Daily Archives: February 1, 2023

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.]