Information Employers Provide to Collectors for DOT Oral Fluid Testing

Overview

For DOT-regulated oral fluid specimen collections to be conducted accurately and in compliance with 49 CFR Part 40, employers must provide specific information to collectors. This information ensures that the collection process is properly documented, that specimens are handled securely, and that the appropriate communication channels are established. This article outlines the key information employers must provide to collectors and best practices for maintaining compliance.

Essential Information Employers Must Provide

1. Employee Information

• Full Name of the employee being tested.
• Employee ID Number or Social Security Number (SSN) (for FMCSA-regulated employees, the Commercial Driver's License (CDL) Number and the issuing state are required).
• Test Reason: Clearly indicate the reason for the test (e.g., Pre-employment, Random, Post-Accident, Return-to-Duty, Follow-up, or Reasonable Suspicion/Cause). This can be pre-printed on the CCF.

2. Employer Details

• Employer Name, Address, Telephone Number, and Fax Number (may be pre-printed on the CCF).
• Designated Employer Representative (DER) name and contact information. This must include a direct contact number, not a call center number.

3. Laboratory and Medical Review Officer (MRO) Information

• Laboratory Name and Address (can be pre-printed on the CCF).
• MRO Name, Address (not a P.O. Box), Telephone Number, and Fax Number (can also be pre-printed on the CCF).

4. DOT Agency Information

• The DOT Agency that regulates the employee’s safety-sensitive duties must be clearly identified. Options include:
  • Federal Aviation Administration (FAA)
  • Federal Motor Carrier Safety Administration (FMCSA)
  • Federal Railroad Administration (FRA)
  • Federal Transit Administration (FTA)
  • Pipeline and Hazardous Materials Safety Administration (PHMSA)
  • United States Coast Guard (USCG)

5. Specimen Type and Testing Instructions

• Specify the type of specimen to be collected (oral fluid or urine).
• Provide standing orders outlining when to use oral fluid versus urine collections.
• Ensure collectors are informed of the laboratory designated for the specimen type collected.

Communication Best Practices

• Employers should provide collectors with after-hours contact information for the DER in case issues arise during collections outside normal business hours.
• If using a Consortium/Third-Party Administrator (C/TPA), include the C/TPA's name, address, and contact information (optional but recommended).
• Employers should regularly review and update the information provided to collectors to reflect any changes in testing procedures, laboratories, or DER contact details.

Handling Missing or Incomplete Information

If the collector does not receive all necessary information:

• Contact the DER immediately to obtain the missing details.
• Do not proceed with the collection until all required information is confirmed.
• Document any communication with the DER regarding missing or incomplete information in the Remarks section of the CCF.

Best Practices for Employers

• Provide collectors with clear and updated standing orders regarding specimen collection procedures.
• Ensure that all information on the CCF is accurate and complete before the collection begins.
• Maintain open communication with collectors to address any issues that arise during the collection process.
• Keep collectors informed of changes in laboratory or MRO service providers.

Conclusion

Providing accurate and comprehensive information to collectors is essential for a compliant and efficient DOT oral fluid specimen collection process. Employers must supply detailed employee, employer, laboratory, and testing information to ensure proper documentation and secure specimen handling. Clear communication and adherence to best practices support the integrity of the DOT drug testing program and protect all parties involved.