The READI Network Blog
How to Become an Oral Fluid Collector
This article will guide aspiring oral fluid collectors through the essential steps required to enter this field.
In an era where the demand for efficient and non-invasive drug testing methods is on the rise, the role of an oral fluid collector has become increasingly important. This specialized profession involves the collection of saliva samples for substance testing, offering a practical alternative to traditional urine and blood tests. Oral fluid collection not only ensures a more comfortable experience for donors but also provides immediate results that can enhance decision-making in various sectors, including law enforcement, workplace safety, and healthcare.
As the landscape of drug testing continues to evolve, becoming an oral fluid collector presents an opportunity for individuals interested in contributing to public health and safety.
This article will guide aspiring oral fluid collectors through the essential steps required to enter this field, from understanding the necessary training and certifications to mastering the techniques for effective sample collection. With insights into the regulatory framework and best practices, potential collectors will be equipped with the knowledge needed to excel in this vital role, promoting accuracy and reliability in the testing process.
Whether you're looking to advance your career in healthcare or seeking a new professional challenge, the path to becoming an oral fluid collector is both rewarding and impactful.
Overview
An oral fluid collector is a trained professional responsible for guiding and assisting employees during the specimen collection process at designated sites. This individual conducts initial inspections of the specimens provided, ensures proper handling, and completes the Federal Drug Testing Custody and Control Form (CCF).
The collector represents the sole point of direct, in-person interaction with the employee throughout the drug testing procedure. Their role is crucial; without the collector's oversight of the oral fluid specimen and the collection process, the validity of the test results may be compromised. The protocol for collecting oral fluid specimens, as detailed in 49 CFR Part 40, is stringent and must be adhered to whenever a Department of Transportation (DOT) mandated collection occurs. These guidelines, including the utilization of the CCF, are specifically applicable to testing required by DOT regulations.
Are there Any Requirements to Become an Oral Fluid Collector?
In order to be recognized as a qualified oral collector within the Department of Transportation (DOT) drug testing program, candidates must fulfill the following criteria:
1. General Information or Basic Information
2. Training for Qualification
3. Demonstration of Initial Proficiency
What constitutes the “basic information” requirement?
To fulfill this requirement, you must be well-versed in three key areas: 1) Part 40, 2) the latest DOT "Oral Fluid Specimen Collection Procedures Guidelines," and 3) the relevant DOT agency regulations that apply to the employers for whom you conduct collections. It is essential to stay updated on any modifications to these documents. Additionally, you are required to subscribe to the DOT’s Office of Drug & Alcohol Policy & Compliance (ODAPC) mailing list at https://www.transportation.gov/odapc/get-odapc-email-updates.
The DOT agency regulations, the "Oral Fluid Specimen Collection Procedures Guidelines," and other pertinent materials can be accessed through ODAPC at the following address: Department of Transportation, 1200 New Jersey Avenue, SE, Washington, DC, 20590, phone number 202–366–3784, or visit the ODAPC website at http://www.transportation.gov/odapc.
What should be included in the “qualification training” program, and who is authorized to conduct it?
Currently, the Department has not established a standardized curriculum for oral fluid collection training; however, the Department of Transportation (DOT) anticipates that trainers will develop their programs in accordance with DOT regulations and the most recent edition of the “Oral Fluid Specimen Collection Procedures Guidelines.” (Details on how to access the latest DOT regulations and collection guidelines are provided in the final section of this document.) The qualification training, as outlined in § 40.35(b), must encompass the following components:
Qualification Training Components:
1. Comprehensive understanding of the collection procedures as specified in 49 CFR Part 40,
2. Proficiency training in the operation of the specific oral fluid collection device utilized,
3. Instruction on the correct completion and transmission of the Federal Drug Testing Custody and Control Form (CCF),
4. Strategies for addressing collection challenges (e.g., dry mouth, tampering attempts, etc.),
5. Insights into critical and rectifiable errors related to collections and associated documentation,
6. An emphasis on the collector’s duty to uphold the integrity and credibility of the collection process, ensuring privacy and specimen security, while avoiding any actions or remarks that could be deemed inappropriate or offensive.
