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DOT Urine Collector Training Requirements & ODAPC Email Update
DOT Urine Collector Training Requirements Under 49 CFR § 40.33
Qualification training is only one part of becoming and remaining a compliant DOT urine specimen collector. Collectors must also complete proficiency demonstrations, maintain documentation, complete refresher training, correct qualifying errors, and subscribe to ODAPC email updates.
Important: DOT Urine Collectors Must Subscribe to ODAPC Email Updates
Under 49 CFR § 40.33(a), a DOT urine specimen collector must remain knowledgeable about current DOT requirements and must subscribe to the Office of Drug and Alcohol Policy and Compliance, or ODAPC, email notification system.
This is not merely an optional professional newsletter. The subscription requirement is included directly in the federal training requirements for DOT urine collectors.
The subscription is currently administered through the federal GovDelivery email notification system.
Who Is Authorized to Perform DOT Urine Collections?
DOT urine specimen collections are highly regulated procedures. Under 49 CFR Part 40, only collectors who meet the applicable qualification and training requirements may perform urine specimen collections for federally regulated drug tests.
Section 40.33 establishes the minimum requirements a person must satisfy before beginning collector functions and the continuing responsibilities the collector must meet to remain qualified.
1. Basic Regulatory Knowledge
A DOT urine collector must be knowledgeable about:
- 49 CFR Part 40;
- The current DOT Urine Specimen Collection Procedures Guidelines;
- Applicable DOT agency regulations governing the employers for whom the collector performs collections; and
- Changes and updates affecting DOT collection procedures.
Depending on the employer, applicable agency requirements may include regulations administered by FMCSA, FAA, FTA, FRA, PHMSA, or the United States Coast Guard.
Why the ODAPC Subscription Requirement Matters
DOT regulations, procedures, forms, guidance documents, interpretations, and collection instructions can change. A collector who relies only on information learned during an older training course may miss an important federal update.
ODAPC email notifications may alert subscribers to matters such as revised collection guidelines, regulatory amendments, updated federal forms, new questions and answers, implementation notices, and other compliance information.
Subscribing helps collectors demonstrate that they have taken a required step toward remaining current. However, collectors must also review relevant updates and apply them to their collection procedures when required.
Recommended ODAPC Subscription Compliance Checklist
☐ Subscribe using an email address you regularly monitor.
☐ Confirm the subscription when prompted by GovDelivery.
☐ Add the sending address to your approved sender list.
☐ Review ODAPC notices when received.
☐ Retain subscription confirmation or other evidence of registration.
☐ Update internal collection procedures when a regulatory change applies.
☐ Notify collection personnel and provide additional training when necessary.
2. Qualification Training
Before performing DOT collector functions, the individual must receive qualification training covering the procedures and responsibilities required by Part 40.
Qualification training must include instruction concerning:
| Training Area | Required Knowledge |
| Collection Procedures | Every step necessary to complete a DOT urine collection correctly. |
| Federal CCF | Proper completion, distribution, and transmission of the Federal Custody and Control Form. |
| Problem Collections | Procedures for insufficient specimen situations, suspected tampering, temperature problems, refusals, and other unusual events. |
| Collection Errors | Fatal flaws, correctable flaws, corrective statements, and procedures for addressing collection problems. |
| Professional Conduct | Protecting the integrity of the process, employee privacy, specimen security, and avoiding offensive or inappropriate conduct. |
3. Five Consecutive Error-Free Mock Collections
Completing the classroom or online instructional portion alone does not qualify a person to begin conducting DOT urine collections. After qualification training, the trainee must successfully complete five consecutive error-free mock collections.
The Five Required Mock Collection Scenarios
- Uneventful collection scenario;
- Second uneventful collection scenario;
- Insufficient quantity of urine scenario;
- Specimen temperature outside the acceptable range scenario; and
- Employee refusal to sign the CCF and initial the specimen bottle tamper-evident seal scenario.
The mocks must be observed and evaluated in person or through a method that provides real-time observation and interaction between the evaluator and trainee. A prerecorded video submitted without real-time interaction does not satisfy this observation requirement.
The evaluator must attest in writing that the five mock collections were error-free and must satisfy one of the experience or instructor qualifications established by § 40.33.
Who May Evaluate the Mock Collections?
The evaluator must be a qualified urine collector who has demonstrated the necessary knowledge, skills, and abilities by meeting at least one of the following criteria:
- Regularly conducting DOT urine drug test collections for at least one year;
- Conducting urine collector training under Part 40 for at least one year; or
- Successfully completing a urine collector train-the-trainer course.
