The Importance of Drug Testing Audits

Loss of valuable licenses, reputation, business and revenue are just a few examples of the importance of drug testing audits. Many service agents, such as Consortiums/Third party Administrators (C/TPAs), as well as employers, utilize collection facilities without ever stepping foot inside the facility to fully evaluate the operations or facilities. The Department of Transportation has guidelines for collection facilities to follow in order to perform federal drug and alcohol tests. Although employers contract with service agents and collection sites to manage and assist with their drug and alcohol testing programs, the responsibility of ensuring these programs are compliant with federal regulations, falls upon the employer, making regular audits an important part of the process.

Before we talk about the importance of drug testing audits, let’s examine some of the most common specimen collection for drug testing mistakes. According to an auditor with the Federal Transit Administration, the agency has compiled statistics from 1000 collection facilities over the past 7 years. Here are the top 5 mistakes:

• 35% of collectors do not require donors to empty their pockets prior to entering the restroom to provide a sample. Therefore, a donor has a 1 in 3 chance of taking an adulterant, substituted specimen or contraband into the restroom.
• 41% of collection sites do not sufficiently secure the enclosure or restroom. In other words, the donor may have access to trash cans, low ceiling tiles and medicine cabinets for disposing of contraband. Also, the donor may have access to water, such as sinks, which can be used to dilute a specimen.
• 56% of collectors will date the seals and instruct the donor to initial the specimen seals while the seals are still attached to the Custody and Control Form (CCF). This is a noncompliant action that goes directly against the collection process as it is stated in Step 3 located on the front of the CCF and on the back of the donor’s copy.
• 70% of collectors complete Step 4 of the CCF prior to completing Step 5 of the CCF. This may sound like a minor point to most people, but DOT is very specific in the process for collection urine specimens. Let’s consider a litigation response in this scenario. An attorney’s question to the collector might sound like this, “If you conduct this process incorrectly and out of sequence, what other aspects of the collection process do you perform incorrectly?”
• 75% of all collectors do not show the donor the instructions on the back of the CCF or the Alcohol Testing Form (ATF). That’s 3 out of 4 collectors! One of the main responsibilities for the technicians is to inform the donor of the collection procedures and to show the donor the back of the CCF containing those steps.

These are prevalent errors committed daily. As an employer, TPA or Consortium, you must not assume the service agents and collection sites are strictly adhering to DOT’s 49 CFR Part 40. Here are some of the main reasons why audits are important for all parties involved in drug and alcohol testing.

Regular audits of your service agent are a great way to ensure your drug testing programs are compliant with federal regulations and furthers your company’s knowledge of DOT testing protocols. As such, you are able to take a leadership role in the testing process. In your search for an ideal partner, you should only select one that is open to external audits.

If you are the service agent or collection site, you need to remember that the employer is your customer and if you want to make the customer happy, external audits should be met with open arms and the right attitude. Regular external drug testing audits as well as DOT appointed audits are the best way to keep your operations in tight compliance and your staff knowledgeable about the regulations. Regular drug testing audits are also the best plan to preserve your business, reputation and subsequent revenues.

If your company has questions regarding compliance audits or would like to enlist AlcoPro to conduct a compliance audit, please feel free to contact us at 800.227.9890.