FTA DRUG AND ALCOHOL PROGRAM NATIONAL CONFERENCE How to Review Your Collection Site for Compliance...
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Transcript of FTA DRUG AND ALCOHOL PROGRAM NATIONAL CONFERENCE How to Review Your Collection Site for Compliance...
FTA DRUG AND ALCOHOL PROGRAM NATIONAL CONFERENCE
How to Review Your Collection Site
for Compliance
Atlanta, GA 2015
Why Inspect?
Central Role• Collection Sites are
final and central component to D&A program
• Highest likelihood of technical flaws (most regs to follow)
Cheating• Many sites fail basic
security/integrity procedures
• Users have most to lose, always a step ahead
Oversight• Thousands of sites• Millions of tests per
year
Why Inspect?FTA’s Clandestine Collections• FTA maintains a full-fledged clandestine collection site inspection program• How will your site do?
FAIL STATS• 7% have failed to identify donor• 36% have failed to check pockets• 31% have failed to require hand washing
Bad Sites• 9% reviewed showed critical failures• Your employees deserve better
Why Inspect?
Critical Flaws (L4) Serious Flaws (L3) Routine Flaws (L2) Admin Flaws (L1)0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
Critical Flaws (L4); 9%
Serious Flaws (L3); 83%
Routine Flaws (L2); 74%
Admin Flaws (L1); 72%
Percentage of Inspections w/ Flaw Type
Includes 691 inspections through Dec. 2014
Traveling Public
US Congress
US DOT
FTA
DAPM
Collector
Collection Site Visits – FTA Method
Scheduled Open ProcessInstructional Identity & Purpose clearly statedIncludes discussion of “problem” collections/scenariosWater sample
Pros
QuestionnaireThorough understanding of policies, practices, knowledgeCan openly inspect equipment, facilityCan openly inspect credentials
Cons
The RingerDynamic can compound collector mistakes “Rest of process” missingSome errors fixed by nature of mock
Collection Site Visits
Begin with:
FTA Collection Site Questionnaires (http://transit-safety.fta.dot.gov/DrugAndAlcohol/tools)
Both Urine and Breath-Alcohol questionnaires availableSet a dateFamiliarize yourself with the questionnaire
(Call us if you have questions!) A review of CCFs/ATFs from site beforehand is extremely helpful
Collection Site Visits
There are two components to collection site inspection:
1. Mock collection
2. Unusual (“problem”) collections discussion
Collection Site Visits
Mock Collection
A demonstration of procedures used during normal/uneventful collections
Corrections should be conveyed after the mock
Collector should perform mock just as he or she normally would
Collection Site Visits
Unusual collections review
A discussion covering scenarios specifically described in 49 CFR Part 40Shy BladderRefusalsDirect ObservationAnd More!
Does not usually include demonstrations
The Breath Alcohol Test §40.211-§40.279
Does the Breath Alcohol Technician (BAT): Request photo ID (if not done already)
Use a Federal Alcohol Testing Form (ATF)?
Complete the form correctly and in order? 1-2-3-(4)
Use a NHTSA-approved EBT (breath device) or ASD (saliva testing device)?
Does the BAT/Site:
Have training/qualification records?
Keep regular accuracy checks recorded?
Maintain their equipment as required?
Does the BAT/Site:
Have a copy of the Quality Assurance Plan (QAP) for the device (EBT) used?
Have a current copy of 49 CFR Part 40?
Understand how to load and troubleshoot problems with the device?
Does the BAT/Site:
Have an EBT for confirmation tests if they use saliva test or non-evidential breath testing device?
Have any experience with positive tests?
Understand special circumstances, such as refusals, fatal flaws, etc.?
The Urine Drug Collection§40.31-§40.73 & §40.191- §40.209
Does the collector:
Request photo ID (if not done already)?Instruct donor to remove outer garments?Instruct donor to empty pockets?Allow the donor to keep wallet?Explain the procedures?
Including showing the donor the instructions printed on the back of the form
Does the collector:
Ask donor to wash hands?
Secure all internal water sources?
Open sealed kit in front of donor
Give donor a 55ml container?
Once in the enclosure:
Concealment areas secured or removed?
Chemicals and fluids removed?
Ceiling tiles secured?
Twelve pieces of paraphernalia found at this major US airport collection site. >
Once in the enclosure:
Are there windows, doors, panels, or pass-through ports?
Is the toilet tank lid secured?
Is the water off?
Does the collector:
Check the temperature strip?
Check the quantity?
Distribute the specimen into each of 2 bottles?
Does the collector:
Provide a clean and suitable writing surface?
Use a Federal CCF?
Ensure all steps completed correctly on the CCF?Don’t forget: 1, 2, 3, 5, 4!
Demonstration of Correct CCF Steps
Steps 1 & 2
What’s Wrong/Missing?
What’s Wrong/Missing?
29
30
Does the collector:
Place specimen label seals on bottle?
Date the seals?
Instruct the donor to initial the seals?And verify initials?
54321
Does the collector:
Seal the specimens into a shipping bag?
Monitor only one donor at a time?
Discussion Topics
Shy Bladders
Uncooperative donor
Direct Observation
Shy Bladder
Donor must make initial attempt, even if:Waiting for representative, or“Just doesn’t have to go”
Donor has 3hrs to provide specimen beginning with QNS cup
Donor may have up to 40 ounces of fluid over 3hrsDoesn’t have to drinkMeasurements must be:
ConsistentAccurate
Uncooperative Donors
If a donor is uncooperative:Terminate testRecord actions in “Remarks” sectionCall DER
This is a refusal to testThis goes for being uncooperative for directly observed or monitored
tests as well… Collector is in Charge!
Direct Observation
If donor:Removes tampering materials from pocketsBehaves in a way that “clearly indicates an attempt to tamper with a
specimen”Provides a specimen out of tempProvides an adulterated/tampered specimen
Collector must require Direct Observation
Direct Observation Cont.
D.O. collection must occur immediatelyNo provision for waiting period, fluid intake
Same-gender observerNeed not be a collector or medical professional
Observer must:Require that donor disrobe (to chest, knees) and rotate to display absence of
devicesWatch urine travel from body to cupRecord name on CCF (if not collector)
Discussion Topics
Frequency of courierDaily
Security of stored specimenNo access by “civilians”
General facility security & privacyBack doors, lock boxes
Fixing FlawsImmediate or next business day
Collector training and retrainingMock collections in training30 days to retrain after a Fatal Flaw
Does the Site:
Have your correct contact information?
Transmit Copy 2 of the CCF directly to the MRO after each collection?
Afford donors confidentiality and privacy before, during, and after the collection?
Does the Site:
Welcome your visits?
Perform other USDOT-regulated tests?
Understand the importance of the collection process as relates to your compliance?
Next steps:
Get questionnaires http://transit-safety.fta.dot.gov/DrugAndAlcohol/tools
Make an appointmentVisit & evaluateRequire corrective actions
Give them a due date!Re-visit
Remember: Your collection site should be… Consistent and accurate
Your partner in the process
Willing to respond to your request for compliant practices
FTA Drug and Alcohol ProgramNATIONAL CONFERENCE
THANK YOU
Atlanta, GA 2015