The Collector
A collector is a trained person who instructs and assists employees at a collection site, receives and inspects the urine specimen, and initiates and completes the Federal Drug Testing Custody and Control Form (CCF).
📌 DOT Definition
Part 40 defines a collector as someone who:
- ✓ Instructs and assists employees at the collection site
- ✓ Receives and makes an initial inspection of the urine specimen
- ✓ Initiates and completes the Federal Drug Testing CCF
🚫 Who CANNOT Be a Collector
Any trained individual may serve as a collector — with these four exceptions:
- 1The employee's immediate supervisor may NOT act as collector for that employee — unless no other collector is available AND the supervisor is permitted to do so under applicable DOT regulations. (The supervisor may act as a monitor or observer of the same gender if no one else is available.)
- 2A safety-sensitive employee subject to DOT drug testing should not be a collector, observer, or monitor for co-workers in the same testing pool or who work together daily — to prevent any appearance of collusion.
- 3An individual working for an HHS-certified drug testing laboratory (e.g., technician, accessioner) may not act as collector if they can link the employee with the specimen result or lab report.
- 4The employee may not collect his or her own specimen.
🪪 Collector Identification
A collector must have appropriate identification that includes:
- ✓ The collector's name
- ✓ The name of the Collection Company or clinic
The collector must provide identification if requested by the employee.
- ✗ No requirement for a photo ID
- ✗ No requirement to provide driver's license with address or phone number
- ✗ No requirement to show certification to the employee
📞 DER Contact Information
The employer must provide the collector with the name and telephone number of the DER (Designated Employee Representative) and C/TPA (where applicable) to contact about any problems during the collection process.
The Collection Site
A collection site is a place — permanent or temporary — selected by the employer where employees present themselves to provide a urine specimen for a DOT-required drug test.
🚽 Types of Collection Facilities
- ✓ Single-toilet restroom with a full-length privacy door (preferred)
- ✓ Multi-stall restroom with partial-length doors
✅ Required Site Elements
- 1A private restroom or stall with a toilet. Single-toilet restrooms with full-length doors are preferred. Mobile facilities (e.g., vehicle with enclosed toilet) are acceptable.
- 2A water source for handwashing — ideally external to the restroom. If the only water source is inside, the employee may wash their hands, then the collector must secure the water source before collection begins. If no water is available, moist towelettes may be used.
- 3A clean work surface for the collector to complete required paperwork.
🚻 Multi-Stall Restroom Requirements
If a multi-stall restroom is used, the collector must either:
- 1 Secure all water sources, soap dispensers, and other substances and place bluing agent in all toilets — OR
- 2 Conduct all collections as monitored collections
🔒 Security Requirements (§40.43)
- 1Procedures to prevent unauthorized access to the site during collection
- 2Procedures to prevent access to adulterants or diluents (soap, disinfectants, cleaning agents, water)
- 3All authorized persons must be under collector supervision at all times when permitted into the site
- 4Procedures for secure handling and storage of specimens
Collection Supplies
The following items must be available at every collection site to conduct a proper DOT urine collection.
📦 Required Supplies
- Collection kit meeting DOT standards for urine collection kits — one kit per DOT drug test
- Federal Drug Testing Custody and Control Forms (CCF) — a five-part carbonless manifold form
- Bluing (coloring) agent to add to the toilet bowl and water tank — prevents the employee from diluting the specimen with toilet water
- Tamper-evident tape for securing faucets, toilet tank tops, and other areas when necessary
- Signs that can be posted to prevent entry into collection areas when needed
The Federal CCF Form
The CCF (Custody and Control Form) must be used to document every DOT urine collection. It is a five-part carbonless manifold form.
