Alcohol Screening Test
Anatomy of a Mock Drug Collection
Years of ASLRRA
John A. Ward, Ed.D., PS Technology (formerly Manager D&A Testing, Union Pacific RR)
Introduction The part of D&A testing that is most vulnerable to fatal flaws and an employee beating the test is not at the laboratory or during the Medical Review Officer (MRO) process but during the collection site process.
1
Introduction (cont.)
Custody and Control Form
Fatal flaws and other errors can result in: canceled tests federal fines unfavorable labor board decisions unproductive use of employees’ time and most importantly, undetected employee substance abuse.
Alcohol Testing Form
2
Introduction (cont.) Federal regulations hold the employer ultimately responsible for all testing errors, not the laboratory, MRO or Tester. “As an employer, you are responsible for meeting all applicable requirements and procedures of this part.” 49 CFR 40.11
3
Agenda In this training, we will discuss:
The Benefits of Mock Audits Whether of Not to Announce Audits Determining the Audit Agenda Tester Pre-test Preparation Key Breath Alcohol Testing Procedures Key Urine Collection Procedures
4
Benefits of Mock Audits Mock audits allow employer representatives to: get an up-close look at Tester procedures without involving employees participate in certain testing procedures that normally are done in private, per the CFR direct Testers to make changes to prevent federal violations and testing program discrediting
5
Announce the Audit or Not? Announcing audits to Testers in advance almost does not matter. Testers tend to establish habits during their training or they adopt other habits (good or bad) that do not change due to an audit. The key is to distinguish between the habits that comply with the CFR and those that do not.
6
Audit Agenda – What Matters? A mock audit can easily last an hour or more, depending on the details examined. So, the employer needs to determine what is of most importance.
Of top priority are issues related to: pre-test preparation fatal flaws vs. correctible errors, and specific company requirements i.e., not covered in the CFR 7
Audit Item 1 – Pre-test Preparation
8
Pre-test Preparation If Testers arrive at tests: not knowing certain key information (e.g., who, when, where and why) or, without a manual or phone number for guidance if something goes wrong they can make uncorrectable, embarrassing, and costly mistakes.
9
Pre-test Preparation (cont.) Below are possible questions to ask Testers on their pre-test preparation (see handout).
KEY – Using wrong testing authority can result in federal fines. CFR and manuals must be accessible during testing. 10
Audit Item 2 – Breath Alcohol Test
11
Approved Test Site and Security The CFR establishes the following minimum requirements (49 CFR 40.221 and 223): visual and aural privacy of test results suitable clean writing surface sufficient security that no unauthorized person enters the test site NOTE: Privacy is not required while completing forms, as long as test results are not being discussed.
12
6
Other “what ifs
”
Breath Alcohol Test: Yes No Audit Item Approved Site and Securit y 1 What is required to have an approved alcohol testing site? 2 What is required to provide security during alcohol test? 3 Other “what ifs ”
Alcohol Screening Test
The CFR requires the following of Testers:
1 2 3 4 5 6 7 8 9 10
KEY – Be 11 12
Screening Test Please demonstrate screening test procedures. o Request photo ID: company or governmen t o Explain testing procedures. Provide educational brochure o Complete ATF Step 1. Instruct EMPL to read + sign Step 2 o Select or allow EMPL to select wrapped/sealed mouthpiec e o Unwrap mouthpiece in front of EMPL + insert into EBT o Instruct EMPL: Blow steadily/forcefully until instructed to sto p o Show test result in EBT display to EMP L o Printout result, incl. test #, result, EBT name/serial # + time o Affix printout to ATF with tamper evident tape o If test result is 0.019 BAC or less, complete ATF Step 3 What is your response to employee who says ? sure to audit. o “I don’t have my company ID card, but it’s in my locker.” o “I won’t sign Step 2, but I’ll blow into EBT. ” If BAC is 0.019 or less, what other actions regarding EMPL?
