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How is a Drug Urine Test Conducted?

By Andrew David Easler, Esq.

A drug urine test mandated under DOT regulations consists of three components – the collection, the lab test, and then a review by the Medical Review Officer. Details can be found by visiting 49 CFR Part 40 at

The Collection

During this part of the process, a urine specimen collector does the following:

  • Verifies the identity of the person being tested using a valid photo identification, such as an employer-issued identification card, a driver’s license or a passport.
  • Ensures that the collection site is secure by restricting access to only the people who are being tested, removing any cleaning products or fluids that might be present at the collection site, securing all sources of water, and placing blue dye in toilets or other containers that may be holding standard water.
  • Permits the person being tested to have privacy while producing the specimen, unless that person has a history of trying to adulterate his or her urine, or substituting the urine of another person’s, or in any other situation where questions have arisen as to the validity of the urine specimen.
  • Requires the person being tested to empty his or her pockets and remove any unnecessary clothing.
  • Instructs the person being tested to provide at least 45ml of urine, after washing and drying his or her hands.
  • Provides a collection kit that has been unsealed in the presence of the person being tested.
  • Checks the color and temperature of the urine provided, and then pours it into two separate bottles that are sealed with tape and has the person being tested sign the seals.
  • Fills out the necessary paperwork including a CCF (Custody and Control Form) and gets the daytime and evening phone number of the person being tested so that the MRO (Medical Review Officer) can contact him or her if necessary.
  • Provides the person being tested with a copy of the CCF, and asks him or her to list any prescription or OTC medications on the back.

If the person being tested finds it impossible to provide 45ml of urine on the first try, he or she will remain at the site under supervision, and provided with fluids, for up to three hours. If it is still not possible, a medical evaluation will be required.

The Lab Test

At the lab, the staff will determine if any flaws existed in the collection process. If there are flaws, the specimen is rejected. Two methods of testing are used on one bottle, and the test is only reported to the MRO as positive if both tests are positive. The second bottle is kept in storage for one year.

MRO Review

When the MRO receives the lab results, he or she will evaluate the paperwork for accuracy, and report a negative result to the DER (Designated Employer Representative). If the result is positive, the person who was tested will be contacted and interviewed in order to identify any legitimate medical reasons for the result. If there is such a reason, the result will be reported as negative.

The information on this page may have changed since we first published it. We give great legal advice, but this page (and the rest of our site) is for informational use only and is no substitute for actual legal advice. If you’d like to establish an attorney-client relationship, reach out to us and we’ll tell you how we can make it official. Sending us an email or reading this page alone doesn’t mean we represent you.
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