Presentation Transcript

1. DRUG/ALCOHOL TESTING PROGRAMS A Testing Site Perspective Jorge Bujanda, MD
2. OBJECTIVES 1. Importance of stakeholders in drug/alcohol testing programs.2. US HealthWorks as a multiple collection site service agent.3. Inside the Mind of a Collector: A. Collection site. B. Preparation for testing. C. Routine collection procedures. D. Problem collection procedures. E. Documentation errors and fatal flaws.4. Impact of Other Stakeholder Deficiencies on Collection Site Performance. 5.Recommendations for Program Revision and Improvement. (Handout) 2
3. STAKEHOLDERS IN THE DEPARTMENT OF TRANSPORTATION DRUG AND ALCOHOL TESTING PROGRAM • Department of Transportation Representatives• Employers• Collectors / Technicians• Program Managers / Administrators• Consultants• Substance Abuse Professionals• Medical Review Officers• Public• Donors 3
4. IMPORTANCE OF STAKEHOLDERS IN DRUG AND ALCOHOL TESTING PROGRAMS • All stakeholders are important elements of the program.• Stakeholders’ expectations drive the program.• Stakeholders must not shift responsibilities.•Stakeholders’ expectations must be reasonable.Encourage perfection, but don’t expect it. 4
5. IMPORTANCE OF THE COLLECTION / TESTING SITE IN DRUG AND ALCOHOL TESTING PROGRAMS COLLECTORS AND TECHNICIANS•Key to success of drug/alcohol testing programs.• Represent employer and operating agency in the process.• Interact with Donors and shoulder the consequences.•Responsible for collection/testing procedural compliance.• Responsible for integrity of process and specimens.• Require the contribution of all other stakeholders. 5
6. SINGLE vs. MULTIPLE COLLECTION / TESTING SITES SIMILARITIES•Training requirements.•Procedures.•Problems.•Proper participation of other stakeholders.DIFFERENCES•Experience.•Training resources.•Knowledge resource network.•Type and/or number of agencies or employers served. 6
7. DRUG/ALCOHOL TESTING PROGRAMS A Testing Site Perspective