📑 The 5 Copies Explained
| Copy | Name | Goes To |
|---|---|---|
| Copy 1 | Test Facility Copy | Accompanies the specimen to the laboratory |
| Copy 2 | MRO Copy | Sent to the Medical Review Officer |
| Copy 3 | Collector Copy | Retained by the collector (minimum 30 days) |
| Copy 4 | Employer Copy | Sent to the employer or authorized service agent |
| Copy 5 | Employee Copy | Given directly to the employee |
✍️ How the CCF is Completed — Step by Step
Step 1 — Copy 1 (Collector/Employer completes before specimen is provided)
Enter employer name, address, phone, fax. Enter MRO name, address, phone, fax. Enter employee SSN or ID number after verifying identity. Check the reason for test and type of drug test. Check the DOT agency (e.g., FMCSA, FAA). Enter collection site information.
Step 2 — Copy 1 (Collector completes after receiving specimen)
Mark whether specimen temperature is within range (32°–38°C / 90°–100°F). Indicate split or single specimen. Indicate if no specimen was collected and why. Indicate if it was an observed collection and why.
Step 3 — Copy 1 (Collector seals and dates bottles)
Seal and date the specimen bottles. Apply seals to the bottles and have the employee initial them. Then instruct the employee to complete Step 5 on Copy 2 (MRO copy).
Step 5 — Copy 2 (Employee completes — listed as "donor")
Employee reads certification statement, prints name, provides date of birth, daytime and evening phone numbers, date of collection, and signs the form. Collector reviews to confirm all required information is present.
Step 4 — Copy 1 (Collector signs and certifies)
Collector signs to certify the specimen was collected, labeled, sealed, and released in accordance with federal requirements. Record the time and date of collection and the specific name of the delivery service used to ship to the laboratory.
🏷️ Specimen Bottle Seals
The bottom area of Copy 1 holds the tamper-evident specimen bottle seals/labels. There must be two seals:
- A Primary specimen seal — labeled "A" (minimum 30 mL)
- B Split specimen seal — labeled "B" (minimum 15 mL)
Information Employers Provide to Collectors
Before conducting a collection, the employer or C/TPA must ensure the collector has the following information. Make sure all of this is present before starting.
📋 Required Information Checklist
- Full name of the employee being tested
- Employee SSN or ID number
- Laboratory name and address (can be pre-printed on CCF)
- Employer name, address, phone, and fax number (can be pre-printed on CCF Step 1-A)
- DER name and telephone number (and C/TPA name where applicable)
- MRO name, address, phone, and fax number (can be pre-printed on CCF Step 1-B)
- DOT Agency that regulates the employee's safety-sensitive duties (e.g., FMCSA, FAA, FRA)
- Reason for test: Pre-employment · Random · Reasonable Suspicion · Post-Accident · Return-to-Duty · Follow-up
- Whether the test is to be observed (per §40.67(a) & (b))
- (Optional) C/TPA name, address, phone, and fax number
Employee Identification
The employee must provide acceptable identification to the collector at the start of the collection process. Know what's acceptable — and what is not.
✅ Acceptable Forms of ID
- ✓ Photo ID — driver's license, employer-issued badge, or any government-issued photo ID
- ✓ Identification by the employer or employer representative
- ✓ Any other ID allowed under a specific DOT operating administration's rules
🚫 Unacceptable Forms of ID
- ✗ Identification by a co-worker
- ✗ Identification by another safety-sensitive employee
- ✗ A single non-photo ID card (social security card, credit card, union card, pay voucher, voter registration)
- ✗ Faxed or photocopied identification documents
❓ What If the Employee Cannot Produce ID?
Contact the DER
The collector must contact the DER to verify the employee's identity. Do NOT proceed until positive identification is obtained.
Owner/Operator or Self-Employed Exception
If an owner/operator has no proper ID, note this in the remarks section. Ask them to provide two items with their signature. Proceed with the collection. When the donor signs the CCF, compare signatures. If they match — continue. If they don't match — note "signature identification is unconfirmed" in remarks.
Collection Procedures
The following 23 steps describe a complete DOT urine collection from site preparation through final shipment. Follow these steps in order, every time.
🔒 Before Every Collection — Site Preparation
- 1Secure all water sources (turn off water, tape faucet handles)
- 2Add bluing agent to the toilet and tank. Tape or secure the toilet tank lid.
