IntoximetersIntoximeters

By Adam Bell

Ten Tips for a Successful Audit

An audit by a DOT Operating Agency can be initiated in various ways. It may be a random event or DOT could be actively investigating. Some operating agencies (e.g. FAA) have regularly scheduled audits with larger employers. Service Agents generally get audited because the inspector found the name of the service provider when auditing an employer or through anonymous tips.

An audit can be a stressful and overwhelming experience. The more prepared you are, the less stressful your audit will be.

Ten tips that can help make your audit less intimidating

1.  Maintain meticulous records.

Remember that a DOT auditor/investigator can inspect any of your DOT records including training, collection, and logbooks as well as name-specific test results.  The best practice is to keep all DOT records separate from any medical charts to avoid confusion and privacy issues.

2.  If notified of an impending audit, have all requested documents available for the auditors when they arrive.

The more prepared you are, the smoother your audit will go. It is much better to dig out the requested information yourself rather than place a giant stack of papers in front of the auditor for him or her to search. Who knows what the auditor might find in the stack.

3.  Make sure that none of the records to be inspected have errors on them.

We recommend that you establish an ongoing policy for reviewing all ATFs and CCFs from the previous day before they are filed. One of the most common citations we hear about from customers is correctable errors that were not corrected.

4.  Advise the employer (your customer) as soon as you know you will be audited.

If the audit is occurring due to actions of an employer, the employer should be informed.

5.  If at all possible, provide the auditors with a workspace.

This simple act of kindness may generate a bit of good will from the inspector.

6.  Make sure you know the quality assurance protocols for your EBT instrument.

Every BAT should understand the QAP and be able to explain the inspection, maintenance, and calibration requirements for the device. Your logbook with records of ALL accuracy checks and calibrations must be current. Be prepared to answer questions such as: “What happens when the gas standard is expired?” or “How often is your device checked for accuracy?” or “Who is authorized to calibrate the equipment?”.

7.  Be prepared to perform a mock collection (alcohol and/or drug) for the auditor.

Auditors have been known to ask questions during mocks: “What would you do if the sample was insufficient?” or “When would you take a manual sample?”. Make sure ALL of your BATs can answer these types of questions. A quick review of procedures may be needed to refresh memories. See our earlier blog entry for more BAT review questions.

8.  BAT & Collector certificates on display or easily accessible.

Certificates should be hung on the wall or organized in a centrally located binder.

9.  Periodic Proficiency Training and internal audits are an excellent way to prepare for DOT audits.

Reviewing and reinforcing concepts such as QAP, Rules and Regulations and the proper procedures for DOT testing is essential.

10.  Audits can be unannounced.

Keep all records up to date and stored appropriately every day – not just on audit day. Remember that DOT drug & alcohol tests are not medical procedures and you should not apply medical recordkeeping processes to DOT test records.

 

By Betye Bailey

DOT Drug & Alcohol Testing – Forensic or Medical?

Many of our customers are medical facilities such as occupational or behavioral health clinics, hospitals, and doctor’s offices. It can be difficult to separate medical procedures and practices from the forensic protocols used in the U.S. Department of Transportation (DOT) testing program. Medical procedures must follow specific rules for documentation, HIPAA, and dialog with the subject. DOT drug & alcohol tests are forensic tests to insure compliance with federal safety regulations and are not medical procedures, even if they are conducted by medical personnel in a medical facility.   Read more

By Betye Bailey

5 Essential Questions to Ask Your Breath Alcohol Technician (BAT)

With far fewer breath alcohol tests being performed compared to urine drug screen collections, you may be faced with the training issue of “If you don’t use it, you lose it”. Confirming that your BAT is proficient and educated on an ongoing basis not only ensures the defensibility of your findings, but also protects the reputation of your business.   Read more

By Betye Bailey

Calibration Logbook Essentials for Workplace Testing

It always surprises us when we discover an alcohol testing program that does not utilize a logbook for their EBT (Evidential Breath Tester). This missing documentation can lead to problems if faced with an audit or legal proceedings. Programs which fail to document their quality assurance practices properly are out of compliance with 49 CFR Part 40.233(c)(4). The term “logbook” in this context refers to a Calibration Logbook. A Calibration Logbook keeps records of accuracy checks, calibrations, and instrument maintenance. This is a different document from a BAT logbook, which holds records of every test and function conducted with a particular device.    Read more

By Betye Bailey

How to Perform an Accuracy Check – Alco-Sensor VXL

Training at Intox Training Academy includes the basics of a Quality Assurance Plan (QAP) and also covers procedures for performing Accuracy Checks for your Alco-Sensor VXL. Understanding these procedures is very important to the health of your Testing Program, and its defensibility. For that reason, we are sharing the video clip below, directly from our training program, as a refresher on these procedures.    Read more

By Betye Bailey

Training Requirements for UDS Collectors

We talk about BAT training a lot here at Intoximeters, so we thought it might be good to discuss training UDS Collectors for a change!

The Department of Transportation has not published a Model Course for collectors like they did for Breath Alcohol Technicians (BATs). The BAT Model Course is what tells us how long the training should take and also provides materials for use in that training. Nothing like that exists for Urine Drug Screen collection training (other than the Urine Specimen Collection Guidelines document). Below is a summary of the Part 40 rules regarding collector training.     Read more

By Betye Bailey

Inspection, Maintenance and Calibration Records

Every EBT device should have its own Calibration Logbook where records related to the maintenance of your instrument are kept. As part of your training, you should have been taught how to fill out a logbook every time you conduct an accuracy check. Logbook entries are routine procedures that become extremely important when an employee challenges a positive test result. If you were NOT taught about logbooks in your BAT training, contact us at training@intox.com.

Intoximeters trainers have the occasional opportunity to examine calibration logbooks when we go to a customer site to do training or to audit their program. Unfortunately, we frequently see careless logbook entries that do not contain complete information.    Read more

By Betye Bailey

Should I Perform an Accuracy Check, or a Calibration?

One of the most common sources of confusion for new BAT’s is the difference between an “Accuracy Check” and a “Calibration“. In short, Calibration is a repair procedure and Intoximeters instruments do not require routine, regular calibration. However, the accuracy of any testing instrument should be checked (Accuracy Check) periodically per the requirements of your company policies or the Intoximeters Quality Assurance Plan (QAP).

  Read more

By Betye Bailey

ATF – Checking the 15 Minute Wait Box

We are often asked the proper way to address the 15 minute wait check box in Step 3 of the DOT Alcohol Testing Form.

ODAPC has informally stated that “the intent of the 15 minute wait boxes in Step 3 of the Federal ATF was for the BAT to indicate whether or not the 15 minute wait was observed between the screening and confirmation tests. There is no requirement for the BAT to complete the 15 minute wait boxes when the screening test result is less than 0.020”.

ODAPC has not published this response in any of the questions and answer guidance to date. If you would like written clarification on this or any other section of 49 CFR Part 40, you can always contact ODAPC directly at 202.366.3784 or by email at ODAPCWebMail@dot.gov.

1 2