In Part 2 of our DER series, we break down the exact steps—and common errors in audits—across both alcohol and urine drug testing procedures. If your clinic or collection site hasn’t revisited your processes recently, this is your cue to review them step by step—before an auditor does.
Part 2
Mastering Your Role as a Designated Employer Representative (DER):
Step-by-Step Collection Procedures
Alcohol Testing Procedures: From ID Check to Splitting Samples
BEFORE THE TEST
- Privacy
One donor, one room. No exceptions.
- Donor Identification
Acceptable: Driver’s license, employer-issued badge, or any government photo ID
Not acceptable: coworker confirmation such as “Johnny from the crew says it’s him!”, photos of ID, non-photo ID
- Collector ID
Provide your name/business ID if asked—no photo ID required.
- Explain the Test
Review the testing procedures with the donor on the back of the ATF form
"You will blow into the alcohol device. If your result is 0.02 or higher, you’ll take a confirmation test..."
- Complete Step 1 of ATF
Full name, employee ID number, employer info, DER name and phone, test reason
CDL replaces SSN for FMCSA tests.
STEP 2: DONOR CONSENT
- Donor must sign Step 2 before testing begins.
No signature = No test. Document and inform DER.
SCREENING TEST
- Show unique test number
- Donor opens a sealed mouthpiece
- Conduct an air blank
- Donor provides breath sample
RESULTS: < 0.02 BAC
- Sign/date Step 3 after printout is attached
- The printout should be attached on EACH copy of the ATF.
- Distribute ATF copies
RESULTS: ≥ 0.02 BAC — Confirmation Test Required
- Explain the 15-minute wait:
"During this time, you may not eat, drink, belch, or place anything in your mouth. You must stay with me."
- Document that instructions were given
- Conduct new air blank and second test with new mouthpiece
- Print result and affix
- Complete Step 3 (check wait box) and have donor sign Step 4 (only if result ≥ 0.02)
- Notify DER
Important: During that 15-minute window, the collector should not call the DER or leave the room. Stay with the donor and protect the integrity of the test.
Urine Drug Testing: From Collection Site Setup to Final Shipment
SET UP AND SECURE THE COLLECTION SITE
- Limit access—only one donor at a time
- Shut off water; place bluing agent in toilet; tape handles using tamper-evident tape (not painters tape), and remove anything a donor could use to hide a substance
- Remove cleaning supplies and storage risks
- Post “Limited Access” signs
- Secure ceiling tiles, windows, and cabinets
DONOR IDENTIFICATION
- Accept photo ID from a valid source
- For self-employed donors: two signature-matching items permitted
- If identity cannot be confirmed, stop and call the DER
PRE-COLLECTION BRIEFING
- Donor removes jackets, hats, gloves
- Empties pockets (wallet and footwear may stay)
- Washes hands
- Personal items stored away
STEP 1: CCF COMPLETION
- Confirm DOT vs Non-DOT
- Enter employer, MRO, DER, authority, reason
SAMPLE COLLECTION
- Donor selects sealed cup
- No flushing; minimum 45mL sample
- Cup returned directly to collector
Critical: Monitoring the sample. The container must stay in the collector’s and donor’s line of sight at all times. If it leaves either’s view, the test could be disputed.
STEP 2: SPECIMEN VALIDATION
- Check temperature (90–100°F)
- Inspect for adulteration
- Record in CCF
SAMPLE SPLIT AND SEAL
- Transfer: 30mL to Bottle A, 15mL to Bottle B
- Attach tamper seals and matching IDs
- Donor initials bottles (not form)
- Discard remainder in view of donor
FINAL DOCUMENTATION
- Donor completes Step 5 (page 2)
- Collector signs Step 4 (page 1), provides Copy 5
- Package bottles + Copy 1 in tamper-evident bag
- Ship from secure location
Common collector error: Collectors often sign or date too early or in the wrong place. That’s how you end up with audit flags.
