May 15, 2025
From the moment an employee enters the testing site to the final sealing of the specimen, each step of the collection process is highly regulated by DOT. Here's how it works:
1. Handwashing – Employees must wash their hands before providing the specimen to remove any potential adulterants from their hands and fingernails.
2. Emptying Pockets – Employees are required to empty their pockets before testing, ensuring they do not bring unauthorized substances into the restroom.
3. Choosing a Collection Kit – A collector presents a pyramid of cardboard boxes, each containing collection kits. Employees pick a kit, and once selected, the test has officially begun.
4. Providing the Specimen – The employee must provide a urine sample within three hours. Initially, the time limit was two hours, but DOT increased it to three hours, recognizing that delays—especially for transit employees—can be disruptive.
5. Checking for Tampering – The collector eyeballs the sample, checks the temperature, and looks for signs of tampering.
6. Sealing the Specimen – The urine is poured into two small bottles (a primary and secondary sample), sealed with barcodes from the Custody and Control Form (CCF), and secured in the employee's presence.
Key Fact: A collector can only perform one collection at a time—meaning if multiple people are being tested simultaneously, there must be multiple collectors.
A major concern in drug testing is substituted or fake urine samples. DOT regulations require the collector to read the temperature within four minutes of collection.
The temperature must be between 90°F and 100°F—if it falls outside this range, the collector immediately triggers an observed collection (more on that later).
Some individuals attempting to cheat the system use hot pads or chemicals to keep urine warm. However, experienced collectors can still detect samples that are too cold or too hot to have come from the body.
Refusal to Test: If an employee cannot or will not provide another sample under observation, it's considered a refusal to test, which can have serious consequences for employment.
Observed collections are extra-secure drug tests required in specific situations, such as:
What Happens During an Observed Collection?
Legal Challenge? Yes, observed collections were challenged in court—but DOT regulations were upheld because employees returning after violations have greater motivation to cheat.
DOT drug testing might seem complicated, but understanding the process can help ease concerns.
DOT regulations continue evolving, but one thing remains the same: drug testing is a serious, structured process designed for safety, fairness, and accuracy.