• Minor errors on testing forms often don't cancel a test, but some are serious enough to require corrections.

Do you know what to do if you see an error on a DOT drug or alcohol testing form? Minor errors on testing forms can and do occur. They usually do not invalidate the test, but they often do need to be corrected.

For example:

• The driver’s license number may have transposed digits,
• The collector may have forgotten to record the urine temperature, or
• An old version of the testing form may have been used.

Don’t ignore the problem

As an employer, you have certain responsibilities when it comes to these types of errors; you cannot just ignore them, even if they weren’t your fault. If they turn up during an audit, you and/or your service providers can be penalized.

You are responsible for the actions of your service providers. You can ask for evidence that they are properly trained and consider switching to a new provider if a pattern of errors emerges.

The DOT testing regulations in 49 CFR Part 40 include specific instructions for correcting errors, both for drug testing and alcohol testing. The following is a summary of those requirements as they relate to the Drug Testing Custody and Control Form (CCF) and Alcohol Testing Form (ATF).

Affidavit required

For the errors listed below, you must notify the person responsible for providing the missing information. That person must then provide a signed written affidavit on the same day. The affidavit must explain the error and the steps taken to prevent future violations.

• The collector’s or technician’s signature is missing. (If the collector or technician is unavailable, a supervisor can supply the affidavit in this case.)
• The driver’s signature is missing, and the reason is not noted on the “Remarks” line.
• The collector failed to check the urine specimen temperature and the “Remarks” line doesn’t say anything about the temperature being out of range.
• Any other required information is missing.

Keep the affidavit with the CCF or ATF and make sure the form is marked in a way that makes it obvious that the flaw was corrected. Forms should never be “corrected” in a way that makes it appear that the error did not occur. One proper way to make a correction is to use a pen to circle the error, then indicate nearby what the correct information should be. Initialing the correction is also helpful, according to the DOT.

Wrong form

If a non-federal or expired form was used, notify the collector. The collector or a supervisor must provide a signed statement, on the same day, which:

• Affirms that the incorrect form contains all the right DOT-required information;
• Affirms that the test was conducted at a certified lab following Part 40 procedures;
• States that the incorrect form was used inadvertently, or as the only means of conducting the test; and
• Lists the steps taken to prevent future errors.

Keep the statement with the testing form and make sure the form is marked in a way that makes it obvious that the statement was provided.

No required actions

These errors don’t require any corrective actions:

• There’s a minor administrative mistake, such as a missing middle initial on a name or no identification of the DOT agency.
• The specific name of the courier is missing or wrong on the CCF.
• There’s personal identifying information on the CCF, such as if the driver signs the top ply (Copy 1).

Though correction of these problems is not required, it’s a good idea to bring them to the attention of the collector.

‘Fatal’ CCF flaws

Some CCF-related errors are not fixable and result in the medical review officer needing to cancel the test. These include:

• There is no CCF at all,
• The printed and signed name of the collector is missing,
• Two separate collections are recorded on one CCF, and
• The specimen ID number on the CCF does not match the number on the specimen bottle.