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Handling Suspected Tampering in DOT-Regulated Urine Drug Tests

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In federally regulated drug testing, the integrity of the specimen collection process is critical. When conducting Department of Transportation (DOT)-regulated urine drug tests, it’s essential to recognize and respond to potential specimen tampering. Ensuring proper protocol is followed helps maintain the reliability of results and keeps workplaces safe and compliant.


Recognizing Tampering: The Collector’s Role

Collectors are the first line of defense in identifying potential tampering. During the collection process, they should remain alert for signs such as:

  • Unusual sample appearance (e.g., blue dye or excessive foaming)

  • Unusual odor (e.g., bleach or chemical-like smell)

  • Temperature or color inconsistencies

If tampering is suspected, the collector must:

  1. Document findings on the Custody and Control Form (CCF)

  2. Notify the Designated Employer Representative (DER)

  3. Begin a second collection immediately under direct observation per 49 CFR §40.67

    • If oral fluid testing is permitted, this method may be used instead


Responsibilities of the Designated Employer Representative (DER)

The DER plays a key role when notified of suspected tampering. Upon receiving the report, the DER must:

  1. Confirm that a second, observed collection is necessary and begin it without delay

  2. Clearly explain the situation to the employee and inform them of next steps

  3. Maintain detailed documentation of the incident and the steps taken


What the Medical Review Officer (MRO) Does

Once the laboratory analyzes the specimen, the MRO evaluates the results and determines next steps:

  1. Review the findings to assess any signs of adulteration or substitution

  2. Contact the employee to offer an opportunity to explain any discrepancies

  3. If no valid medical explanation is provided, confirm the tampering and report the result to the DER


Why It Matters

Following these procedures ensures your organization remains compliant with DOT regulations while upholding the integrity of your workplace drug testing program. Failure to follow proper steps can compromise safety, invite legal risk, and reduce trust in your testing policies.


For assistance with training collectors, policy review, or handling tampering cases, Mid-South Drug Testing is here to help.


Call us at (901) 320-9295 or (870) 215-0025

 
 
 

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