    Drug Testing: Undercover Tests Reveal Significant Vulnerabilities
    in DOT's Drug Testing Program (01-NOV-07, GAO-08-225T).

    To help prevent accidents resulting from drug use by individuals
    in safety-sensitive positions, the Department of Transportation
    (DOT) requires motor carriers to conduct drug testing of their
    employees. These drug tests involve collecting a urine specimen
    from employees. To ensure the integrity of the urine specimen and
    the collection process, DOT regulations provide numerous
    protocols that outline collection procedures and identify
    controls to prevent employees from defeating a drug test. Recent
    media accounts indicate that some sites performing DOT drug test
    collections may not be adhering to the collection protocols.
    Moreover, given the different techniques a drug user may employ
    in an attempt to defeat a drug test, it is possible that a
    commercial truck driver could defeat a drug test by diluting,
    substituting, or adulterating a urine specimen in order to obtain
    a passing result. GAO was asked to perform an undercover
    operation to determine whether (1) urine collectors followed DOT
    protocols at selected collection sites and (2) commercially
    available products could be used to defeat drug tests. To perform
    this undercover operation, GAO created two fictitious trucking
    companies and produced bogus driver's licenses. GAO investigators
    then posed as truck drivers to test 24 collection sites
    throughout the United States. GAO briefed DOT officials on its
    results and they agreed with the findings.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-08-225T
        ACCNO:   A77889
      TITLE:     Drug Testing: Undercover Tests Reveal Significant
    Vulnerabilities in DOT's Drug Testing Program
         DATE:   11/01/2007
      SUBJECT:   Alcohol or drug abuse problems
    	     Collection procedures
    	     Data integrity
    	     Drug testing
    	     Employees
    	     Federal regulations
    	     Internal controls
    	     Investigations into federal agencies
    	     Motor carriers
    	     Program evaluation
    	     Protocols
    	     Truck drivers
    	     Urinalysis
    	     Corrective action
    	     Program goals or objectives
    	     Program implementation

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    GAO-08-225T

         * [1]Summary
         * [2]Background
         * [3]Most Collection Sites Failed to Comply with All DOT Protocol

              * [4]Washington, D.C., Metropolitan Area
              * [5]Los Angeles Area
              * [6]New York/Northern New Jersey Area
              * [7]Dallas/Fort Worth Area

         * [8]Commercially Available Products Can Defeat Drug Tests at Sel

              * [9]Products to Defeat Drug Tests Are Widely Available
              * [10]Adulterants and Synthetic Urine Used at 8 of 24 Collection S
              * [11]Adulterants and Substitutes Were Not Detected by Laboratorie

         * [12]Corrective Action Briefing
         * [13]Conclusion
         * [14]Contacts and Acknowledgments

              * [15]Washington, D.C., Metropolitan Area
              * [16]Los Angeles Metropolitan Area
              * [17]New York/Northern New Jersey Metropolitan Area
              * [18]Dallas/Fort Worth Metropolitan Area Undercover Testing

         * [19]GAO's Mission
         * [20]Obtaining Copies of GAO Reports and Testimony

              * [21]Order by Mail or Phone

         * [22]To Report Fraud, Waste, and Abuse in Federal Programs
         * [23]Congressional Relations
         * [24]Public Affairs
         * [25]PDF6-Ordering Information-Young-10-25-07.pdf

              * [26]GAO's Mission
              * [27]Obtaining Copies of GAO Reports and Testimony

                   * [28]Order by Mail or Phone

              * [29]To Report Fraud, Waste, and Abuse in Federal Programs
              * [30]Congressional Relations
              * [31]Public Affairs

    Testimony

    Before the Subcommittee on Highways and Transit, Committee on
    Transportation and Infrastructure, House of Representatives

    United States Government Accountability Office

    GAO

    For Release on Delivery
    Expected at 10:00 a.m. EDT
    Thursday, November 1, 2007

    DRUG TESTING

    Undercover Tests Reveal Significant Vulnerabilities in DOT's Drug Testing
    Program

    Statement of Gregory D. Kutz, Managing Director
    Forensic Audits and Special Investigations

    GAO-08-225T

    Mr. Chairman and Members of the Subcommittee:

    Thank you for the opportunity to discuss our undercover operation to test
    Department of Transportation (DOT) drug testing regulations as they relate
    to commercial truck drivers. According to DOT, its regulations implement
    the world's largest drug and alcohol testing program covering six DOT
    operating administrations and over 12.1 million employees  in the United
    States, including school bus drivers, commercial truck drivers
    transporting hazardous materials, and airline pilots. We focused our
    efforts on the DOT drug testing program for commercial truck drivers,
    which DOT considers to be a safety-sensitive transportation position. If
    an employee in a safety-sensitive transportation position were using
    controlled substances such as marijuana, cocaine, or phencydidine (PCP), a
    clear public safety risk would exist.

    To help prevent accidents resulting from drug use by individuals holding
    safety-sensitive positions, federal law requires motor carriers to drug
    test their employees.1 Motor carriers in the United States are responsible
    for conducting the drug testing of their employees and can use third-party
    administrators to help them coordinate the drug tests. Drug tests involve
    collecting a urine specimen from the employee at a collection site. As
    long as the collection site meets the requirements of DOT's regulations,
    urine collection can be performed at sites across the nation, in addition
    to being performed  onsite at an employer's facilities. DOT regulations
    contain numerous control measures intended to ensure the integrity of the
    urine specimen and the collection process during these tests. However, a
    drug using employee may attempt to defeat a drug test using techniques
    commonly known as substitution, dilution, and adulteration.  To prevent an
    employee from defeating the drug test, DOT regulations mandate that
    collection sites follow certain protocols, for instance:

               o DOT protocols require collectors to validate that an employee is
               carrying photo identification before the test. This is designed to
               prevent an employee from having somebody else take the test for
               him or her, which is one form of substitution.

               o DOT protocols require collectors at drug testing sites to ensure
               that no clear water source is available in the collection area,
               among other measures, to prevent an employee from using water in
               the bathroom to dilute their urine specimen.

               o DOT protocols specify that employees should not be able to
               access soap, air freshener, or other chemicals to prevent them
               from using these products to adulterate a urine specimen. Other
               DOT protocols designed to prevent adulteration require employees
               to empty their pockets and wash their hands before providing the
               specimen.