13
5 6 7 8 9 10
o Unwrap mouthpiece in front of EMPL + insert into EBT o Instruct EMPL: Blow steadily/forcefully until instructed to sto p o Show test result in EBT display to EMP L o Printout result, incl. test #, result, EBT name/serial # + time o Affix printout to ATF with tamper evident tape o If test result is 0.019 BAC or less, complete ATF Step 3 What is your response to employee who says ? o “I don’t have my company ID card, but it’s in my locker.” o “I won’t sign Step 2, but I’ll blow into EBT. ” If BAC is 0.019 or less, what other actions regarding EMPL? o Release employee and report test result as "Negative " What actions would you take if BAC is 0.02 or above? o Instruct EMPL to stay with you for confirmation tes t o Instruct EMPL to not eat, drink, put anything in mouth or belch During 15 minute wait, is it OK to begin urine collection? Is it a “fatal flaw” to conduct confirmation test before 15 min. wait? Other “what ifs ”
Alcohol Screening Test (cont.)
Depending on test results, the CFR also requires: 11 12
13
KEY – Be sure to audit.
14 15 16 17 18
14
Alcohol Screening Test (cont.) Fatal flaws include: not obtaining an employee signature in Step 2 of the Alcohol Testing Form (ATF) not waiting 15 minutes before initiating a confirmation test Other ATF errors are correctable with a Statement of Correction from the Tester.
15
Alcohol Confirmation Test The CFR requires the following of Testers:
Breath Alcohol Test (cont.): Yes No Audit Item ConfirmationTest Please demonstrate confirmation test procedures. o Explain testing procedures to EMPL 1 o Select or allow EMPL to select wrapped/sealed mouthpiec e 2 o Unwrap mouthpiece in front of EMPL + insert into EBT 3 o Conduct Air Blank test. Show result in EBT display to EMP L 4 o Show EBT unique test number in display window to EMP L 5 o Instruct EMPL to blow steadily/forcefully until instructed to sto p 6 o Show test result in EBT display to EMP L 7 o Printout + ensure it incl. test #, result, EBT name/serial # + time 8 o Complete ATF Step 3. Affix printout w/ tamper evident tape 9 o If test result is 0.020 BAC or higher, 10 – Instruct EMPL to sign ATF Step 4 11 – Notify manager of EMPL + DAT Hotline KEY – Be sure to result audit. 12 If the test is 0.019 BAC or lower, what action would you take? 13 If the printer failed, what options are there to complete the test? 14 Other “what ifs ”
No
16
Alcohol Confirmation Test (cont.) Fatal Flaws include: testing without an air blank test or without an air blank test result of 0.00 BAC EBT printer fails to print out results EBT out of calibration on next accuracy check Other ATF errors are correctable with a Statement of Correction from the Tester.
EBT = Evidentiary Breath Testing device i.e., breathalyzer 17
Audit Item 3 – Urine Collection
18
Approved Collection Site The CFR requires: (49 CFR 40.41 and 43): water for washing hands (or moist towelettes) suitable clean writing surface toilet for urination privacy during urination, incl. full-length door, unless authorized to monitor or directly observe
NOTE: A portable toilet can meet toilet and privacy requirement.
19
Bathroom Preparation and Security The CFR requires: (49 CFR 40.43): possible water sources and adulterants made secure (e.g., taped) water in toilet is blue sufficient security that no unauthorized person enters the test site
20
Collection Procedures – Donor The CFR requirements of donors include: positive donor ID (e.g., photo drivers license) removal of outer garments (e.g., jacket) display items in pockets and wallet wash and dry hands attempt to provide urine sample (45 mL) follow other instructions of Collector NOTE: Other requirements are in 49 CFR 40.61 – 73.
21
Collection Procedures – Collector The CFR requirements of Collectors include: explain basic collection procedures to donor check specimen volume, temp. and tampering split specimen into A and B bottles place tamper-evident seals on bottles print and sign Custody & Control Form (CCF)
NOTE: Other requirements are in 49 CFR 40.61 – 73.
22
Collection Procedures (cont.) Fatal Flaws include: Insufficient specimen is collected Specimen seals are absent or breached CCF and seal ID numbers do not match Collector fails to print name & sign CCF Step 4 Other CCF errors are correctable with a Statement of Correction from the Tester.
