From the Research
If a DOT donor refuses to sign the Chain of Custody Form (CCF), the collector should note "Refusal to Sign" in the designated area and document the refusal in the "Remarks" section, then complete the collection process and notify the Designated Employer Representative (DER) immediately. This action is crucial as the refusal to sign is considered a refusal to test under DOT regulations, which can have significant consequences, including removal from safety-sensitive duties 1. The collector should prioritize completing the collection process and ensuring the specimen is sent to the laboratory for testing, despite the missing donor signature.
Key Steps for the Collector
- Note "Refusal to Sign" in the designated area of the CCF
- Document the refusal in the "Remarks" section, including details about the circumstances
- Complete the collection process as normal, including signing the form themselves
- Immediately notify the DER of the situation
- Ensure the test is processed by the laboratory despite the missing donor signature
The signature on the CCF is a critical component of the testing process, as it confirms the donor's understanding of the specimen collection procedure and the chain of custody 2. However, the collector's primary responsibility is to ensure the integrity of the testing process and comply with DOT regulations. By following the outlined steps, the collector can maintain the integrity of the process while also addressing the donor's refusal to sign.
Considerations for the Collector
- The refusal to sign should be treated as a refusal to test, with the same consequences as a positive test result
- The collector should prioritize clear and detailed documentation of the refusal
- The DER should be notified immediately to ensure prompt action is taken in accordance with DOT regulations
- The laboratory should process the test as normal, despite the missing donor signature, to ensure compliance with regulations and maintain the integrity of the testing process.