Presentation Transcript

1. FTA Drug & Alcohol Program National Conference Little Rock April, 2014 Joseph Lofgren FTA Audit Team Leader Collection Site Inspections
2. Why Inspect?
3. Why Inspect?
4. Why Inspect? Includes 552 inspections through Dec. 2013
5. Vendor Oversight – Collections
6. Scheduled ahead of time Open Process Instructional Format Identity & Purpose clearly stated Includes discussion of “problem” collections/scenarios Water sample Collection Site Visits – FTA Method
7. Questionnaire Thorough understanding of policies, practices, knowledge Can openly inspect equipment, facility Can openly inspect credentials FTA Method - Pros
8. The Ringer Dynamic can compound collector mistakes Rest of process missing Dr. T. Ringer, M.D. Errors collector usually makes might be fixed by nature of mock FTA Method - Cons
9. Begin with: FTA Collection Site Questionnaires (http://transit-safety.fta.dot.gov/DrugAndAlcohol/TechnicalAssistance/default.asp) Both Urine and Breath-Alcohol questionnaires available Set a date Familiarize yourself with the questionnaire (Call us if you have questions!) A review of CCFs/ATFs from site beforehand is extremely helpful Collection Site Visits
10. There are two components to collection site inspection: Mock collection Unusual (“problem”) collections discussion Collection Site Visits
11. Mock Collection A demonstration of procedures used during normal/uneventful collections Corrections should be conveyed after the mock Collector should perform mock just as he or she normally would Collection Site Visits
12. Unusual collections review A discussion covering scenarios specifically described in 49 CFR Part 40 Shy Bladder Refusals Direct Observation And More! Does not usually include demonstrations Collection Site Visits
13. Collection Site VisitsA quick guide to beginning a mock collection
14. The Breath Alcohol Test §40.211-§40.279
15. Request photo ID (if not done already)? Use a Federal Alcohol Testing Form (ATF)? Complete the form correctly and in order? 1-2-3-(4) Use a NHTSA-approved EBT (breath device) or ASD (saliva testing device)? Does the BA Technician (BAT):
16. Have training/qualification records? Keep regular accuracy checks recorded? Maintain their equipment as required? Does the BAT/Site:
17. Have a copy of the Quality Assurance Plan (QAP) for the device (EBT) used? Have a current copy of 49 CFR Part 40? Understand how to load and troubleshoot problems with the device? Does the BAT/Site:
18. Have an EBT for confirmation tests if they use saliva test or non-evidential breath testing device? Have any experience with positive tests? Understand special circumstances, such as refusals, fatal flaws, etc.? Does the BAT:
19. The Urine Drug Collection§40.31-§40.73 &§40.191- §40.209
20. Request photo ID (if not done already)? Instruct donor to remove outer garments? Instruct donor to empty pockets? Allow the donor to keep wallet? Explain the procedures? Including showing the donor the instructions printed on the back of the form Does the collector:
21. Ask donor to wash hands? Secure all internal water sources? Open sealed kit in front of donor Give donor a 55ml container? Does the collector:
22. Instruct donor to remain within site of the collector? Inspect the enclosure? Add bluing to the toilet? Does the collector:
23. Are all concealment areas secured or removed? Are all chemicals and fluids removed? Are the dropped-ceiling tiles secure? >Twelve pieces of paraphernalia found at this major US airport collection site. Once in the enclosure:
24. Are there windows, doors, panels, or pass-through ports? Is the toilet tank lid secured? Is the water off? Once in the enclosure:
25. Check the temperature strip? Check the quantity? Distribute the specimen into each of 2 bottles? Does the collector:
26. Provide a clean and suitable writing surface? Use a Federal CCF? Ensure all steps completed correctly on the CCF? Don’t forget: 1, 2, 3, 5, 4! Does the collector:
27. Demonstration of Correct CCF Steps
28. Steps 1 & 2
29. What’s Wrong/Missing?
30. What’s Wrong/Missing?
31. Place specimen label seals on bottle? Date the seals? Instruct the donor to initial the seals? And verify initials? Does the collector:
32. Seal the specimens into a shipping bag? Monitor only one donor at a time? Does the collector:
33. Shy Bladders Uncooperative donor Direct Observation Discussion Topics
34. Donor must make initial attempt, even if: Waiting for representative, or “Just doesn’t have to go” Donor has 3hrs to provide specimen beginning with QNS cup Donor may have up to 40 ounces of fluid over 3hrs Doesn’t have to drink Measurements must be: Consistent Accurate Shy Bladder
35. If a donor is uncooperative: Terminate test Record actions in “Remarks” section Call DER This is a refusal to test This goes for being uncooperative for directly observed or monitored tests as well… Collector is in Charge! Uncooperative Donors
36. If donor: Removes tampering materials from pockets Behaves in a way that “clearly indicates an attempt to tamper with a specimen” Provides a specimen out of temp Provides an adulterated/tampered specimen Collector must require Direct Observation Direct Observation
37. D.O. collection must occur immediately Same-gender observer Need not be a collector or medical professional Observer must: Require that donor disrobe (to chest, knees) and rotate to display absence of devices Watch urine travel from body to cup Record name on CCF (if not collector) Direct Observation Cont.
38. Frequency of courier Daily Security of stored specimen No access by “civilians” General facility security & privacy Back doors, lock boxes Fixing Flaws Immediate or next business day Collector training and retraining Mock collections in training 30 days to retrain after a Fatal Flaw Discussion Topics
39. Have your correct phone number? Transmit Copy 2 of the CCF directly to the MRO after each collection? Welcome visits? Exhibit consistent refresher training? Afford donors confidentiality and privacy before, during, and after the collection? Does the site:
40. Communicate directly with the DER? Understand the importance of the collection process as relates to your compliance? Does the site:
41. Also perform other USDOT-regulated tests? Have hours or availability that match company hours of safety-sensitive operations? Can they be flexible? Does the site:
42. Get questionnaires (http://transit-safety.fta.dot.gov/DrugAndAlcohol/TechnicalAssistance/default.asp or Audit Team Leader) Make an appointment Visit & evaluate Require corrective actions Give them a due-date! Re-visit Next steps:
43. Should be your partner in this process Should be willing to help you with your collection changes required Should be consistent and accurate Remember: Your collection site

44. Thank you

    Joseph Lofgren FTA Drug & Alcohol Audit Team