23
Questions?
24
Handout
25
Years of ASLRRA
John A. Ward, Ed.D., PS Technology (formerly Manager D&A Testing, Union Pacific RR)
Introduction The part of D&A testing that is most vulnerable to fatal flaws and an employee beating the test is not at the laboratory or during the Medical Review Officer (MRO) process but during the collection site process.
1
Introduction (cont.)
Custody and Control Form
Fatal flaws and other errors can result in: canceled tests federal fines unfavorable labor board decisions unproductive use of employees’ time and most importantly, undetected employee substance abuse.
Alcohol Testing Form
2
Introduction (cont.) Federal regulations hold the employer ultimately responsible for all testing errors, not the laboratory, MRO or Tester. “As an employer, you are responsible for meeting all applicable requirements and procedures of this part.” 49 CFR 40.11
3
Agenda In this training, we will discuss:
The Benefits of Mock Audits Whether of Not to Announce Audits Determining the Audit Agenda Tester Pre-test Preparation Key Breath Alcohol Testing Procedures Key Urine Collection Procedures
4
Benefits of Mock Audits Mock audits allow employer representatives to: get an up-close look at Tester procedures without involving employees participate in certain testing procedures that normally are done in private, per the CFR direct Testers to make changes to prevent federal violations and testing program discrediting
5
Announce the Audit or Not? Announcing audits to Testers in advance almost does not matter. Testers tend to establish habits during their training or they adopt other habits (good or bad) that do not change due to an audit. The key is to distinguish between the habits that comply with the CFR and those that do not.
6
Audit Agenda – What Matters? A mock audit can easily last an hour or more, depending on the details examined. So, the employer needs to determine what is of most importance.
Of top priority are issues related to: pre-test preparation fatal flaws vs. correctible errors, and specific company requirements i.e., not covered in the CFR 7
Audit Item 1 – Pre-test Preparation
8
Pre-test Preparation If Testers arrive at tests: not knowing certain key information (e.g., who, when, where and why) or, without a manual or phone number for guidance if something goes wrong they can make uncorrectable, embarrassing, and costly mistakes.
9
Pre-test Preparation (cont.) Below are possible questions to ask Testers on their pre-test preparation (see handout).
KEY – Using wrong testing authority can result in federal fines. CFR and manuals must be accessible during testing. 10
Audit Item 2 – Breath Alcohol Test
11
Approved Test Site and Security The CFR establishes the following minimum requirements (49 CFR 40.221 and 223): visual and aural privacy of test results suitable clean writing surface sufficient security that no unauthorized person enters the test site NOTE: Privacy is not required while completing forms, as long as test results are not being discussed.
12
6
Other “what ifs
”
Breath Alcohol Test: Yes No Audit Item Approved Site and Securit y 1 What is required to have an approved alcohol testing site? 2 What is required to provide security during alcohol test? 3 Other “what ifs ”
Alcohol Screening Test
The CFR requires the following of Testers:
1 2 3 4 5 6 7 8 9 10
KEY – Be 11 12
Screening Test Please demonstrate screening test procedures. o Request photo ID: company or governmen t o Explain testing procedures. Provide educational brochure o Complete ATF Step 1. Instruct EMPL to read + sign Step 2 o Select or allow EMPL to select wrapped/sealed mouthpiec e o Unwrap mouthpiece in front of EMPL + insert into EBT o Instruct EMPL: Blow steadily/forcefully until instructed to sto p o Show test result in EBT display to EMP L o Printout result, incl. test #, result, EBT name/serial # + time o Affix printout to ATF with tamper evident tape o If test result is 0.019 BAC or less, complete ATF Step 3 What is your response to employee who says ? sure to audit. o “I don’t have my company ID card, but it’s in my locker.” o “I won’t sign Step 2, but I’ll blow into EBT. ” If BAC is 0.019 or less, what other actions regarding EMPL?
