Both employers and employees are sometimes confused about the direct observation urine drug test. Some believe that every drug test happens under direct observation. Others think a direct observation drug test is a rights violation and should never happen.
But in U.S. Department of Transportation-regulated industries, direct observation drug screens are necessary and mandated under very specific circumstances and are stringently regulated to protect the donor, their employer, the collector and the workplace.
Here is an overview of where and when direct observation collections need to be conducted according to DOT 49 CFR Part 40:
1. Any time the urine specimen temperature is out of range. If the temperature strip on the specimen cup is too hot, too cold or does not register any temperature, the collections professional will perform a second test under direct observation. Temperature failure assumes that the specimen did not come from the donor’s body. A urine test completed under direct observation ensures the specimen has come from the donor’s body without any tampering via adulteration or substitution.
2. When the collector detects signs of tampering. If a specimen has an unusual color or odor or the collector finds something in the employee’s possession that could be used to adulterate a specimen, they may determine the need for a direct observation.
3. During every Follow Up and Return to Duty situation, we observe the collection and follow the process as outlined in 49 CFR Part 40. Follow up and Return to Duty tests are conducted when a donor has previously failed a drug test and is now working toward successfully completing a drug test (or series of tests) that will allow them to remain at work.
4. The DER (Designated Employer Representative) may request that a donor be tested under direct observation if they have reason to believe the donor may try to adulterate or substitute the specimen.
In these situations, the observer must be of the same gender as the donor and will follow very specific procedures to ensure the integrity of the test.
DOT drug testing is about safety. While a direct observation collection may not be pleasant for anyone, it is another tool to ensure the employee’s ability to perform their duties in a safe manner and can serve as a deterrent when the temptation to submit false samples arises. At TSS, specimen integrity is our priority and safety is our middle name!