DOs and DON’TS of alcohol testing

By Jan Kornmann, KorManagement Services, LLC

There are multiple components of breath alcohol testing that are key to a successful collection. Adequate training, using the appropriate device correctly and carefully following each step of the process are critical in our role of keeping communities and workplaces safe.

Below are the main aspects to consider for breath alcohol testing and best practice recommendations for collectors:

DEVICES

Breath alcohol testing devices are not all created equal. By that, I mean there are requirements that a device must meet before you can use it for U.S. Department of Transportation alcohol testing. A Breath Alcohol Technician or company providing breath alcohol testing will want to make sure the devices they are using are approved by the Department of Transportation before they perform tests for DOT-qualifying donors.

You can find the list of accepted devices under Approved Evidential Breath Measurement Devices | US Department of Transportation. EBT devices on this site are the only devices that may be used to conduct alcohol confirmation tests under 49 CFR Part 40.  These EBTs may also be used to conduct alcohol screening tests under Part 40.

For initial screening tests that must be performed for alcohol, the approved Alcohol Screening Devices (ASDs) are listed at: Approved Screening Devices to Measure Alcohol in Bodily Fluids | US Department of Transportation.  Screening Test Technicians (STT) can only use these devices for initial screening tests for alcohol. They may not be used for confirmation tests. An STT can only perform the initial screening for alcohol and will have to send the donor/employee to a trained BAT for any confirmation testing. 

Some helpful tips for using the correct devices for DOT testing:

• DO NOT just go on the internet and buy the cheapest one. Look at the specifications and make sure they are on the list for approved devices.

• If an STT is performing initial testing only, don’t assume that the company understands that a confirmation test must be performed within the mandated 15-to-30-minute window. To ensure compliance, the STT should arrange in advance for a designated location to send the donor/employee to for confirmation testing.

• If the testing is being conducted under the company policy (non-DOT testing) it is highly recommended the testing company’s policy follow Department of Transportation best practices and utilizes the same types of devices.

• Always be sure to comply with state law(s) and verify that the confirmation test  can be performed on an EBT. There are some states that require confirmation tests via blood, meaning the company cannot use an EBT for confirmation testing.

TRAINING

The technician performing the breath alcohol test for DOT must be trained in accordance with the DOT Model BAT or STT Course. Training must include the operation of the particular alcohol testing device(s) (i.e., the ASD(s) or EBT(s) the technician will be using) as well as proficiency demonstrations on their specific device. The instructor of the technician must be an individual who has demonstrated necessary knowledge, skills, and abilities by regularly conducting DOT alcohol tests as an STT or BAT, as applicable, for a period of at least a year or who has successfully completed a “train the trainer” course. 

Technicians Can NOT just be “shown” how to use the device. They are required to attend initial training and then refresher training every five years.

DONOR IDENTIFICATION

The identification of the donor/employee who you are testing is a critical part of the alcohol test. The Technician must see a driver’s license, passport, military I.D. card, or company I.D. badge that has the full name of the person being tested, along with a photo.

• Alcohol testing can NOT be performed on someone without identifying them. If the donor/employee does not have a picture I.D.  the next step is to call the Designated ER who will need to provide a verbal identification. The only exception to this rule is in the case of an Owner-operator or other self-employed individual who does not have proper identification, the individual should be asked to provide two forms of identification bearing his/her signature.

• A reminder to all technicians performing DOT collections under FMCSA: remember to look at the driver’s license and make sure the donor holds a Commercial Driver’s License (CDL) or Commercial Learner’s Permit (CLP).  If this is not noted on their license, the technician must call the DER to determine if the test should be performed as a non-DOT test. The technician should document comments under the “Remarks” section of the Alcohol Testing Form (ATF).

• DO NOT do the alcohol test if you cannot identify the person.

INSTRUCTIONS PRIOR TO THE COLLECTION

The Technician must explain the testing procedure to the donor/employee, including showing the employee the instructions on the back of the ATF prior to the collection.  

• DO NOT assume the employee/donor already know what is going to happen during this collection. In the DOT model training this is the statement the technician should use: “I will be conducting an alcohol screening test on you today.  After you sign this form (ATF), you will blow into the alcohol testing device and I will record your results. If the result is 0.020 or greater, you will be required to take a confirmation test. You will receive a copy of the testing form when we are finished with the process.”  Then show them the steps in the testing on the back of the ATF.

