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Drug Testing – Specimen Collection

This article describes what you need to know when it comes to the DOT/FAA drug testing, more specifically on the urine specimen collection process.

A vast majority of employees represented by NATCA are subject to random, post-accident, reasonable suspicion, and follow-up drug and alcohol testing because they occupy what the Department of Transportation has described as Testing Designated Positions (TDP). All NATCA bargaining units’ CBAs contain provisions concerning substance testing. For air traffic controllers, it can be found in Article 73 of the 2009 CBA.

What is a Testing Designated Position (TDP) and who holds it?

All FAA employees who hold a safety or security-sensitive position are classified as a TDP. These positions have been identified by the DOT/FAA as requiring safety-sensitive responsibilities related to the mission of the Department; or positions occupied by individuals requiring possession of a security clearance of confidential or higher. Employees occupying a TDP are subject to random, reasonable suspicion, post-accident, return to duty, and follow-up testing.

Some NATCA BUEs hold Non-Testing Designated Positions (Non-TDPs) – positions that are categorized as non-safety or security sensitive. Although Non-TDPs are not subject to random testing, they may still be required to undergo reasonable suspicion, post-accident, and follow-up drug testing where applicable.

What do I need to know about the urine collection process for drug testing?

The following describes the steps the collector must follow for the urine sample collection. These steps are applicable to all the different types of drug testing mentioned above. You are afforded to have a union representative present during the collection process if you elect for one pursuant to the substance testing article found in your CBA.

  • The collector must secure a collection site by restricting access to the collection site to only authorized personnel; securing all water sources and placing blue dye in any standing water; and removing or securing all cleaning products/fluids at the collection site.
  • Your identity will be verified using a current valid photo ID, or if a photo ID not available, then your supervisor will be contacted to confirm your identity.
  • The collector will complete the pre-test information on the Federal Drug Testing Custody and Control Form (CCF) that serves as the chain of custody of your specimen.
  • You will be asked to remove any unnecessary outer garments, empty your pockets and display the items to ensure that no items are present that could be used to adulterate or substitute the specimen. Any items in your pockets that may be used to substitute or adulterate your specimen will be held outside the collection area with your outer garments. You may retain your wallet.
  • You will be instructed to wash and dry your hands.
  • A collection kit will be selected by the collector (or you may be asked to select the kit). The collector will open the kit in your presence.
  • You will be afforded privacy to provide a urine specimen. Exception to the rule occurs if the collector suspects attempted adulteration or substitution of a specimen or any situation where general questions of validity arise, such as an unusual temperature. Also, if the collection is for a follow-up test, it will be performed using direct observation collection procedures. Note: If the collection is under a direct observation, it must always be performed by a same gender collector as you.
  • You will be asked to provide at least 45 ml of your urine into a collection container.
  • The collector will check to ensure the specimen is at least 45 ml, check the temperature, and conduct an inspection to determine color and any signs of contaminants.
  • In your presence, the collector will pour the urine specimen into two separate bottles (A and B), seal them, date each label, and ask you to initial each label.
  • The collector will complete steps 1 through 4 of the CCF.
  • You will be asked to complete step 5 of the CCF (i.e., print and sign your name, date of birth, daytime and evening phone numbers).
  • You will be given the employee copy (copy #5) of the CCF.
  • The collector will place both sealed specimen bottles along with the laboratory copy (copy #1) in a single shipping box/bag, package it into a larger box, and ship to the laboratory.

Remember: neither you nor the collector should let the specimen out of your sight until it has been poured into two separate bottles and sealed.

If the collector fails to follow any of these steps, or if you have any concerns during the collection process, alert your union representative or contact the site coordinator who is responsible to be on site during the collection to ensure the testing process is strictly adhered to by the collector.