Employee Identification Procedures for DOT Oral Fluid Testing

Overview

Accurately identifying the employee (donor) is a critical first step in the DOT-regulated oral fluid specimen collection process. Ensuring that the correct individual is providing the specimen helps maintain the integrity of the testing program and prevents fraudulent activity. This article outlines the procedures collectors must follow to properly identify employees in compliance with 49 CFR Part 40.

Acceptable Forms of Employee Identification

Before initiating the collection process, the collector must verify the employee's identity using one of the following forms of government- or employer-issued photo identification:

1. Government-Issued Photo ID:

   • State-issued driver's license or identification card (including Commercial Driver's License [CDL])
   • Passport (U.S. or foreign)
   • Military ID card
   • Tribal ID card

2. Employer-Issued ID:

   • Employee badge with a photo (issued by the current employer, not applicable for owner-operators or self-employed individuals)

3. Alternate Methods (if no photo ID is available):

   • Verification by a Designated Employer Representative (DER)
   • Presentation of other forms of government-issued ID, as allowed by DOT regulations

Expired IDs

• A government-issued photo ID expired for no more than one year may be accepted.
• Digital IDs or images of IDs are not acceptable.

Unacceptable Forms of Identification

Collectors must not accept the following forms of ID for verifying employee identity:

• Identification by a co-worker or another employee being tested
• Non-photo IDs (e.g., Social Security card, credit card, union membership card)
• Photocopies or digital versions of acceptable IDs

Procedures for Verifying Identity

1. Request ID: Prompt the employee to provide acceptable identification.
2. Verify ID: Inspect the ID to confirm that the employee matches the provided photo and details.
3. No Valid ID? If the employee cannot produce a valid ID:
   • Contact the DER for identity verification.
   • Do not proceed until the DER confirms the employee's identity.
4. Document Verification: Note in the Remarks section of the Custody and Control Form (CCF) if identity verification involved the DER.

Collector Identification Requirements

Employees have the right to request the collector’s identification. Collectors must:

• Provide an ID showing their name and employer's name.
• A photo ID or personal address/phone number is not required.

Addressing Identity Discrepancies

If any issues arise during identification:

• Pause the collection process.
• Contact the DER immediately to resolve the issue.
• Document the details of the issue and resolution in the Remarks section of the CCF.

Best Practices for Collectors

• Double-check IDs even if presented earlier to other staff.
• Remain professional and respectful when addressing identity concerns.
• Explain the reason for ID verification to employees to maintain transparency.

Conclusion

Proper employee identification is a critical part of maintaining the integrity and security of the DOT oral fluid specimen collection process. By following these procedures and best practices, collectors can ensure compliance with DOT regulations and protect the accuracy and fairness of the drug testing program.