The point of collection is the part of the process where the donor is involved, there needs to be a priority that the collection is done with integrity, security, and overall good customer service. The donor will report back to their employer – your client. The donor should have a good experience in a urine specimen collection or alcohol test.
If you are managing specimen collections at your fixed facility and perhaps dispatching mobile collectors, you must ensure that your employees are trained and qualified to perform this service. Your employees must be knowledgeable on all applicable DOT and modal regulations. They need to know how to handle any problems that may arise through a detailed training program and your Standard Operating Procedures manual.
If as an employer or TPA you are outsourcing fixed facility collections or mobile collections it is critical that you are utilizing trained qualified collectors and breath alcohol technicians. Make sure you have contracts or agreements with these vendors and that you verify credentials for specimen collectors and for breath alcohol technicians.
High-quality collectors can be found on the DATIA website on the Searchable Directory. DATIA has a comprehensive certification program for collectors, which covers the DOT requirements. DATIA’s Certified Professional Collector (CPC®) and Certified Professional Collector Trainer (CPCT®) programs provide an opportunity for collectors to be trained with the highest standards available ensuring that collections are performed in a professional and consistent manner, maintaining confidentiality for the donor and security, integrity, and control of the specimen.
Other training programs for collectors are available, it is important to verify the collector has met the qualifications that are required including the five consecutive error-free mock collections. A training certificate by itself does not verify these proficiency demonstrations. It is important to ask for documentation for both the training and the proficiency demonstrations. Also, check the dates of the training – refresher training must occur every five years, and must cover all areas of the initial training and proficiency demonstration.
DATIA has a comprehensive accreditation program for collection sites. If your C/TPA provides in-house collection services for your clients, it is recommended that you get accredited as an Accredited Collection Facility. This will ensure that any in-house training is supplemented with objective outside evaluation with tests and performance standards. Similarly, if you use a collection site, best to use one that meets industry standards through accreditation.
DOT regulations are very clear on who can do a collection and the training requirements. Review the specific DOT requirements for collectors:
- The collector must be knowledgeable about 49 CFR Part 40, the current “DOT Urine Specimen Collection Procedures Guidelines,” and DOT agency regulations applicable to the employers for whom the collector performs collections, and the collector must keep current on any changes to these materials.
- The collector must receive training on the following subjects:
- All steps necessary to complete a collection correctly and the proper completion and transmission of the CCF;
- “Problem” collections (e.g., situations like “shy bladder” and attempts to tamper with a specimen);
- Fatal flaws, correctable flaws, and how to correct problems in collections; and
- The collector’s responsibility for maintaining the integrity of the collection process, ensuring the privacy of employees being tested, ensuring the security of the specimen, and avoiding conduct or statements that could be viewed as offensive or inappropriate;
- Following the collectors’ completion of the qualification training, the collector must demonstrate proficiency in collections by completing five consecutive error-free mock collections.
- The five mock collections must include two uneventful collection scenarios, one insufficient quantity of urine scenario, one temperature out of range scenario, and one scenario in which the employee refuses to sign the CCF and initial the specimen bottle tamper-evident seal.
- Another person must monitor and evaluate the collector’s performance, in person or by a means that provides real-time observation and interaction between the instructor and trainee, and attest in writing that the mock collections are “error-free.” This person must be a qualified collector who has demonstrated necessary knowledge, skills, and abilities by regularly conducting DOT drug test collections for a period of at least a year; conducting collector training under this 49 CFR Part 40.33 for a year; or successfully completing a “train the trainer” course.
- No less frequently than every five years from the date on which the collector satisfactorily completes the initial qualification requirements, the collector must complete refresher training that meets all the same requirements met previously including qualification training and proficiency demonstration.
- If the collector makes a mistake in the collection process that causes a test to be canceled (i.e., a fatal or uncorrected flaw), the collector must undergo error correction training. This training must occur within 30 days of the date the collector is notified of the error that led to the need for retraining.
- Error correction training must be provided and the collector proficiency documented in writing by a person who meets the requirements to monitor mock collections.
- Error correction training is required to cover only the subject matter area(s) in which the error that caused the test to be canceled occurred.
- As part of the error correction training, the collector must demonstrate the collector proficiency in the collection procedures of this part by completing three consecutive error-free mock collections. The mock collections must include one uneventful scenario and two scenarios related to the area(s) in which the collector error(s) occurred. The person providing the training must monitor and evaluate the collector’s performance and attest in writing that the mock collections were “error-free.”
- The collector must maintain documentation showing that the collector currently meets all requirements of 49 CFR Part 40.33. The collector must provide this documentation on request to DOT agency representatives and to employers and C/TPAs who are using or negotiating to use the collector services.
Visit our training courses page for upcoming Collector Training and Mock Collections sessions.