   INSIDE THE MIND OF A COLLECTOR/TECHNICIAN

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8. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN COLLECTION SITE•A place where Donors provide urine specimens for testing.• Source of water for washing hands secured during the collection process. Towelettes when not available. • Single lavatory or multi-stall restroom that provides privacy for specimen collection.• No access to running or clear water.• Clean surface for processing the specimen and to complete the documentation. 8
9. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN COLLECTION SITE•Security requirements: ○ Prevent unauthorized access to site during collection. ○ Prevent unauthorized access to collection materials and supplies. ○ Prevent Donor’s access to potential specimen adulterating or diluting substances (e.g., soap, disinfectants, etc.). ○ Ensure supervision by Collector or authorized site personnel of any person authorized to enter site. ○ Provide secure handling and storage of specimens. 9
10. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN COLLECTION SUPPLIES• Necessary to conduct proper collections.• Include: ○ DOT-compliant drug test collection kit. ○ Federal Drug Testing Custody and Control Form (CCF). ○ Coloring agent for water in toilet bowl or tank to prevent specimen dilution. ○ Tamper-evident tape available to secure faucets, water tanks, etc. ○ Disposable gloves recommended for Collectors. 10
11. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN PREPARATION FOR TESTING• Ensure compliance of collection site.• Ensure availability of collection supplies.• EBT Calibration Checks performed every 30 days. (Daily before use at USHW centers). 11
12. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN PREPARATION FOR TESTINGDetermine Test Type:•Drug Tests: Regulated urine drug test, non-regulated urine lab-based test, instant urine tests, hair tests, etc.•Alcohol Tests:Regulated breath alcohol test, non-regulated breath alcohol test, screening saliva alcohol tests, etc. 12
13. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN PREPARATION FOR TESTINGDetermine reason for Test:• Regulated:Pre-employment, random, post-accident, reasonable suspicion, return to duty and follow up.• Non-Regulated:Pre-employment, reasonable suspicion, post-accident, post-injury, random, return to duty, follow up. 13
14. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN PREPARATION FOR TESTING•Identify employer policy to follow:Single policy vs. multiple policies.•Determine applicable rules:HHS, NRC, FMCSA, FAA, FRA, FTA, PHMSA, USCG, FBI, DOD, etc.•Identify governing agency:California Public Utilities Commission, State of Florida Drug Free Workplace, etc. 14
15. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN PREPARATION FOR TESTINGAssuming DOT/FTA Rules apply:• Collector ideally has access to an updated CCF (9/30/2011). Copies: 1. Testing Facility (lab) Copy sent with specimen.2. Medical Review Officer Copy sent to the MRO.3. Collector Copy retained by Collector. 4. Employer Copy sent to employer. 5. Employee Copy given to employee. • Collector needs to complete CCF orderly and thoroughly. 15
16. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN INFORMATION REQUIRED FROM EMPLOYERS/SERVICE AGENTS • Donor’s full name, SSN or ID number.• Laboratory name and address.• Employer name, address, telephone and fax numbers.• MRO name, address, telephone and fax numbers.• DER name and telephone number (C/TPA when applicable).• Agency governing the employee’s safety-sensitive duties.• Reason for test.• Whether the test is to be observed or not. 16
17. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN ENSURING A SECURE SITE TO DETER SPECIMEN TAMPERING•Secure any water sources available to Donors. • Use coloring agent in toilet water/tank. • Secure toilet tank cover. • Inspect for possible adulterants or substances. • Inspect and securing areas/items that appear suitable for concealing contaminants. • Ensure undetected access to site is not possible. • Recheck items above following each collection to ensure site’s continued integrity. 17
18. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN OTHER COLLECTOR/TECHNICIAN CONSIDERATIONS• If breath alcohol test applies, it must be performed before the urine collection, to the greatest extent practicable. • Only one collection at a time per Collector (except during a shy bladder period).• Donor’s scheduled test time. Employer responsibility. • Pre-employment unique characteristics before starting a collection.• Collection should begin without undue “delay”.• Before the collection, employer must provide DER, laboratory and governing agency information. 18
19. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN ROUTINE COLLECTION PROCEDURESDonor identification:• Acceptable forms include: ○ Government or employer-issued photo identification. ○ Identification by representative of higher hierarchy. ○ Other form of identification allowed by operating agency. • If not provided, Collector must contact DER. 19
20. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN ROUTINE COLLECTION PROCEDURES• Explanation of procedures to Donor, including back of CCF.•Laboratory name and address. • Correctly enters Step 1 information: ○ Employer name, address, telephone/fax numbers. ○ MRO name, address, telephone/fax numbers. ○ I.D. number. ○ Testing authority. ○ Reason for test. ○ Type of test. ○ Collection site information. 20
21. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN ROUTINE COLLECTION PROCEDURES•Donor must remove outer clothing and leave with Collector, together with belongings. Donor may retain wallet. No additional request of clothing removal or exam gown, with exceptions.• Donor may keep head covering if refused based on religious practice, unless indication of specimen tampering intent. 21
22. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN ROUTINE COLLECTION PROCEDURES•Collector asks Donor to empty pockets for possible presence of adulterating substances/devices. If no substances present, Donor returns items to pockets.• Collector encourages Donor to leave all belongings outside.• Ideally, Donor belongings are locked.•Collector provides receipt for belongings, if asked.• All belongings are returned to Donor after collection. 22
23. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN ROUTINE COLLECTION PROCEDURES• Donor instructed to wash and dry hands in Collector’s presence.No further access to water or other materials allowed.•Donor selects sealed collection kit/container from supply.•Collector or Donor, unwraps it.•Donor takes collection container into the collection room.•Sealed specimen bottles remain with Collector. 23
24. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN ROUTINE COLLECTION PROCEDURES• Collector directs Donor: ○ To collect a specimen of at least 45 mL. ○ Not to flush the toilet. ○ Return as soon as possible after the void. ▪ Collector should set and explain a reasonable time limit for Donor to stay in the collection room. ▪ Collector should explain Donor the importance of specimen temperature determination and possible requirement of an observed collection. 24
25. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN ROUTINE COLLECTION PROCEDURES• After receiving the specimen, Collector: ○ Determines temperature within 4 minutes. ○ Inspects specimen for tampering signs. ○ Determines specimen volume. • Donor’s admission of specimen tampering, refusal to follow directives or disruptive behavior are refusals to test. Collector discards specimens and notifies DER. 25
26. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN ROUTINE COLLECTION PROCEDURES• If specimen is acceptable, Collector proceeds with collection: ○ Unwrapping specimen bottles and pouring a minimum of 30 and 15 mL in bottles A and B, respectively. ○ Placing caps on bottles A and B. ○ Placing seals over bottles A and B, and dating them. ○ Having Donor initial the seals. ○ Allowing Donor to wash hands. 26
27. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN ROUTINE COLLECTION PROCEDURES• Collector directs Donor to Step 5 on Copy 2 of the CCF and: ○ Read the certification statement. ○ Enter personal contact information. ○ Sign. ○ If Donor refuses to any of it, Collector ensures that: ▪ Donor’s name is entered; and ▪ Notation is made on the Remarks section.• Collector signs Step 4 on Copy 1 after entering personal and collection information, including courier service to lab. 27
28. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN ROUTINE COLLECTION PROCEDURES• Collector: ○ Ensures all copies of the CCF are legible and complete. ○ Removes Copy 5 and gives to employee. ○ Places bottles and Copy 1 inside plastic bag and seals. ○ Places sealed plastic bag in appropriate shipping container, when applicable. ○ Informs Donor collection is finished and may leave site. ○ Discards any left over urine specimen in the collection container. 28
29. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN ROUTINE COLLECTION PROCEDURES• Collector: ○ Sends Copy 2 to MRO and Copy 4 to DER (or designee) within 24 hours or during the next business day. ○ Keeps Copy 3 of CCF. ○ Ships specimen to laboratory within 24 hours or during next business day. ○ Ensures integrity and security of specimen, while on site, until given to a courier. 29
30. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN PROBLEM COLLECTION PROCEDURESDonor identification problems:• Unacceptable forms of include: ○ Identification by a co-worker or safety-sensitive employee. ○ Non-photo identification card (SS card, credit card, etc.). ○ Photocopies of an acceptable identification document. •Collection must not proceed until positive identification. 30
31. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN PROBLEM COLLECTION PROCEDURESInsufficient Specimens (Shy Bladder): • Ifthe specimen provided is insufficient (<45 mL), a Shy Bladder process is started. Collector: ○ Discards specimen and notes the events and time in CCF. ○ Explains process to Donor, including inability to leave the designated area. ○ Facilitates a maximum of 40 ounces of drinking fluids within 3 hours. ○ Continues to document time and amount of each attempt. 31
32. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN PROBLEM COLLECTION PROCEDURESInsufficient Specimens (Shy Bladder): • If no acceptable specimen is provided within the three hours, the Collector: ○ Discontinues the collection, notes the fact on the Remarks line and completes documentation. ○ Immediately notifies the DER. ○ Distributes Copies 2 and 4 to MRO and DER respectively. • Employer arranges a Shy Bladder medical evaluation together with MRO. 32
33. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN PROBLEM COLLECTION PROCEDURESInsufficient Specimens (Shy Bladder): • If any insufficient specimen is out of temperature range, Collector must consider it as evidence of tampering and must proceed with an observed collection.• If Donor refuses to provide another specimen or leaves the collection site for any reason, before doing so, it is considered a refusal to test. 33
34. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN PROBLEM COLLECTION PROCEDURESDirectly Observed Collections:• It is a routine collection except with use of an observer. • Apply after a routine collection when: ○ Specimen temperature is outside acceptable range. ○ Donor is found to have possible tampering materials. A Memorandum for Record (MFR) describing devices substances found suspected of use for specimen tampering is sent to MRO and employer. 34
35. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN PROBLEM COLLECTION PROCEDURESDirectly Observed Collections:• Apply after a routine collection when: ○ Donor’s conduct is indicative of possible tampering. ○ Collector believes specimen has been adulterated (e.g., specimen is green, exhibits excessive foaming when shaken, bleach smell, etc.). • Apply to all Return-To-Duty and Follow-Up tests. 35
36. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN PROBLEM COLLECTION PROCEDURESDirectly Observed Collections:• Apply when a previous drug test was reported as: ○ Positive ○ Diluted ○ Adulterated ○ Substituted ○ Unsuitable for testing ○ Canceled due to split specimen not available for testing. 36
37. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN PROBLEM COLLECTION PROCEDURESDirectly Observed Collections:• If Collector observes clear behavior of tampering attempt: ○ Collector documents on Remarks line that it is first of two collections, the specimen numbers of both CCFs, the reason for observed second collection; and completes first collection. ○ Completes second collection under observation, entering similar information on second CCF. ○ Informs site supervisor and DER. 37
38. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN PROBLEM COLLECTION PROCEDURESDirectly Observed Collections:•Observer: ○ Must be same gender as Donor, without exception. ○ May be the Collector or another person. ○ Must accompany Donor into restroom. ○ Must direct Donor to raise clothing above navel, lower it to mid-thigh and turn in a circle for possible presence of tampering devices/substances. ○ Must watch Donor void in the collection container. 38
39. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN PROBLEM COLLECTION PROCEDURESRefusals to test:•It is considered a refusal to test when Donor: ○ Refuses to display pocket contents. ○ Refuses to wash hands. ○ Refuses to follow any other mandatory directives. ○Displays disruptive behavior. ○ Admits to specimen tampering. • Collector must then stop the collection process, discard any specimens and notify the DER of the refusal to test. 39
40. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN MONITORED COLLECTIONS• Collection procedure performed in a multi-stall restroom during which a person (Monitor) is present inside the restroom during the collection.• Allows specimen collection in private. • Monitor must be of the same sex, unless a medical professional. 40
41. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN DOCUMENTATION ERRORS / FATAL FLAWSUpon receiving a specimen, the laboratory ensures that:•Specimen ID number on CCF and labels/seals match.•Specimen bottle seals are intact. •CCF is properly completed.•There are no discrepancies and/or errors of omission in CCF (e.g., Collector’s signature missing, unchecked specimen temperature boxes, etc.) in the CCF. 41
42. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN DOCUMENTATION ERRORS / FATAL FLAWS•When documentation errors are found, the laboratory must: ○ Determine if the error/omission can be corrected. ○ Request a MFR from the Collector, stating that the required action took place but its documentation inadvertently missed in the CCF.• Once a MFR is requested, Collector must respond immediately, indicating whether it can be issued.• If a MFR is not issued, laboratory reports the specimen as "Rejected for Testing" to MRO and provides reasons. 42
43. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN DOCUMENTATION ERRORS / FATAL FLAWS• MROs may also request a MFR to correct collection or documentation flaws.•Collector must undergo Error Correction Training within 30 days of a cancelled test.• Donors can only be recalled for a repeat collection when a directly observed collection was required and was not performed. Collectors must contact the DER for arrangement. 43
44. INSIDE THE MIND OF A COLLECTOR / TECHNICIAN REGULATED vs. NON-REGULATED COLLECTIONS• Regulated (DOT) collections must be done on Federal CCFs and employers are prohibited from using Federal CCFs for non-regulated collections.•Using a non-regulated form for a regulated collection is not grounds for test cancellation. However, the laboratory and/or MRO must ensure that : ○Regulatory collection process was followed. ○Specimen was tested in accordance with regulations. ○Ensure that all documentation required exists. ○A compliant MFR from the Collector is obtained. 44
45. U.S. HEALTHWORKS EXPERIENCE 2013 SERVICES TOTAL CANCELLED DOT Drug Tests: 67,200 DOT Drug Test Collections: 189,700 Non-DOT Drug Tests: 138,800Non-DOT Drug Test Collections: 280,000 Non-DOT Instant Drug Tests: 368,800 Breath Alcohol Tests: 134,000 Saliva Screening Alcohol Tests: 7,900 Medical Review Officer Reviews: 131,700 45
46. U.S. HEALTHWORKS EXPERIENCE 2013 SERVICES TOTAL CANCELLED DOT Drug Tests: 67,200 (12) (1/5,600) 0.018 % DOT Drug Test Collections: 189,700 Non-DOT Drug Tests: 138,800 (13) (1/10,676) 0.009 %Non-DOT Drug Test Collections: 280,000 Non-DOT Instant Drug Tests: 368,800 Breath Alcohol Tests: 134,000 Saliva Screening Alcohol Tests: 7,900 Medical Review Officer Reviews: 131,700 46
47. DRUG/ALCOHOL TESTING PROGRAMS A Testing Site Perspective

