Department of Transportation (DOT) Oral Fluid Drug Testing for Regulated Employees Still Delayed

Although the 49 CFR Part 40 Department of Transportation (DOT) rules were changed over nine (9) months ago to allow the use of oral fluid specimens for federal drug testing under the Procedures for Transportation Workplace Drug and Alcohol Testing Programs, no oral fluid collections may be conducted as of the publication of this newsletter (March 18, 2024). We realize that everyone in this industry is anxiously awaiting the green light to begin training collectors to conduct oral fluid collections, but the public has no idea at this point when this will happen. We continue to receive questions from customers, such as: What are we waiting for??? Before a trained oral fluid specimen collector may begin collections using this particular bodily fluid, there must be at least two laboratories certified by the Department of Health and Human Services (HHS), and this has not occurred yet. Under the federal regulations, there must also be one laboratory to serve as a primary laboratory and a second lab to serve as a split-specimen testing laboratory. In addition, there are currently no oral fluid collection devices approved and available that meet the DOT rule requirements. Appendix B of the Part 40 Rules requires a single oral fluid collection device that may be subdivided in the donor’s presence. Once device(s) are available that meet the Appendix B requirements, the next hurdle is that they must be approved by HHS for use by the specific laboratory that will test the specimen that was collected by this particular, approved device. As you may imagine, this is a lengthy process.

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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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NEW FMCSA Instructions for DOT Drug Tests

The Federal Motor Carrier Safety Administration (FMCSA) recently issued new instructions to specimen collectors and employers in an effort to ensure that only federally-mandated drug tests are recorded on federal custody and control forms (CCFs). You may find it here: https://www.fmcsa.dot.gov/regulations/drug-alcohol-testing/fmcsa-regulated-drivers-use-federal-ccf-only-when-conducting-dot When beginning a collection for a Department of Transportation (DOT)-regulated drug test, specimen collectors […]

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Federal Custody and Control Form (CCF) Expiration Date Extended through August 2021

The currently-used United States Department of Transportation (DOT) Federal chain of custody form for recording specimen collection and drug testing of federally-regulated employees was due to expire at the end of August 2020. However, HHS/SAMHSA has extended the expiration date and is allowing continued use of the current CCF through August 31, 2021.What Specimen Collectors Need to […]

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Department of Transportation Re-qualification Training Guidance Announced – Certified Training Solutions Can Help!

PUBLIC NOTICE:  On June 17, 2020, due to the COVID-19 pandemic, the U.S. Department of Transportation (DOT) Office of Drug and Alcohol Policy and Compliance (ODAPC) has issued extended guidance relating to re-qualification training requirements for certain service agents in the DOT drug and alcohol testing process. Service agents affected include breath alcohol technicians (BATs), […]

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Breathalyzer Care & Cleaning During the Coronavirus Pandemic

During this time of the Coronavirus pandemic and concerns regarding the transmission of COVID-19, Certified Training Solutions would like to pass along breathalyzer-care information from the manufacturer of Alcovisor devices, such as the Jupiter, Mercury, and Mark V: “… we want to help ensure that everyone remains safe and healthy while using of our products.As […]

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