    ^1 49 U.S.C. S 31306.

    Recent media accounts indicate that some private sector collection sites
    performing DOT drug test collections may not be adhering to established
    collection protocols. Moreover, given the different techniques a drug user
    may employ in an attempt to defeat a drug test, it is possible that a
    commercial truck driver  could defeat a drug test by diluting,
    substituting, or adulterating a urine specimen in order to obtain a
    passing result. You asked us to perform an undercover operation to
    determine whether (1) urine collectors followed DOT protocols at selected
    collection sites and (2) commercially available products could be used to
    defeat drug tests.

    To determine whether urine collectors followed DOT protocols at selected
    publicly advertised urine collection sites, we created two fictitious
    trucking companies. Since our focus was on commercial truck drivers, we
    produced bogus commercial driver's licenses using computer software and
    hardware available to the public. Our investigators then posed as
    commercial truck drivers employed at the fictitious companies. We also
    used the fictitious company names to hire third-party administrators (TPA)
    to help us coordinate the drug tests by recommending collection sites and
    processing the required paperwork. Our undercover investigators then
    reported to urine collection sites pretending they had been selected by
    their company to receive a drug test and submitted urine specimens. The
    specimens were sent to the drug testing laboratories by the collection
    sites, and through our TPA we were able to access the laboratory results
    of our drug tests. We selected 24 publicly advertised urine collection
    sites to test four major geographic areas throughout the United States,
    including 6 urine collection sites in the Washington, D.C., metropolitan
    area and 6  in each of the following three areas--Los Angeles, New
    York/Northern New Jersey, and Dallas/Fort Worth. We chose the Washington,
    D.C., area because of its size and for reasons of convenience and economy,
    and the other three areas due to the large number of truck drivers
    residing within each area.2 At each urine collection site we tested 16
    specific DOT protocols which we determined, based on our research, to be
    the most critical in preventing an employee from defeating a drug test.
    Investigators brought mobile phones with photographic capability into the
    collection sites to photograph any breaches of protocol they observed.

    ^2According to the U.S. Department of Labor, Bureau of Labor Statistics.

    To determine whether commercially available products could be used to
    defeat drug tests, we researched products available to mask drug use by
    conducting Internet searches, reviewing prior GAO reports, and
    interviewing knowledgeable government officials.3 We then purchased
    adulterants and substitute synthetic urine over the Internet and used them
    in an attempt to defeat 8 out of the 24 drug tests. We did not test any
    commercially available dilutants or use dilutants we found in the
    collection area (e.g., tap water). While synthetic urine requires complete
    substitution, adulterants were mixed with the urine specimen our
    investigators provided. It is therefore important to note that since our
    investigators' urine specimens did not contain traces of drug use, we
    cannot report on whether the adulterants we used were able to mask drug
    use--only on whether the laboratories could detect the presence of the
    adulterant. We assumed that a drug user could receive a passing result as
    long as the laboratories did not detect the presence of the synthetic
    urine. It is not possible to generalize the results of our undercover
    testing to apply to all collection sites or to all drug-masking products.

    We conducted this investigation from May to September 2007 in accordance
    with standards prescribed by the President's Council on Integrity and
    Efficiency.

    Summary

    While all urine collection sites followed DOT protocols by asking our
    undercover investigators to provide identification, we successfully used
    bogus driver's licenses to gain access to all 24 sites--demonstrating that
    a drug user could send someone to take a drug test in their place using
    fake identification. In addition, 22 of the 24 selected urine collection
    sites did not adequately follow the remaining protocols we tested. For
    example, 75 percent of the 24 urine collection sites we tested failed to
    restrict access to items that could be used to adulterate or dilute the
    specimen, meaning that running water, soap, or air freshener was available
    in the bathroom during the test. Table 1 provides information about the
    high failure of selected protocols for the 24 collection sites tested.

    ^3GAO, Products to Defeat Drug Use Screening Tests Are Widely Available,
    [32]GAO-05-653T (Washington, D.C.: May 17, 2005).

    Table 1: Failure Rates for Selected DOT Protocols GAO Tested

                                                             Percentage of the 24
    Selected DOT collection protocol              collection sites that failed
    Secure the facility from all substances that                            75
    could be used to adulterate or dilute the
    specimen
    Secure all sources of water in the restroom                             67
    Ask the employee to empty his/her pockets and                           42
    display items to ensure no items are present
    that could be used to adulterate the specimen
    Check the temperature of the specimen                                   19
    Place a bluing agent in the toilet or secure                            17
    it with tape

    Source: GAO.

    We also determined that drug-masking products, such as adulterants,
    dilutants, and substitutes, were widely available on the Internet. After
    purchasing drug-masking products from Web sites, we used adulterants at
    four of the collection sites and substitute synthetic urine at another
    four sites without being caught by site collectors--demonstrating that
    these products could easily be brought into a collection site and used
    during a test. Even in one case where a collection site followed all DOT
    collection protocols regarding administration of the test, we were still
    able to substitute synthetic urine for our specimen. Every drug-masking
    product went undetected by the drug screening labs. Provided the
    adulterant we used would be able to mask drug use as advertised, a drug
    user would likely be able to use the substances we tested to obtain a
    passing result on his or her test. According to officials we interviewed
    at the Substance Abuse and Mental Health Services Administration (SAMHSA),
    companies that make drug-masking products are aware of government test
    standards and devise products that prevent laboratories from detecting
    them.

