Direct Observation Collections All Around?
Question:
“A trucking company wants to do all of their collections for DOT-covered employees using direct observation procedures. Is this allowable?”
Answer:
A DOT-covered employer, such as a trucking company, is only allowed to use direct observation procedures for reasons allowed by the rules (49 CFR Part 40). DOT-covered employers include those in the trucking industry, airlines, railway, pipeline, transit and others. These employers are required to use the DOT’s Direct Observation procedures only for the following reasons, and for only these reasons:
- The employee attempts to tamper with his or her specimen at the collection site; such as:
- The specimen temperature is outside the acceptable range;
- The specimen shows signs of tampering, such as unusual color or odor;
- The collector finds an item in the employee’s pockets or wallet which appears to be brought into the site to contaminate a specimen, or the collector observes conduct suggesting tampering.
- The collection is for a return-to-duty or follow-up test.
- The MRO orders a direct observation collection for certain reasons allowed under the regulations.
Therefore, a company may not arbitrarily decide to do all of their DOT drug tests under direct observation, nor should they direct their service agents (such as a collection site) to do so.
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