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The page below is a sample from the LabCE course Department of Transportation (DOT) Federally Regulated Urine Specimen Collection Training. Access the complete course and earn ASCLS P.A.C.E.-approved continuing education credits by subscribing online.

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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

Requirement DOT HHS
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 Sites To 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.
Testing DOT 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 Instrumental Initial test Facility (IITF).
Custody and Control Form The 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 Collections It 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.