Joseph Leone

Document ID: DOT-OST-2003-15245-0068
Document Type: Public Submission
Agency: Department Of Transportation
Received Date: August 29 2008, at 10:06 AM Eastern Daylight Time
Date Posted: August 29 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: August 29 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: September 25 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 806e57b9
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This is comment on Rule

Procedures for Transportation Workplace Drug Testing Programs

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I am concerned about the new DOT regulations on observed collections for return to duty and follow-up drug screens referencing OST-2003-15245. I am a male Medical Technologist in a physician laboratory. Currently I am the only male and I have to do all the observations. I think it is very uncomfortable to have someone raise there shirt and lower their pants and have to visually check them and then watch them urinate into a cup. The donor should be visually examined by a physician in a medical clinic prior to coming to the Lab for the urine collection. I can not seem to get this across to my superiors. It seems it would be an easy solution to a problem that DOT must regulate. Can that not be put into the regulation changes that the donor must be checked by a physician prior to submitting his specimen if that donor comes to a medical clinic or hospital lab for urine collection?