What are the DOT’s Direct Observation Procedures?

Last updated on February 21st, 2021 at 04:08 pm

The Department of Transportation (DOT) requires all employees to be drug tested for pre-employment, post-accident and in some cases, at random. If an employee has tampered with a previous sample or the collection site has reasonable suspicion of foul play, the DOT can then require a Direct Observation Test. This will prevent any further tampering and provide the department with the information it needs on their employees. Below, we outline the DOT’s Direct Observation policy so you know what to expect if this type of test is requested:

The DOT requires directly observed collections when:

  • The employee tries to tamper with his/her specimen at the collection site.

  • The specimen is outside the temperature range, carries an unusual odor or has any discoloration.

The Medical Review Officer orders direct observation because:

  • The employee has no justified medical condition to yield a certain lab result.

  • If the test is a Follow-Up or Return-To-Duty test.

The rules for direct observation are as follows:

  • The observer MUST be the same gender as the person they are testing.

  • If the collector is not the observer (due to gender difference), the collector must instruct the observer on how to detect any kind of foul play.

  • The observer can ask the employee to raise his/her shirt to the navel and lower pants to mid-thigh level. They can then ask the employee to turn around and make sure there are no hidden tampering devices.

  • IF THE EMPLOYEE HAS A DEVICE: The observer will notify the collector and the collector will document the circumstances in the chain of custody. This is the equivalent of a ‘Refusal to Test.’

  • IF THE EMPLOYEE DOES NOT HAVE A DEVICE: He or she can then return their clothing to normal position and begin observation. The observer must watch the specimen enter the cup and then also observe the specimen as it is handed to the collector. This ensures no foul play throughout the entirety of the test.

At National Drug Screening, we specialize in DOT Compliance and we help DOT regulated employers pass their drug screening audits. The Direct Observation process outlined above is important and it is necessary in some testing environments.


For all of your DOT Compliance concerns, call National Drug Screening at 866-843-4545 or visit our comprehensive web pages on DOT Compliance.

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What are the DOT’s Direct Observation Procedures?

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