Instructors for this qualification training program can be anyone; there is no requirement for the trainer to possess extensive experience as a collector, nor do they need to be the same individual overseeing the proficiency assessment. Training can be delivered through various formats, including in-person sessions, video presentations, online courses, or virtual conferences, among other acceptable methods. Additionally, there are no specified duration requirements for this segment of the training. While an examination is not mandated, it is advisable for the training program to incorporate mechanisms that confirm the successful acquisition of knowledge by participants.
What should be included in the oral fluid collector "proficiency demonstration," and who is authorized to administer it?
Upon completion of the qualification training program, the aspiring collector is required to perform five consecutive error-free mock oral fluid collections for each device to be utilized. These demonstrations must occur under the direct supervision of a qualified monitor, as outlined in § 40.35(c).The five mock oral fluid collections should encompass the following scenarios, which can be presented in any sequence:
1. A standard, uneventful collection,
2. A collection that yields an insufficient quantity of oral fluid,
3. A situation where the individual has an object in their mouth that could potentially compromise the collection,
4. A scenario in which the individual attempts to tamper with the specimen, and
5. An instance of refusal to complete the Chain of Custody Form (CCF).
The proficiency monitor or evaluator must fulfill two essential criteria:1) They must be a certified oral fluid collector*, and
2) They must possess the requisite knowledge, skills, and abilities as demonstrated by one of the following:
a. Having conducted DOT oral fluid collections for a minimum of one year,
b. Having provided training for Part 40 oral fluid collectors for at least one year, or
c. Successfully completing a train-the-trainer course specifically focused on oral fluid collection practices.
Important Update:
Due to the lack of certification for an oral fluid laboratory by HHS, we have revised the criteria for individuals authorized to oversee mock oral fluid collections. This is outlined in further detail below.
On November 5, 2024, the Department of Transportation (DOT) issued a final rule that introduces temporary regulatory adjustments regarding the qualifications for monitoring mock oral fluid collections (89 FR 87798). Under this new guidance, individuals designated as monitors for these collections are not required to be certified oral fluid collectors. Instead, they must either: 1) undergo oral fluid collector training (with the one-year qualification requirement waived), or 2) successfully complete a 'train the trainer' course focused on oral fluid collection.
This regulatory flexibility will take effect on December 5, 2024, coinciding with the implementation date of the final rule, and will remain in place for one year following the publication of a Federal Register notice by HHS regarding the first certified oral fluid drug testing laboratory. The DOT will communicate the expiration date of this provision through the Federal Register.
The Purpose of Oral Fluid Collection Sessions
The purpose of these simulated oral fluid collection sessions is to replicate an authentic scenario involving a participant, who may be the instructor, acting as the donor. It is essential that these collections are overseen by the instructor in real-time, either through direct observation or via a live video feed that facilitates meaningful interaction between the instructor and the trainee, in accordance with § 40.35(c)(2)
Utilizing a checklist during these mock sessions is permissible, provided that the checklist was incorporated into the training received by the collector and is intended for use in actual oral fluid collections.
Regardless of whether the sessions are conducted in person or online, it is necessary to have at least two participants engaged in the mock collections. It is advisable to involve a third individual to assume the role of the donor, allowing the trainee to gain experience in "collecting from an employee" without the actual collection of a specimen during the training process. This aspect is crucial, as collectors must be adept at handling real individuals and conducting genuine specimen collections. If the only participants in the mock proficiency sessions are the monitor and the trainee, the monitor must also take on the role of the donor, actively engaging with the trainee to ensure they are exposed to a variety of scenarios, including both routine and challenging collections.
Important Notice:
It is advisable for participants to schedule both qualification training and initial proficiency demonstration training concurrently. The comprehensive training program should be finalized within 30 days from the commencement date. Should the participant fail to complete the device proficiency training within this specified period, it is recommended that they re-enroll in the qualification training segment of the program.
What documentation is necessary to demonstrate my qualifications?
Upon successful completion of the entire training course, most organizations or trainers will issue a certificate. Nonetheless, collectors are required to furnish documentation, when requested, to inspectors from the DOT Agency, employers, and designated service agents (such as C/TPAs) that verifies their current eligibility to collect DOT specimens, as outlined in § 40.35(g).