- 3Remove all soap, disinfectants, cleaning agents, and potential adulterants
- 4Inspect the site — no foreign or unauthorized substances present
- 5Ensure no undetected access is possible (doors, windows not in view)
- 6Secure areas suitable for concealing contaminants (ledges, trash receptacles, dropped ceilings)
- 7Recheck all of the above after each collection
📋 The 23-Step Collection Process
Prepare the Collection Site
Ensure all supplies are available, the area is secured, water sources are secured, and bluing agent is in all toilets.
Begin Collection Without Delay
Start as soon as the employee arrives. Do not wait because the employee says they cannot urinate — most can and will provide a sufficient specimen.
Verify Employee Identity
Request acceptable photo ID. If no ID, contact the DER. The collector must also show ID if the employee asks — it must include the collector's name and employer's name (not a home address or photo required).
Explain the Procedure
Explain the basic collection procedures to the employee and show them the instructions on the back of the CCF.
Complete Step 1 of the CCF
Enter all required information: employer info, MRO info, employee SSN/ID, reason for test, type of drug test, DOT agency, and collection site information. If the employee refuses to provide SSN — that is NOT a refusal to test, but note it in remarks.
Secure Employee's Outer Clothing and Belongings
Direct the employee to remove outer clothing (coat, jacket, hat) and leave briefcases, purses, and belongings with the collector. The employee may keep their wallet. Provide a receipt for belongings if requested.
Empty Pockets
Direct the employee to empty pockets and display all items. If nothing can adulterate the specimen, they replace items and continue. If the employee refuses — this is a refusal to test.
Employee Washes Hands
Instruct the employee to wash and dry their hands under your observation. Inform them not to wash hands again until after handing over the specimen. If the employee refuses to wash — this is a refusal to test.
Provide Collection Container
Give the employee (or allow them to select) the collection kit or container from available supply. Either the collector or employee — with both present — unwraps or breaks the seal. The employee takes only the collection container into the restroom. Sealed specimen bottles remain with the collector.
Direct Employee to Provide Specimen
Instruct the employee to go to the restroom, provide at least 45 mL of urine, not flush the toilet, and return with the specimen as soon as possible.
Check Temperature, Volume, and Appearance
Temperature: Check immediately upon receiving specimen — no later than 4 minutes. Acceptable range: 32°–38°C / 90°–100°F. Mark "Yes" in Step 2 of CCF if in range. If out of range, mark "No" and initiate an observed collection.
Volume: Must be a minimum of 45 mL. If sufficient, check the split specimen box on CCF Step 2.
Appearance: Inspect for unusual color, foreign objects, or signs of tampering. If apparent adulteration (e.g., blue color, excessive foam, bleach smell), immediately begin a second collection under direct observation.
Open Specimen Bottles
The collector (recommended) opens the specimen bottles. Both the collector and employee maintain visual contact with the specimen until labels/seals are placed on the bottle caps.
Pour Specimen into Bottles
The collector — not the employee — pours the specimen.
- 🅐 Primary (A) Bottle: At least 30 mL
- 🅑 Split (B) Bottle: At least 15 mL
Apply Tamper-Evident Seals
The collector — not the employee — applies the seals. Place the "A" seal on the 30 mL bottle and the "B" seal on the 15 mL bottle. Center the seal over the cap and down the sides so the cap cannot be removed without destroying it. The collector writes the date on the seals. The employee then initials each seal.
Employee Completes Step 5 of Copy 2
Direct the employee to read, sign, and date the certification statement on Copy 2 (MRO copy). Provide printed name, date of birth, and day/evening phone numbers. If the employee refuses to sign or provide info — note it in Remarks and complete the collection. This is NOT a refusal to test.
Collector Completes Step 4 of Copy 1
Print or confirm your name (may be pre-printed). Record the date and time of collection. Sign where indicated. Enter the specific name of the delivery or courier service transferring specimens to the laboratory.
Check CCF for Completeness — Give Copy 5 to Employee
Ensure all copies are legible and complete. Remove Copy 5 from the CCF and give it to the employee. You may suggest the employee note any prescription or over-the-counter medications on their Copy 5 — not on any other copy.
