{"id":50882,"date":"2014-09-01T13:19:57","date_gmt":"2014-09-01T13:19:57","guid":{"rendered":"https:\/\/www.nationaldrugscreening.com\/?p=50882"},"modified":"2023-09-06T10:29:47","modified_gmt":"2023-09-06T15:29:47","slug":"collection-audits","status":"publish","type":"post","link":"https:\/\/www.nationaldrugscreening.com\/blogs\/collection-audits\/","title":{"rendered":"Collection Audits"},"content":{"rendered":"\r\n<p>By <a href=\"\/joe-reilly-bio\/\" target=\"_blank\" rel=\"noreferrer noopener\" aria-label=\"Joe Reilly (opens in a new tab)\">Joe Reilly<\/a>, Past Chairman DATIA<\/p>\r\n\r\n\r\n\r\n<p>Collection sites are often audited by FAA and FTA auditors and recently I have been retained by several regional and national collection site operators to provide audits of their company owned collection sites and mobile collections.\u00a0 Audits are a good thing because if you find out what your collectors are doing wrong, you can make the appropriate corrections and get the appropriate training completed so that your collectors eliminate mistakes that cause non-compliance and fatal flaws.<\/p>\r\n\r\n\r\n\r\n<p>GOVERNMENT ACCOUNTABILITY OFFICE (GAO) 2007 UNDERCOVER INVESTIGATION FINDINGS<\/p>\r\n\r\n\r\n\r\n<ul>\r\n<li><em>75% failed to restrict access to items that could be used to adulterate or dilute the urine specimen; individuals had access to soap, air freshener, and other potential adulterants in the privacy enclosure.<\/em><\/li>\r\n<li><em>67% had access to running water in the privacy enclosure.<\/em><\/li>\r\n<li><em>42% failed to ask the employee to empty his\/her pockets and display items to ensure no items were present that could be used to adulterate the specimen. The GAO Investigators brought drug masking agents and synthetic urine (bought over the Internet) into the collection sites and mixed them with their specimen without being detected by trained collection site personnel.<\/em><\/li>\r\n<li><em>19% failed to check the temperature of the specimen.<\/em><\/li>\r\n<li><em>17% failed to add bluing agent in the toilet water or secure the tank with tape<\/em><\/li>\r\n<\/ul>\r\n\r\n\r\n\r\n<p>You might remember back in 2007 media exposure that exposed procedural errors in direct violation of the testing procedures defined in 49 CFR Part 40.\u00a0 An NBC Nightly News news story, aired on November 1, 2007, and reported the findings of a Government Accountability Office (GAO) undercover investigation that found it was surprisingly easy to cheat on random drug tests. The story was picked up by many other media outlets including FOX news. The news reports were aimed specifically at truck drivers.\u00a0 The box to the right lists a summary of those findings and in addition investigators used bogus identification to initiate the testing process in all (100%) of the 24 sites that were investigated demonstrating the ease at which safety-sensitive employees can send other (presumably drug-free) individuals to take the tests for them. Only two of the twenty-four sites followed all of the remainder of the testing procedures tested by the Investigators. The remaining twenty-two (91.7%) had two or more serious protocol violations.<\/p>\r\n\r\n\r\n\r\n<p>Reviewing over 100 audits performed over the past 12 months, I am proud to say that collection sites are doing better but there are still issues that can certainly be corrected if collection site operators would pay more attention to DOT training requirements.\u00a0 Qualification training as a <strong><a href=\"https:\/\/www.nationaldrugscreening.com\/dot-drug-test\/\">DOT specimen collector<\/a><\/strong> is not difficult to obtain, but it is also not a quick easy process for a new collector.\u00a0 When I train new collectors, there is a minimum 6 hour training process and mock collections always take at least two hours.<\/p>\r\n\r\n\r\n\r\n<p>So what are we finding on current audits?\u00a0 You might be surprised at some of these findings.<\/p>\r\n\r\n\r\n\r\n<ul>\r\n<li>Very common in my audit finding is that prior to the collection, the collector failed to explain collection procedures or show the instructions on the back of the CCF.\u00a0 It is important to review with your collectors 49 CFR Part 40 Section 40.61 &#8211;<em>\u00a0(e) Explain the basic collection procedure to the employee, including showing the employee the instructions on the back of the CCF.<\/em>\u00a0\u00a0\u00a0\u00a0\u00a0<\/li>\r\n<li>A collector becomes familiar with the donor after 12 follow up tests and neglects to check the donors ID.\u00a0 In addition the procedures for direct observation are not followed properly.\u00a0 Familiarly does not grant the collector a pass to not follow strict collection procedures, always perform the collection the same way every time with every donor.<\/li>\r\n<li>Collector has a temperature out of range situation which goes into a Shy Bladder process for the second collection.\u00a0 The donor gets frustrated after 1 hour and leaves the collection site stating \u201cI don\u2019t have time for this\u201d.\u00a0 Collector then throws away the first specimen collected and all of the paperwork.\u00a0 This of course is a major issue because now there is no documentation of anything that occurred.<\/li>\r\n<li>In another temperature out of range situation, the collector starts the second collection process immediately after receiving the first specimen.