If we want to do in-house DOT drug and alcohol testing, what do we need to consider?

In an attempt to save money and for convenience, some motor carriers have set up their own in-house collection facilities. This is often accomplished through training someone within an existing health department, separating the collection process from the safety department. Carriers that do not separate the process may have potential legal implications and must be prepared to defend against accusations of bias or tampering.

If your organization wants to set up an on-site collection facility, you must take the following into account:

• Does your current facility meet the requirements in order to conduct a collection? Will you have to modify your current restrooms in order to conduct the tests?
• Is there someone other than a safety manager who can be trained to conduct the urine or oral-fluid drug-testing collection or the alcohol screening? An immediate supervisor of a driver may not be used unless there is absolutely no one else available to conduct the test. A supervisor is unable to conduct the reasonable suspicion test if they were the manager who requested it. (See 382.307(c).)
• Are you willing to invest in the proper alcohol screening and/or evidential testing equipment?
• Are you able to ensure that the drug-testing specimens are properly stored and shipped within 24 hours of collection or the next business day?
• Are you willing or able to take on the recordkeeping requirements of a collection site/service provider? You must maintain such items as documentation of the drug specimen collection and/or alcohol testing personnel’s training, proficiency, and refresher training; the collector’s copy of the chains of custody for at least 30 days; and records of calibration tests of breath alcohol testing equipment.

You will need to weigh the answers to these questions against the money you would be saving by performing the tests in-house.