Last updated: September 25, 2023
In early May 2023, the Department of Transportation (DOT) released its final ruling in regard to oral fluid drug testing. The ruling went into effect on June 1st, approving oral fluid drug testing as an alternative to urine drug testing. Some companies have, undoubtedly, been looking forward to the announcement. There are many ways that oral fluid testing can benefit employers.
- The ability to detect recent drug use.
- Saving time due to the possibility of on-site testing rather than traveling to a testing facility.
- Oral fluid testing is less intrusive.
- Test subjects are always in view of technicians.
The oral fluid test can be used for any DOT-regulated drug test; pre-employment, random, reasonable suspicion, post-accident, return-to-duty, or probationary. Moreover, if there is a problem with the first test, say the urine specimen was out of temperature range by a smidgen, the employer may choose to switch to the other collection method to conduct the second test.
It can also benefit employees who suffer from shy bladder syndrome. Rather than being forced to remain on site for up to three hours in hopes of producing a urine specimen, an oral fluid test can be done instead.
Laboratory certification not completed
The oral fluid specimens must be submitted to a laboratory that has been certified by the Substance Abuse and Mental Health Services Administration (SAMHSA). Unfortunately, no laboratory has earned the certification as of yet. Moreover, the ruling stipulates that there must be at least two. One laboratory will serve as the primary laboratory and the second as a split-specimen laboratory.
In order to become certified to analyze oral fluid specimens, an applicant laboratory or Instrumented Initial Testing Facility (IITF) undergoes three rounds of performance testing. There is, also, a rigorous on-site inspection that must be passed with flying colors. Afterward, maintaining certification entails participating in a quarterly performance testing program and undergoing periodic on-site inspections. Lastly, certified laboratories will be required to provide the DOT with data, bi-annually, showing oral fluid tests are categorized correctly. The test reason must be given, as well as the specimen type.
Now that the final ruling regarding oral fluid drug testing has been released, laboratories will begin seeking certification. It’s anticipated that there will be at least two that have received certification by year-end or early 2024 at the latest.
DOT requires Collector certification
As with all DOT regulations, the oral fluid testing protocol lists a step-by-step procedure that must be strictly adhered to at all times. Failing to follow the mandated process puts employers out of compliance—even if using a third-party administrator (TPA) to conduct testing. The responsibility for remaining in compliance falls on the employer’s shoulders at all times.
Oral Fluid Collectors (OFC) must complete training before being allowed to administer the drug test. These classes are poised to spring up all over the country—online and in real-time. The hold-up is knowing what devices will be used for testing so proficiency demonstrations can be completed. That won’t be determined until laboratory certification is complete.
Collectors will learn to be proficient in operating various oral fluid devices and how to accurately perform the test. In addition, the importance of checking to see that tests aren’t expired is stressed because failure to do so causes a “fatal flaw” result. The test would be rendered null and void.
USAMDT plans to jump in that race. Our DOT Oral Fluid Collector Training course is designed for individuals working in the DOT-regulated industry who want to learn proper collection and specimen-handling techniques. Those who want to expand their knowledge base in this growing field to further advance their career in the safety-sensitive industry will benefit from successfully completing this course.
- Consortiums/Third Party Administrators (C/TPAs)
- Medical Review Officers (MROs)
- Substance Abuse Professionals (SAPs)
You will gain an in-depth understanding of the benefits of oral fluid drug testing over the urine drug test. Some of which are the convenience, non-invasiveness, and efficiency of oral fluid collection. The employee benefits, as well, because the process is more comfortable for them—not to mention faster—from start to finish. Moreover, the testing procedure is completed in view of the collector which eliminates the possibility of someone trying to falsify the results.
Classes also equip certified Oral Fluid Collectors in the following areas:
- Complete understanding of the DOT’s final ruling in regard to oral fluid drug testing
- Proper techniques and procedures for collecting oral fluid specimens
- Best practices for handling, storing, and shipping specimens to labs for analysis
- Understanding the differences between oral fluid and traditional urine testing
- Techniques that are useful in instructing others who are becoming oral fluid collectors, including properly using the device, observing the collection process, and completing the Chain of Custody Form (CCF) correctly
- Aid in developing effective training strategies and creating materials that can be used to train others to become certified oral fluid collectors
An overview of responsibilities
The DOT specifically breaks down the responsibilities of everyone who works in connection with company drug testing. Following the step-by-step protocol ensures that each test is administered correctly.
Employers are free to determine which testing method works best for their company and can even intermix the two. The entire testing process should be documented in writing before administering an oral fluid drug test. It’s also a wise idea to establish a working business relationship with oral fluid collector sites and laboratories—once they become available in your area.
Other duties include:
- Creating a standing order with collection sites
- Ensuring that Designated Employee Representatives (DERs) are available 24/7
- Ensure the information submitted on the CCF is correct
- Ready to interact with collectors who experience problems while collecting samples
- Discussing standing orders left at the collection site regarding any collection issues that arise
- Determining a refusal
If working with a third-party agent (TPA), it’s okay to go ahead and submit your standing orders as to when to use the oral fluid test as an alternative to urine testing or vice versa.
Whether a TPA or a direct employee of the company, collectors must have the employer’s testing preferences, known as standing orders, documented and on file. Additionally, as the employer must make themselves available to collectors, they, in turn, need to ensure that the employer has a telephone number that reaches them directly.
Other responsibilities include:
- Ensuring the employee’s ID number included on the CCF is either a social security number (SSN) or commercial driver’s license (CDL) number
- Determining that there are ample collectors on site who are qualified to administer both the urine or oral fluid test
- Being capable of correctly operating the specific test device used on site
- Completing the CCF training course
It’s also important to note that under most circumstances the employer determines whether a urine or oral fluid drug test will be used. However, there’s an exception to the rule. If a specimen donor identifies as non-binary or transgender and a direct observation test is necessary, the direct observation collection must be with oral fluid.
Medical Review Officers (MROs)
The medical review officer plays an important role after the tests are analyzed. The results are sent directly to them and are handled accordingly from that point on. Regarding oral fluid drug testing, once obtaining the certification, MROs don’t have to get recertified. They have the ability to “un-cancel” a drug test as well, say, perhaps if a missing CCF was submitted later on. Also, MROs don’t have the ability to determine a refusal.
Get all systems ready to go
Employers are encouraged to get their oral fluid specimen collectors lined out for certification now. Moreover, get all changes to their drug testing program due to using the oral fluid test documented in writing. It’s important to notify employees of the upcoming change as well. That way when the announcement is made that two laboratories have been SAMHSA approved, you’re ready to go.
Oral fluid drug testing is going to be a welcome addition to the DOT drug testing program. It’s considered far less invasive than the urine drug test. Employers are free to intermix the urine test and oral fluid drug test how they deem fit which can affect overall cost and time management too. Moreover, switching up the drug test may even provide a positive boost within your work culture as a whole.