New Department of Transportation (DOT) Publication Helps Employers Monitor Their Collection Sites for Compliance

​New Department of Transportation (DOT) Publication Helps Employers Monitor Their Collection Sites for Compliance
The DOT has issued a new publication called: “What Employers Need to Know About Monitoring Collection Sites”
You may find the brochure at:
If you are like most employers, you probably use “service agents” to assist you in meeting the DOT drug and alcohol testing regulatory requirements.  For example, you may send your employees to a collection site whenever they are due for drug or alcohol test (say a random or post-accident drug test). 
As the employer, YOU are 100% responsible for the actions of your service agents (a service agent is any entity or person that supplies services to you in meeting the DOT testing requirements…this may be a collection site, such as an occupational health clinic; your C/TPA, a breath alcohol technician, or a specimen collector).  If one of your service agents does something wrong (i.e. performs a test in a way that is not compliant with the DOT regulations), YOU are liable for their actions, even if you did not know they were non-compliant. In this case, ignorance is no excuse. To reduce your potential liability, your company must take all necessary steps to ensure that your service agents are strictly following ALL DOT rules and procedures in the drug and alcohol testing process.
The new DOT brochure will help you understand what you can do to monitor the activities of the collection sites that are performing those drug and alcohol tests and collections.  The DOT believes that, “Having an effective substance abuse prevention and testing program is vital to your organization’s success and to public safety.  An excellent drug and alcohol testing program starts with a collection site that fully meets all requirements for the safety, privacy, security and integrity of the testing site and the testing process.  As the drug and alcohol program manager for the employer, you are the employer’s representative and are responsible for ensuring that the collections are performed in compliance with the various DOT regulations.”
An area where we often see a breakdown in compliance is in TRAINING.  Employers will often simply hire a collection site or occupational health clinic to perform their employees’ drug and alcohol tests without thoroughly checking to make sure that each and every breath alcohol technician (BAT) and that each specimen collector employed at the clinic meets the training requirements as outlined in 49 CFR Part 40.  Employers: It is YOUR job to verify all qualifications of your service agents to ensure that they meet the minimum training requirements. Hint: Ask for full training records and Certificates for every testing technician employed at the collection site.
If any of your service agents or collection sites are in need of proper, compliant, and affordable training, CERTIFIED TRAINING SOLUTIONS offers breath alcohol technician (BAT), Screening Test Technician (STT), and DOT Specimen Collector training. Training is conveniently offered online, by webcam, and in live classes.
Every employer must also have a Designated Employer Representative (DER) at their organization. This is the person in charge of your company’s drug and alcohol testing program.  The DER at your company should be extremely knowledgeable about all of the DOT’s drug and alcohol testing Rules, as well as those Regulations that cover your particular operating agency (FMCSA, PHMSA, FRA, FTA, or the FAA).  If your DER is not knowledgeable about the Part 40 and your operating agency Rules, he or she may be interested in our online Designated Employer Representative (DER) training courses.
For more information on our array of online training courses, visit us at: or call 307-640-5859.

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