Package and Seal the Specimens
Place specimen bottles and Copy 1 of the CCF into the appropriate pouches of the leak-resistant plastic bag. Seal both pouches. The employee may now wash their hands if they haven't yet. Inform the employee they may leave the collection site.
Discard Remaining Urine
Discard any leftover urine from the collection container after both bottles are filled and sealed. Excess urine may only be used for clinical tests (e.g., protein, glucose) if the collection was conducted alongside a DOT-authorized physical examination. No additional testing (DNA, extra drugs, adulteration) is allowed on excess urine.
Place in Shipping Container
Place the sealed plastic bag in an appropriate shipping container (box, express courier mailer) designed to minimize damage during shipment. Multiple sealed bags can go in one container. Seal the shipping container.
Distribute CCF Copies
Send Copy 2 to the MRO and Copy 4 to the DER (or authorized service agent). This must be done within 24 hours or the next business day. Keep Copy 3 for a minimum of 30 days.
Ship Specimen to Laboratory
Ship the specimen as quickly as possible — but no later than within 24 hours or the next business day.
Secure Any Specimens Awaiting Shipment
If the specimen won't be shipped immediately, keep it in a secure location with restricted access until it is picked up or shipped.
Shy Bladder Procedures
"Shy bladder" occurs when an employee cannot provide a sufficient urine specimen (45 mL) for a DOT drug test. Even if the employee says they cannot urinate, begin the collection procedure regardless.
📋 Shy Bladder Step-by-Step
Direct the Employee to Attempt the Void
Tell the employee that most individuals can provide 45 mL even when they think they cannot. Direct them to make the attempt. Send them in with the collection container.
Discard Insufficient Specimen
If the employee returns with an insufficient quantity, discard it. Note the time in the Remarks line — this is when the shy bladder process officially starts. Use the same CCF and collection container for subsequent attempts.
Fluid Consumption Period
Explain the process to the employee. Urge them to drink up to 40 ounces of fluid, distributed reasonably over up to 3 hours — or until they provide a sufficient specimen, whichever comes first.
If Employee Refuses or Leaves
If the employee refuses to make another attempt or leaves the collection site before the process is complete — discontinue the collection. Note the fact in the Remarks line on CCF Step 2 and immediately notify the DER. This is a refusal to test.
If Still Unable After 3 Hours
If the employee still cannot provide a sufficient specimen after the 3-hour window, stop the collection. Note the time the employee was given to provide the specimen and the time the collection was stopped. Notify the DER. Document the insufficient specimen attempts on the CCF.
⚠️ Important Reminders
- ✓ During the 3-hour waiting period, the collector MAY conduct a collection for another employee — but the shy bladder employee must be monitored for continued integrity
- ✓ The employee may retain possession of the empty collection container during the waiting period
- ✗ NEVER combine urine from multiple voids into one specimen
- ✗ There is no requirement to inform the employee that leaving constitutes a refusal — but it is best practice to do so
Continue through the final four sections covering training requirements, site security, collection kit standards, and direct observation procedures.
Collector Training Requirements
To be permitted to act as a collector in the DOT drug testing program, you must meet all of the following requirements under 49 CFR Part 40. This section walks you through exactly what is required — and how TestRight Academy fulfills each one.
📖 (a) Basic Information
You must be knowledgeable about 49 CFR Part 40, the current "DOT Urine Specimen Collection Procedures Guidelines," and DOT agency regulations applicable to the employers for whom you perform collections, and you must keep current on any changes to these materials.
You must subscribe to the ODAPC list-serve: https://www.transportation.gov/odapc/get-odapc-email-updates
🎓 (b) Qualification Training
You must receive qualification training that provides instruction on the following subjects:
- 1All steps necessary to complete a collection correctly and the proper completion and transmission of the CCF
- 2"Problem" collections (e.g., situations like "shy bladder" and attempts to tamper with a specimen)
- 3Fatal flaws, correctable flaws, and how to correct problems in collections
- 4The collector's responsibility for maintaining the integrity of the collection process, ensuring the privacy of employees being tested, ensuring the security of the specimen, and avoiding conduct or statements that could be viewed as offensive or inappropriate
✅ (c) Initial Proficiency Demonstration
Following completion of qualification training under paragraph (b), you must demonstrate proficiency in collections by completing five consecutive error-free mock collections.
