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Where to Find? .....
DHHS Labs
The current list of DHHS certified labs is published the first week of each
month and is printed in the Federal Register under the Substance Abuse and
Mental Health Services Administration (SAMHSA) heading. Only those labs
certified can be used for FTA drug testing. The list should be checked
monthly as new labs are being added and others are being removed.
Website location:
http://
www.workplace.samhsa.gov/
ResourceCenter/lablist.htm
To verify the certification status of a
laboratory, DHHS has established a telephone HELPLINE (800) 843-4971.
The information presented on this page should be used to update Chapters
7 and 12 of
the revised Implementation Guidelines.
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Oversight Remains Responsibility of Grantee
Even though most FTA grantees/subrecipients contract out their drug
and alcohol testing services to various service agents (e.g., collection
sites, laboratory, MRO, BAT and SAP), they cannot contract away their
compliance responsibilities. If an agency’s service agents do not
perform testing services consistent with the regulations, the agency’s
good faith effort is not a defense for noncompliance (§40.15(c)).
Many grantees/subrecipients assume that their contractors are
performing their duties in a compliant manner and fail to monitor and
provide oversight. In many cases, this assumption is wrong with
significant consequences for the transit agency. Even though the
regulation does not stipulate how an employer should monitor its service
agents, the following activities have become standard industry practice:
- Conduct periodic mock collections to identify
procedural flaws;
- Conduct periodic review of service agent employee
credentials including training documentation;
- Investigate any employee reports of flawed
procedures;
- Provide service agents with copies of appropriate DOT
guidelines, regulations, and related materials;
- Monitor cancelled tests and require detailed
explanations for each;
- Include minimum performance standards in contracts
that provide disincentives for cancelled tests or non-performance.
Transit agencies must
document their oversight process and take corrective action when
necessary. If a service agent is unwilling or unable to perform their
duties consistent with the regulations, the transit agency should obtain
the service elsewhere.
Common Collection Mistakes Should be Avoided
Even though 49 CFR Part 40 Subpart C requires
collectors to receive training and demonstrate proficiency, collectors
are still making common mistakes that are compromising the testing
process. One of the most common mistakes is that collectors initial the
tamper evident seal while the seal is still affixed to the Chain of
Custody and Control Form (CCF) prior to placing it on the bottle.
Another common mistake is that the donor dates the seal rather than the
collector. This is incorrect. Once the urine is poured from the
collection cup to the primary and split specimen bottles and the caps
are secure, the collector should place the seals on the bottles. It is
only once the labels are on the bottles that the collector writes the
date on the seals and then requests the employee to initial the labels
verifying that the specimen is his/hers.
One way to determine if these mistakes are being made is to review
the employer’s copy of the CCF and see if the date has come through the
carbon on the bottom right of the form. If the date shows, this
indicates that seals were dated while affixed to the CCF rather than the
bottle.
ODAPC 411
The Office of Drug and Alcohol Policy and Compliance (ODAPC)
established a new electronic information dissemination system called
ODAPC 411. The email list is open and free to all individuals interested
in receiving electronic news, updates and information related to DOT’s
Workplace Drug and Alcohol Testing Procedures as published by ODAPC. To
subscribe, enter your email address on the ODAPC website in the space
indicated under News/Updates by E-Mail at
www.dot.gov/ost/dapc/email.
In addition to the electronic mail distribution system, news and
information will continue to be available on the ODAPC website at
www.dot.gov/ost/dapc/news.
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