    We briefed DOT officials on the results of our work and they agreed with
    our findings. We will provide DOT with a referral letter that specifies
    the geographic areas and collection site names for those sites that we
    determined had failures in protocols.

    Background

    Six operating administrations under DOT have issued regulations requiring
    antidrug programs in the aviation, highway, railroad, mass transit,
    pipeline, and maritime industries. Antidrug programs for commercial truck
    drivers are regulated by the Federal Motor Carrier Safety Administration
    (FMCSA), which is the operating administration responsible for enforcing
    FMCSA regulations and establishing who is tested and when they are
    tested.4 FMCSA antidrug regulations require that employers of commercial
    motor carriers, including those who are owner-operators, conduct drug
    testing according to the DOT "Procedures for Transportation Workplace Drug
    Testing Programs."5 These DOT regulations mandate that motor carriers must
    conduct pre-employment, reasonable suspicion, random, and post-accident
    drug testing on their employees. While these scenarios are all different,
    DOT requires collectors and collection sites to follow uniform collection
    protocols regardless of the reason for the test. Collection sites are
    privately run facilities, where the collectors at the sites do not have to
    be certified by DOT, but must meet DOT regulations by completing the
    required training and following DOT protocols. Because collection sites
    are spread throughout the nation, it is easy for an employee in any of the
    drug testing scenarios, from pre-employment to post-accident drug testing,
    to get to a collection site within the given time frame.6 According to DOT
    regulations, collection sites must promote privacy, incorporate the
    scientific and technical guidelines of the Department of Health and Human
    Services (HHS), utilize a scientifically recognized testing method, and
    require that specimens be labeled and secured in the presence of the
    tested employee to prevent tampering. To help collection sites comply with
    these regulations, DOT's Office of Drug and Alcohol Policy and Compliance
    issued revised protocols in December 2006.7 The protocols indicate that
    the collector has a major role in the success of the DOT drug testing
    program because he or she is the one individual in the testing process
    with which all employees have direct, face-to-face contact. The protocols
    also state that the test may lose validity if the collector does not
    ensure the integrity of the specimen and collection process.

    DOT protocols have specific requirements that collection sites must meet,
    including procedures to (1) prevent unauthorized access to the urine
    collection site; (2) prevent the tested employee or anyone else from
    gaining unauthorized access to the collection materials/supplies;

    ^4These regulations apply to those who operate commercial motor vehicles in
    any state and are subject to commercial drivers' license requirements
    under 49 CFR 382, Licencia Federal de Conductor (Mexico) requirements, or
    the requirements of Canadian National Safety Code.

    ^549 CFR Part 40.

    ^6Post-accident drug tests must be conducted as soon as practicable, but
    within 32 hours of the crash, while employees required to take a random
    drug test must report immediately once he or she is notified.

    ^7Urine Specimen Collection Guidelines for the U.S. Department of
    Transportation Workplace.

    (3) ensure that the tested employee does not have access to items that
    could be used to adulterate or dilute the specimen such as soap,
    disinfectants, cleaning supplies, and water; and (4) ensure that the
    tested employee is under the supervision of a collector or appropriate
    site personnel at all times when permitted into the site.

    To document the collection of the specimen, DOT requires that urine
    collection sites correctly complete the Federal Drug Testing Custody and
    Control Form (CCF) for every collection under the DOT drug testing
    program. This form is also used to document the transfer of the specimen
    to the HHS-approved, private sector laboratories, where the urine specimen
    is sent to be tested for marijuana, cocaine, amphetamines, opiates, and
    phencydidine (PCP) as identified by HHS regulations.  It is important to
    note that the laboratories that test the specimen are separate entities
    than the urine collection sites. The collection sites must follow DOT
    protocols and their role is to collect the urine specimen, while the
    laboratories must be certified by HHS and their role is to perform the
    drug testing of the specimen. The laboratories are authorized to also
    conduct validity testing to determine if the specimen is consistent with
    normal human urine, whether adulterants or foreign substances are present,
    or if the specimen was diluted or substituted. The HHS organization,
    Substance Abuse and Mental Health Services Administration (SAMHSA),
    administers the Federal Workplace Drug Testing Program and revised the
    guidelines in 2004 to require that specimen validity tests be conducted on
    all urine specimens of federal employees due to the increase in the number
    of chemical adulterants that were marketed on the Internet and in certain
    magazines. DOT did not adopt this update in their regulations------so
    currently drug testing laboratories are only authorized, not required, to
    perform validity testing for all DOT required commercial motor carrier
    drug tests.

    As an additional quality control check, DOT requires that a Medical Review
    Officer (MRO) serve as an independent, impartial authority to verify the
    lab results. After the results are verified, the MRO, who is a licensed
    physician, informs the designated company official whether the employee
    passed or failed the drug test. The MRO may also designate test results as
    cancelled in the case of an invalid test. An invalid test results when a
    drug screening lab identifies an unidentified adulterant, substitute, or
    abnormal physical characteristic in the specimen that prevents the lab
    from obtaining a valid test result. In the case of a cancelled test, the
    MRO conducts an interview with the employee to determine if there is a
    legitimate medical reason for the result. If the MRO determines there is a
    legitimate medical reason, no further action is required.8 However, if the
    MRO determines there is no legitimate medical reason, the employee is
    required to take another drug test under direct observation--effectively
    getting another opportunity to take the test, but without the privacy
    afforded previously.9 In the case of a positive result, which is defined
    as a failed drug test, a supervisor or company official is required to
    immediately remove the employee from the job. Employees who test positive
    and continue to perform safety-sensitive functions and employers who
    permit them to do so are both subject to criminal and civil fines.

