Ask the experts: what is a direct observation drug test collection?

observed collection

Drug tests are frequently part of an employer’s drug-free workplace program and may require both prospective and current employees, known as donors, to provide a drug test specimen. With urine being the most widely used specimen type, a donor will often visit a collection site and complete a urine drug test collection. The process is typically seamless and straightforward. However, there may be scenarios where witnessing the collection of the specimen is necessary, for example, when a donor takes part in well-choreographed and intentional efforts to undermine, or cheat, the drug test collection process.

In 2008, the US Department of Transportation (DOT) implemented a new drug testing rule in the Federal Register allowing observed collections for return-to-duty and follow-up drug tests.1 Direct observation collections are used to help ensure cheating does not take place when the donor provides their drug test specimen.

When is a direct observation collection necessary?

According to the DOT’s Office of Drug and Alcohol Policy and Compliance, direct observation collections are authorized and required only in the following scenarios2 :

  • The employee attempts to tamper with his or her specimen at the collection site
  • The specimen temperature is outside the acceptable range
  • The specimen shows signs of tampering, such as unusual color or odor
  • The collector finds an item in the employee’s pockets or wallet, which appears to be brought into the site to contaminate a specimen; or the collector notes suggest tampering
  • The Medical Review Officer orders the direct observation because the employee has no legitimate medical reason for a certain atypical laboratory result
  • The employee’s positive or refusal [adulterated / substituted] test result had to be cancelled because the split specimen test could not be performed (for example, the split was not collected)
  • The test is a follow-up or a return-to-duty drug test

Drug test collections are a critical part of the drug testing process. From a donor’s perspective, the experience may be daunting because he or she may not know what to expect during a collection. From a collector’s point of view, the process must follow strict criteria to ensure quality. When risks of potential cheating occur, our collection sites are prepared and trained to handle a variety of situations.

To learn more about drug test collections, visit our website.


1 US Department of Transportation. “Federal register / Vol. 74, No. 145”

Published July 2009. Accessed March 22, 2019

2 US Department of Transportation’s Office of Drug and Alcohol Policy and Compliance. “DOT’s Direct Observation Procedures”

Accessed March 20, 2019