How can an employer verify its collection personnel are qualified to conduct federal drug or alcohol collections?
As an employer, you are responsible for ensuring that the urine and/or oral fluid collector, screening test technician (STT), and/or breath alcohol technician (BAT) you use meet the qualifications outlined in 49 CFR §§ 40.15, 40.33, 40.35, and 40.213 to conduct drug and alcohol test collections. While a collector, STT, and/or BAT may provide you with a certificate of training to demonstrate that he or she is qualified, that may not be sufficient if it does not include the proficiency requirements. We encourage you to ask for additional documentation to ensure you and your collection personnel are complying with the federal testing requirements. The following are examples of what you might ask your collector, STT and/or BAT to provide to demonstrate they meet the proficiency requirements:
- For a collector, you may obtain copies of the following:
- Federal Custody and Control Forms (CCFs) completed during the five (5) mock error-free collections to demonstrate the collector conducted two (2) uneventful collections, one (1) insufficient quantity collection, one (1) temperature out of range collection, and one (1) collection involving a donor's refusal to sign or initial the specimen bottle seal.
- Documentation indicating that the five (5) mock collections were monitored by a qualified collector with one (1) year practical experience as a collector, or one (1) year experience training other collectors, or successful completion of a "train the trainer" course.
- Written statement from the person who observed the mock collections and can attest that they were error-free and monitored in person or "real-time". The statement should include the number and type of scenarios/events covered during the mock exercises and other relevant information.
- For an STT and/or BAT, you may obtain copies of the following:
- Alcohol Testing Forms completed during the seven (7) consecutive error-free mock breath alcohol tests or five (5) error-free saliva tests. The mock tests must be performed using the alcohol testing devices that will be used by the BAT/STT and adequately gauge the BAT/STT's knowledge, skill and ability pertaining to the device's messages, commands or displays including error messages or device malfunctions, as well as the procedures for performing air blank and external calibration checks.
- Documentation indicating that the seven (7) mock breath alcohol tests (and/or five (5) mock saliva tests) were monitored by a qualified instructor with one (1) year practical experience performing as a BAT/STT, or one year as a BAT/STT trainer, or successful completion of "train the trainer" course.
- Written statement from the person who observed the mock collections and can attest that they were error-free and monitored in person or "real-time". The statement should include the number and type of scenarios/events covered during the mock exercises and other relevant information.
- Other documents, which may include course materials and descriptions, checklists, etc.
For more information on this topic, please visit the DOT’s website and review the Q&As about the collector and BAT/STT requirements.
If you have any further questions or need additional guidance that is more specific to your situation, please contact the FAA Drug Abatement Division at 202-267-8442 or drugabatement@faa.gov. Please visit our website to learn more about our program.