case, let’s assume his results were negative. Next month we’ll discuss what happens when the test results are positive. Until then, take it one load at a time!

Sandra Brakstad
http://www.midwestcompliance.com/
800-656-1396