Short Answer

A DOT collection site is the location where a urine or oral fluid specimen is obtained for drug testing, or where an alcohol test is administered. The employer is responsible for using a collection site and alcohol testing site that meets Part 40's requirements, whether that site is a dedicated collection facility, a clinic, a mobile collection unit, or a location set up temporarily for a specific test. The requirements for the site itself do not change based on its physical form. What matters is that the site allows the collector, BAT, or STT to follow the required procedure correctly.

General Categories of Collection Sites

Collection Site (Drug Testing)

A place selected by the employer or its service agent where employees present themselves for a urine or oral fluid specimen collection, staffed by a qualified collector who completes the Federal Custody and Control Form. Collection sites range from dedicated occupational health clinics to mobile or on-site collection setups arranged for a specific employer.

Alcohol Testing Site

A place selected by the employer where an alcohol screening test, and if necessary a confirmation test, is conducted by a qualified BAT or STT. The site must provide the privacy and equipment conditions needed to conduct the test in accordance with Part 40.

Direct Observation and Oral Fluid Collection

Most urine collections are conducted without direct observation of the employee providing the specimen. Direct observation, meaning a same-gender observer watches the employee provide the specimen, is required only in specific circumstances defined by Part 40, such as certain return to duty and follow-up tests. Oral fluid collection works differently: because the collector places the collection device in the employee's mouth and monitors the collection, an oral fluid collection is inherently observed as part of the collection method itself. Readers who need the precise regulatory language on this point should confirm it against the current text of Part 40's oral fluid testing provisions.

Applicable Regulations and Sources

• 49 CFR § 40.3, Definitions (collection site)

Professional Observation

In my experience, employees are sometimes concerned that a mobile or on-site collection setup is somehow less legitimate than a clinic. What actually matters is not the physical setting but whether the collector follows the required procedure and completes the CCF correctly. A properly run mobile collection is just as valid as one conducted in a permanent facility.

Related Articles

• What Is an Observed Collection?
• DOT Drug Testing Process
• What Is the DOT Shy Bladder Procedure?
• How Laboratory Testing Works
• Common DOT Drug and Alcohol Testing Forms

Primary Authorities

• 49 CFR § 40.3, Definitions

Questions About a Recent Collection?

If you have a question about how your specimen was collected, a DOT qualified Substance Abuse Professional can help you understand whether the process followed Part 40.

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