Observed Collections

Observed Collections are used as a way to help ensure cheating does not take place when the donor provides their drug test specimen. When an observed collection is requested, the observer must be the same gender as the employee. The applicant should contact the clinic prior going into the clinic to ensure the site has a same sex collector available.

 

Observed Collection Clinic Process :

The observer will request the donor to raise their shirt, blouse or dress/skirt, as appropriate, right above the navel and lower pants/shorts or skirt, and underpants to mid-thigh. The donor will then show the observer, by turning around, that the donor does not have a device holding liquid/urine. If the donor does not have a device, they are permitted to return clothing to its proper position for the observed collection.

The observer must watch the urine go from the donor’s body into the collection container and as the donor takes the specimen to the collector. The collector then completes the collection process. Failure of the employee to permit any part of the observation procedure is a refusal to test and will be reported through the system to the employer.

The DER is not contacted.

DOT vs. NON-DOT Regulations/Guidelines

Non-DOT collections are not federally regulated and only conducted under an employer’s authority so the client dictates their policy/guidelines.

DOT collections are federally regulated and must follow the guidelines provided in section 49 CFR Part 40. Observed collections are authorized and required only when:

• The employee attempts to tamper with his or her specimen at the collection site.

• The specimen temperature is outside the acceptable range;

• The specimen shows signs of tampering ~ unusual color / odor / characteristic; or

• The collector finds an item in the employee’s pockets or wallet which appears to be brought into the site to contaminate a specimen; or the collector notes conduct suggesting tampering.

• The Medical Review Officer (MRO) orders the direct observation because:

• The employee has no legitimate medical reason for certain atypical laboratory results; or

• The employee’s positive or refusal [adulterated / substituted] test result had to be cancelled because the split specimen test could not be performed (for example, the split was not collected).

• The test is a Follow-Up test or a Return-to-Duty test.

Reference : https://www.transportation.gov/odapc/DOT_Direct_Observation_Procedures