Study expectations of Elkhorn’s D&A policies Study the different DOT expectations Learn Collection expectations Learn Collection Techniques How to handle difficult canadaites Hands on training of collection process Proper paperwork completion
Pipeline Hazardous Materials Safety Administration (PHMSA) › Safety Sensitive Position, “If the person is going to perform work or supervision on a pipeline or facility and that work or supervision could be detrimental to the integrity of the pipeline or facility” › The majority of our work force belong to this random pool. Random Rate is a minimum of 25% per year.
Federal Motor Carrier Safety Administration DOT “Truck Drivers” Random Pool › Those employees that drive a CMV for the family then they belong to this random pool › A commercial motor vehicle is a vehicle that has a gross vehicle weight rating (GVWR) of 10,001 pounds or greater, › Random Rate is 50% UA, 25% Alcohol per year
This pool is our NON-Dot pool. It mirrors the PHMSA policy If an employee doesn’t belong in the other two pools they will be part of this pool. We use this pool for collection of samples that don’t meet the guidelines of the DOT policies. In other words, annuals for clients, post accident/event/incident sweeps, etc. Random rate of 25% per year
Pool is designed as a catch all All post accident (non-DOT) All project sweeps Client requirement for annuals When the test won’t fit anywhere else
Part 40 defines a collector as a trained person who instructs and assists employees at a collection site, Makes an initial inspection of the urine specimen provided by those employees, Who initiates and completes the Federal Drug Testing Custody and Control Form (CCF)
Exceptions to being an collector… › The immediate supervisor of a donor › An individual that works for an approved lab › Collection of your own sample › Relative of the donor
A collection site is a place (permanent or Temporary) selected by the employer where employees present themselves for the purpose of providing a urine specimen for a DOT-required drug test.
The best collection sites are › A single-toilet restroom, with a full length privacy door › A multi-stall restroom with partial-length doors. › A secure place that offers the donor privacy
Collection Site must have › A restroom or stall with a toilet for the employee to have privacy while providing the urine specimen › A source of water for washing hands that, if practical, is external to the restroom where the urination occurs.
› If the water supply is in the same room employees must wash their hands and then the collector secures the water source. › If no water is available moist towelettes needs to be supplied outside the restroom. › A suitable clean surface for the collector to use as a work area and for completing the required paperwork.
Multi Stall Facility › Requires special attention › Must provide substantial visual privacy › Collector needs to secure all sources of water and other substances that could be used for adulteration and substitution of sample › Place bluing agent in all toilets or secure all toilets to prevent access › All collections as a monitored collection
› No one but the employee may be present in the multi-stall restroom during the collection, › The monitor when required › The observer when required › The collectors work area can be located outside the restroom. The area needs to be secure, clean and large enough to perform collections.
Security of Collection site › Procedures or restrictions to prevent unauthorized access to the site during the collection › Procedures to prevent the employee or anyone else from gaining access to the collection materials/supplies. › Procedures to ensure that all authorized persons are under the supervision of a collector › Secure handling and storage of the specimens.
An approved collection kit Federal Drug Testing Custody Form (CCF) Bluing agent to add to the toilet bowl/water tank to prevent employee from diluting the specimen. Single use disposable gloves are recommended for use by collectors while handling specimens Tape to secure facets, tank tops, etc. Signs to prevent access during the collection process
A collector must do the following before each collection to deter potential tampering, adulteration, alteration or substitution of the specimens
Secure any water sources or otherwise make them unavailable to employees, (turn off the water inlet, tape handles to prevent opening the faucets) Ensure that the water in the toilet and tank (if applicable) has bluing (coloring) agent in it. Tape or otherwise secure to prevent the flushing of the toilet.
Ensure that no soap, disinfectants, cleaning agents, or other possible adulterants are present Inspect the site to ensure that no foreign or unauthorized substances are present Ensure that undetected access is not possible Secure areas and items that appear suitable for concealing contaminants Recheck facility before each collection
Collector must only collect one specimen at a time to avoid distraction During the three hour time period an employee is consuming fluids, a collector can conduct collection from other employees. › The employee that is in the three hour process must be properly monitored while waiting to provide a sample
Prepare the collection site Begin the collection without delay after the employee arrives at the collection site The collector requests the employee to present an acceptable form of identification, a picture ID is preferred but any of the I-9 forms are acceptable
Explain the basic collection procedures › Instructions are on the back of the CCF Ensure that the required information is provided at the top of the CCF (pre- printed material.) Ask employee to remove any unnecessary outer clothing such as jacket, coat, hat, etc.
Leave all personal belongings, briefcases, purses, backpacks, etc with the outer clothing. Encourage the employee to also leave any other items that will not be needed or prohibited from carrying into the restroom, (water bottles, pop cans, etc) › The donor must not be asked to remove other articles of clothing, such as a shirt, pants, dress, or under garments
› Work Boots or Cowboy boots do not have to be removed unless the collector has a reason to suspect that the employee has something in them, which may be used to adulterate or substitute a specimen › An employee that refuses to remove head coverings due to religious beliefs can be exempt unless the collector suspects hidden sources of adulterants etc.
Direct the donor to empty his/her pockets and display the items to ensure nothing can be used adulterate the specimen › If an employee refuses to empty his or her pockets, this is considered a refusal to cooperate in the testing process › If an item is discovered that may appear to have been brought to adulterate the sample then a direct observation is requried
Ask the employee to wash and dry their hands, liquid soap is best, bar soap can be used to adulterate the specimen Open the collection kit in front of the employee, giving the collection container to the employee, sealed specimen bottles are to stay in the possession of the collector.
