How DOT Rules Regulate Collectors

Frequently Asked Questions on the DOT Regulations and Their Impact on Urine Specimen Collectors

1. When did the specimen collector training requirements go into effect?

The new CFR 49 part 40 regulations concerning collector training went into effect August 1, 2001. Persons who become a collector on or after August 1, 2001 will need to meet the qualification training and proficiency demonstration requirements before performing specimen collections.

2. What are the qualification training and proficiency demonstration requirements for specimen collectors?

Qualification training must include instruction on (1) all steps necessary to complete a collection correctly and the proper completion and transmission of the Custody and Control Form (CCF); (2) problem collections such as shy bladder and attempts to adulterate a specimen; (3) fatal flaws, correctable flaws, and how to correct problems in collections; and (4) 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.

Proficiency demonstration consists of completing five consecutive error-free mock collections. The five mock collections must include two uneventful collection scenarios, one insufficient quantity of specimen scenario, one temperature out of range scenario, and one scenario where the donor refuses to sign the CCF and initial the specimen bottle tamper evident seal. These mock collections must be monitored and evaluated by a person that meets the DOT requirements to do so (see #3). This person must attest in writing that the mock collections were error-free.

For recertification, DOT requires that you complete training to their standards as well as 5 Error-Free Mock Collections every 5 years to do DOT collections. See (c) 1: Please note: Mock collections must be overseen by someone who has been doing DOT collections for at least 1 year OR who has taken a Train-the-Trainer course.  When you are training people (CPCT), you will need to oversee these for people.

3. What qualifications must a collector meet to be able to monitor and evaluate a collector’s proficiency demonstration?

This person must have demonstrated the necessary knowledge, skills, and abilities by (1) regularly conducting DOT drug test collections for a period of at least one year; (2) conducting collector training under part 40 for at least one year; or (3) successfully completing a “train the trainer” course.

4. What should you look for in a training course?

(1) Nationally Recognized Certification.
 The DATIA collector training program has been in existence since 1997. Since its transition to a formal certification program in June of 1999, the program has certified over 1500 collectors. These certified collectors receive and are able to use the professional designation of either CPCT (Certified Professional Collector Trainer® ) or CPC (Certified Professional Collector®). DATIA’s program is currently the only collector certification program offering National Recognition. In addition, although not in the DOT requirements, the Department of Health and Human Services (HHS) is in the process of preparing requirements for collector certification as part of their Mandatory Guidelines for Federal Drug Testing Programs.

(2) Small Class Size. Specimen collections, although they appear simple, can be very complex. A small class size allows attendees to receive special attention from the instructor during class. This attention ensures that attendees do not leave the course with outstanding questions or misinterpretations of the information. DATIA has limited its course size to 25 persons to ensure that all attendees have the opportunity to have questions answered and information clarified.

(3) Experienced Instructors
. The information taught in a course can only be as good as the person presenting the material. Be sure that the instructor has enough experience to answer questions on even very obscure collection scenarios. A person experienced not only in performing collections, but also in presenting a training course will be better equipped to present the material in a way that allows attendees to get the most out of the course. Sherri Vogler and John Corpus have been presenting DATIA’s collector training programs since 1998 and continue to receive near perfect ratings for their effective delivery, ability to answer questions, and ability to clarify even the most difficult information.

(4) Thorough Coverage of all Information. Be sure that the course allows ample time to thoroughly cover all aspects of the collection process and to pay particular attention to problem collection scenarios such as shy bladder and specimen adulteration. If the course skims over certain areas of the collection process, attendees may leave the course without learning the correct procedures. Ample time should also be allotted for question and answer periods. These are often the most enlightening segments of the course as everyone can learn from the experiences of others. DATIA’s course is offered only as a full day course providing 7 hours of intense instruction and question and answer periods.

(5) Interactivity. Look for a course that offers interaction between attendees and the presenter. Courses where the instructor simply states out loud the information contained in the course handouts is no more effective than if the attendee simply read the manual on his/her own. Discussing real life situations enhances the learning of all attendees. The presenter should have the knowledge and class time to asisst attendees in relating the information provided during the course to real wold scenarios experienced by the attendees. Standard scenarios as well as out of the ordinary scenarios should be discussed to ensure that the attendees have a solid understanding of how to apply the infomation presented.

(6) Sample Forms and Checklists.
Courses that provide attendees with sample forms and checklists to be used after the course is completed greatly increase the likelihood that the information presented during the course will be retained and applied correctly. Forms and checklists force the attendee to follow the guidelines presented during the course and can be used until the attendee is comfortable with the using the newly learned information. These forms and checklists are also sometimes required to be used, and being provided with samples ensures that the attendee will use forms in compliance with the requirements.

(7) Comprehensive Course Development. 
A good training course is developed by those with extensive experience with the information being taught. By knowing first hand what skills tend to cause the most difficulties for collectors, a course can be developed to overcome these difficulties and ensure that proficiency is attained in all areas of specimen collections. DATIA's course is the only peer developed and industry reviewed course currently available. A committee of industry professionals spent over a year preparing the agenda and materials for the DATIA collector training program. This program was reviewed multiple times by DATIA's committee and finally reviewed by the DOT for accuracy.

(8) Follow-up Materials. A good training course doesn't end when the attendee walks out of the door at 5:00 pm. Be sure that you receive reference materials to refer to when questions arise and/or information on how to contact your instructor for questions. In addition, be sure that you can be easily updated on changes to the information that you were taught. Good training occurs daily. DATIA provides its attendees with a comprehensive manual on the collection procedures and problem scenarios along with copies of the regulations concerning specimen collections. Through the DATIA website, emails, and letters, DATIA alerts its CPCTs to changes in specimen collection procedures and standards. Most recently, DATIA alerted its CPCTs to new information concerning the new 5-part CCF and how to correctly complete the form.

DATIA offers its training courses regionally across the nation, review information on our upcoming courses. Make plans now to attend a course in your area….remember you do not need to rush to attend the first course offered. Please contact us at [email protected] if you have any questions.