\u00a0 Upon receiving the second specimen, the collector is pouring off the specimen into the four specimen vials and filling out the Custody and Control forms (CCF) simultaneously.\u00a0 Of course what happens is that the specimen seals are put on the incorrect bottles and at the lab the specimen ID numbers on the bottles do not match the specimen ID numbers on the CCF forms.<\/li>\r\n<li>The practice of altering a form when the correct form is not available seems to come up often in our audits.\u00a0 Some collectors are stating that altering a form is not allowed by DOT.\u00a0 Other collectors when altering forms, do not alter the forms properly.\u00a0 DOT is clear that when the collector has no \u201cblank\u201d CCFs and the CCFs on-hand contain inaccurate pre-printed employer, MRO, collection site, and\/or laboratory information, the collector is permitted to \u201cline through\u201d the inaccurate information and insert legibly the proper information. I always advise collectors to be as neat as possible when altering a form and provide the correct account number for the test.\u00a0 The collector should also \u201cline through\u201d barcodes on the form so that at the laboratory the new printed information is utilized.<\/li>\r\n<li>Pre-filling out the CCF is a very common audit item discovered.\u00a0 Collectors like to pre-date the specimen security seals, pre-print the collector name, date and time on Step 4; and in some cases pre-sign on Step 4.\u00a0 In one large mobile collection event I audited, the two collectors handed out the CCF forms to 35 donors and asked them to initial the specimen security seals and complete Step 5 in its entirety.\u00a0 I cannot tell you how messed up this collection became with 4 fatal flaws and 12 correctable errors.<\/li>\r\n<li>Several audits have revealed collections sites that do not properly secure the bathroom to be used for the collection.\u00a0 Some have made a half-hearted attempt at this with partial security and integrity measures, and some just plain do not make any proper attempt at all.\u00a0 One collector used bleach as the bluing agent for the toilet.\u00a0 I always highly recommend DOT\u2019s 10 Steps to Collection Site Security and Integrity Video and DOT\u2019s 10 Steps to Collection Site Security and Integrity poster.\u00a0 Both are available from DOT at\u00a0<a href=\"http:\/\/www.dot.gov\/odapc\">www.dot.gov\/odapc<\/a>\u00a0and both are excellent tools to help a facility learn how to properly secure a restroom for a DOT urine specimen collection.<\/li>\r\n<li>Lastly I have performed audits on collection sites for alcohol testing where the facility did not have an evidential breath alcohol testing device on hand.\u00a0 An instant alcohol test device was used and when I tested positive (with mouthwash); there was no mechanism for the collection site to perform the required confirmation testing.\u00a0 This was really a disaster as the collection site sent me on my way in my car after their knowledge that I was at a .09 alcohol level.\u00a0 They were lost in space as to how to properly arrange for the required confirmation testing.\u00a0\u00a0\u00a0<\/li>\r\n<\/ul>\r\n\r\n\r\n\r\n<p>As mentioned, still common in the specimen collection industry is the incorrect practice of filling out Step 4 of the CCF prior to starting the collection and pre dating the security seals.\u00a0 There are no shortcuts in the collection process, shortcuts lead to errors.\u00a0 The steps of the collection should be followed in order, and remember the DOT specimen collection order is 1, 2, 3, 5, and 4. \u00a0If the steps are filled out properly and in order, the percentage of mistakes that occur declines significantly.\u00a0 I cannot over emphasize the importance of taking your time with a collection and not taking short cuts; taking your leads to perfect collections.<\/p>\r\n\r\n\r\n\r\n<p>The <strong>Federal Transit Administration (FTA)<\/strong> is particularly aggressive on collection audits.\u00a0 FTA maintains a full-fledged clandestine collection site inspection program.\u00a0 Reports from April 2014 from the FTA indicate that 10% of collection sites audited showed critical failures.\u00a0 Most common findings included not checking identity of donor, not checking pockets and not requiring hand washing. These are easily correctable errors, review these items with your collectors today.<\/p>\r\n\r\n\r\n\r\n<p>Audits are occurring more and more.\u00a0 Several large collection services have begun doing internal audits.\u00a0 Of course the bottom line is proper training of collectors; and of course don\u2019t forget the DOT required refresher training and proficiency demonstration every five years.<\/p>\r\n\r\n\r\n\r\n<p>Why is all of this so important?\u00a0 There are several reasons. We hear often that the collector or collection site is the weakest link in the drug testing process \u2013 lets change this.\u00a0Errors in the collection process can lead to issues with <a href=\"https:\/\/www.nationaldrugscreening.com\/dot-drug-test\/\"><strong>DOT regulators<\/strong><\/a> and the employer might be out of compliance facing fines and other sanctions.\u00a0 What about the donor, the employee who might have an erroneous test result reported due to an error?