    Most Collection Sites Failed to Comply with All DOT Protocols

    In our tests of the selected 24 urine collection sites in four major
    geographic areas throughout the United States, we determined that 22 of
    the 24 sites showed varying degrees of failure in complying with the
    protocols that we tested. While all urine collection sites followed DOT
    protocols by asking our undercover investigators to provide
    identification, we successfully used bogus driver's licenses to gain
    access to all 24 sites--demonstrating that a drug user could send someone
    else to take a drug test in their place. This fact in and of itself shows
    that in 100 percent of our tests we successfully used a form of
    substitution. However, we did not count these instances as a failure of
    protocol because the collectors are not required to validate the identity
    of the employee--they are only required to ensure that an employee
    presents identification.

    Twenty-two of the 24 tested collection sites failed to comply with many of
    the remaining DOT protocols we tested. In table 2, we provide a summary of
    the results of our testing of the 16 protocols by geographic area in the
    order that we tested them. The table identifies the number of protocols
    with which each site failed to comply.

    ^8In the case of pre-employment, return-to-duty, or follow-up tests, a
    negative result is required.

    ^9A directly observed collection procedure is the same as a routine
    collection with the additional requirement that an observer physically
    watch the employee urinate into the collection container.

    Table 2: Results of Testing the 16 Protocols by Geographic Area

                                           Number of protocols failed
    Geographic area              Site 1 Site 2 Site 3 Site 4 Site 5 Site 6
    Washington, D.C.                  2      2      0      2     12      2
    Los Angeles                       8      5      6      2      2      3
    New York/Northern New Jersey      6      4      5      3      6      5
    Dallas/Fort Worth                 2      5      2      4      0      2

    Source: GAO.

    For a summary of the protocols we tested and their rationale, see figure
    1.

    Figure 1: Key Collection Protocols Tested by GAO Undercover Investigators

    Note: We selected these protocols from 49 CFR Part 40, "Procedures for
    Transportation Workplace Drug Testing Programs."

    Some of the criteria above relate to preventing the employee from having
    access to items at the collection site, such as water or cleaning
    products, which could be used to adulterate or dilute the specimen. These
    types of products might be detected by drug testing laboratories, however,
    we did not test this. We provide detail on our findings of the tested
    urine collection sites by area in the order of our testing below.

    Washington, D.C., Metropolitan Area

    In our testing of the Washington, D.C., metropolitan area we determined
    that, in five of the six sites tested, there were varying degrees of
    failure in complying with the 16 protocols. Most of the sites failed only
    two protocols, while site 3 did not fail any of the protocols and site 5
    performed poorly by failing 12 protocols--75 percent of the protocols
    tested. In the case of site 5, we determined that although this collection
    site failed to comply with most of the protocols, the drug screening lab
    identified errors and cancelled the test due to the inappropriate
    collection process. We provide additional detail below on our experiences
    at three of the Washington, D.C., metropolitan area collection sites.

               o Washington D.C., Area, Site 3: This collection site did not fail
               any of the protocols that we tested. However, our investigator
               used substitute synthetic urine he brought with him to contaminate
               the urine specimen during the test and the laboratory did not
               detect the presence of the synthetic urine.

               o Washington D.C., Area, Site 4: At this collection site, the
               investigator had access to water which could be used to dilute a
               specimen. In addition, the investigator brought in and used an
               adulterant at this site and the laboratory did not detect the
               presence of the adulterant.

               o Washington D.C., Area, Site 5: This site failed to comply with
               12 of the 16 protocols that we tested. Although it was not one of
               the protocols we tested at other facilities, one of our
               investigators exhibited a "shy bladder" at this site and could not
               provide a full urine specimen of 45 mL. The collector permitted
               our investigator to provide half of the specimen, leave the
               facility, and return approximately 1 hour later--a violation of
               DOT protocols, which state that the employee should not be allowed
               to leave the collection site and should be monitored during the
               waiting time. When completing the collection process, the
               collector used half of the specimen from the original collection
               and half from what the investigator provided later. The drug
               screening lab identified this error and cancelled the test due to
               the inappropriate collection process.

    See appendix I for a site-specific breakdown, by protocol, of the results
    of our testing in the Washington, D.C., metro area.

    Los Angeles Area

    In our testing of the Los Angeles area we determined that, of the six
    sites tested, there were varying degrees of failure in complying with the
    16 protocols--including one site that failed 8 of the 16 protocols. Other
    selected sites in the Los Angeles area failed up to 5 and 6 protocols
    while the remaining sites failed 3 protocols or less. We provide
    additional detail below on our experiences at four of the Los Angeles area
    collection sites.

               o Los Angeles, Site 1: The investigator was not instructed to wash
               his hands before providing the specimen. This could have allowed a
               tested employee to hide a drug-masking product in his hand when
               taking the test. In addition, there was no bluing agent in the
               toilet. That means a tested employee could have used the clear
               water in the toilet to dilute his or her specimen. The collector
               did not perform the split specimen correctly by only filling one
               specimen bottle. 10 The results were still valid despite the
               incorrect split specimen because the lab result was passing for
               the first specimen bottle, so according to DOT protocols a second
               bottle is not needed to validate a passing result.

               o Los Angeles, Site 3: The collector did not tell our investigator
               that the toilet should not be flushed, allowing the employee to
               potentially use the clear un-blued water in the flushed toilet to
               dilute the specimen. In addition, the collector did not instruct
               the investigator to return with the specimen as soon as possible
               after voiding--the temperature of the specimen needs to be taken
               within 4 minutes in an attempt to determine whether the specimen
               was substituted, diluted, or adulterated. Our investigator used
               synthetic urine in this drug test and the laboratory was not able
               to detect the presence of the synthetic urine.

               o Los Angeles, Site 4: The collector at this site asked our
               investigator to empty his pockets. However, he did not have to
               empty all of his pockets--this enabled our investigator to bring
               an adulterant into the collection area by hiding it in his back
               pocket. The laboratory did not detect the presence of the
               adulterant.

               o Los Angeles, Site 6: The collector failed to instruct our
               investigator to empty his pockets before providing a specimen at
               this site. In addition, our investigator had access to running
               water in the sink--this could potentially be used to dilute the
               specimen. The collector did not perform the split specimen
               correctly and only filled one specimen bottle. The results were
               still valid despite the incorrect split specimen because the lab
               result was passing for the first specimen bottle, so according to
               DOT protocols a second bottle is not needed to validate a passing
               result.

