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Use of a pass-through door for regulated urine drug test collections

Posted: Tue Feb 06, 2018 10:07 am
by dsitzes
I encourage my clinic staff to question my decisions, so I'm asking about something one of them is questioning:

We have a new clinic with a pass-through door for specimens from the bathroom used by urine drug test donors to the lab, where the CCF's are completed by the collector and donor and the specimen is sealed. According to DOT Rule 49 CFR Part 40 Section 40.43(d)(2) "To the greatest extent you can, keep an employee's collection container within view of both you and the employee between the time the employee has urinated and the specimen is sealed." When the pass-through door is used, the specimen is no longer in the view of both the collector and the donor (even if just for the few seconds it takes to walk from the bathroom around the corner into the lab) "to the greatest extent" possible. Instead, I am having the collector wait outside the bathroom door, then accompany the donor and the specimen as they make their way around the corner to the lab so that the specimen is always in the view of both the donor and collector. This method is possible and follows the regulation, so I think we need to continue in this manner. Do you agree or am I missing something and using the pass-through door is OK?

Thank you.