Collection site proof of qualifications

I am updating our DOT Substance Abuse Program, and I can't figure out just what records we are required to get from our collection site in order to verify that the collectors are qualified.

I have the list from the Federal Register that shows our testing lab meets minimum standards, and the MRO sent us a copy of his MRO certificate verifying his certification.

But we use a medical clinic for our collections, and in the past we have asked them to have every collector they employ (that could possible do our collections) sign a long list verifying their certifications and stating that if they leave the employment of the medical clinic that they will notify us. This form just doesn't seem reasonable to me (really - who is really going to notify us if they leave the clinic's employment?) Also, this is so much to keep updated, constantly checking to see if they have new staff!

It seems to me that we should have just one general agreement signed by an authorized rep. of the clinic stating that they will only employ collectors who meet the qualfications, and that the clinic will follow all procedures as outlined by FMCSA, including any new regulations that occur. This should not need to be updated.

But I can't seem to find any documentation saying specifically what we are required to have. Anybody else know? What do others do with their DOT programs if you use an outside collection site?


  • 6 Comments sorted by Votes Date Added
  • Look for a SAMSHA certification for the lab you are using. (Substance Abuse and Mental Health Administration) There are several good websites with information on the purpose and certification.
  • LORRIE: You are absolutely right, it is alot of extra work that your company has put on your organization. We have a retained physician (a medical clinic) and his lab techs to our collection and shipping off of the urine for validation. It is the Physician that is also our RMO. He conducts all DOT physicials and the Random Drug test as necessary based on our referral to the clinic. We do not worry about the certifications of any of his assigned staff. That is his responsibility to make sure all is right with his certifications. We do not even have an agreemnet signed by our company and his business. We interviewed several clinics and physicians and selected the one that met all DOT requirements, we selected our retained physician and his clinic based on the best price. When and if the price to do our work is raised we will have discussions and interviews all over again, like we did 6 + years ago.

    Don't get tied up in knots with certificatiions upon certifications it is not necessary, as long as the physician is a licensed physician in practice within your state.

    Good luck!

  • Federal DOT regs do not require any of this unnecessary work and I doubt that your state does either. It is not the employers' responsibility to maintain the certification of the testing or collection facility. They have their own regulations to deal with at those sites. There is absolutely no reason for an employer to track or even have an interest in this.

    Disclaimer: This message is not intended to offend or attack. It is posted as personal opinion. If you find yourself offended or uncomfortable, email me and let me know why.
  • I don't know about Motor Vehicle Carrier, but if you're subject to FTA transit regulations (49 CFR Part 655/Part 40), then you do need to track that the lab (*not* collection site) is SAMHSA certified, that your collection staff has proof of BAT and STT training, proof that any breath alcohol machinery is accepted by SAMHSA or DSHS (I can't remember which), and that your MRO is certified. Your MRO may be at a different location from your collection staff, and may have nothing to do with them. It's not enough that the MRO has certifications because their function is different. Collection staff needs proof of training too. Unfortunately, it would be your responsibility to track all this and you would be the one to have a finding or a fine if they were not compliant.

    I've found that collection sites can be wiley - they don't want to do everything they're supposed to do. They lose the ccf or give it to the employee directly. Or they don't want to stay open in the case of an insufficient sample. It helps to have a contract with them and also to have alternative collection sites available that you can use if the first one is not cooperative.

    Half HR

  • That is interesting. What you describe sounds a lot like how our program was set up, although we are governed by FMCSA instead of FTA.

    Thanks to everyone for the info.
  • I'd recommend getting a hold of the Best Practices guide and also taking a look at audit questions. That'll help you understand what the feds expect.

    Half HR
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