    ^10DOT regulations require a split specimen, which entails splitting the
    urine specimen into two vials. The collector pours the primary specimen of
    at least 30 mL of urine in the first vial, and then pours at least 15 mL
    in the second vial. The second vial is not tested unless there is a
    positive result and it is needed to confirm the positive result.

    See appendix I for site-specific breakdown, by protocol, of the results of
    our testing in the Los Angeles area.

    New York/Northern New Jersey Area

    In our testing of the New York/Northern New Jersey area we determined
    that, of the six sites tested, collection sites failed to comply with a
    large number of the 16 protocols--sites 1 and 5 failed to comply with six
    protocols, sites 3 and 6 failed to comply with five protocols, and sites 2
    and 4 failed to comply with four and three protocols, respectively. We
    provide additional detail below on our experiences at five of the New
    York/Northern New Jersey area collection sites, including photographs of
    the collection areas taken with mobile phone cameras.

               o New York/Northern New Jersey, Site 1: In addition to failing to
               comply with five other protocols, this collection site had an
               adulterant (bleach) located on top of the toilet (see fig. 2).

    Figure 2: Bleach Located in Collection Area in Violation of DOT Protocols

               o New York/Northern New Jersey, Site 2: The collector failed to
               instruct our investigator to empty his pockets before providing a
               specimen at this site, making it easy for our investigator to
               bring an adulterant into the collection room. Moreover, the
               collector did not watch our investigator to see whether he washed
               his hands before providing the specimen. The bathroom had liquid
               soap and liquid cleaning products available in the collection
               area. Our investigator used an adulterant he brought with him to
               contaminate the urine specimen during the test. The laboratory did
               not detect the presence of the adulterant.

               o New York/Northern New Jersey, Site 4: The collector failed to
               instruct our investigator to empty his pockets before providing a
               specimen at this site, making it easy for our investigator to
               bring synthetic urine into the collection room. In addition, the
               bathroom had water and disinfectant spray available in the
               collection area. The laboratory did not detect the presence of the
               synthetic urine.

               o New York/Northern New Jersey, Site 5: The collector did not
               supervise our investigator in the collection site. While the
               collector remained in one room, he told our investigator to use a
               bathroom located down an adjoining hallway. According to DOT
               protocols, a tested employee should be supervised at all times
               during the collection process.

               o New York/Northern New Jersey, Site 6: Our investigator was
               unsupervised at the collection site, allowing him to identify
               cleaning products outside the collection room that could be used
               as adulterants, pick up a large can of disinfectant, and bring it
               with him into the collection room. Our investigator took pictures
               of this violation using a mobile phone camera. Figure 3 shows the
               disinfectant spray and other adulterants outside the collection
               room.

    Figure 3: Adulterants Located Outside a Collection Room in Violation of
    DOT Protocols

    In figure 4, the investigator has brought the disinfectant with him into
    the collection room and placed it next to his urine specimen on the
    toilet.

    Figure 4: Adulterant Moved into Collection Room

    See appendix I for a site-specific breakdown, by protocol, of the results
    of our testing in the New York/Northern New Jersey area.

    Dallas/Fort Worth Area

    In our testing of the Dallas/Fort Worth area we determined that, in five
    of the six sites tested, there were varying degrees of failure in
    complying with the 16 protocols. Many of the sites failed 2 protocols,
    while site 2 failed 5, site 4 failed 4, and site 5 did not fail any of the
    protocols. We provide additional detail below on our experiences at five
    of the Dallas/Fort Worth area collection sites, including photographs of
    the collection areas taken with mobile phone cameras.

               o Dallas/Fort Worth, Site 2: Our investigator was able to bring an
               adulterant into the collection site and used it to adulterate his
               urine specimen. While in the collection area, the investigator
               noticed that running water was available--in violation of DOT
               protocols. See figure 5.

    Figure 5: Running Water in the Collection Room in Violation of DOT
    Protocols

    After providing his urine specimen to the collector, the investigator
    observed that the collector only filled one specimen bottle rather than
    the two required under DOT's split specimen protocols. The collector threw
    out the remaining specimen. The laboratory did not detect the presence of
    the adulterant. The results were still valid despite the incorrect split
    specimen because the lab result was passing on the first specimen bottle,
    so according to DOT protocols a second bottle is not needed to validate a
    passing result.

               o Dallas/Fort Worth, Site 4: The collector failed to instruct our
               investigator to empty his pockets before providing a specimen at
               this site, making it easy for our investigator to bring synthetic
               urine into the collection room. Once he was in the collection
               room, the collector instructed our investigator to leave the door
               completely open while providing the specimen. The collector waited
               outside the collection room and did not directly observe the
               collection; nevertheless, our investigator was able to pour
               synthetic urine into the provided specimen cup. The laboratory did
               not detect the synthetic urine.

               o Dallas/Fort Worth, Site 5: This collection site performed well
               in meeting all of the DOT protocols. This site had a 15-item
               checklist outlining DOT protocols hanging on the wall. Our
               investigator observed the technician using the checklist while
               conducting the collection of the urine specimen.

               o Dallas/Fort Worth, Site 6: This collection site allowed the
               employee access to water by not securing the toilet lid in the
               collection room--leaving the employee an opportunity to use the
               clear un-blued water to potentially dilute the specimen. Also in
               the collection room was an automatic spray disinfectant on the
               wall. A tested employee could have used this spray to dilute or
               adulterate his or her specimen.