13
5 6 7 8 9 10
o Unwrap mouthpiece in front of EMPL + insert into EBT o Instruct EMPL: Blow steadily/forcefully until instructed to sto p o Show test result in EBT display to EMP L o Printout result, incl. test #, result, EBT name/serial # + time o Affix printout to ATF with tamper evident tape o If test result is 0.019 BAC or less, complete ATF Step 3 What is your response to employee who says ? o “I don’t have my company ID card, but it’s in my locker.” o “I won’t sign Step 2, but I’ll blow into EBT. ” If BAC is 0.019 or less, what other actions regarding EMPL? o Release employee and report test result as "Negative " What actions would you take if BAC is 0.02 or above? o Instruct EMPL to stay with you for confirmation tes t o Instruct EMPL to not eat, drink, put anything in mouth or belch During 15 minute wait, is it OK to begin urine collection? Is it a “fatal flaw” to conduct confirmation test before 15 min. wait? Other “what ifs ”
Alcohol Screening Test (cont.)
Depending on test results, the CFR also requires: 11 12
13
KEY – Be sure to audit.
14 15 16 17 18
14
Alcohol Screening Test (cont.) Fatal flaws include: not obtaining an employee signature in Step 2 of the Alcohol Testing Form (ATF) not waiting 15 minutes before initiating a confirmation test Other ATF errors are correctable with a Statement of Correction from the Tester.
15
Alcohol Confirmation Test The CFR requires the following of Testers:
Breath Alcohol Test (cont.): Yes No Audit Item ConfirmationTest Please demonstrate confirmation test procedures. o Explain testing procedures to EMPL 1 o Select or allow EMPL to select wrapped/sealed mouthpiec e 2 o Unwrap mouthpiece in front of EMPL + insert into EBT 3 o Conduct Air Blank test. Show result in EBT display to EMP L 4 o Show EBT unique test number in display window to EMP L 5 o Instruct EMPL to blow steadily/forcefully until instructed to sto p 6 o Show test result in EBT display to EMP L 7 o Printout + ensure it incl. test #, result, EBT name/serial # + time 8 o Complete ATF Step 3. Affix printout w/ tamper evident tape 9 o If test result is 0.020 BAC or higher, 10 – Instruct EMPL to sign ATF Step 4 11 – Notify manager of EMPL + DAT Hotline KEY – Be sure to result audit. 12 If the test is 0.019 BAC or lower, what action would you take? 13 If the printer failed, what options are there to complete the test? 14 Other “what ifs ”
No
16
Alcohol Confirmation Test (cont.) Fatal Flaws include: testing without an air blank test or without an air blank test result of 0.00 BAC EBT printer fails to print out results EBT out of calibration on next accuracy check Other ATF errors are correctable with a Statement of Correction from the Tester.
EBT = Evidentiary Breath Testing device i.e., breathalyzer 17
Audit Item 3 – Urine Collection
18
Approved Collection Site The CFR requires: (49 CFR 40.41 and 43): water for washing hands (or moist towelettes) suitable clean writing surface toilet for urination privacy during urination, incl. full-length door, unless authorized to monitor or directly observe
NOTE: A portable toilet can meet toilet and privacy requirement.
19
Bathroom Preparation and Security The CFR requires: (49 CFR 40.43): possible water sources and adulterants made secure (e.g., taped) water in toilet is blue sufficient security that no unauthorized person enters the test site
20
Collection Procedures – Donor The CFR requirements of donors include: positive donor ID (e.g., photo drivers license) removal of outer garments (e.g., jacket) display items in pockets and wallet wash and dry hands attempt to provide urine sample (45 mL) follow other instructions of Collector NOTE: Other requirements are in 49 CFR 40.61 – 73.
21
Collection Procedures – Collector The CFR requirements of Collectors include: explain basic collection procedures to donor check specimen volume, temp. and tampering split specimen into A and B bottles place tamper-evident seals on bottles print and sign Custody & Control Form (CCF)
NOTE: Other requirements are in 49 CFR 40.61 – 73.
22
Collection Procedures (cont.) Fatal Flaws include: Insufficient specimen is collected Specimen seals are absent or breached CCF and seal ID numbers do not match Collector fails to print name & sign CCF Step 4 Other CCF errors are correctable with a Statement of Correction from the Tester.
23
Questions?
24
Handout
25
