The Collection Process: What Happens When You Take a DOT Drug Test?

May 15, 2025

Ophthalmologist's Department

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.

Temperature Checks: Catching Substituted Samples

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: When Are They Required?

Observed collections are extra-secure drug tests required in specific situations, such as:

  1. Return-to-Duty Testing (after a previous violation)
  2. Follow-Up Testing (for employees with prior violations)
  3. Suspected Tampering or Substitution (if the specimen appears altered)

What Happens During an Observed Collection?

  1. The employee must lower their pants/skirt, underwear, and raise their shirt in front of the observer.
  2. The observer checks for hidden containers or devices used to substitute or adulterate the sample.
  3. The urine must be watched leaving the body and entering the cup to confirm authenticity.

Legal Challenge? Yes, observed collections were challenged in court—but DOT regulations were upheld because employees returning after violations have greater motivation to cheat.

Final Thoughts: Be Informed, Stay Compliant

DOT drug testing might seem complicated, but understanding the process can help ease concerns.

  1. Know Your Rights: Employees can request a split sample test if they suspect a lab error—but should know positive results are rarely overturned.
  2. Follow the Steps: Compliance protects the integrity of testing and ensures fairness for all employees.
  3. Stay Prepared: Keeping a copy of Custody and Control Forms (CCF) can help confirm testing history and prevent unnecessary repeat tests.

DOT regulations continue evolving, but one thing remains the same: drug testing is a serious, structured process designed for safety, fairness, and accuracy.

Karishma Sarfani

Karishma is a Qualified Substance Abuse Professional (SAP) with a background in mental health and substance abuse counseling, holding credentials as an MS, LCDC, ICADC, CADC II, CSAC, CASAC II, LPC, and EMDR-trained therapist. Inspired by personal experiences with addiction and mental health challenges in her community, she has dedicated her career to supporting individuals on their journey to recovery and success.