Effective June 30, 2026, the revised DOT Urine Specimen Collection Procedures Guidelines replace the January 2018 version — and every version before it. Here's a full breakdown of what changed and what it means for collectors, employers, and C/TPAs.
All previous versions of the collection guidelines are no longer valid guidance. Every collection site should replace its copy — the full document is free at transportation.gov/odapc.
This is the big one. DOT added oral fluid testing to Part 40 in 2023, but DOT-regulated employers still cannot use it until at least two HHS-certified oral fluid laboratories with DOT-conforming devices are available and DOT announces implementation in the Federal Register. The new guidelines prepare collectors and employers for that day:
Bottom line: don't let anyone tell you oral fluid DOT testing is available today — it isn't.
DOT's stated best practice: employers should have a written protocol telling collection sites when to collect urine vs. oral fluid — including shy bladder / dry mouth situations, DER-directed observed collections, and tampering attempts. Collectors are expected to be familiar with each employer's standing orders before problems arise.
If your company doesn't have standing orders in writing yet, now is a good time to start — our free DOT policy generator is a solid companion for the written program side.
A government-issued photo ID that's expired may now be accepted — as long as it hasn't been expired more than 1 year. Still unacceptable: co-worker vouching, non-photo cards (Social Security cards, credit cards, union cards), and faxed or photocopied IDs. No acceptable ID? The collection doesn't proceed until the DER verifies identity.
Employees may now use hand sanitizer or wash and dry their hands before providing a specimen. Refusing to do either after being directed is still treated as a refusal to cooperate — the collector stops the collection and notifies the DER/employer, who makes the refusal determination.
Using an electronic CCF and the printer fails when producing the "authoritative copy" (the printout of Copy 1 that ships with the specimen)? The collector should sign the reprinted Copy 1 with a wet-ink signature in Step 4 — in the donor's presence — and document the issue in the Remarks section.
Also a reminder: keep paper CCFs on hand in case of power or device failure.
The observer must still be the same sex as the employee — no exceptions. The new guidelines spell out what happens when no same-sex observer is available:
The refusal table now clearly separates who makes each determination:
The collector's job in every case: document thoroughly, notify the DER immediately, and let the right party make the call. Collectors never make the refusal determination themselves.
DOT added Appendix A, a suggested (not required) format for documenting collector qualification training under 49 CFR §40.33 — covering qualification training, the five error-free mock collections (two uneventful, one insufficient quantity, one temperature out of range, one refusal to sign), and monitor attestation.
Collectors must maintain training documentation and provide it on request to DOT, employers, or C/TPAs. If a collector cannot demonstrate qualification, they may be treated as not qualified and may need to complete collector qualification training again.
The full document is free on the ODAPC website — every collector should keep a copy at their site alongside Part 40.
Our DOT collector qualification training is built on the current guidelines: self-paced modules plus a live Zoom proficiency demonstration, with audit-ready documentation.