With the approval of oral fluid drug testing for the United Stated Department of Transportation (DOT) drug and alcohol testing program; oral fluid specimen collector training will be required. Those qualified for DOT urine specimen collections and interested in oral fluid collections will also be required to be trained and qualified for oral fluid specimen collections. Proficiency demonstration (Mock Collections) for oral fluid specimen collections will be required.
Drug testing industry collectors and in house employer representatives may be interested in training and qualification for DOT oral fluid specimen collections.
Learn more with upcoming webinars on DOT oral fluid drug testing, these are not collector trainings.
In this post we will cover the following:
DOT Final Rule on DOT Oral Fluid Drug Testing
DOT published the final rule for oral fluid drug testing May 2, 2023; and it takes effect June 1, 2023. No labs are currently certified for oral fluid drug testing so the actual oral fluid drug testing will not likely be operational until late 2023 or early 2024.
When Will DOT Oral Fluid Specimen Collector Training Be Available
Once at least two labs are certified for oral fluid drug testing, National Drug Screening (NDS) will offer DOT Oral Fluid Specimen Collector Training with proficiency demonstrations (mock collections). NDS will offer live training, computer-based remote training, webinar training, custom webinar training and custom live training.
National Drug Screening (NDS) will provide a comprehensive training manual for DOT oral fluid drug testing along with video links of the actual collection process. Oral fluid mock collections will be available remotely with computer webcam or with live sessions.
DOT Regulations on Oral Fluid Collections
DOT has updated 49 CFR Pat 40 to include training requirements for DOT oral fluid drug testing. The preamble to the final rule from DOT states:
“We have added a new § 40.35 to separately specify the requirements for collectors of urine and oral fluid specimens, respectively. Adding this section required renumbering existing § 40.35 to become § 40.36. We have paralleled the new § 40.35 as closely as possible to our existing training requirements for urine specimen collectors in § 40.33. We have added language to parallel § 40.213(b) for training on the specific devices.” DOT also stated “We have adopted the requirement for a collector to obtain training to proficiency in the operation of the particular oral fluid collection device(s) you will be using.”
Similar to the DOT publication Urine Specimen Collection Guidelines, DOT will also provide an Oral Fluid Specimen Collection Guidelines publication. This Oral Fluid Specimen
Collection Guidelines publication will be the regulatory guidance for the requirements for oral fluid collectors as outlined in the new Part 40 section 40.35. Once the Oral Fluid Specimen
Collection Guidelines are published, NDS will make this available as part of our training programs.
What are the Specimen Collector Requirements for DOT Oral Fluid Collections?
- Be knowledgeable about the current “DOT Oral Fluid Specimen Collection Procedures Guidelines,” and DOT agency regulations applicable to the employers for whom you perform collections.
- Receive qualification training covering:
- Testing procedures
- Proficiency in the operation of the particular oral fluid collection device(s) the collector will be using
- All steps necessary to complete a collection correctly and the proper completion and transmission of the CCF
- “Problem” collections (e.g., situations like “dry mouth” and attempts to tamper with a specimen)
- Fatal flaws, correctable flaws, and how to correct problems in collections;
- 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
- Complete Initial proficiency demonstration – five consecutive error-free mock collections for each device the collector will use
- Refresher training at lease every five years
- Error correction training after a fatal flaw
- Maintain documentation of oral fluid collector training, proficiency demonstration and refresher training
What are the required mock collections for DOT oral fluid drug testing?
The five mock collections for each collection device must include one uneventful collection scenario, one insufficient specimen quantity scenario; one scenario in which the employee has something in their mouth that might interfere with the collection; one scenario in which the employee attempts to tamper with the specimen; and one scenario in which the employee refuses to sign the CCF. For each of the five mock collections, the collector must check the expiration date of the device, show it to the employee, and record the date on the CCF used. The collector must ensure, when applying the labels, they do not cover the expiration dates.
What are the Requirements for Training on DOT Oral Fluid Collections and Monitoring Proficiency Demonstrations?
- One who has regularly conducted oral fluid DOT drug test collections for a period of at least one year
- One who has conducted DOT oral fluid collector training for at least one year; or
- One who has successfully completed a “train the trainer” course.
Joe Reilly, NDS President has started the process to complete the train the trainer course for DOT oral fluid specimen collections. He will be attending the first industry train the trainer course for DOT oral fluid drug testing. This course entitled DOT Oral Fluid Trainer Certification will be provided May 23, 2023, at the annual conference of the National Drug & Alcohol Screening Association (NDASA).
Here is a link for a summary of the current status of DOT Oral Fluid Drug Testing, Collections & Mocks