Last updated : January 20, 2025
As soon as the Department of Transportation (DOT) released its final ruling approving the oral fluid drug test as an alternative testing methodology to urine drug testing in May 2023, companies that plan to provide DOT Oral Fluid Collectors training courses sprang into action to complete their teaching methods. They are ready to shoot out of the gate nationwide as soon as the DOT announces that there have been two laboratories that have been certified by the Substance Abuse and Mental Health Services Administration (SAMHSA).
That’s predicted to happen in late 2023 or early 2024.
The final ruling lists the updates made to 49 CFR Part 40. They are as follows:
- Applicants and employees could be subject to either an oral fluid collection or a urine collection for any DOT-regulated test
- If there is a reason that a second collection is needed during a testing event—say, the specimen is of insufficient quantity for either a urine or oral fluid submission, perhaps—the employer may choose to use the other type of collection to complete the testing event.
- The employer decides which test to conduct. The only exception to that rule is if an observed test is required and the person to be tested identifies as either non-binary or transgender. In that event, the oral fluid test must be used.
Beginning the collection process
During the training course, collectors will learn the proper procedure for administering the DOT oral fluid drug test. After completing the identification and sign-in process, the collector will request the employee to open his mouth. The collector inspects the oral cavity to ensure that it’s free of any items that could impede or interfere with the oral fluid collection process. That could include candy, gum, food, or tobacco. The collector also looks for anything that could be used to adulterate, substitute, or alter the specimen.
If the collector discovers anything identified above, they will ask the employee to lift their tongue and separate their cheek from their gum to permit further inspection. Should the employee claim they are unable to comply due to a medical condition, the collector follows the procedure described in § 40.193(a).
Should the collector observe materials brought to the collection site—or the employee’s demeanor clearly indicates—an attempt to adulterate, substitute, or alter the specimen, they will immediately terminate the drug test. They document the reason for termination in the Remarks section of the Custody and Control Form (CCF) and report the circumstances to the Designated Employer Representative (DER). It is then the employer’s responsibility to determine whether to deem the situation a refusal.
Should the collector discover something in the employee’s mouth that could interfere with collecting the specimen, they request the employee to remove the item. If the employee refuses, the collector is to follow the same refusal procedure as listed above. If the item is removed and the saliva is an abnormal color, the collector must give the employee up to 8 ounces of water to thoroughly rinse their mouth. The employee may drink the water as well. After a 10 minute wait period, the collector proceeds with specimen collection.
If nothing is discovered in the oral cavity, the collector starts a 10-minute wait period and proceeds with the steps below:
- Review the procedure for a successful oral fluid specimen collection as stated in the manufacturer’s instructions for that specific collection device.
- Complete all items under Step 1 of the CCF.
- The collector will either provide or have the employee select a specimen collection device that is wrapped and sealed in its original packaging.
- It’s the collector’s responsibility to check the expiration date on the device or packaging and to show it to the employee.
- If the device has expired, a new one will be chosen.
- The employee is to have a full view of the collector opening the device package.
- Completing Step 2 of the CCF form includes: checking the test type to be “Oral Fluid.” Therefore, “Subdivided” is checked off next to “Oral Fluid: Split Type.” Lastly, the collector checks off that the expiration date hasn’t been reached.
Carrying out the collection process
The device is placed between the employee’s cheek and lower gum and they are asked to keep it there for the duration of the test. The testing device is equipped with a colored signal that registers the test as complete. The collector removes the device from the employee’s mouth. And, in the presence of the employee, the collector splits the sample at the divider and places one piece in the specimen bottle designated as “Bottle A” and the other in “Bottle B.”
The employee watches as the collector places a tamper-evident seal from the CCF over each cap. The expiration date should not be obstructed in any way. The collector records the date of the collection on the tamper-evident seals after they are placed on the containers.
The collector enters the Split Specimen Device Expiration Date in Step 4 of the CCF because only one oral fluid device is used that is then divided in the presence of the donor and placed in separate vials.
The collector instructs the employee to initial the tamper-evident seals on each specimen container. If they decline, the collector documents that fact in the “Remarks” section of the CCF. Either way, this completes the collection process.
We’ll be ready to roll
USA Mobile Drug Testing (USAMDT) is committed to staying abreast of the changes made to the DOT drug testing program. We have our training classes in the works and will be ready to roll them out as soon as the DOT gives the green light at the end of this year or early next.
In the meantime, if you have any questions or want to get set up for DOT drug testing, don’t hesitate to reach out. You can contact our Training Team at the USAMDT headquarters in Tampa. The telephone number is 866-965-7071 or email the team directly at: [email protected].