    See appendix I for a site-specific breakdown, by protocol, of the results
    of our testing in the New York/Northern New Jersey area.

    Commercially Available Products Can Defeat Drug Tests at Selected Sites

    We determined that drug-masking products were widely available for
    purchase over the Internet and used this method to purchase adulterants
    and synthetic urine for our tests. As discussed above, we submitted
    specimens containing adulterants at four of the collection sites and at
    another four sites we used synthetic urine without being caught by site
    collectors, demonstrating that these products could easily be brought in
    and used during a test. In every case that investigators used adulterants
    or substitutes during the drug test, the drug-masking products went
    undetected during lab testing, lab validation, and MRO review of the labs'
    results. We also determined that publicly available regulations provide
    details on how drug testing labs test and validate urine specimens.
    Companies that sell drug-masking products can access this information and
    update their products to prevent them from being detected by the
    laboratory.

    Products to Defeat Drug Tests Are Widely Available

    In performing Internet searches, we found drug-masking products that the
    public can easily obtain and that are marketed as products that can be
    used to pass urine drug tests. A simple Internet search using a phrase
    such as "pass drug test" resulted in over 2 million Web site hits. We
    determined that these types of Web sites contained various adulterants and
    urine substitutes available for purchase, including accessories that would
    allow an employee to conceal the product on their body when taking a test.
    We used these types of Web sites to purchase drug-masking products for our
    testing of selected urine collection sites. SAMHSA is aware of these
    products and revised the Mandatory Guidelines for Federal Workplace Drug
    Testing Programs in 2004 to require that specimen validity tests be
    conducted on all urine specimens, noting that there was a recent increase
    in the number of chemical adulterants that are marketed on the Internet
    and in certain magazines. DOT did not adopt this update in their
    regulations------so currently drug testing laboratories are only
    authorized, not required, to perform validity testing for all DOT required
    commercial motor carrier drug tests. According to SAMHSA, approximately
    400 different products are available to defeat urine drug tests.

    Adulterants and Synthetic Urine Used at 8 of 24 Collection Sites

    We were able to easily bring drug-masking products into a collection room
    at every one of the eight collection sites we tested with these products.
    Even in cases where the collector followed DOT protocol and asked our
    investigator to empty his pockets, our investigators simply hid these
    products in their pockets and elsewhere in their clothing. At one
    Dallas/Fort Worth collection site discussed above, the collector
    instructed our investigator to leave the bathroom door completely open
    when providing the specimen. The collector waited outside the bathroom;
    nevertheless, the investigator was able to pour synthetic urine into the
    specimen cup undetected. Investigators determined that there is
    information on the Internet about concealing drug-masking products. For
    example, one Web site noted that "although most testing sites will require
    you to remove items from your pockets, it is still possible to sneak in
    another specimen." Even a knowledgeable government official with SAMHSA
    stated that, because collection protocols do not allow collectors to
    directly observe urination unless they are suspicious, the opportunity to
    substitute or adulterate a urine specimen exists.

    Adulterants and Substitutes Were Not Detected by Laboratories

    SAMHSA officials stated that validity tests are intended to produce
    accurate, reliable, and correctly interpreted test results and to decrease
    or eliminate opportunities to defeat drug tests. We found that none of the
    adulterants or synthetic urine we used were identified by the
    laboratories, however, we cannot confirm if the laboratories performed
    validity testing because under DOT regulations they are only authorized,
    not required, to do so. SAMHSA is required to provide information to
    laboratories on how to test the validity of the urine specimen and
    publicly provide detailed information on lab testing procedures.11
    According to a SAMHSA official with whom we spoke, companies that market
    masking substances periodically offer new formulations of their products
    to avoid detection. In fact, one Web site we located appeared to verify
    this claim by advertising that its product was "continuously updated and
    adjusted to keep up with changing technologies." Despite their
    sophistication and ease of use, there is no regulation prohibiting the
    sale of these products. Under 21 U.S.C. Section 863 it may be illegal to
    sell drug-masking products if the products are determined to be "drug
    paraphernalia." However, we have not found any reported federal cases in
    which an individual has been prosecuted for selling drug-masking products
    under this statute.

    ^11Under P.L. 100-71, Section 503 (July 11, 1987).

    Corrective Action Briefing

    We briefed DOT on the results of our investigation on October 1, 2007. DOT
    officials agreed with our findings and indicated that they were not
    surprised by the results of our work, stating that they have performed
    similar tests themselves in prior years with similar results. We agreed
    with DOT that we would provide a referral letter that specifies the areas
    and collection site names for those sites that we determined had failures
    in protocols. DOT added that it has already taken steps to improve the
    collection facilities' performance in the drug testing program. For
    example, officials said they have developed posters with 10 key DOT
    protocols to be distributed at urine collection sites. These posters are
    intended to help collectors follow the appropriate protocols while
    conducting drug tests under the DOT drug screening program.12 DOT
    officials also stated that the Real ID Act could close the vulnerability
    we identified of using fake drivers' licenses to take the drug tests, but
    that, because implementation of this act is years away, there should be an
    interim solution.13 Finally, regarding drug-masking products, DOT
    officials stated that they have continually supported legislation to ban
    the sale and marketing of drug-masking products.

