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Ensuring workplace safety through certified training programs

As a seasoned trainer, collector, and a person who has been a part of the drug and alcohol testing industry for over 30 years, I have found that many people are not trained properly in the regulations, procedure, all the requirements mandated. And those trainers are training others in the industry. My goal is to train the required information for collecting, consulting, and training transportation employers, manufactured employers, construction employers- all the companies that the employees are considered safety sensitive? Employers need to have drug and alcohol testing to show that the employees are not using drugs or abusing alcohol while they're working to keep fellow workers, themselves and the public-SAFE.

To become a trainer, you really need to have good training. I always suggest that trainers should belong to an association where they can get great training and attend the training course to keep up with the regulations. As a Founder/ Organizer, Board Member, and Training and Certification Chair of National Drug and Alcohol Screening Association I would suggest being a member. To join go to https://ndasa.com. NDASA has training that was developed by the experts in the industry. All the trainers at D.ACT are Certified Professional Collector Trainers (CPCT ™) for drug urine collections and oral fluid collections. Also, the trainers are Certified Designated Employee Representative Trainers and Reasonable Suspicion Trainers.

In contacting individuals/ companies for any drug and alcohol training get proof of training from the trainer and make sure they are certified trainers who have done training for at least one year or at the minimum done drug and or alcohol collections for one year.

In this ever-changing industry trainers need to be aware of and keep up on any changes and reflect on those changes in their training. There are many changes throughout the year(s) and trainers must make those changes in their training and not keep doing the same training year after year. It's not good or advisable to use outdated training.

Now for a fun fact. When I started to do urine drug collections back in the late 80's we did all collections as observed collections and not gender specific. Thank goodness the regulations changed!

The current: DOT's Direct Observation Procedures

1. DOT's 49 CFR Part 40 directly observed collections are authorized and required only when:

• The employee attempts to tamper with his or her specimen at the collection site.

• The specimen temperature is outside the acceptable range;

• The specimen shows signs of tampering ~ unusual color / odor / characteristic; or

• 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 notes conduct suggesting tampering.

• The Medical Review Officer (MRO) orders the direct observation because:

• The employee has no legitimate medical reason for certain atypical laboratory results; or

• The employee's positive or refusal [adulterated / substituted] test result had to be cancelled because the split specimen test could not be performed (for example, the split was not collected).

• The test is a Follow-Up test or a Return-to-Duty test.

2. The observer must be the same gender as the employee.

3. If the collector is not the observer, the collector must instruct the observer about the procedures for checking the employee for prosthetic or other devices designed to carry "clean" urine and urine substitutes AND for watching the employee urinate into the collection container.

• The observer requests the employee to raise his or her shirt, blouse or dress / skirt, as appropriate, above the waist, just above the navel; and lower clothing and underpants to mid-thigh and show the observer, by turning around, that the employee does not have such a device.

• If The Employee Has A Device: The observer immediately notifies the collector; the collector stops the collection; and the collector thoroughly documents the circumstances surrounding the event in the remarks section of CCF. The collector notifies the DER. This is a refusal to test.

• If The Employee Does Not Have A Device: The employee is permitted to return clothing to its proper position for the observed collection. The observer must watch the urine go from the employee's body into the collection container. The observer must watch as the employee takes the specimen to the collector. The collector then completes the collection process.

4. Failure of the employee to permit any part of the direct observation procedure is a refusal to test.

Regulatory Topic: Drug and Alcohol Testing

Effective Date: Wednesday, October 10, 2012

Issued Date: Monday, August 31, 2009

Another fun fact:

ALL ORAL FLUID COLLECTIONS WILL BE DIRECT OBSERVED.

Stay tune for more of this type of information from Jan @ D.ACT

Author Bio

Jan Kornmann

Author photo

Jan Kornmann, CEO/owner of KorManagement Services LLC, has over 30 years of experience in workplace drug and alcohol testing. A founding member of NDASA, she has served as Board Secretary, chaired the Training and Certification Committee, and held multiple leadership roles. Recognized for her expert training in DOT and non-DOT compliance, she offers courses on reasonable suspicion, specimen collection, and alcohol testing. Jan holds a Medical Laboratory Technician degree from the Medical Institute of Minnesota and has managed various clinical teams.

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