⚠️ Shy Bladder, Refusals, and Out-of-Range Temps
INSUFFICIENT SAMPLE
- Start collection anyway
- Note start time in CCF remarks (e.g., “INSF at 13:20 / 15mL / 5oz water”)
- Allow 40oz water over 3 hours; document all attempts
OUT-OF-RANGE TEMP
- Mark “No” in Step 2
- Complete collection, seal, label as usual
- Start direct observation using new CCF
- Link both CCFs with specimen ID note
REFUSALS
- Step 5 signature refusal ≠ test refusal
Write “Refused to Sign” and continue
- If donor refuses to drink, it is not a refusal to test
- Donor must follow your instructions
The top audit triggers
What FTA Auditors Catch—And You Can Prevent
The Federal Transit Administration’s (FTA) audits reveal patterns in collection site errors. The percentages below reflect how often each mistake was observed across audited sites—meaning they’re not rare, and they’re absolutely correctable:
- Failing to explain procedures or show instructions (74%)
- Collectors completing Step 4 before donor signs Step 5 (69%)
- Letting donors date seals (55%)—collector's job only
- Insecure enclosures (44%)
- Pockets not emptied (38%)
- Missing bluing agent (32%)
- No pre-test handwashing (32%)
- Enclosure not checked before test (30%)
- Outerwear not removed (28%)
- Initialing seals while still on CCF (23%)
- Taking wallet/cash from donor (21%)
- Skipping review of Step 5 entries (20%)
Other common issues:
- Using outdated or non-federal CCFs
- Missing CCF data: employer, MRO, DOT authority
- Not logging full shy bladder details
- Failing to circle AM/PM or name the courier
- Observation by wrong-gender collector
Best practice tip:
If your clinic or collection sites haven’t gone through a mock audit recently, it’s worth doing. It’s always better to catch issues—before an auditor does.
✔️ Strengthen Your DER Practices
A solid program doesn’t run on autopilot. The DER role isn’t just about oversight—it’s about being ready to act when something doesn’t go as planned. Day to day, that means:
- Know the rules—and verify they're followed
- Review site setup regularly
- Train and retrain collectors on protocol
- Be accessible during collections
- Run internal mock audits
- Keep paperwork tidy and test-ready
Need help with your collection process?
Not sure what’s actually happening during collections? If your collectors are struggling or you’re unsure what’s being done at your site, we can help. Whether you’re concerned about paperwork, protocol, or audit readiness, we can help you spot gaps, run mock audits, and strengthen your site’s procedures.
We’re here to support you!
Need a checklist or want help running one? Contact us and we’ll walk through it with you.
📩 Email us at DAT@sparkts.net
📞 844-827-5371
Keep Building Your DER Skills
Each part of the Mastering Your DER Role series builds on the last covering real scenarios, processes, and best practices for testing and compliance.
Our drug and alcohol testing platform is built specifically for transportation professionals. They make it easier to track compliance, manage exceptions, and support your team through testing scenarios.
🎥 Watch the full webinar video with Holly Rainwater for detailed guidance, participant Q&A, and real-world examples. 👉 Watch the video here
Continue the series: Mastering Your DER Role
Part 1: What Every DER Should Know from Day One
🎥 Webinar video
Part 3: Test Exceptions
🎥 Webinar video
Part 4: Return to Work
🎥 Webinar video
📚 Catch up on our demand webinars and find more practical resources at https://www.sparkts.net/on-demand-webinars.
Spark TS, a railcube company, is a leader in offering safety and compliance software and services solutions for the railroad and transportation industries. Spark TS set the standards for the CFR Part 243 Training Rule implementation with Rail Tasker™, a railroad mobile application for building safer work environments including operations testing, safety alert briefings, training, and are industry experts in CFR Part 40 DOT Workplace Drug and Alcohol Testing Programs. Spark TS, a railcube company provides Hours of Services (HOS), Time Tracking, Electronic Rule Books, and Asset Management services.
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