    IMPACT OF OTHER STAKEHOLDERS’ DEFICIENCIES ON COLLECTION SITE PERFORMANCE

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48. FREQUENT PROBLEMS WITH SERVICE REQUEST FORMS •Missing or incorrect DOT agency selection.•Missing or incorrect test reason:Pre-Employment vs. Return To Duty/Follow Up , Post- Accident DOT vs. non-DOT, Return To Duty or Random vs. Follow Up.•Missing or incorrect test type:DOT, non-DOT and instant testing, urine drug test vs. breath alcohol test, urine, breath, saliva, blood.•Discrepancy between request and Donor-provided information.• Donors unaware of reason to be at the collection site. 48
49. FREQUENT PROBLEMS WITH SERVICE REQUEST FORMS • Missing or incorrect employer policy selection. •Discrepancy between request, protocol and CCF provided.•Incomplete information and no name/signature on request.• Contradictive instructions between employer and TPA.(TPA reimbursement problems with altered CCFs.)• Multiple divisions with multiple DERs.• Incorrect or no instructions to Donors on testing time limits and restrictions (e.g., Post-Accident, Random).• Donors sent for testing without their knowledge. 49
50. FREQUENT PROBLEMS WHEN CONTACTING THE DER •The need to contact the DER /Sender, for any reason, is among the most frequent source of testing delays and problems.○ Correct DER contact information not available for problems or reports.○ Alternate DER contact information almost never provided.○ Corporate DER in another time zone.○ Clinic or sender unable to reach DER, especially after hours. ○ Senders do not know who their DER is. ○ DER changes not reported to Collectors or Technicians. 50
51. FREQUENT PROBLEMS WHEN CONTACTING THE DER • Only the DER knows testing policy and cannot be located. • DER/sender almost never provides date and time on time-sensitive test requests.•DER number does not allow to leave voice messages.• DER/sender is reached but lacks program knowledge.•Process is more difficult when a TPA is involved.• Unaccompanied Donors dropped or sent for Reasonable Suspicion testing. 51
52. FREQUENT PROBLEMS WHEN COMPLETING THE CCF • Incorrect, outdated or expired CCFs provided by employers, laboratories and/or TPAs. • Donor sent for testing with only one CCF or kit.•Employer/Donor not aware of operating agency for test.•Different CCFs coming from employer and TPA.• Donor sent for testing without service request form, CCF or kit and Collector expected to alter one and use another employer’s kit. 52
53. FREQUENT PROBLEMS WHEN COMPLETING THE CCF • CCF alterations:○ Some employers “demand” CCF alteration and use of someone else’s kit.○ Some TPAs do not allow CCF alteration.○ Laboratory kit, CCF or account information for alteration not available.○ Employer’s faxed information to alter a CCF is unreadable.○ TPA reimbursement problems.○ Altering a CCF leads to delays and triggers problems all throughout the process.○ Unavailable information to alter or hand-print CCF. 53
54. FREQUENT PROBLEMS WHEN COMPLETING THE CCF •Discrepancy between type of test requested and CCF provided.• Unusable CCFs sent with excessive information or signature.• MRO information on file conflicts with service request or CCF. 54
55. FREQUENT PROBLEMS WITH LABORATORIES •Although paper trail proves they were picked up and received; laboratories:○ Misplace specimens. ○ Lose specimens.•Constantly report: ○ Insufficient specimens. ○ Leaks in transit. 55
56. FREQUENT PROBLEMS DUE TO DIRECTIVES FROM STAKEHOLDERS THAT ARE INCORRECT OR IN CONFLICT WITH REGULATIONS •Employers’ deficient knowledge of regulations and/or their own testing program. ○ More prevalent after-hours and with subcontractors. ○ Donors allowed by employers to leave premises and return later. ○ Employer requests DOT testing when not applicable or incorrect test: ▪ DOT post-accident test when accident does not apply. ▪ DOT Post-injury test or incorrect Return To Duty test. 56
57. FREQUENT PROBLEMS DUE TO DIRECTIVES FROM STAKEHOLDERS THAT ARE INCORRECT OR IN CONFLICT WITH REGULATIONS • Employers’ deficient knowledge of regulations and/or of their own testing program. ○ Employer requests usually do not address alcohol tests when accompanying a drug test. ○ Employer’s lack of knowledge about testing time limitations and not addressing on request (random, post-accident, drug and alcohol). ○ Employer requests random drug test and assumes alcohol test applies automatically. ○ Employer instructs Collector to accept photocopies or faxes as valid forms of identification. 57
