How to Train In-House Collectors for DOT-Regulated Drug Testing (49 CFR Part 40)

Overview

Employers regulated by the U.S. Department of Transportation (DOT) may choose to train their own employees as drug test collectors. These collectors must meet the requirements outlined in 49 CFR Part 40, which governs all DOT drug and alcohol testing procedures. Proper training ensures collections are legally defensible and protects the integrity of the testing program. This article outlines the qualifications, training process, and documentation needed for a company to train and qualify in-house collectors.

Requirements to Qualify as a DOT Collector

According to 49 CFR § 40.33, an individual is qualified to act as a DOT drug test collector if they meet the following:

• Complete Qualification Training, including:

  • DOT regulations and guidance (Part 40 procedures)

  • Collection procedures for all scenarios (standard, shy bladder, etc.)

  • How to properly complete and transmit the Federal Custody and Control Form (CCF)

  • Problem collections and fatal/serious errors

• Demonstrate Proficiency through:

  • Successfully completing five consecutive error-free mock collections, covering:

    • One uneventful collection

    • One insufficient specimen (shy bladder)

    • One temperature out of range

    • One suspected tampering

    • One refusal to test

The mock collections must be directly observed by a qualified monitor or trainer.

• Maintain Training Records documenting completion of qualification and mock collections.

Step-by-Step: How to Train an In-House DOT Collector

1. Select a Trainer or Training Provider

Choose a training provider that offers DOT-compliant collector training. Trainers should be well-versed in 49 CFR Part 40 and capable of monitoring mock collections.

• Tip: The DOT does not certify trainers but recommends using reputable, experienced training services.

2. Complete Qualification Training

The employee must go through a formal qualification training course covering:

• The DOT’s drug testing process

• Collector responsibilities

• Common errors and how to avoid them

• Use of the CCF form

• Privacy and chain of custody requirements

This can be done online or in person.

3. Conduct Five Error-Free Mock Collections

After completing the classroom portion, the trainee must demonstrate proficiency by completing five observed mock collections:

• Each must simulate a different collection scenario

• They must be directly observed by a qualified trainer who can confirm accuracy and compliance

4. Document Training and Proficiency

You must keep records showing:

• The topics covered in the qualification training

• Date and provider of the training

• The results of the five mock collections (including observation confirmation)

These records must be retained and made available in case of a DOT audit or legal challenge.

5. Begin Conducting Live Collections

Once training and documentation are complete, the employee is authorized to conduct DOT collections. They must follow all procedures in 49 CFR Part 40 Subpart E during each collection.

Ongoing Requirements

• Error Correction Training: If a collector makes a fatal flaw (such as using the wrong form or failing to seal the specimen), they must immediately undergo retraining before resuming collections.

• Refresher Training: While not required at regular intervals by DOT, it is best practice to provide periodic refresher training (e.g., annually) to reinforce procedures and update on regulatory changes.

Frequently Asked Questions (FAQs)

Q: Does the DOT provide certification for collectors?
No. The DOT does not issue or require any official certification. However, collectors must meet the qualification requirements in Part 40, and employers should maintain proof of training.

Q: Can a supervisor of a driver perform their drug test?
Only under limited circumstances. Per 49 CFR § 40.31(c), a supervisor may collect a specimen from an employee only if that employee is not under the supervisor’s authority at the time of the collection.

Q: Are there specific forms we must use?
Yes. DOT-regulated tests must use the Federal Custody and Control Form (CCF). Ensure the collector is trained on how to fill it out completely and accurately.

Q: Can we use the same collector for DOT and non-DOT tests?
Yes, but collectors must clearly distinguish between DOT and non-DOT collections and use the appropriate forms and procedures for each.

Regulatory References

• 49 CFR Part 40 – Procedures for Transportation Workplace Drug and Alcohol Testing Programs
  View regulation on eCFR

• 49 CFR § 40.31-33 – Who can collect and training requirements

• DOT Office of Drug and Alcohol Policy and Compliance (ODAPC) Guidance: https://www.transportation.gov/odapc

Last updated: May 1, 2025
This article reflects federal regulations in effect as of this date. Always consult the most recent version of 49 CFR Part 40 for updates.