Required Mock Collection Scenarios
The five mock collections must include:
- ✓ Two uneventful collection scenarios
- ✓ One insufficient quantity of urine scenario
- ✓ One temperature out of range scenario
- ✓ One scenario in which the employee refuses to sign the CCF and initial the specimen bottle tamper-evident seal
Qualified Evaluator Requirement
Another person must monitor and evaluate your performance — in person or by a means that provides real-time observation and interaction between the instructor and trainee — and attest in writing that the mock collections are "error-free." This person must be a qualified collector who has demonstrated necessary knowledge, skills, and abilities by:
- i Regularly conducting DOT drug test collections for a period of at least a year
- ii Conducting collector training under this part for a year
- iii Successfully completing a "train the trainer" course
⏱️ (d) Sequence Requirement
🔄 (e) Refresher Training
No less frequently than every five years from the date on which you satisfactorily complete the requirements of paragraphs (b) and (c), you must complete refresher training that meets all the requirements of paragraphs (b) and (c).
⚠️ (f) Error Correction Training
If you make a mistake in the collection process that causes a test to be cancelled (i.e., a fatal or uncorrected flaw), you must undergo error correction training. This training must occur within 30 days of the date you are notified of the error.
- iError correction training must be provided and your proficiency documented in writing by a person who meets the requirements of paragraph (c)(2).
- iiError correction training is required to cover only the subject matter area(s) in which the error that caused the test to be cancelled occurred.
- iiiAs part of the error correction training, you must demonstrate proficiency by completing three consecutive error-free mock collections. The mock collections must include one uneventful scenario and two scenarios related to the area(s) in which your error(s) occurred. The person providing the training must monitor, evaluate, and attest in writing that the mock collections were "error-free."
📁 (g) Documentation
You must maintain documentation showing that you currently meet all requirements of this section. You must provide this documentation on request to:
- ✓ DOT agency representatives
- ✓ Employers using or negotiating to use your services
- ✓ C/TPAs using or negotiating to use your services
Collection Site Security & Integrity
These 10 security steps are required practice for every DOT urine collection. As a collector, you are personally responsible for maintaining a secure, tamper-resistant environment from the moment the employee arrives until the specimen is sealed and documented.
✅ DOT's 10 Security Steps
Monitor the Employee Throughout
Pay careful attention to employees throughout the entire collection process.
Secure All Access Points
Ensure that there is no unauthorized access into the collection areas and that undetected access (e.g., through a door not in view) is not possible.
Verify Photo ID
Make sure that employees show proper picture ID before the collection begins.
Empty Pockets and Remove Outer Garments
Make sure employees empty pockets; remove outer garments (e.g., coveralls, jacket, coat, hat); leave briefcases, purses, and bags behind; and wash their hands.
Maintain Control of Specimen and CCF
Maintain personal control of the specimen and CCF at all times during the collection.
Secure All Water Sources
Secure any water sources or otherwise make them unavailable to employees (e.g., turn off water inlet, tape handles to prevent opening faucets, secure tank lids).
Add Bluing Agent
Ensure that the water in the toilet and tank (if applicable) has bluing (coloring) agent in it. Tape or otherwise secure shut any movable toilet tank top, or put bluing in the tank.
Remove Potential Adulterants
Ensure that no soap, disinfectants, cleaning agents, or other possible adulterants are present in the collection area.
Inspect for Unauthorized Substances
Inspect the site to ensure that no foreign or unauthorized substances are present.
Secure Concealment Areas
Secure areas and items (e.g., ledges, trash receptacles, paper towel holders, under-sink areas, ceiling tiles) that appear suitable for concealing contaminants.
Urine Collection Kit Standards
Every component of your DOT urine collection kit must meet specific standards. Using non-compliant equipment can invalidate a test and create compliance exposure for you and the employer. Know these requirements before you collect.
