Who Can Monitor DOT Mock Collections for Collectors and Alcohol Technicians?

Mock collections (the initial proficiency demonstration) are the step that turns classroom or online instruction into DOT collector or alcohol technician qualification. Organizations that train several people a year often ask who is allowed to watch those mocks and sign the error-free attestation. Part 40 answers that question with three paths for urine collectors and the same three paths for BAT and STT instructors.

Urine collector mock monitors (49 CFR 40.33(c)(2))

After qualification training under 40.33(b), the trainee must complete five consecutive error-free mock collections that include two uneventful scenarios, one insufficient quantity scenario, one temperature out of range scenario, and one scenario in which the employee refuses to sign the CCF and initial the specimen bottle seal (40.33(c)(1)). Another person must monitor and evaluate that performance in person or by a means that provides real-time observation and interaction, and must attest in writing that the mocks were error-free.

That monitor must be a qualified urine collector who has shown the needed knowledge, skills, and abilities by one of the following:

• Regularly conducting DOT urine drug test collections for at least one year (40.33(c)(2)(i)).
• Conducting urine collector training under Part 40 for at least one year (40.33(c)(2)(ii)).
• Successfully completing a urine train-the-trainer course (40.33(c)(2)(iii)).

A recorded video without live interaction does not meet the real-time observation and interaction rule. See how to prepare for virtual mock collections.

BAT and STT instructors (49 CFR 40.213)

For alcohol testing, the instructor who provides qualification training must meet 40.213(b)(4): regularly conducting DOT alcohol tests as an STT or BAT (as applicable) for at least a year, or conducting STT or BAT training under Part 40 for a year, or successfully completing a train-the-trainer course. The person who monitors the seven consecutive error-free BAT mocks or five consecutive error-free STT mocks must meet those same (b)(4) requirements (40.213(c)(1)). The mocks must use the alcohol testing devices the trainee will use on the job (40.213(c)(2)).

Device makers may offer factory instructor courses, but they are not the only path. Intoximeters' public FAQ states that a factory instructor course is not required to train BATs for DOT workplace testing when the instructor meets the Part 40 experience or train-the-trainer rules and follows the DOT Model Course or an equivalent. Calibration under 49 CFR 40.233 is separate. See BAT training from a device maker versus independent training.

Oral fluid monitors (49 CFR 40.35)

Oral fluid mocks require five consecutive error-free collections for each device the collector will use (40.35(c)). The monitor rules in 40.35(c)(2) mirror the urine paths, with temporary flexibility in 40.35(c)(3) until one year after HHS publishes notice of the first certified oral fluid laboratory. See urine collector versus oral fluid qualification.

Why organizations use train-the-trainer

The train-the-trainer path lets a clinic, TPA, or regulated employer keep a qualified monitor on staff for initial qualification, five-year refresher mocks, and error correction mocks, which also require a monitor who meets the same rules.

For collector steps outside the monitor question, see qualified specimen collector requirements and what 49 CFR Part 40 covers.

Organizations can enroll monitors through a Training Manager account in DOT Urine Collector Train-the-Trainer, DOT Breath Alcohol Technician Train-the-Trainer, or DOT Oral Fluid Train-the-Trainer.