• No Designated Employee Representative (DER) contact information on file:  According to 49 CRF, Part 40.215, the employer is required to provide the name and telephone number of a DER. A BAT or Specimen Collector must have a contact to ask about issues that may arise during the testing process. A best practice in this testing challenge is to proactively establish one or two alternate employer contacts and keep on file all daytime, nighttime and weekend phone numbers. To maintain your contact database, designate an intern or administrative assistant in your office or clinic to periodically follow up with DERs to verify if the data you have on file remains accurate.  If you prefer a more automated approach, there are data cleansing tools or resources that can be used to better clean and maintain your data. Data.com tied with Salesforce or other CRM programs can help verify data for accuracy and with a click of a button a customer record can be instantly updated. Most CRM programs will allow you to automate periodic emails inviting your contacts to supply you with any changes to their contact information, thus keeping your customer data squeaky clean.
• No reason for the test provided:  It is incumbent upon the employer to provide the reason for the test.  Don’t rely on the donor or subject to provide you with this information.  In most all cases, they won’t know. You also don’t want to run the risk of asking the donor or subject only to document incorrect information.  Solving this problem goes back to solving the first challenge. If you have all the DER’s correct contact information, you will have a much better chance of getting this information first hand. If you cannot reach the DER and are unsure about the reason to test, perform the test using a non-DOT form.  You can always write an affidavit later to make it a DOT test.
• Improper identification:  Step one of the testing process is to collect and review the donor’s identification to ensure you are testing the right person. It is not uncommon for a donor or subject to arrive at the testing site without proper identification. It is important to note that you are in control of the testing process, which includes insisting on the proper form of identification in order to initiate the testing process.  The DOT regulations recognize the following acceptable types of employee identification:
  • A Government issued photo ID, such as a driver’s license, passport, military or parole ID
  • A company provided photo ID
  • If a physical form of the aforementioned identification cannot be produced, the DOT regulations allow for positive identification made by the direct supervisor or DER.

  Photocopies or facsimilies of any of these forms of identification or positive identification made by friends or coworkers should not be accepted. In the case of owner operators, if these forms of photo identification are not available, two forms of identification bearing their signature must be provided. Some examples of this are, credit cards, voter registration card or a social security card. If these are the only forms of identification provided by an owner operator, it is important to check the signature provided by the donor or subject on the ATF or CCF form to ensure it matches with the signature on these non-photo forms of identification. Additionally, if the owner operator can only produce forms of identification bearing their signature, then you must document the forms of identification provided in the “Remarks” section of your ATF or CCF form.

Being familiar with these common alcohol and drug testing challenges and solutions will ensure a much smoother testing process.