Last updated : February 3, 2025
On January 15, 2025, the Office of Drug and Alcohol Policy and Compliance (ODAPC) released the “DOT Oral Fluid Specimen Collection Procedures Guidelines.” The Department of Transportation (DOT) published its final rule on May 2, 2023, authorizing employers to use oral fluid testing as an alternative to the urine drug test.
The ODAPC provided the Guidelines to ensure that proper collection procedures will be followed. They also address some of the common problems encountered, as well as situations that may arise during oral fluid collection. The ODAPC stressed that the Guidelines aren’t intended to be interpreted or viewed as changes to the legal requirements of Part 40.
The Guidelines breakdown
The DOT Oral Fluid Specimen Collection Procedures Guidelines lay out specific information for DOT drug testing collectors that includes:
- How to become a DOT-approved oral fluid collector
- Procedures for collecting oral fluid specimens
- List of certified oral fluid laboratories—currently, of which there are none
- Acceptable oral fluid devices to use for DOT testing
- The eCCF Notice to Specimen Collectors
Information regarding how to become certified to be an oral fluid specimen collector is broken down into three sections.
Basic info
This section of the document explains that collectors must be knowledgeable about Part 40. The 49 CFR Part 40 is a DOT-wide regulation breaking down the entire DOT drug testing procedure. It states how to conduct testing and how employees can return to safety-sensitive duties after violating a DOT drug and alcohol regulation.
Collectors must also understand the “Oral Fluid Specimen Collection Procedures Guidelines.” Additionally, they must subscribe for email updates to keep them abreast of any future changes.
Collectors may request a complete copy of the Guidelines by several methods.
They are:
Writing to:
ODAPC [Department of Transportation]
1200 New Jersey Avenue, SE
Washington DC, 20590
By phone: 202-366-3784
Or online.
Qualification training
There isn’t a published curriculum for oral fluid collection training, but the DOT expects its trainers to base their curriculum on DOT regulations and the latest version of the above-mentioned Guidelines.
The DOT’s qualification training includes:
- Knowledge about 49 CFR Part 40 (Part 40) collection procedures,
- Training to proficiency in the operation of the oral fluid device you will be using,
- How to properly fill out/transmit a Federal Drug Testing Custody and Control Form (CCF),
- How to handle problem collections (dry mouth, attempts to tamper with the test, etc.),
- Information about fatal and correctable flaws in collections and collection paperwork, and
- The collector’s responsibility for maintaining the integrity and credibility of the collection
process, privacy, and specimen security and avoiding conduct or statements that could be
viewed as offensive or inappropriate.
Anyone can provide qualification training as long as it meets the above criteria.
The trainer isn’t required to be an experienced or qualified collector. Moreover, future collectors may take online courses provided by third-party administrators (TPAs). The courses may be presented in person, conducted via video, online courses, or by taking part in a video conference.
Examinations aren’t required, however, the DOT recommends that the course provider has some means of ensuring that the information has been learned successfully.
Mock collections are the final task
After completing training, the future collector must perform five consecutive directly observed error-free mock oral fluid collections using an approved device or devices. These observations must be handled by a qualified monitor.
The mock oral fluid collections must include the following:
- One uneventful/routine,
- One insufficient quantity of oral fluid,
- One scenario in which the employee has something in their mouth that might interfere with
the collection, - One scenario in which the employee attempts to tamper with the specimen and
- One refusal to sign the CCF paperwork.
Once these five directly observed mock collections are complete, the future collector is ready to seek employment. Whether going to work for a large company full-time or freelancing to meet several smaller companies needs for oral fluid drug testing is up to the individual.
Electronic CCF filing
Familiarizing yourself with the electronic custody and control form is also an important step as many companies are switching to this method rather than keeping stacks of paper records on-site for future reference. As laboratories that accept electronic CCF forms become certified by the Department of Health and Human Services, they will be posted on the following website:
https://www.samhsa.gov/workplace/drug-testing-resources/eccf-approved-list
Interested in becoming a qualified collector?
Training isn’t hard to obtain and job security shouldn’t be an issue in this field as the trucking industry is a vital part of keeping goods and services flowing throughout our country. Subsequently, it appears that deciding to become a DOT-certified oral fluid specimen collector is a solid career choice.
Good luck!
