Differences between Department of Transportation (DOT) and Department of Health and Human Services (HHS) Mandatory Guidelines for Federal Drug Testing Programs

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Differences between Department of Transportation (DOT) and Department of Health and Human Services (HHS) Mandatory Guidelines for Federal Drug Testing Programs

Table 1. DOT and HHS Guidelines for Federal Drug Testing Programs.
RequirementDOTHHS
Who may act as a collector of an employee?The immediate supervisor of an employee may not serve as the collector unless no other collector is available. DOT guidelines do not stipulate that the supervisor must be a trained collector. If no other collector is available, then a supervisor who is trained as a collector may act as the collector.
Monitoring of Collection SitesTo determine collection site adherence to DOT requirements i) more effective monitoring by collection site parent companies and ii) on-site audits and inspections by DOT agencies. A federal agency must i) inspect five percent of up to a maximum of 50 collection sites each year and must ii) investigate any reported collection site deficiencies and institute appropriate action, such as inspecting the involved site.
TestingDOT does not allow the use of Instrumental Initial Test Facilities (IITFs). Collector must continue to send specimens to an HHS certified laboratory that has confirmation testing capabilities. When appropriate, collector may send specimen to an IITF.
Custody and Control FormThe collector or collection site must maintain their copy of the CCF for no less than 30 days. The collector or collection site must maintain their copy of the CCF for no less than two years.
Direct Observation CollectionsIt is the collector's decision based on specific guidelines. If an observer is required, the observer only needs to be given precise directions at the time of the collection. It is required that the donor raise clothing and turn around to demonstrate the absence of any thing that could adulterate the specimen or be used as a substitution. The collector (or observer) must watch the urine leave the body and go into the container. Direct observations must be done on all return-to-duty and follow-up collections. Before a collector may initiate an observed collection, the collector must contact a supervisor who must concur that a direct observed collection is appropriate. If an "observer" is required, the observer must be trained in directly observed collections. The collector only watches the urine leave the donor's body and into the collection container. Return-to-duty and follow-up testing are not automatically designated for a direct observed collection.