September 28, 2000
Mr. Walt Vogl
Division of Workplace Programs
5600 Fishers Lane
Rockwall II, Suite 815
Rockville, MD 20857
Dear Mr. Vogl:
Following are the comments from the Drug and Alcohol Testing Industry Association (DATIA) on the Second Draft Mandatory Guidelines for Federal Workplace Drug Testing Programs. DATIA is a 1,000+ member non profit national trade association representing the entire spectrum of service providers in the drug and alcohol testing industry, including consortia, third party administrators, specimen collectors, medical review officers, laboratories, and testing equipment/product manufacturers.
DATIA wishes to commend the SAMHSA/CSAP Division of Workplace Programs and the Drug Testing Advisory Board (DTAB) on the great efforts made in drafting the second draft of the revised Mandatory Guidelines for Federal Workplace Drug Testing Programs. The second draft is a great improvement. The revised draft successfully integrates alternative specimens and point of collection testing into guidelines that can be adhered to by industry professionals while maintaining the integrity of the drug testing process. This creates a win-win situation for both providers of drug and alcohol testing as well as the end-users of drug and alcohol testing.
We thank you for this opportunity to participate in the formulation of these revised guidelines at this stage in their development. We look forward to working with you as you continue to revise the Mandatory Guidelines. DATIA is available to assist you in any way that you may need. Please feel free to contact me if you would like to further discuss any of the following comments.
Sincerely,
Laura E. Norfolk
Executive Director
Subpart C, §3.1 For which drugs can a specimen be tested?
With the recent activity amongst states in enacting “Medical Marijuana” laws, DATIA suggests that this section be clarified to indicate that controlled substances only be considered “legal” when otherwise authorized by Federal law.
“…but not when used pursuant to a valid prescription or when used as otherwise authorized by Federal law.”
Subpart D, §4.4 What are the requirements of an HHS-approved collector certification program?
Subpart L, §12.8What are the requirements of an HHS-approved POCT certification program?
DATIA is pleased to see that the new guidelines hold all service providers accountable for attesting to their proficiency in their respective drug-testing specialty (medical review, collections, etc.), however, the guidelines do not indicate how the required training must be administered. DATIA would like to offer what has been learned from the association’s experiences in providing training to industry professionals.
DATIA members have reported major success with face-to-face or “hands-on” training with proper supervision as the only effective means for a proper instruction and training in the complex area of specimen collection.
The committees of industry professionals that have advised DATIA’s specimen collection training and certification program, recommended that face-to-face training was the only way to ensure that the trainee actually understood the material presented to him/her and would be able to use that information to successfully collect urine specimens while maintaining the integrity of the specimen and the privacy of the donor. The committees also realized that not all companies had the resources to send their entire staff to an off-site training seminar. Therefore, DATIA set up a program to require only the company’s designated supervisor to attend a DATIA seminar, where they are trained on the intricacies of specimen collection as well as how to administer a successful training program to their colleagues. After successfully completing the course and passing the exam, the “Supervisor/Trainer” then returns to his/her company and trains the remaining collection personnel using the materials provided by DATIA. After being trained by a “Supervisor/Trainer”, the collectors are eligible to take the DATIA certification exam (via fax in restricted time period) and receive their Certified Professional Collector (CPC) designation.
Although technology offers many “convenient” forms of training and/or certification, these mediums do not, in our experience, offer the interaction needed to ensure that the trainee absorbs the necessary information to become proficient in his/her respective specialty. As an example, an administrative staff member with no prior knowledge of drug testing or collections, completed a computer-training course in specimen collections on the Internet during her first week of employment and was designated a “Certified Specimen Collector” by the course provider without ever having performed or witnessed a specimen collection. While this program presented a multitude of information on specimen collection, it clearly did not accurately measure the trainee’s proficiency or prepare the trainer to perform specimen collections.
The primary benefit of face-to-face training is the ability for the trainees and the presenter to interact. Although some computer-training programs boast interaction, this interaction is extremely limited to only the information contained in the program. In face-to-face training, comments made by one attendee can turn into a full-blown discussion on an issue affecting numerous collectors that otherwise would not have been covered in a “cookie cutter” computer/video course. As such, face-to-face training courses lend themselves to the opportunity to tailor the course to the current attendees and their particular strengths and weaknesses. Over the past three years, DATIA has received hundreds of comments from attendees who greatly benefited from DATIA’s seminars. Here are some of our constituents’ comments on the benefits of face-to-face training:
“The presentation of the information was excellent. There were quite a few areas that were eye-opening for me.”
“Sharing of experiences is always of value.”
“(the presenter) did a great job on making sure we understood everything.”
“Great class – good open forums during class.”
“Very good and thought provoking information.”
“Extremely beneficial – especially for people who know everything.”
“The program was well done. All questions were very informational.”
Clearly, this face-to-face or “hands-on” approach has proven to be popular and cost effective. DATIA’s Certified Professional Collector Trainer (CPCT) Training Seminar has been offered since April 1997 (April 1997 through June 1999 offered as the DATIA Train the Trainer in Urine Specimen Collections Course). In July of 2000, one year after the integration of certification into the collector training program, the association certified its 1000th specimen collector.
In light of the association’s experiences in administering and evaluating education and training programs, DATIA urges HHS to require that HHS-approved certification programs include face-to-face or “hands-on” training. This form of training provides substantial human interaction, an opportunity for personalization of the training, and the ability to determine whether or not trainees successfully understand the material being presented.
Subpart H, §8.2 What are the basic requirements for collecting any type of specimen?
In subsection (f), DATIA suggests that clarification on who can provide the donor with permission to conduct a direct observed collection be included. Under current standards and regulations, this concurrence must come from a collection facility supervisor or the donor’s designated employer representative. This clarification will ensure that collectors receive the appropriate concurrence before subjecting a donor to a direct observed collection.
“(f) The collector must obtain permission from a collection facility supervisor or employer representative to immediately collection another specimen when a tampered specimen is collected.”