58. FREQUENT PROBLEMS DUE TO DIRECTIVES FROM STAKEHOLDERS THAT ARE INCORRECT OR IN CONFLICT WITH REGULATIONS • Employers’ deficient knowledge of regulations and/or of their own testing program. ○ Employer requests observed collections when not applicable. ○ Employer requests a retest after a shy bladder or a refusal, sometimes demanding disposal of original specimen. ○ Employer’s lack of understanding of the laboratory analysis, medical review and reporting process. (Request results from Collector, want Collector to contact MRO to expedite results, etc.).• TPA protocol contradicts CCF presented by Donor (MRO, lab).• Barcode and lab automation problems when altering another employer’s CCF. 58
59. FREQUENT PROBLEMS DUE TO DIRECTIVES FROM STAKEHOLDERS THAT ARE INCORRECT OR IN CONFLICT WITH REGULATIONS •Others: ○ Donor statement contradicting employer’s request. ○ Employer directs Collector to TPA for questions and TPA is usually not available. 59
60. FREQUENT PROBLEMS WITH ADVERSE EVENTS AND REPORTS •Unable to contact DER to: ○ Discuss collection problems. ○ Report breath alcohol test results.•DER/Sender: ○ Asks technician what to do with a positive result. ○ Asks what is a shy bladder process. ○ Wants to allow Donors to leave after collection has started.•DER has been changed without notification to collection site.• Busy or incorrect MRO and fax numbers. •Employers requiring faxing of CCF to multiple parties. 60
61. FREQUENT PROBLEMS WITH ADVERSE EVENTS AND REPORTS •Misplaced/lost MRO copy with Collector’s proof of delivery.•Conflict between employer corporate instructions and field branches.• MRO Office: ○ Collector name or signature missing. ○ Occasional CCF number and seals’ number discrepancy. ○ Wrong reason for testing checked on the CCF. ○ Wrong DOT agency checked on the CCF.○ Reporting problems when using another employer’s CCF. ○ Not getting the MRO copy of the CCF on time. 61
62. OTHER FREQUENT PROBLEMS • Most frequent employer questions to Sales Associates: ○ “Do I need to have a written drug/alcohol testing policy before testing my employees?” ○ “Can I choose who is “randomly” selected or who to include in the random pool?” (Usually by owners or senior management) ○ “We believe we have a drug use problem in one of our departments. I want to arrange for testing everyone in that department.” 62
63. OTHER FREQUENT PROBLEMS • Most frequent employer questions to Sales Associates: ○ “Can I send my employees for testing after their shift?” ○ ”How much time after notification can I give my random- selected employees to give the specimen; 24 hours?” • Lack of knowledge of drug and alcohol testing, as far as what they want or need, and how to do it.• Lack knowledge of the program by subcontractors that need to implement regulated drug and alcohol testing are a frequent source of delays and problems. 63
64. FINAL OBSERVATIONS

    Do not blame Collectors/Technicians without looking at all the factors, including all other stakeholders involved.

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65. FINAL OBSERVATIONS Do not blame Collectors/Technicians without looking at all the factors, including all other stakeholders involved. When you, or your consultant, visit them for a review, ask them about possible problems with your program and ideas on how to improve it. They can give you better feedback than most, in certain aspects of your program. 65
66. FINAL OBSERVATIONS Do not blame Collectors/Technicians without looking at all the factors, including all other stakeholders involved. When you, or your consultant, visit them for a review, ask them about possible problems with your program and ideas on how to improve it. They can give you better feedback than most, in certain aspects of your program.Consider that Collectors/Technicians may be your best allies to assist in correcting a problem and giving you feedback about your programs when everyone else is unavailable, or not doing all they should to ensure its success. 66
67. DRUG/ALCOHOL TESTING PROGRAMS A Testing Site Perspective

    RECOMMENDATIONSFOR PROGRAM REVISIONAND IMPROVEMENTHANDOUT

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68. DRUG/ALCOHOL TESTING PROGRAMS A Testing Site Perspective

    QUESTIONS

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