ATF STEP ONE

The correct information for Step One on the Alcohol Test Form (ATF) must be provided.  According to 49 CFR Part 40 Subpart B – Employer Responsibilities: §40.14 “What collection information must employers provide to collectors?”  The name of the employee/donor, ID number to use, the company/DER information, reason for the test, and which DOT agency the testing is under. 

• DO NOT ask the donor/employee to supply this information. The technician should only be confirming the information they received from the DER.

• It is critical that the technician knows who the DER is and has the DER’s phone number, as this is the only person who can make decisions regarding the alcohol testing procedure. DO NOT give information to just anyone, such as a supervisor.

ATF STEP TWO

Step 2 of the ATF contains the donor/employee acknowledgment for allowing alcohol testing.  I suggest that the technician read this statement out loud to the donor, to ensure they understand and then ask them to sign if they understand what they are signing. 

• If the donor/employee will NOT sign Step Two, the alcohol test cannot proceed.

• Should the donor fail to sign Step Two of the ATF, It is best practice to call the DER and ask them to speak with the donor/employee to encourage them to sign. DO NOT go ahead and perform the test if they will not sign.

BREATH SAMPLE

To capture an accurate breath sample for alcohol testing, the technician should have the donor/employee stand up straight to obtain a deep lung sample and the best possible measurement. Not doing so could lead to a diluted test result.

• DO NOT allow the donor employee to sit during the testing.

CONFIRMATION TESTING

Confirmation testing must be performed by a trained Breath Alcohol Technician (BAT) on an EBT not before 15 minutes and no longer than 30 minutes after the positive screening result. The technician needs to give the donor/employee instructions not to eat, drink, belch, or put anything in their mouth during that 15-minute wait period because it could affect their confirmation result, should they do so. The technician must stay with the donor/employee for the full 15 minutes.

• The BAT should not leave the donor/employee alone during this 15-minute wait and the donor/employee must be monitored during this period of time.

• The technician must perform a confirmation test when the results are 0.02 or higher.  If the result is 0.020-0.039 the donor/employee will not be able to perform safety-sensitive duties until the result is under 0.020. The timeframe for re-testing depends on the DOT testing agency. DO NOT forget to contact the DER as soon as possible.

• If the result of the test is 0.040 or higher the donor/employee will be removed from safety-sensitive position until they are evaluated by a Substance Abuse Professional.  DO NOT forget to contact the DER as soon as possible.

QUALITY ASSURANCE PLAN (QAP)

The QAP for each specific device used to perform testing is created by the manufacturer of the device. The technician must follow the QAP for specific times for calibrating the device annually and for performing the monthly calibration check. A log must be maintained of all calibrations and calibration checks for each and every device. The logs should be kept for a minimum of five years. This is usually completed by printing the label from the EBT device and placing it in a logbook.

There are two methods for performing calibrations and calibration checks on EBTs. One is by using dry gas (which is used most of the time) and the other is the “wet bath” method.

• Expiration dates must be tracked for dry gas tanks. DO NOT use expired gas. Only use the specific alcohol standard recommended by the QAP for each specific device. 

Always follow the QAP for the acceptable range of tolerance allowed for external calibration accuracy checks for each specific device.

• DO NOT use the device for testing if it falls outside of the acceptable range during the calibration check. The technician must stop and calibrate the EBT before using the device again.

• DO NOT keep trying over and over if the calibration check does not work. The device will need to be re-calibrated.  Be sure to follow the device QAP for the wait-time between performing the re-calibration and the next procedure, to ensure the device is clear of gas.

• DO NOT perform calibrations on the device if you are not trained and certified on the specific device per DOT regulations.

OUR WHY

Remember, why we perform alcohol testing.  We all play a part in keeping the employees, their communities, and the general public SAFE.

The technician is NOT there to “catch” the donor/employee but to test and give the results to the DER.

SUMMARY REMINDERS

• Technicians must be trained and retrained.

• Use approved EBT devices only for DOT.

• Follow instructions.

• Follow the QAP for the specific device used.

• The technician and the DER must have contact.

• Remember we do this for SAFETY.