DOT Observed Collection: A Guide for Collectors and Observers

If you are a collector or an observer for drug testing under the Department of Transportation (DOT) regulations, you may encounter situations where you have to conduct a directly observed collection. A directly observed collection is a special type of urine specimen collection that requires the collector or an observer to watch the employee provide the specimen.

In this blog post, we will explain what a directly observed collection is, when and how it should be performed, and what are the roles and responsibilities of collectors and observers. We will also provide some tips and best practices to help you conduct a directly observed collection professionally and respectfully.

What is a Directly Observed Collection?

A directly observed collection is a urine specimen collection that requires the collector or an observer to watch the employee provide the specimen. The purpose of a directly observed collection is to prevent cheating or tampering with the specimen, such as by using adulterants, substitutes, or devices, when the specimen is invalid or diluted, or when the test reason is return-to-duty or follow-up.

How Observed Collection is done?

A directly observed collection must also follow specific procedures and protocols to ensure the integrity and validity of the test result. It can only be performed by a collector who has been trained and qualified in accordance with DOT regulations, or by an observer who has been designated by the collector. The observer must be the same gender as the employee, unless the observer is a medical professional.

The observed urine collection must be conducted in a private and secure location that prevents unauthorized access or observation. The collector or the observer must ask the employee to raise his or her clothing above the waist, lower clothing and underpants, and turn around to show that he or she does not have any item that could be used to tamper with the specimen. The collector or the observer must then watch the urine go from the employee’s body into the collection container.

A directly observed collection must be documented on a new Custody and Control Form (CCF) that indicates the reason for the direct observation and the name of the observer. The collector must also follow specific procedures for urine specimen collection, such as checking the temperature, sealing and labeling the specimen, and sending it to the laboratory.

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When is a Directly Observed Collection Required?

A directly observed collection is required only in certain situations that are specified by DOT regulations. These situations are:

The employee attempts to tamper with his or her specimen at the collection site, such as by using adulterants, substitutes, or devices.
The specimen temperature is outside the acceptable range of 90°F to 100°F.
The specimen shows signs of tampering, such as unusual color, odor, or characteristic.
The collector finds an item in the employee’s pockets or wallet that appears to be brought into the site to contaminate a specimen.
The collector notes conduct suggesting tampering, such as excessive delay in providing a specimen or unusual behavior during the collection process.
The laboratory reports to the Medical Review Officer (MRO) that a specimen is invalid, and the MRO determines that there is no adequate medical explanation for the result.
The MRO reports to the employer that the original positive, adulterated, or substituted result had to be cancelled because the test of the split specimen could not be performed.
The laboratory reports to the MRO that the specimen was negative-dilute with a creatinine concentration greater than or equal to 2 mg/dL but less than or equal to 5 mg/dL, and the MRO directs a second collection under direct observation.
The employer realizes that a collection under direct observation was required but was not conducted, or the service agent informs the employer that a direct observation should have been conducted but was not.
The drug test is a return-to-duty test or a follow-up test.

In any of these situations, the employer must direct an immediate collection under direct observation with no advance notice to the employee. The employee must comply with the request for a directly observed collection; otherwise, it will be considered a refusal to test.

What are the Roles and Responsibilities of Collectors and Observers?

Collectors and observers play important roles in ensuring that a directly observed collection is conducted properly and respectfully. Collectors and observers must:

Be trained and qualified in accordance with DOT regulations.
Be familiar with DOT’s direct observation procedures and protocols.
Be respectful of the employee’s privacy and dignity.
Be professional and courteous at all times.
Be impartial and objective in performing their duties.
Be attentive and vigilant in detecting any signs of tampering.
Be accurate and thorough in documenting and reporting any issues or incidents.

Collectors have additional responsibilities, such as:

Informing the employee of the reason for the directly observed collection and explaining the procedures and protocols.
Designating an observer of the same gender as the employee, unless the observer is a medical professional.
Supervising the observer and ensuring that he or she follows the procedures and protocols.
Completing a new CCF for the directly observed collection and indicating the reason and the name of the observer.
Following all other procedures for urine specimen collection, such as checking the temperature, sealing and labeling the specimen, and sending it to the laboratory.

What are Some Tips and Best Practices for Conducting a Directly Observed Collection?

Conducting a directly observed collection can be a challenging and sensitive task, as it involves watching an employee provide a urine specimen. Collectors and observers should follow some tips and best practices to make the process smoother and more comfortable for everyone involved. Some of these tips and best practices are:

Be discreet and respectful: Do not announce or discuss the reason for the directly observed collection in front of other employees or staff. Do not make any comments or gestures that could be perceived as offensive or intrusive. Do not touch or handle the employee or the specimen unless absolutely necessary.
Be clear and concise: Explain to the employee what is expected of him or her and what will happen during the directly observed collection. Use simple and direct language and avoid any jargon or slang. Answer any questions that the employee may have honestly and politely.
Be calm and confident: Maintain a professional demeanor and tone of voice throughout the directly observed collection. Do not show any signs of nervousness, impatience, or frustration. Do not let any personal feelings or biases affect your judgment or performance.
Be fair and consistent: Follow the DOT’s direct observation procedures and protocols exactly as they are written. Do not deviate from or modify them for any reason. Do not make any exceptions or allowances for any employee. Treat every employee equally and impartially.
Be careful and cautious: Watch for any signs of tampering, such as unusual items, behaviors, or specimens. Document and report any issues or incidents promptly and accurately. Do not make any assumptions or accusations without sufficient evidence. Do not engage in any confrontations or arguments with the employee.

Conclusion

A directly observed collection is a special type of urine specimen collection that requires the collector or an observer to watch the employee provide the specimen. It is only required in certain situations where there is a risk of cheating or tampering with the specimen, such as when the test reason is return-to-duty or follow-up.

Collectors and observers must follow specific procedures and protocols to conduct a directly observed collection properly and respectfully. They must also be trained and qualified in accordance with DOT regulations.

Collectors and observers should follow some tips and best practices to make the process smoother and more comfortable for everyone involved, such as being discreet, clear, calm, fair, and careful.

A directly observed collection is an important tool to ensure the integrity and validity of drug testing under DOT regulations. It helps to prevent cheating or tampering with specimens, which could compromise safety and compliance.

Call us at 980-202-1466 for more information about DOT drug & alcohol testing and collection methods. goMDnow is a certified TPA providing services for random drug testing and return-to-duty process for FMCSA and DOT regulated truck drivers. Reach us today for all your drug testing needs.