THE DOT DRUG TEST

Custody & Control Form (CCF) 

All Department Of Transportation required drug tests must be collected using a Federal Custody & Control Form (CCF). 

Do Not  use Department Of Transportation forms for non-covered employee testing.  (EX: office staff, salespeople etc.)  or you will be fined penalties start at $2,000.

A DOT CCF is identified by the word(s)  “Federal” or "Department of Transportation (DOT)" printed on the form.

• The DOT CCF  is  5 part, 8x10 form with security tapes affixed on bottom.  The Federal CCF is the same for all tests and for all laboratories.

In emergency situations only   Non-DOT forms may be substituted. The use of these forms will require an affidavit stating the reason for the test and what steps have been taken so that this situation does not re-occur. 

EMPLOYER SUBSTANCES OF ABUSE TEST HISTORY REQUIREMENT (3) YEAR

Pre-Employment 

Applicant original authorization (in writing) applicant must allow request  of drug and alcohol testing history information pertinent to all positive tests and/or  refusals to test , from all prior employers for the past *3 years (All Modes).  If the applicant refuses to provide this authorization you cannot continue with the offer of employment.

If the applicant has tested positive or refused to take any DOT required test on notice you can not continue to allow them to perform safety-sensitive functions

You can:  Allow an applicant to begin safety sensitive functions but must document all attempts to get history that were made even if you did not get a responce.  If you get a reply  after the employee has started that indicates a history problem (1) If the employ remains in your employ you must  assume the return to duty process responsibility.  (2) You may terminate an individual on notification of a positive or refusal to test from a previous employer; if this action is specified in your company policy.

THE WRONG TEST WAS~PERFORMED 

Examples

DOT post accident test (does not meet Post accident criteria) was conducted on a DOT CCF and the donor has a positive result.

0. This test result must be canceled and cannot be acted on under DOT direction.
0. In writting advise the MRO to down grade the test to NON regulated include the details of the situation then take appropriate action, only as indicated under company policy.

THE BASIC EMPLOYER OBLIGATION :

• A written company substances of abuse policy (will be reviewed in a DOT audit) Understand your company substances of abuse policy
• Keep company random list up to date  (will be reviewed in a DOT audit)
• Conduct random testing (will be reviewed in a DOT audit)
• Make sure all supervisors have DOT required training to recognize substance abuse problems (will be reviewed in a DOT audit)
• Ensure that a blind specimen priogram is in place - Blind specimen testing:  a required percentage of  negative and positive known results are submitted in accordance with Department Of Transportation guidelines in order to test laboratories for accuracy  – the laboratory must result these tests correctly.
• Make certain your DER’s are trained in the duties of a Designated Employer Representative

COLLECTION 

• All Collectors require training to collect DOT drug tests 
• Medical personnel  and civilians  can train and certifiy to become collectors
• A DOT Collection can be conducted anywherre as long as the site and the collector meet DOT specifications.

ALCOHOL - Only trained persons are allowed to conduct DOT alcohol tests(BAT or STT)

• the collector may be asked to provide verification that they have been trained and qualified to act as collectors for drug and alcohol. 
• The collector must be able to communicate with the company Designated Employer Representative (DER)  for assistance with problems in order to resolve collection issues including but not limited to Shy Bladder, Adulteration, Cold specimens and refusals. The collector must advise the DER of Alcohol Test Results.