🧪 1. Collection Container
- aSingle-use container, made of plastic, large enough to easily catch and hold at least 55 mL of urine voided from the body.
- bMust have graduated volume markings clearly noting levels of 45 mL and above.
- cMust have a temperature strip providing graduated temperature readings 32–38°C / 90–100°F, affixed at a proper level on the outside of the container. Other methodologies (e.g., temperature device built into the wall of the container) are acceptable provided measurement is accurate and there is no potential for contamination.
- dMust be individually wrapped in a sealed plastic bag or shrink wrapping; or must have a peelable, sealed lid or other easily visible tamper-evident system.
- eMay be made available separately at collection sites to address shy bladder situations when several voids may be required to complete the testing process.
🍶 2. Plastic Specimen Bottles
- aEach bottle must be large enough to hold at least 35 mL; or alternatively, two distinct sizes may be used — primary specimen bottle holds at least 35 mL and split specimen bottle holds at least 20 mL.
- bMust have screw-on or snap-on caps that prevent seepage of urine from the bottles during shipment.
- cMust have markings clearly indicating the appropriate levels — 30 mL for the primary specimen and 15 mL for the split.
- dMust be designed so that the required tamper-evident bottle seals from the CCF fit with no damage to the seal when the employee initials it and do not conceal printed information.
- eMust be wrapped (with caps) together in a sealed plastic bag or shrink wrapping separate from the collection container; or individually wrapped; or must have peelable, sealed lids or other tamper-evident system.
- fPlastic material must be leach resistant.
🛍️ 3. Leak-Resistant Plastic Bag
- aMust have two sealable compartments or pouches which are leak-resistant — one large enough to hold two specimen bottles and the other large enough to hold the CCF paperwork.
- bThe sealing methodology must be such that once the compartments are sealed, any tampering or attempts to open either compartment will be evident.
🧽 4. Absorbent Material
Each kit must contain enough absorbent material to absorb the entire contents of both specimen bottles. Absorbent material must be designed to fit inside the leak-resistant plastic bag pouch into which the specimen bottles are placed.
📦 5. Shipping Container
- aMust be designed to adequately protect the specimen bottles from shipment damage in the transport of specimens from the collection site to the laboratory (e.g., standard courier box, small cardboard box, plastic container).
- bMay be made available separately at collection sites rather than being part of an actual kit sent to collection sites.
- cA shipping container is not necessary if a laboratory courier hand-delivers the specimen bottles in the plastic leak-proof bags from the collection site to the laboratory.
Direct Observation Procedures
Direct observation is one of the most sensitive procedures in DOT urine collection. It is only authorized and required under specific circumstances — and when it applies, the steps must be followed exactly. This section covers when it is required and how to execute it correctly.
📋 1. When Direct Observation Is Required
DOT's 49 CFR Part 40 directly observed collections are authorized and required only when:
The employee attempts to tamper with his or her specimen at the collection site:
- ! The specimen temperature is outside the acceptable range
- ! The specimen shows signs of tampering — unusual color, odor, or characteristic
- ! The collector finds an item in the employee's pockets or wallet which appears to be brought into the site to contaminate a specimen
- ! The collector notes conduct suggesting tampering
The Medical Review Officer (MRO) orders direct observation because:
- ! The employee has no legitimate medical reason for certain atypical laboratory results
- ! The employee's positive or refusal (adulterated/substituted) test result had to be cancelled because the split specimen test could not be performed (e.g., the split was not collected)
The test is one of the following:
- ✓ A Follow-Up test
- ✓ A Return-to-Duty test
⚖️ 2. Gender Requirement for the Observer
👤 3. When the Collector Is Not the Observer
If the collector is not the observer, the collector must instruct the observer about:
- ✓ Checking the employee for prosthetic or other devices designed to carry "clean" urine or urine substitutes
- ✓ Watching the employee urinate into the collection container
Check for Prosthetic Devices
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 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
- ✓ Watch as the employee takes the specimen to the collector
The collector then completes the collection process.
🚫 4. Refusal to Permit Observation
Review any section using the sidebar navigation. When you're ready, contact us to schedule your live Zoom training session and mock collections.