What do you do when a state DOT inspector comes to your collection site for an audit or inspection and instructs you to do something that is not required by or contradicts Part 40 regulations or the SAMHSA Specimen Collection Guidelines? For example, the state DOT inspector might instruct that prior to every collection your collectors must take every donor into the restroom and lift the lid of the commode to show the donor that bluing has been added to the toilet tank.
The key to responding to state DOT inspectors is knowing that there is only one set of regulations and guidelines that you must follow: the Federal regulations inCFR Part 40. There is not a separate set of state regulations that control how to perform a DOT specimen collection in your state.
Here is our recommendation for what to do when confronted by a state DOT inspector who instructs you to add additional steps to the specimen collection procedure, or instructs you to change your procedure in a way that conflicts with the Part 40 procedure. Politely ask the inspector to show you the relevant section of the Federal Part 40 regulation or Specimen Collection Guideline that documents their request. If the inspector cannot produce the appropriate documentation, then you have reasonable grounds to object to the inspector’s instructions.
If the inspector can produce the appropriate documentation, then perhaps there is a misunderstanding on your part or the inspector’s part in reading or interpreting the written procedure. At that point you can do further research on the DOT Office of Drug & Alcohol Policy & Compliance website orAlcoPro’s Knowledge Base.
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