DOT Collectors – Are You Ready for an FAA Audit?

By Lisa Ruehle

…..Every Designated Employer Representative (DER) relies on their collection sites to perform collections as required by

49 CFR Part 40 for Urine Collectors and Breath Alcohol Technicians (BAT) and Screening Test Technicians (STT). Many FAA companies have collection sites across the country by the very nature of the modality, making it challenging to schedule tests for Flight Crews, such as Pilots and Flight Attendants. Other safety sensitive employees such as Mechanics, Dispatchers, Operation Specialists and Ground Security Coordinators usually do not travel and therefore, they most likely will visit the same local collection sites. 

Having so many different collection sites across the country, the DER may never visit those collection sites; however, the DER is still responsible for those collections and will be held accountable for the actions of those administering the tests. This is why the DER or their Third Party Administrator (TPA) may contact the collectors regarding errors on the Custody and Control Form (CCF) and the errors also for the Breath Alcohol Form. When an FAA audit is taking place and the same collector continues to have systematic problems a Mock collection may be coming your way. 

Even if your collection site does everything correctly, you may still be asked to participate in a mock collection. How do you prepare for such an event? We have tips for you! 

Go back to the regulations.

Over time we may stray from the regulations little by little. Maybe because we found an “easier way” Go back to the basics and look at the regulations objectively, you will see things that you forgot along the way. Also, look at the Urine Specimen Collection Guide published by the Office of Drug and Alcohol Policy and Compliance.  

Do everything the same way every time.

No collector can remember every test; however, if you do and say the same thing every time, you are well on your way to a less stress mock audit. 

Ensure your collection site provides the appropriate security.

Collectors are responsible for ensuring the collection site meets the security requirements. When Donors are at the site, they should have confidentiality while the paper work is taking place, in the collection room and the specimen’s security. 

Things you may not think of- but you should.

You will need to present your training records. If you have finished your five year cycle and you did not get-retrained, this is a serious problem. Get re-trained immediately. Make sure the alcohol instrument has the correct time, provide the calibration checks. Be prepared to describe eventful collections and when you must speak to the DER. 

To prepare, go to the FAA website and download the “FAA Drug Abatement Program Inspection Guide” 

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by Lisa Ruehle

Since 2013 Lisa has worked as a consultant in the drug and alcohol testing industry specializing in compliance and training particularly for aviation related employers.  Lisa is also a national instructor for DATIA – the Drug & Alcohol Testing Industry Association.  Lisa teaches several courses for DATIA:

  • Auditing Success
  • Designated Employer Representative Train the Trainer Course
  • Advanced DER Course
  • Developing an Effective Supervisor Training Program Course
  • Ins & Outs of Drug and Alcohol Testing Course

Lisa is also the author of the DATIA Auditing Success course manual and the Developing an Effective Supervisor Training Program Course manual.  Also serving on the DATIA Board of Directors, Lisa heads up the DATIA Education Committee and serves as the Secretary of the DATIA association.  In addition, Lisa is a DATIA Certified Professional Collector Trainer (CPCT).

Contact Lisa for FAA compliance programs for the DOT required drug and alcohol testing programs for FAA regulated employers including airlines, aircraft repair stations, air tour operators and flight schools.  Available services will include custom written FAA DOT drug and alcohol testing policies, Designated Employer Representative (DER) Training, Supervisor Training, Mock DOT FAA audits and general consultation for DOT required drug and alcohol testing programs for FAA regulated employers.   

Joe Reilly & Associates, Inc is pleased to welcome Lisa Ruehle to our team of consultants for the drug & alcohol testing industry.