With substance abuse costing the United States over $740 billion every year in productivity, health care, and crime, the money you spend on employee drug testing is probably money well spent. You and employers like you conduct over 55 million drug tests every year, and while the costs for individual tests vary, the drug testing in the U.S. is valued at over $2.2 billion per year.
With this kind of money on the line, however, you want to know your drug programs work. Certifications might be the answer. Certifications for key personnel in your drug testing program can help you ensure your drug testing programs are effective, lawful and enforceable.
Department of Transportation (DOT)
The Department of Transportation (DOT) does not offer certifications for drug testing but it does set minimum standards and requirements for those who provide drug testing services. Certifications are offered by the companies who provide testing services and often include training on administering their specific tests offered as well as vital information about DOT and other regulatory requirements.
Courses leading to certifications in hair specimen collection, saliva, and oral fluid drug testing are all available from drug test providers. (Learn more in Oral Fluid, Urine and Hair Testing: What's the Difference?) Certifications should match the types of tests you conduct. Consider both your collection method and your status as a DOT or non-DOT employer. For example, 90% of drug tests are urine tests and separate DOT and non-DOT urine specimen collection certifications are offered by several providers. While DOT does not require certification, DOT regulations do require collectors to be qualified. A curriculum is not provided nor dictated by DOT, but qualification training must include:
- Knowledge about Part 40 collection procedures
- All the steps necessary to conduct a proper collection
- How to properly fill out a federal collection form (Custody and Control Form, or CCF)
- How to handle problem collections (shy bladder, attempts to tamper with the test, etc.)
- Information about fatal and correctable flaws in collections and collection paperwork
- The collector’s responsibility for maintaining the integrity and credibility of the collection process, privacy, and specimen security
Non-DOT urine test certification should cover best practices and procedures as well as compliance with state or federal laws, such as the Americans with Disabilities Act (ADA), that could impact your testing. This certification will also likely cover both collections for laboratories and rapid-dip panels or instant tests for non-DOT covered employers.
Hair specimen collection is not regulated by DOT so certification in this method of collection will include the specific regulations and procedures used by the laboratory you have contracted to process your samples.
As with urine, saliva and oral fluid drug testing certifications will include both collections for laboratory testing and instant result style testing. This certification ensures testing reliability and admissibility and will also cover procedures for having non-negative tests reconfirmed by an independent lab as required by law. (Learn more in How to Avoid Adulteration in Employee Drug Testing).
Designated Employer Representative (DER)
If you are a DOT employer, you are required to designate someone to represent you as the main point of contact between the drug testing provider and your employees. DER responsibilities also include:
- Educating employees
- Conducting drug and alcohol testing
- Ensuring confidentiality
- Ensuring DOT compliance
- Documentation of testing and results
These responsibilities are dictated by DOT and while certification isn’t required, it is a simple way to ensure your DER understands both the responsibilities and the regulations that govern the position.
Breath Alcohol Technician (BAT)
Breath Alcohol Technician (BAT) Certification is required for anyone performing DOT breath alcohol tests but it’s a good idea for non-DOT employers to insist on this certification as well. Certification courses are based on a model DOT course and include the legal requirements of 49 CFR Part 40 as well as a live equipment proficiency demonstration, specific to the manufacturer and model purchased by the employer, that must be observed "live" by the BAT instructor either in person or via webcam.
Screening Test Technician (STT)
Screening Test Technicians (STTs) must be used to conduct DOT alcohol testing using DOT approved testing devices. BATs can serve as your STT but STTs must have additional training before they can serve as a BAT. DOT provides a model course for STT certification which is offered by a number of service providers. It’s important to note that certified STTs can conduct screening tests but may not conduct the confirmation tests required for positive tests. These must be conducted by a BAT.
Substance Abuse Professionals (SAP)
Substance Abuse Professionals (SAPs) are responsible for evaluating your employees after a positive drug test and will make recommendations regarding education, rehabilitation, follow-up testing, and aftercare. DOT maintains a list of professionals who may certify as SAPs and maintains strict guidelines regarding further training these professionals must take. At a minimum, qualified SAPs must be trained in:
- 49 CFR Part 40 and DOT agency drug and alcohol testing rules
- Key DOT drug testing requirements, including collections, laboratory testing, MRO review, and problems in drug testing
- Key DOT alcohol testing requirements, including the testing process, the role of BATs and STTs, and problems in alcohol tests
- SAP qualifications and prohibitions
- Role of the SAP in the return-to-duty process, including the initial employee evaluation, referrals for education and/or treatment, the follow-up evaluation, continuing treatment recommendations, and the follow-up testing plan
- SAP consultation and communication with employers, MROs, and treatment providers
- Reporting and record keeping requirements
- Issues that SAPs confront in carrying out their duties under the program
Further requirements include a final exam and re-certification every three years. While non-DOT employers are not required to meet these guidelines, from a compliance and legal standpoint it may make sense to insist that your non-DOT SAPs are also certified.
Why Certifications Matter
Despite the fact that certifications are not legally required, they can help you ensure your drug tests are administered safely and are in line with regulations. Since the reliability of a drug test depends as much on the administrator as it does on the test itself, these certifications can be crucial to ensuring the people you hire to conduct your drug testing do it right.