When asked, you must provide comprehensive details regarding the training content and proficiency evaluations to assure the Federal Inspector that you have adequately fulfilled the regulatory requirements. Acceptable forms of documentation may include training completion certificates or letters from qualified trainers or observers attesting to your attendance and successful completion of the course.
It is important to note that the qualifications of an oral fluid collector are not tied to a specific location or collection site; their eligibility is valid wherever DOT Agency-regulated oral fluid specimens are collected.
Additional Resources from Transportation.gov
Applicable Regulations
With the above in mind, it is important oral fluid collectors fully understand the regulations and follow the established collection procedures. Therefore, collectors should familiarize themselves with 49 CFR Part 40, while paying particular attention to the following Subparts:
Subpart C - Specimen Collection Personnel
Subpart E - Specimen Collections
Subpart I - Problems in Drug Tests
Subpart Q - Roles and Responsibilities of Service Agents
Documents/Publications
How Can I Become an Oral Fluid Collector For DOT Drug Testing?
DOT’s Steps to Oral Fluid Collection Site Security and Integrity (coming soon)
Revised Federal Drug Testing Custody and Control Form (CCF)
Association/Industry Links
Frequently Asked Questions About Becoming an Oral Fluid Collector
Is refresher training a requirement?
Absolutely. It is mandatory for each certified oral fluid collector to complete refresher training every five (5) years to maintain their eligibility for collecting DOT specimens, as outlined in § 40.35(e). The refresher training must cover content that is either identical to or comparable with the initial training and proficiency assessment. Additionally, it is advisable to stay informed about any updates to DOT regulations independently, rather than relying solely on the refresher training for this knowledge.
Does the DOT provide training for oral fluid collectors?
No, the DOT does not provide training for oral fluid collectors, nor does it maintain a directory of training programs or qualified trainers. Furthermore, the DOT does not endorse, certify, or recommend the training programs offered by any organization or entity.
Collection sites have the option to conduct their own training or engage an external organization or professional training service to facilitate this training. To locate such training services, consider searching online or reaching out to relevant industry associations or organizations.
Is Certification Required for Conducting DOT Oral Fluid Collections or Operating a Collection Site for DOT Drug Testing?No, the Department of Transportation (DOT) does not mandate certification for individuals collecting oral fluid samples or for collection sites engaged in DOT drug testing. It is important to note that only individual collectors can achieve qualification to collect DOT oral fluid specimens, not the collection sites themselves.
Does the DOT Provide a List of Qualified Oral Fluid Collectors or Collection Sites?
No, the DOT does not maintain a list of qualified oral fluid collectors or collection sites.
How Can I Establish a Business Once Qualified?
Entering the field as an oral fluid collector is a strategic business venture. Therefore, you will need to develop your business in line with your specific business model and strategy.
Attending transportation trade shows and utilizing online platforms can be effective ways to connect with potential clients subject to DOT regulations.Where Can I Find More Information on Collection Regulations and Guidelines for Collectors?
For comprehensive information regarding collection regulations, guidelines for collectors, and other pertinent DOT regulations, please visit the Office of Drug and Alcohol Policy and Compliance (ODAPC) website at www.transportation.gov/odapc. On the homepage, you will find links to the ‘Oral Fluid Collectors’ section, providing direct access to relevant portions of Part 40 that pertain to oral fluid collectors and collection procedures. You can also download the most recent version of Part 40 and the collection guidelines.
Additionally, the homepage features various links to information and documents covering all aspects of Part 40 as well as DOT Agency regulations.
If you do not have internet access, please contact 202-366-3784 to request a printed copy of Part 40 and/or the ‘Oral Fluid Collection Procedures Guidelines’ to be sent to you.
READI COLLECT: Your Partner as an Oral Fluid Collector
We have an ongoing opportunity for you as an Oral fluid Collector. Whether you are an agency representative running drug test collections or a full pledged qualified collector, we want to partner with you.
Readi Collect App, is the Fastest and Most Reliable Onsite Drug and Alcohol Test Collections. We use a patented technology to connect employees to a nationwide network of professional collectors like you with our mobile app.
Making this the best way to meet impossible deadlines for critical testing like DOT post-accident. If you are required are interested, you may sign up here.