Collection Site Inspections

1. Joseph H. Lofgren, Audit Team Leader Collection Site Inspections

2. Why Inspect? • Collection Sites are final and central component to entire D&A program

3. The ENTIRE program depends on the accuracy of a single test between one employee and one collector. Public Transit Employees Program Management Donor / Collector

4. 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

5. 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

6. 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

7. 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

8. Collection Site Visits • There are two components to collection site mock-collections • Mock collection • Question review

9. Collection Site Visits • Mock Collection • Is a demonstration of the procedures normally used during collections

10. Collection Site Visits • Questions Reviews • Is an academic discussion covering scenarios specifically described in 49 CFR Part 40 • Often does not include demonstrations

11. Collection Site VisitsA quick guide to beginning a mock collection

12. Drug & Breath Alcohol Tests

13. Collection Site Visits Does the collector: - Ask for photo ID? - Require a consent form? (Q: What is an acceptable form to have?)

14. 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?

15. Breath Alcohol Collection

16. Does the collector: • Use a Federal ATF? • Complete the steps correctly? • Use an approved EBT or saliva testing device?

17. Demonstration of Correct ATF Steps

18. Does the collector: • Have certifications and training records? • Keep regular accuracy checks recorded? • Maintain their equipment as required?

19. 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?

20. 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.?

21. Drug Collection

22. 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?

23. Does the collector: • Instruct the donor to remain within site of the collector? • Inspect the enclosure? • Add bluing to the toilet?

24. 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)

25. Once in the enclosure: • Are all concealment areas secured or removed? • Are all chemicals and fluids removed? • Are the ceiling tiles accessible?

26. Once in the enclosure: • Are there windows, doors, panels, or pass-through ports? • Is the toilet tank lid secured? • Is the water off?

27. Does the collector: • Check the temperature strip? • Check the quantity? • Distribute the specimen into each of 2 bottles?

28. Does the collector: • Provide a clean and suitable writing surface? • Use a Federal CCF? • Ensure all steps completed correctly on the CCF?

29. Demonstration of Correct CCF Steps

30. Does the collector: • Place specimen label seals on bottle? • Date the seals? • Instruct the donor to initial the seals?

31. Does the collector: • Seal the specimens into a shipping bag? • Monitor only one donor at a time?

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

33. Does the collector: • Have your correct phone number? • Transmit Copy 2 of the CCF directly to the MRO after each collection?

34. Does the collector: • Welcome visits? • Get regular refresher training? • Afford donors confidentiality and privacy before, during, and after the collection?

35. Does the collector: • Communicate directly with you? • Use the correct forms? • Understand the importance of the collection process as relates to your compliance?

36. Does the collector: • Also perform other USDOT-regulated tests? • Have hours or availability that match your hours of safety-sensitive operations?

37. 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

38. 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

39. Thank you for your attendance