\u00a0 On the legal front, you certainly want all collections done properly and consistently \u2013 if not, you might face issues from a plaintiff\u2019s attorney on any challenge or law suit from a donor who tested positive and lost his or her job.<\/p>\r\n\r\n\r\n\r\n<p>Without proper security and integrity in the collection process, donors have an opportunity to cheat on the test.\u00a0 This is a real safety issue as these same donors are driving on our public roads and may be under the influence of drugs or alcohol and undetected.<\/p>\r\n\r\n\r\n\r\n<p>Employers should be monitoring the collection facilities or collectors that they hire to make sure collections are being performed correctly and collectors are not making the errors noted above.\u00a0 It is an employer\u2019s responsibility to make sure that the process is in compliance.\u00a0 I urge employers to not use collection facilities that are not up to speed and not doing collections properly.\u00a0 Ask your collectors about their training and about their procedures.\u00a0 Many collectors have not received the five year refresher training required by DOT and many have done collections that resulted in fatal flaws and not completed the required error correction training and proficiency demonstration.\u00a0 Employers and their Designated Employer Representatives (DER\u2019s) need to be proactive in monitoring the work performed by the service agents in the DOT drug testing program.<\/p>\r\n\r\n\r\n\r\n<p>Collectors and collection site companies need to step up and make sure that the required training and refresher trainings are conducted by qualified trainers.\u00a0 There is no way this process can be learned by merely reading a pamphlet or watching a short video. \u00a0It is time to be proactive and eliminate and change the common phrase mentioned previously \u2013 collectors should not be the weakest link in the drug testing process.\u00a0 Qualified trainers should go through a train the trainer process like the DATIA Certified Professional Collector Trainer Program (CPCT).\u00a0 Don\u2019t have your existing collectors with bad habits train your new collectors.\u00a0<\/p>\r\n\r\n\r\n\r\n<p>When errors occur, many times the donor will more than likely have to go back for another specimen collection; this will annoy both the donor and the employer \u2013 and the employer will not want to pay for the first collection which resulted in the fatal flaw. As collectors, we need to avoid all of these issues and do it right the first time \u2013 the key is training and refresher training and keeping up to date with the regulations.\u00a0 Look to DATIA, which is now the\u00a0<a href=\"https:\/\/ndasa.com\/\" target=\"_blank\" rel=\"noopener\">National Drug &amp; Alcohol Screening Association (NDASA)<\/a>, for a great resource for regulatory updates, training and promotion of the highest possible standards for the industry.<\/p>\r\n\r\n\r\n\r\n<p><em>Joe Reilly entered the world of drug testing in 1993, he is well known throughout the industry and considered a leading expert on workplace drug testing issues. Joe served for nine years on the DATIA Board of Directors and served as Chairman of the Board from 2004\u20132008. Joe is currently a Regional Certified Professional Collector Trainer (RCPCT) for DATIA and is available for DATIA CPC training in all areas of Florida.\u00a0 He is also active in assisting buyers and sellers in the drug testing industry work through the merger and\/or acquisition process and provides various other consulting and training services.<\/em><\/p>\r\n","protected":false},"excerpt":{"rendered":"<p>By Joe Reilly, Past Chairman DATIA Collection sites are often audited by FAA and FTA auditors and recently I have been retained by several regional and national collection site operators to provide audits of their company owned collection sites and mobile collections.\u00a0 Audits are a good thing because if you find out what your collectors [&hellip;]<\/p>\n","protected":false},"author":12,"featured_media":51762,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_seopress_robots_primary_cat":"none","_relevanssi_hide_post":"","_relevanssi_hide_content":"","_relevanssi_pin_for_all":"","_relevanssi_pin_keywords":"","_relevanssi_unpin_keywords":"","_relevanssi_related_keywords":"","_relevanssi_related_include_ids":"","_relevanssi_related_exclude_ids":"","_relevanssi_related_no_append":"","_relevanssi_related_not_related":"","_relevanssi_related_posts":"","_relevanssi_noindex_reason":"","footnotes":""},"categories":[1],"tags":[],"acf":[],"_links":{"self":[{"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/posts\/50882"}],"collection":[{"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/users\/12"}],"replies":[{"embeddable":true,"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/comments?post=50882"}],"version-history":[{"count":1,"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/posts\/50882\/revisions"}],"predecessor-version":[{"id":118348,"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/posts\/50882\/revisions\/118348"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/media\/51762"}],"wp:attachment":[{"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/media?parent=50882"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/categories?post=50882"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.nationaldrugscreening.com\/wp-json\/wp\/v2\/tags?post=50882"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}