April 2006
Questions & Answers
Specimen Temperature Out of Range
Question: I was notified by the collection
site that my driver’s specimen was less than
90ºF It was a very cold day could that be
the cause of it being too low?
Answer: The collector must check the temperature of the specimen by reading the temperature strip attached to the collection container, no later than four minutes after the employee has given them the specimen. The acceptable temperature range is 32-38ºC/90-100ºF.
If the specimen temperature is within the acceptable range, they must mark the “Yes” box on the CCF (Step 2) or if the specimen temperature is outside the acceptable range, they must mark the “No” box and enter in the “Remarks” line (Step 2) their findings about the temperature.
In some cases, though not required, we have seen where the collector will take the donor’s temperature and also make the notes in the “Remarks” line.
If the specimen temperature is outside the acceptable temperature range, the collector must immediately conduct a new collection using direct observation procedures (refer to §40.67). In a situation where a specimen is collected under direct observation, the collector must process both the original specimen; the two sets of specimens must be sent to the laboratory. This is true even in a case where the original specimen has insufficient volume, but the temperature was also out of range.
The collector must also, as soon as possible, inform the DER (Designated Employer Represenitive) and collection site supervisor that a collection took place under direct observation and the reason for doing so.
In a collection where the employee refuses to provide another specimen (refer to §40.191(a)(3)) including an observed collection (refer to §40.191(a)(4)), the collector must notify the DER. Once the DER has been notified the collector must discard any specimen the donor has provided previously during the collection procedure. Refer to the regulations in CFR Part 40, §40.65 for further clarification.
It has been our experience that in most cases concerning a cold specimen, the donor substituted the first sample with a container of hidden urine thus the reason for it not being in the acceptable temperature range. In these types of situations, the donor either refused to take a re-collection and left the site, or the second specimen collection is within the acceptable temperature and once tested at the laboratory, confirms positive for a controlled substance.
Addressing The Proper Procedure
In The
Event Of A Specimen Temperature Out Of
Range
In the March issue we had addressed some of the various situations that we have experienced regarding insufficient volume or leaving the collection site prior to the completion of the testing process. In this issue we will address the proper procedure in the event of a specimen temperature out of range. Although “cold specimen” is usually the case, we have also experienced where a specimen was “extremely warm”.
Believe It Or Not!
- The following true story
was recently conveyed to us by an MRO (Medical
Review Officer). The MRO had received a call
from an irate donor who had tested positive
for both cocaine and marijuana. Originally the
donor had provided a cold specimen at the collection
site, so he was instructed to re-collect observed.
Once both specimens had been tested at the laboratory
and reviewed by the MRO, the donor was notified
he had tested positive for both cocaine and
marijuana. He was very adamant that he had never
used cocaine in his life, convinced that this
was a false positive and that the laboratory
testing was not accurate. The MRO explained
to the donor that the first specimen sample
was positive for cocaine and the second re-collection
was positive for marijuana. He then asked the
donor to honestly tell him where did he get
the first specimen? The donor admitted he got
the first specimen from his son, to which the
MRO then informed him that the donor’s
son was using cocaine.
- We had another case where
a collection site contacted us to let us know
they had a situation where a father and his
two sons went in for pre-employment urine collections.
In this case, all three had cold specimens and
when instructed to re-collect observed, all
three choose to leave the collection site.
So as you can see though the requirements of the testing for controlled substance and alcohol may not be foolproof in catching everyone, these are just a couple of examples where the system is working.
Random Testing Reminder:
With our 2nd quarter of the random testing upon
us, again I cannot emphasize enough the importance
of promptly responding to a notification. As the
employer, once you have notified your employee,
they must proceed directly to the collection site,
technically the donor should only be allotted
the reasonable amount of time that it takes to
get from the point of the notification to the
collection site. If they stop off in-between it
can constitute as a refusal. The cases described
above are another reason why it is so important
that the donor is not given advanced notice.
This applies to the owner-operator too, once you have received your notification you must proceed directly to the collection site.
Collection Sites Updates:
Be sure to review the C-DATA collection site list
of authorized sites. The list was included in
your 2006 renewal packets. If you recently enrolled,
it can be found in Section 7 of your C-DATA Compliance
Manual. You can also view it 24-hours a day on
our website at c-data.com or contact our office
if you are in doubt.
Although changes to our site list is infrequent, please do not assume that the site you went to in previous years is still an authorized site; it may have moved, closed, changed hours, changed ownership or even may no longer perform DOT collections.
Remember, our qualified AADT staff encourages and welcomes your inquiries!
Respectfully,
Lonnie
Johnson
AADT Operations Director
Note that throughout this article, when I refer to the applicable federal regulations, I’m referring to CFR 49, Parts 40 & 382; these regulations can be found in Section 5 of the AADT Company Compliance Manual or in the AADT website at www.aadrugtesing.com under links at DOT Office of Drug and Alcohol Policy and Compliance at www.dot.gov/ost/dapc or Federal Motor Carrier Safety Administration at www.fmcsa.dot.gov.