Oral Fluid Drug Testing for Department of Transportation (DOT) Regulated Employees: Approved But Delayed

Oral fluid specimen collectors must successfully complete training as outlined in Section 40.35. Collectors must be thoroughly trained in the regulations and procedures relating to oral fluid specimen collections such as: how to properly complete the Custody and Control Form (CCF), how to conduct collections using your specific collection device(s), how to handle problem collections, and maintaining integrity and privacy. Collectors are also required to know the publication, “DOT Oral Fluid Specimen Collection Procedures Guidelines” (which is not yet available). After completing the training mentioned above (called Basic Information and Qualification Training), the oral fluid specimen collector student must successfully complete a hands-on training component called the proficiency demonstration. The proficiency demonstration requires that the oral fluid collector student conduct a series of specific, error-free mock tests under the observation of a qualified monitor/instructor. Unlike urine collections, oral fluid specimen mock tests must be conducted using the specific oral fluid collection device that the collector will be using in the real world. Therefore, there is no ‘one size fits all’ with oral fluid specimen collector training. If you wish to become qualified on all approved oral fluid collection devices, you will need to complete the proficiency demonstration on each and every device. Certified Training Solutions will be offering online Oral Fluid Specimen Collector procedures training and device proficiency training by webcam (when approved devices become available).

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Department of Transportation (DOT) Will Soon Allow Oral Fluid for DOT Drug Tests

The Department of Transportation (DOT) announced the effective date of regulations allowing oral fluid specimens to be used for federal drug tests. Under the DOT’s mandated testing program, found in 49 CFR Part 40, the addition of oral fluids is effective June 1, 2023.  (Note: The correct term for the bodily fluid used in drug testing regulations is ‘oral fluid’; however, we often notice people referring to it is “saliva testing”. Saliva is just one of the components that make up oral fluid.) The new rules require specific training for any person who will be conducting oral fluid collections for DOT drug tests. No currently-trained urine specimen collectors will be ‘grandfathered in’ or anything of the sorts. Basically, anyone wishing to become trained as an oral fluid specimen collector must participate in compliant training that meets the regulatory requirements. Oral fluid (O.F.) collector training is a little more complicated than urine specimen collector training, due to the requirement that O.F. specimen collectors need to be trained on the specific oral fluid collection device(s) they will use in the real world. There is no “one size fits all” for O.F. collector training, as there is with urine specimen collector training.

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What if a donor will not provide their SSN or ID number for a urine drug collection?

Every employer should have a comprehensive policy that addresses their procedures for testing/collections (i.e. What are the applicants' or employees' identification requirements at the collection site, What substances do they test for, How are collections conducted, How are refusals handled, What are the consequences of refusing or testing positive, etc.) ... if this had been a DOT collection, the answer is more cut and dry. If the collection was occurring under FMCSA authority, the Part 382 rules instruct the collector to use the donor's Commercial Driver License (CDL) number as the ID number in Step 1 of the CCF. This is a requirement due to Clearinghouse reporting. [The employer should have the donor's CDL number on file, even for applicants before they send them to you for a collection, so you can always call the DER for this information.]

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