Observed and Monitored Urine Specimen Collections

Within the drug testing regulations, the Department of Transportation provides rules regarding when a urine collection must be performed using a "directly observed collection." A directly observed collection is one in which the collector actually watches the donor urinate into the collection cup.

If the donor provides a specimen that is out of the normal temperature range, or if the specimen is obviously tampered with (blue in color, for example), the collector is required to immediately begin the process of collecting a new specimen under direct observation. Beginning in November 2008, observed collections will also be routinely required for all Return-to-Duty and Follow-up testing.

To protect the privacy and modesty of the donor during a directly observed collection, the D.O.T. requires that the collector be of the same gender as the donor. If the collector and the donor are not the same gender, another person who is the same gender as the donor (usually a supervisor), must observe the collection. The collector instructs the third party as to their role in the collection process including checking the employee for prosthetic or other devices designed to carry clean urine or urine substitutes and to watch the employee urinate into the collection cup. Recently, the Department of Transportation revisd the observed collection process which now provides much less privacy to the donor.

The new regulations require the following procedures:

• The observer requests the employee to raise his or her shirt, blouse or dress / skirt, as appropriate, above the waist, just above the navel; and lower clothing and underpants to mid-thigh and show the observer, by turning around, that the employee does not have such a device.

• If The Employee Has A Device: The observer immediately notifies the collector; the collector stops the collection; and the collector thoroughly documents the circumstances surrounding the event in the remarks section of CCF. The collector notifies the DER. This is a refusal to test.
  
  
• If The Employee Does Not Have A Device: The employee is permitted to return clothing to its proper position for the observed collection. The observer must watch the urine go from the employee’s body into the collection container. The observer must watch as the employee takes the specimen to the collector. The collector then completes the collection process.
  
  
• Failure of the employee to permit any part of the direct observation procedure is a refusal to test.

Unlike an observed collection, in a monitored collection, the collector does not actually watch the donor. The collector goes into the bathroom with the donor, but does not go into the stall. As long as the collector is a medical professional, he or she does not have to be of the same gender as the donor. A monitored collection can be used for any preemployment, random, reasonable suspicion or post-accident collection.

Most collections are not monitored or observed. Instead, the collector secures the collection site using tape and blue dye to prevent tampering with the specimen by adding water. If the collection site is a large bathroom with multiple sinks and stalls, it can sometimes be difficult to properly secure it. The collector can choose to do a monitored collection under those circumstances.