If you operate a DOT-regulated drug and alcohol testing program for your drivers, do you audit the testing forms?

It’s not unheard of for collection sites to make errors on the Federal Drug Testing Custody and Control Form (CCF) or the DOT Alcohol Testing Form (ATF). If you simply file the forms as soon as you receive them, you may miss an important mistake — one that could come back to haunt you in the event of an audit or litigation.

Auditing the completed forms when you receive them is an easy way to check up on your collection sites and make sure they’re completing the forms properly (performing more in-depth collection-site audits is recommended, but the forms are a good place to start.) Errors could be a “red flag” that your service providers — including collection site, lab, and/or medical review officer — may be having compliance problems, and that it’s time for a closer look at their handling of the testing process.

The following are some important things to watch for when reviewing a DOT drug or alcohol testing form:

• Did you receive the proper copy of the form, marked “Employer Copy”?
• Check the date and time listed on the form, showing when the employee reported for testing. Are they what you expected? Was there an unusual delay between when you notified the driver of the need to go for the test and the time the driver arrived at the testing site?
• Is the driver identified on the forms the same driver you sent?
• Did the collector and the driver both sign the CCF or ATF as needed?

For alcohol tests:

• Was an alcohol test ordered at all? If so, was it completed?
• If a drug test was also ordered, was the alcohol test conducted first? (If both tests are required, the alcohol test should be completed before the urine collection process begins, whenever possible.) You can check this by reviewing the time printed or written on the ATF versus the time written by the collector in Step 4 of the CCF.
• Note the time on the ATF — it should either be on a printout affixed to the form, printed directly onto the form, or written in by hand. Is the time accurate, as far as you can tell?
• Is the date accurate?
• What was the final screening test result? If it was 0.02 or greater, then a confirmation test should have been performed.
• If required, was an air-blank performed? An air-blank calibrates or “zeroes out” an evidential breath testing device (EBT) before it’s used for a confirmation test. The collector has to conduct an air-blank and show the reading to the driver. If the reading is 0.00, the test can proceed. If the reading is greater than 0.00 on two attempts, the EBT has to be taken out of service.
• Is the description, name, or serial number of the device used clearly indicated?

For drug tests:

• Was a drug test ordered at all? If so, was it completed?
• Did the collection site use the correct federal form? Sometimes collection sites mistakenly use non-federal forms.
• Does the CCF contain accurate information in Step 1, Parts A and B?
• Is the “FMCSA” box checked in Step 1, Part D?
• Can you read the handwriting of the collector?
• Did the collector press hard enough when writing, so that the carbon images are clearly visible and legible?
• For urine specimens, Check Step 2 to make sure the temperature was in range and that a split specimen was collected and checked.
• If a urine collection was “Observed,” make sure that an explanation is clearly written in the Remarks section. Unless it’s a return-to-duty or follow-up test, it’s a good business practice for you to confirm (by telephone or email), why the collection was directly observed, making certain that it was justified and that it did actually occur.
• If “Observed” is NOT indicated and it was a return-to-duty or follow-up test, verify that the test was in fact not observed — perhaps the box wasn’t checked by mistake. However, if the urine sample wasn’t collected under direct observation, the driver must immediately have another collection under direct observation.
• Are there “carbon shadows” visible on the bottom of the CCF? Specifically, shadows indicate that the donor initialed the labels while they were on the CCF and not after the collector applied them to each of the two specimen bottles.
• If the driver was unable to provide a specimen (“shy bladder”), was it written up in the Remarks in Step 2? Does your protocol with the collection site require additional documentation to record shy bladders?
• Do the dates in Steps 4 and 5 match? They should.

If you find errors, it may be a good time to converse with the collection site — or even schedule a visit or request additional documentation — to verify that they’re complying with the regulations. It’s your responsibility as a motor carrier to ensure that your service providers are following the rules.