Donor refused to wash hands

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hawkdoc

Donor refused to wash hands

Post by hawkdoc » Tue Jun 22, 2010 5:34 pm

A donor presented to a clinic for a random drug test collection. He was not happy about being chosen for a random and refused to wash his hands. By DOT urine specimen collection guidelines this is considered a refusal. The DER should have been immediately notified.

Does the collector complete a CCF with the explanation on the comments section, and with the donor's printed name on the form, or is the CCF not completed. (I don't think one was ever started.)

What if a CCF form was never completed. Is this still a refusal to test?

If the company has written documentation of what occurred from the collector, is that enough for a refusal for their records in case of legal issue, FMCSA audit etc?

If no CCF was completed is the MRO involved in anyway?

Thanks

Steve



Robert Swotinsky MD
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Re: Donor refused to wash hands

Post by Robert Swotinsky MD » Wed Jun 23, 2010 11:08 am

The collector should document the event on the CCF. If the collector documents the event elsewhere instead of the CCF, it's no big deal. The collector sends the documentation to the DER. The DER reviews that documentation and if it appears sufficient calls the event a refusal to test. It's not unusual for DERs to ask their TPAs (and MROs) to review the documentation and label these "refusal to test" events on behalf of the DERs.

hawkdoc

Re: Donor refused to wash hands

Post by hawkdoc » Thu Jun 24, 2010 11:26 am

Is the collector allowed to complete a CCF with the events described in the remarks section after (several days) the event occurred?

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Re: Donor refused to wash hands

Post by Robert Swotinsky MD » Thu Jun 24, 2010 1:50 pm

Federal rules neither allow nor prohibit the collector from entering data on the CCF after the test has been performed. It's a good practice, however, to identify when information is entered on the form if it's entered after the test event. This is because the default presumption is that entries are put on the CCF at the time of collection.

You know, this is getting complicated. If it was me, and if it was several days later, I'd print a few sentences explaining what happened on a piece of letterhead paper including my opinion that it looks like a refusal to test, and I'd sign that page and fax it to the employer. I'd do it on a separate piece of paper because it has enough space to enter those few sentences.

docrja

Re: Donor refused to wash hands

Post by docrja » Thu Jul 01, 2010 7:10 pm

I concur w/Dr Swotinsky that a MRO letter/memo w/letterhead would be ideal, IF the MRO is consulted by the Employer/DER.
Thanks for great issue posting to all!

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