Direct the employee to provide a sample of at least 45mL › Don’t flush the toilet › Return the specimen as soon as possible › Return specimen before washing hands or flushing toilet. › Share with the employee that the temperature of the specimen is a critical factor and the sample should be given over as soon as possible 4 minutes at a max.
› any conduct that would lead to the adulteration or substitution of a specimen after the sample is given, the sample is to be processed, noted on the CCF, and a second observed sample is collected. Place a note in the remarks section as to why the second sample is collected, place the note on both CCF’s and add the ID number of the first sample to the second CCF. Communicating two samples and why to the MRO and Lab. › Place a call to DER about the situtation
Check the temperature of the specimen, › Within 4 minutes, acceptable range is 90-100 degrees. › Mark appropriate box on CCF › If out of temperature range then an observed collection must follow › Communicate on the CCF what has taken place, and add the ID number from the first CCF in the remarks section of the second CCF
check the volume › At least 45 mL is required, up to 60 mL can be submitted to the lab. inspect for adulteration or substitution › Look for floaties, discolorations, oddities etc. After inspection of the sample the collector opens the specimen bottles in front of the donor › Visual contact of the specimen by both collector and the donor at all times
Collector then pours 30 mL into the first specimen bottle and caps the bottle, then at least 15 mL into the second bottle cap the bottle. › If one of the bottles contains less than 30 mL this bottle will receive the “B” label The collector must then remove the seals from the CCF and place them over the lid of the bottle and down both sides
› If a seal is broken during the removal from the CCF, a new CCF should be utilized and the first one shredded. › If the first seal is in place and the second seal breaks start a new CCF and place the reason in the remarks section. › If the “A” label is placed on the bottle with the less than 30 mL sample then a note in the remarks section is needed.
Direct the employee initial and date the label on each bottle, while it is on the bottle. › If the donor refuses to sign the labels on the bottle then it should be noted on the CCF, this is not a refusal of the test. Collector then asks the donor to complete the donor portion of the CCF, giving a day time and night time contact number, birth date, etc.
Complete the Collector section of the CCF, printing and signing your name, inserting the correct collection site code WYO7B and 307-783-5052 as the collection phone number. (tracking purposes) date of collection, and carrier selected (fed-ex) Place the specimen bottles and the first page of the CCF into the appropriate sections of the specimen pouch.
Seal the pouch, place the tracking sticker on the outside of the pouch Give the last copy of the CCF to the employee, Marked employee’s copy at the bottom of the form. Scan and email or fax the second copy or MRO copy to the MRO. If emailing, carbon copy (cc:) the safety assistant Email to MRO_Notification@disa.com
Place the specimen pouch inside the box, more than one specimen pouch can be placed inside the box, but the pouch must be in a box. Place the box inside the provided shipping pack and attach the shipping label. Call for carrier to pick up or drop the sample off at the carriers pick up spot
Samples need to be shipped to the lab as quickly as possible. The collector is responsible to ensure the security and integrity of the samples until the carrier has possession of the samples Samples do not have to be under lock and key but needs to be secured to prevent tampering etc.
The term “Shy Bladder” refers to a situation when the employee does not provide a sufficient amount of urine(45mL) for a DOT- required drug test. If a donor states when he arrives at the collection site that he can’t provide a sample, ( I just went to the bathroom you shoulda been here 5 minutes ago) the collector starts the collection process.
Ask for a sample, if an insufficient amount is given, dispose of the sample and start the clock on the three hour count down. Place a note in the remarks about the insufficient amount Provide fluids for the donor to consume to help in the process of providing an ample amount of urine. Suggested amount up to 40 oz.
If the insufficient sample is out of temp range or appears to be adulterated then it must be noted on the CCF, and sent to the lab. A Second collection under direct observation is required. If a sample is not given or the employee leaves the collection site before giving a sample or the 3 hours is up, discontinue the test, note the facts in the Remarks section and send the CCF to the MRO and DER
A directly observed collection is the same as a routine collection procedure with the additional requirements that an observer physically watches the employee urinate into the collection container. Observer must be of the same gender, no execptions
An Observed Collection is required when: › the lab reports an invalid specimen and the MRO reports that there was not an adequate medical explanation for the result › Because the split specimen test could not be performed (inadequate amount) › The MRO reports a negative-dilute result with a creatinine concentration greater than or equal to 2mg/dL but less that or equal to 5 mg/dL
› The test is a return to duty or follow up test › The collector observed materials brought to the collection site or employee’s conduct clearly indicated an attempt to tamper the specimen › The temperature on the original specimen is out of range or the specimen appeared to have been tampered with.
Explain to the donor why a directly observed collection is required Must complete a new CCF and mark the same as the first CCF Mark the observed and enter a remark as to why and the name of the observer if different than collector Add the ID number from the first CCF to the second CCF
The observer enters the restroom or facility where urination occurs with the employee. › Observer must request the employee to raise his or her shirt, blouse or dress/skirt, as appropriate above the waist, just above the navel; and lower clothing and under pants to mid thigh to show the observer by turning around that no prosthetic device is present › After determining that no such device is present the employee can return clothes to proper position and then conduct the collection
The observer must watch the employee urinate into the collection container. Specifically, the observer must personally and directly watch the urine go from the employee’s body into the collection container (use of mirrors or video cameras is not permitted). › If it is a multi-stall restroom, the observer must enter the stall with the employee.
With respect to direct observation collections, the following situations are considered refusals to test: › the employee refuse to allow a direct observation › The employee fails to follows observers directions › Employee has a prosthetic device In these situations the collector discards the specimen, and notifies the DER