instruct donor to remove outer garments

Joseph H. Lofgren, Audit Team Leader

Why Inspect?

Collection Sites are final and central component to entire D&A

program

The ENTIRE program depends on the accuracy of a single test between one employee and one collector.

Public

Transit Employees

Program Management

Donor / Collector

Collection Site Visits

FTA Method

– Scheduled up to one month ahead of time

– Open Process– Instruction/Seminar Format– Identity & Purpose clearly stated– Includes academic review of scenarios (non-normal collections)

– ‘Mock’ sample

Cons: Best collector provides demonstration

Collection Site Visits

Inspector carries questionnaire Can get a thorough understanding of collection site policy and collector’s knowledge

Can openly inspect equipment, facility, and security of enclosure

Can openly inspect credentials and certifications

Collection Site Visits

• Mock collection should go just as collector would normally conduct it

• Corrections should be conveyed AFTER the mock collection

• The dynamic can be so uncomfortable for a nervous collector that certain mistakes may be compounded

• A review of CCF’s from that site beforehand is extremely helpful

Collection Site Visits

Begin with: FTA Collection Site Questionnaires (http://transit-safety.volpe.dot.gov/DrugAndAlcohol/TechnicalAssistance/default.asp)

Both Drug and Alcohol questionnaires are available

Set a date Familiarize yourself with the questionnaire fully

Collection Site Visits

There are two components to collection site mock-collections

1. Mock collection

2. Question review

Collection Site Visits

Mock Collection

Is a demonstration of the procedures normally used during collections

Collection Site Visits

Questions Reviews

Is an academic discussion covering scenarios specifically described in 49 CFR Part 40

Often does not include demonstrations

Collection Site Visits

A quick guide to beginning a mock collection

Drug & Breath Alcohol Tests

Collection Site Visits

Does the collector:

- Ask for photo ID?

- Require a consent form?(Q: What is an acceptable form to have?)

Does the collector:

- Instruct donor to remove outer garments?

- Instruct donor to empty their pockets?

- Allow the donor to keep their wallet?

- Explain the procedures?

Breath Alcohol Collection

Does the collector:

Use a Federal ATF?

Complete the steps correctly?

Use an approved EBT or saliva testing device?

Demonstration of Correct ATF Steps

Does the collector:

Have certifications and training records?

Keep regular accuracy checks recorded?

Maintain their equipment as required?

Does the collector:

Have a copy of the Quality Assurance Plan (QAP)?

Have a copy of 49 CFR Part 40?

Understand how to load, and troubleshoot problems with the device?

Does the collector:

Have an EBT for confirmation tests if they use saliva tests?

Have any experience with positive tests?

Understand special circumstances, such as refusals, etc.?

Drug Collection

Does the collector:

Ask donor to wash hands?

Secure all external water sources?

Open sealed specimen containers in front of donor

Give donor a 55ml container?

Does the collector:

Instruct the donor to remain within site of the collector?

Inspect the enclosure?

Add bluing to the toilet?

Does the collector:

Give the donor a 4-minute time limit?

NOTE: This presentation describes MOCK-collections only. Auditors recommend using a water specimen (low temperature reading can be disregarded)

Once in the enclosure:

Are all concealment areas secured or removed?

Are all chemicals and fluids removed?

Are the ceiling tiles accessible?

Once in the enclosure:

Are there windows, doors, panels, or pass-through ports?

Is the toilet tank lid secured?

Is the water off?

Does the collector:

Check the temperature strip?

Check the quantity?

Distribute the specimen into each of 2 bottles?

Does the collector:

Provide a clean and suitable writing surface?

Use a Federal CCF?

Ensure all steps completed correctly on the CCF?

Demonstration of Correct CCF Steps

Does the collector:

Place specimen label seals on bottle?

Date the seals?

Instruct the donor to initial the seals?

Does the collector:

Seal the specimens into a shipping bag?

Monitor only one donor at a time?

Discussion Scenarios

Shy-bladder procedures Uncooperative donor Leaving the collection site Frequency of courier Security of stored specimen General facility security Collector training (certificate?)

Does the collector:

Have your correct phone number?

Transmit Copy 2 of the CCF directly to the MRO after each collection?

Does the collector:

Welcome visits?

Get regular refresher training?

Afford donors confidentiality and privacy before, during, and after the collection?

Does the collector:

Communicate directly with you?

Use the correct forms?

Understand the importance of the collection process as relates to your compliance?

Does the collector:

Also perform other USDOT-regulated tests?

Have hours or availability that match your hours of safety-sensitive operations?

Your next steps:

Get questionnaires (http://transit-safety.volpe.dot.gov/DrugAndAlcohol/TechnicalAssistance/default.asp or Audit Team Leader)

Make an appointment with your collection site

Visit & evaluate Require corrective actions Re-visit

Remember:

Your collection site should be your partner in this process

Should be willing to help you with your collection changes required

Should be accurate and exacting

Thank you for your attendance