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Compliance, Drug and Alcohol Testing

10 Steps to Collection Site Security and Integrity – What Are You Doing to Assist Your Collector?

The Department of Transportation (DOT) has done a good job providing collection agents with information on maintaining the integrity of a collection event.  As a DOT employer, how good of a job have you done in ensuring that your collector can complete an onsite or mobile DOT collection event within these guidelines?  

Here is a list of the DOT’s 10 Steps to Collection Site Security and Integrity with a list of items for employers to consider under each.

1. Pay careful attention to employees throughout the collection process.

Where is the collector performing the collection? Have you provided them with a secured / quiet location where the collector controls the entire collection process? Where is the manager during the collection process?

2. Ensure that there is no unauthorized access into the collection areas and that undetected access (e.g., through a door not in view) is not possible.

Are there window coverings on your windows…including the windows on the door?   If you are using frosted glass, make sure no one can see in.

3. Make sure that employees show proper picture ID.

What if the donor does not bring his/her ID, is someone nearby to verify his/her identity?

4. Make sure employees empty pockets; remove outer garments (e.g., coveralls, jacket, coat, hat); leave briefcases, purses, and bags behind; and wash their hands.

Is there a location available for the collector to secure these items during the collection process? Where is the donor’s cell phone – it should also be left behind.

5. Maintain personal control of the specimen and CCF at all times during the collection.

Why is the collector walking down the hall carrying an open specimen container?  Provide a writing surface in the bathroom so the collection can be split and sealed immediately after the collection inside the bathroom.

6. Secure any water sources or otherwise make them unavailable to employees (e.g., turn off water inlet, tape handles to prevent opening faucets, secure tank lids).

Even though automatic faucets and toilets are the norm and somewhat of a luxury, they are very difficult to secure during the collection process.  Standard faucets and toilets are preferred for collectors.

7. Ensure that the water in the toilet and tank (if applicable) has a bluing (coloring) agent. Tape or otherwise secure shut any movable toilet tank top, or put bluing in the tank.

Reiterating….be leery of automatic toilets.  They are very difficult to secure.

8. Ensure that no soap, disinfectants, cleaning agents, or other possible adulterants are present.

Sometimes bathrooms take on the role of a storage closet. As an employer, if you don’t remove these items, your collector will need to remove or secure these items on his/her own.  Use liquid soap in the bathroom so donors cannot use bar soap as an adulterant.

9. Inspect the site to ensure that no foreign or unauthorized substances are present.

Look around, where can items be hidden, i.e., inside toilet paper roll holders, behind to disposable seat cover container, in the sink cabinet.

10. Secure areas and items (e.g., ledges, trash receptacles, paper towel holders, under-sink areas, ceiling tiles) that appear suitable for concealing contaminants.

Provide the collector with a collection location that doesn’t allow for tampering.  Locker rooms and shower areas are very difficult to secure.  Donors can hide adulterants in wall-mounted garbage cans, paper towel and toilet paper holders.  Even though these items promote a clean bathroom, they make it very difficult for the collector properly secure.

See DOT’s original article here:  https://www.transportation.gov/odapc/dot-10-steps-collection-site-security-and-integrity-english

What to learn more? Join us for a webinar on this topic later this month here.

Did you know Spark Training Solutions now offers Drug and Alcohol Program Management Solutions?  Our drug and alcohol testing services are designed in partnership with you to allow the Designated Employer Representative (DER) to leverage online tools and an industry network so that they can avoid unnecessary administrative tasks and focus on managing a compliant and effective program.  We can help! Contact us at info@sparkts.net 

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