Note: eCCF refers to “electronic Chain of Custody Forms”

With the recent HHS approval of various labs to implement an eCCF system for regulatory testing, there have been questions about what are Type 1 and Type 2 eCCFs. Below is a brief explanation:

Type 1: the collector uses an electronic CCF to document the collection process and then prints the CCF (Copies 1-5) without signatures. The collector, the donor, and the test facility personnel (e.g., accessioner, certifying technician, certifying scientist) sign the CCF using wet signatures. The electronic form is not signed.

Type 2: the collector uses an electronic CCF to document the collection process, the collector and donor sign using electronic signatures (the donor uses a digitized signature), and the collector prints Copy 1 with his/her electronic signature. This Copy 1 is the authoritative copy sent to the test facility with the specimen. The test facility personnel (e.g., accessioner, certifying technician, certifying scientist) sign the CCF using wet signatures.

Background:

HHS originally defined an electronic/paper Federal eCCF system in the HHS/NLCP Oversight and Requirements document on the SAMHSA website.

Subsequently, to enable the use of eCCF systems currently in place for non-regulated specimens (that were proposed for use with regulated specimens), HHS revised definitions to allow the 2 types of electronic/paper combination systems described above. See the June 23, 2015 National Laboratory Certification Program (NLCP) Notice. These 2 system types and requirements for their use are also defined in the NLCP Manual and addressed in other NLCP guidance (e.g., CCF Decision Trees).

 

With the first quarter of 2016 testing coming to a close we would like to point out a few things regarding your random notifications. When the notification and authorization forms are mailed out to you, we ask that you take a moment to review and read the notification instructions. The most important section is what the employee/driver has been selected to complete. Many of our clients just hand the authorization form to the selected individual without explaining which type of test(s) they will need to complete once they arrive at the collection site. If the selected individual has to complete a drug and alcohol test and the collector only performs the drug test you will then receive a Second Notice that the individual still needs to complete the alcohol test. This would be an inconvenience for you and the driver to have to stop working and go out to test again.

It’s also important to send the driver to a collection site that does both drug and alcohol tests. We have an online list of our collection sites and you should only select sites that do both tests just by simply marking the box in the search feature.

Once the driver has completed both tests you must then fill out the notification form and email or fax back to AADT with a copy of the Chain of Custody Form and Breath Alcohol test form. The Breath Alcohol test has immediate test results and they do not need to be sent to the laboratory and MRO to report the result, so AADT does not get a copy of the result unless you send it to us. Following these easy steps will help us all out.

As your service provider we need to notify all our clients what is required by the FMCSA to be compliant and in January we mailed out the Reasonable Suspicion training requirements and the order form. All clients with employees must have someone trained in Reasonable Suspicion. If you only use owner-operators under your operating authority, this requirement still applies to you. The only exception to this requirement is for single truck independent owner-operator motor carriers; they do not need to take this training for themselves. There is confusion on this requirement surrounding whether supervisor training applies to O-O’s who are incorporated. We are seeking guidance from U.S. DOT and will follow-up in a future issue.

IT IS REQUIRED UNDER DOT-FMCSA 49 CFR PART 382
According to §382.603 Training for Supervisors – Every employer shall ensure that persons designated to determine whether reasonable suspicion exists. In order to require a driver to undergo testing under §382.603, they must receive at least 60 minutes of training on alcohol misuse and 60 minutes of training on controlled substance use. The training shall cover the physical, behavioral, speech and performance indicators of probable alcohol misuse and use of controlled substances.

So if you have not had somebody supervisor-trained please fill out the order form on the back of the letter and send to us so we can process your request.

Our first month of 2016 has come to an end and if that’s an example of what the year is going to be like then we are prepared for a fast roller coaster ride. The month flew by so quickly but not without many changes for 2016.

We have been updating all our documents including the Compliance Manual and should have all the updated information available online at www.aadrugtesting.com hopefully before the end February. We are also looking at changing the renewal forms and random notifications to a simpler format. Read more

We hear this question quite regularly, and the answer is Yes!

The FMCSA issued a Notice of Proposed Exclusion (NOPE) to a Elizabeth “Betsy” Pope, and Eastgate Laboratory Testing, in Tennessee and all other places that it was doing business.

On January 20, 2015, the agency notifyed Ms. Pope that she had engaged in serious noncompliance. In the NOPE, the FMCSA stated that the DOT’s Office of the Inspector General conducted a criminal investigation of the company’s activities.

On August 18, 2015, The Department of Transportation (DOT) issued a decision and order under the Procedures for Transportation Workplace Drug and Alcohol Testing Programs that excludes a service agent, Elizabeth “Betsy” Pope d/b/a Eastgate Laboratory Testing, from providing drug and alcohol testing services in any capacity to any DOT regulated employer for a period of 5 years.

Ms. Pope and her company provided Medical Review Officer services to DOT-regulated trucking companies when Ms. Pope was not qualified to act as a Medical Review Officer.

Read the Federal Register notice on the Public Interest Exclusion. – See more at: https://www.transportation.gov/odapc/news#sthash.CArxyW2b.dpu

“Over the past five years, market share concentration has marginally increased due to some consolidation among leading industry firms,” says Blau. For instance, Sterling Infosystems’ 2011 acquisition of Axciom’s background screening business doubled the market share of one of the larger firms in this industry. Likewise, Symphony Technology Group acquired industry major player LexisNexis in 2013, forming First Advantage, one of the largest global screening analytics and identity solutions providers.

http://www.prweb.com/releases/2015/04/prweb12646808.htm

The year is finally coming to an end; time just seems to fly by faster every year. We at AADT have a few reminders that you should always have in mind when the year closes.

Final Quarter Random Notifications:

Please make sure to test all drivers right away and get all documentation over to us so it can be documented in our system. If a person is no longer with the company then make a notation on the random notification over to us so we can remove the driver/person and the system will select an alternate if there is one to select. Any person who will be out for more than 30 days should be removed from your list of active drivers. Read more