Should Collection Sites That Are Unable to Perform Observed Testing Offer DOT Collections?

I’ve been in the C/TPA (Consortium / Third-Party Administrator) and drug testing collection industry for four and a half years now, and it amazes me that so many in the industry fall short of providing services that comply with laws and regulations. At CleanFleet, we pride ourselves on being a full-service TPA who eliminates as many pain points as possible for our members when it comes to managing drug & alcohol programs. One of the pain points we handle for our consortium members is finding qualified collection sites and authorizing the proper services. All our members have to do is tell their employees where to show up.

So far, we have built a network of over 3,000 collection sites nationwide that offer DOT urine collections. However, we have found that not all of them are able or willing to handle the entire collection process. There are certain situations during the collection process in which requires someone to observe the donor void into the cup in order to ensure the sample is not tampered with and is valid. When these situations arise, the person observing must be of the same gender.

This is where the issue lies. Most collection sites are a 1 or 2 person operation and usually don’t staff both genders.

In cases where the reason for testing is Return-to-Duty or Follow-up, it is known ahead of time that observation is required for the donor sample. In these cases, it is relatively easy to make sure a collection site can perform the observation before sending the donor in. However, this might mean sending the donor to a more inconvenient site because the most convenient site does not have anyone to perform the observation. This in turn makes for an unhappy consortium member.

There are also cases where the testing process has started and the collector notices suspicious activity or gets handed an out-of-temperature specimen. These are usually signs of cheating, and the DOT requires a second collection to immediately take place under direct observation. If the collection site does not have anyone on staff who can observe, the collection process is stalled, and the question becomes who is responsible for providing an observer. In my opinion, it should fall on the collection site.

The collection site should be responsible for getting someone to observe the donor provide the specimen. After all, the collection site says it offers DOT collections. It needs to handle the complete process. The collection site is also going to want payment for the collection. If I, as a TPA, or my consortium members have to be responsible for providing an observer, why should we use the collection site in the first place? How does the DOT even allow these collection sites to perform DOT collections? A collection site needs to either be all in or completely out when it comes to DOT collections.

At CleanFleet, we take the collection process seriously. Both of our collection sites in Portland, OR are able to handle direct observations of males and females. If collection sites cannot handle situations where cheating might be occurring, those sites shouldn’t be in business. People’s lives depend on it.