4. Training Must Be Completed Before Performing Collector Functions
A trainee must complete both the required qualification training and the initial proficiency demonstration before beginning to perform DOT urine collector functions. A person should not conduct DOT collections independently while waiting to complete the five required mock collections.
5. Refresher Training Every Five Years
DOT urine collectors must complete refresher training no less frequently than every five years. The five-year period is measured from the date the collector satisfactorily completes both qualification training and the required proficiency demonstration.
Refresher training must satisfy the qualification training and proficiency demonstration requirements of § 40.33. This includes completing five consecutive error-free mock collections again.
6. Error Correction Training
When a collector makes an error during the collection process that causes a DOT drug test to be cancelled, the collector must complete error correction training.
The 30-Day Deadline
Error correction training must occur within 30 days from the date the collector is notified of the error that created the retraining requirement.
Error correction training only needs to address the subject matter area in which the collector made the error. As part of the training, the collector must complete three consecutive error-free mock collections:
- One uneventful collection scenario; and
- Two scenarios related to the area in which the collector’s error occurred.
The trainer must monitor and evaluate the collector’s performance and document in writing that all three mock collections were error-free.
Not Every Cancelled Test Requires Collector Retraining
When cancellation results from an event outside the collector’s collection process—such as a specimen being lost, crushed, or damaged during transportation—the cancellation is not necessarily attributable to a collector error and does not automatically require the collector to complete error correction training.
7. Collector Documentation Requirements
Collectors must maintain documentation demonstrating that they currently satisfy all requirements of § 40.33. This responsibility belongs to the collector and should not be left entirely to a former employer, training company, or collection site.
A collector’s qualification file should generally include:
- Qualification training certificate or completion record;
- Written documentation of the five initial error-free mock collections;
- Refresher training and refresher mock collection records;
- Error correction training records, when applicable;
- Written documentation of the three error-free corrective mocks, when applicable;
- Trainer or evaluator qualification information;
- ODAPC email subscription confirmation; and
- Records showing the collector remains current with applicable DOT procedures.
These records must be provided upon request to DOT agency representatives and to employers or consortium/third-party administrators that use or are considering using the collector’s services.
Key Compliance Takeaways
- Training alone does not qualify a collector without the required mock collections.
- The initial proficiency demonstration requires five consecutive error-free mocks.
- Collectors must complete refresher training at least every five years.
- A qualifying collector error must be addressed through error correction training within 30 days of notification.
- Error correction training requires three consecutive error-free mock collections.
- Collectors are responsible for maintaining their qualification documentation.
- Every DOT urine collector must subscribe to ODAPC email updates and remain current on regulatory changes.
Complete Your DOT Urine Collector Training
Accredited Training Academy provides professional DOT urine specimen collector qualification training designed to help collectors understand federal procedures, problem collections, Federal CCF requirements, collection errors, privacy, specimen security, and proficiency demonstration requirements.
View ATA Training CoursesFrequently Asked Questions
Is subscribing to the ODAPC email list optional for DOT urine collectors?
No. Section 40.33(a) states that a DOT urine collector must subscribe to the ODAPC list-serve. ODAPC currently distributes its email notifications through GovDelivery.
Does an online training certificate alone qualify someone to conduct DOT urine collections?
No. The trainee must complete qualification training and five consecutive error-free mock collections before beginning DOT collector functions.
Can DOT mock collections be completed remotely?
Yes, provided the method allows real-time observation and interaction between the evaluator and trainee. The evaluator must be able to monitor the trainee’s performance and attest that the collections were error-free.
How often must a DOT urine collector complete refresher training?
Refresher training must be completed no less frequently than every five years from the date the collector satisfactorily completed the applicable training and proficiency requirements.
How many mocks are required for error correction training?
Three consecutive error-free mocks are required: one uneventful scenario and two scenarios related to the error that caused the test to be cancelled.
How long does a collector have to complete error correction training?
The collector must complete the training within 30 days from the date the collector is notified of the error requiring retraining.
Who may request a collector’s qualification documentation?
DOT agency representatives, employers, and C/TPAs using or negotiating to use the collector’s services may request documentation demonstrating that the collector currently meets § 40.33.
Official DOT Resources
Electronic Code of Federal Regulations: 49 CFR § 40.33
ODAPC: DOT Rule 49 CFR Part 40 Section 40.33
Educational Notice: This article is provided for general educational and training purposes and does not replace 49 CFR Part 40, applicable DOT agency regulations, official ODAPC guidance, or legal advice. Collectors and service agents should review the current regulation and official DOT materials before performing regulated services.