    Conclusion

    Our work shows that a drug user could easily pass a DOT drug test and
    continue to work in his or her safety-sensitive commercial transportation
    job--driving children to school or transporting hazardous materials, for
    example. To fully address the vulnerabilities we identified, improvements
    will need to be made in both the design of the entire process and the
    ability of collection site employees to adhere to current protocols. In
    ongoing work, expected to be complete in May 2008, GAO is examining
    options to deal with these and related drug testing issues.14

    ^1249 CFR Part 40.

    ^13Real ID Act of 2005, P.L. No. 109-13, div. B (May 11, 2005).

    ^14GAO, Preliminary Information on Challenges to Ensure the Integrity of
    Drug Testing Programs, [33]GAO-08-220T (Washington, D.C.: Nov. 1, 2007)

    Mr. Chairman and Members of the Subcommittee, this concludes my statement.
    I would be pleased to answer any questions that you may have at this time.

    Contacts and Acknowledgments

    For further information about this testimony, please contact Gregory D.
    Kutz at (202) 512-6722 or kutzg@gao.gov. Contact points for our Offices of
    Congressional Relations and Public Affairs may be found on the last page
    of this testimony. In addition to the individual named above, the
    individuals who made major contributions to this testimony were John Ryan
    Assistant, Director; Verginie Amirkhanian; Shafee Carnegie; Paul
    Desaulniers; Matthew Harris; Jason Kelly; Jeffrey McDermott; and Andrew
    McIntosh.

    Appendix I: Results of Undercover Testing in Four Metropolitan Areas of
    the United States

    The following four tables present a site-specific breakdown, by protocol,
    of our undercover test results. We provide these tables in the order of
    our testing. Our investigators used a data collection instrument to track
    the compliance of collectors at each site. An "unknown" result means that
    investigators could not determine whether the collection site failed to
    comply with the particular protocol because it was not observed.

    Washington, D.C., Metropolitan Area

    Table 3 provides our findings for the Washington, D.C., metropolitan area,
    which is the first area where we tested the 16 key collection protocols.

    Table 3: Washington, D.C., Undercover Test Results

    Protocol                       Site 1  Site 2 Site 3 Site 4 Site 5  Site 6
    Did the collector require the
    employee to provide
    appropriate identification?
    Did the collector ask the                                     Fail
    employee to empty his/her
    pockets and display items to
    ensure no items are present
    that could be used to defeat
    the test?
    Did the collector instruct                                    Fail
    the employee to wash his/her
    hands under the collector's
    supervision?
    Did the collector direct the
    employee to provide a
    specimen of at least 45 mL?
    Did the collector direct the                                  Fail
    employee to not flush the
    toilet?
    Did the collector direct the                                  Fail
    employee to return with the
    specimen as soon as possible
    after voiding?
    Were all sources of water in     Fail    Fail          Fail   Fail    Fail
    the restroom secured?
    Was bluing agent placed in                                    Fail
    the toilet or was it secured
    with tape?
    Did the collector check the
    temperature of the specimen?  Unknown Unknown                 Fail Unknown
    Was the employee allowed to
    place the tamper-evident
    seals from the CCF onto the
    specimen bottles?
    Did the collector seal and
    date the specimen?                                            Fail    Fail
    Did the collector have the
    employee initial the specimen
    bottle seals after placing
    them on the bottles?                                          Fail
    Did unauthorized people have
    access to the collection
    site?
    Did the employee have access
    to the collection materials
    or supplies?                                                  Fail
    Did the employee have access
    to items that could be used
    to adulterate or dilute the
    specimen?                        Fail    Fail          Fail   Fail
    Was the employee under the
    supervision of the collector
    or appropriate site personnel
    at all times?                                                 Fail
    Number of protocols failed          2       2      0      2     12       2

    Source: GAO.

    Los Angeles Metropolitan Area

    Table 4 provides our findings for the Los Angeles metropolitan area, which
    is the second area where we tested the 16 key collection protocols.

    Table 4: Los Angeles Undercover Test Results

    Requirement                      Site 1 Site 2 Site 3 Site 4 Site 5 Site 6
    Did the collector require the
    employee to provide appropriate
    identification?
    Did the collector ask the          Fail                               Fail
    employee to empty his/her
    pockets and display items to
    ensure no items are present that
    could be used to defeat the
    test?
    Did the collector instruct the     Fail   Fail   Fail   Fail   Fail
    employee to wash his/her hands
    under the collector's
    supervision?
    Did the collector direct the
    employee to provide a specimen
    of at least 45 mL?
    Did the collector direct the       Fail          Fail
    employee to not flush the
    toilet?
    Did the collector direct the       Fail   Fail   Fail
    employee to return with the
    specimen as soon as possible
    after voiding?
    Were all sources of water in the   Fail   Fail                        Fail
    restroom secured?
    Was bluing agent placed in the     Fail   Fail   Fail
    toilet or was it secured with
    tape?
    Did the collector check the                                    Fail
    temperature of the specimen?
    Was the employee allowed to
    place the tamper-evident seals
    from the CCF onto the specimen
    bottles?
    Did the collector seal and date
    the specimen?
    Did the collector have the         Fail          Fail   Fail
    employee initial the specimen
    bottle seals after placing them
    on the bottles?
    Did unauthorized people have
    access to the collection site?
    Did the employee have access to
    the collection materials or
    supplies?
    Did the employee have access to    Fail   Fail   Fail                 Fail
    items that could be used to
    adulterate or dilute the
    specimen?
    Was the employee under the
    supervision of the collector or
    appropriate site personnel at
    all times?
    Number of protocols failed            8      5      6      2      2      3

    Source: GAO.

    New York/Northern New Jersey Metropolitan Area

    Table 5 provides our findings for the New York/Northern New Jersey
    metropolitan area, which is the third area where we tested the 16 key
    collection protocols.

    Table 5: New York/Northern New Jersey Undercover Test Results

    Requirement                    Site 1 Site 2  Site 3 Site 4  Site 5 Site 6
    Did the collector require the
    employee to provide
    appropriate identification?
    Did the collector ask the        Fail   Fail    Fail   Fail    Fail   Fail
    employee to empty his/her
    pockets and display items to
    ensure no items are present
    that could be used to defeat
    the test?
    Did the collector instruct       Fail   Fail    Fail
    the employee to wash his/her
    hands under the collector's
    supervision?
    Did the collector direct the                    Fail
    employee to provide a
    specimen of at least 45 mL?
    Did the collector direct the
    employee to not flush the
    toilet?
    Did the collector direct the                    Fail           Fail   Fail
    employee to return with the
    specimen as soon as possible
    after voiding?
    Were all sources of water in     Fail   Fail           Fail
    the restroom secured?
    Was bluing agent placed in
    the toilet or was it secured
    with tape?
    Did the collector check the      Fail        Unknown        Unknown
    temperature of the specimen?
    Was the employee allowed to   Unknown
    place the tamper-evident
    seals from the CCF onto the
    specimen bottles?
    Did the collector seal and
    date the specimen?
    Did the collector have the                      Fail
    employee initial the specimen
    bottle seals after placing
    them on the bottles?
    Did unauthorized people have                                   Fail
    access to the collection
    site?
    Did the employee have access     Fail                          Fail   Fail
    to the collection materials
    or supplies?
    Did the employee have access     Fail   Fail           Fail    Fail   Fail
    to items that could be used
    to adulterate or dilute the
    specimen?
    Was the employee under the                                     Fail   Fail
    supervision of the collector
    or appropriate site personnel
    at all times?
    Number of protocols failed          6      4       5      3       6      5

    Source: GAO.

    Dallas/Fort Worth Metropolitan Area Undercover Testing

    Table 6 provides our findings for the Dallas/Fort Worth metropolitan area,
    which is the fourth area where we tested the 16 key collection protocols.

    Table 6: Dallas/Fort Worth Undercover Test Results

    Requirement                    Site 1  Site 2 Site 3  Site 4 Site 5 Site 6
    Did the collector require the
    employee to provide
    appropriate identification?
    Did the collector ask the                               Fail
    employee to empty his/her
    pockets and display items to
    ensure no items are present
    that could be used to defeat
    the test?
    Did the collector instruct               Fail           Fail
    the employee to wash his/her
    hands under the collector's
    supervision?
    Did the collector direct the             Fail
    employee to provide a
    specimen of at least 45 mL?
    Did the collector direct the
    employee to not flush the
    toilet?
    Did the collector direct the             Fail
    employee to return with the
    specimen as soon as possible
    after voiding?
    Were all sources of water in     Fail    Fail   Fail    Fail          Fail
    the restroom secured?
    Was bluing agent placed in
    the toilet or was it secured
    with tape?
    Did the collector check the   Unknown Unknown        Unknown
    temperature of the specimen?
    Was the employee allowed to
    place the tamper-evident
    seals from the CCF onto the
    specimen bottles?
    Did the collector seal and
    date the specimen?
    Did the collector have the
    employee initial the specimen
    bottle seals after placing
    them on the bottles?
    Did unauthorized people have
    access to the collection
    site?
    Did the employee have access
    to the collection materials
    or supplies?
    Did the employee have access     Fail    Fail   Fail    Fail          Fail
    to items that could be used
    to adulterate or dilute the
    specimen?
    Was the employee under the
    supervision of the collector
    or appropriate site personnel
    at all times?
    Number of protocols failed          2       5      2       4      0      2

    Source: GAO.

    (192248)

    This is a work of the U.S. government and is not subject to copyright
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    its entirety without further permission from GAO. However, because this
    work may contain copyrighted images or other material, permission from the
    copyright holder may be necessary if you wish to reproduce this material
    separately.

    To view the full product, including the scope
    and methodology, click on [34]GAO-08-225T .

    For more information, contact Gregory Kutz at (202) 512-6722 or
    kutzg@gao.gov.

    Highlights of [35]GAO-08-225T , a testimony before the Subcommittee on
    Highways and Transit, Committee on Transportation and Infrastructure,
    House of Representatives

    November 1, 2007

    DRUG TESTING

    Undercover Tests Reveal Significant Vulnerabilities in DOT's Drug Testing
    Program

    To help prevent accidents resulting from drug use by individuals in
    safety-sensitive positions, the Department of Transportation (DOT)
    requires motor carriers to conduct drug testing of their employees. These
    drug tests involve collecting a urine specimen from employees. To ensure
    the integrity of the urine specimen and the collection process, DOT
    regulations provide numerous protocols that outline collection procedures
    and identify controls to prevent employees from defeating a drug test.

    Recent media accounts indicate that some sites performing DOT drug test
    collections may not be adhering to the collection protocols. Moreover,
    given the different techniques a drug user may employ in an attempt to
    defeat a drug test, it is possible that a commercial truck driver could
    defeat a drug test by diluting, substituting, or adulterating a urine
    specimen in order to obtain a passing result. GAO was asked to perform an
    undercover operation to determine whether (1) urine collectors followed
    DOT protocols at selected collection sites and (2) commercially available
    products could be used to defeat drug tests.

    To perform this undercover operation, GAO created two fictitious trucking
    companies and produced bogus driver's licenses. GAO investigators then
    posed as truck drivers to test 24 collection sites throughout the United
    States.

    GAO briefed DOT officials on its results and they agreed with the
    findings.

    DOT's drug testing program is vulnerable to manipulation by drug users,
    especially given the wide availability of products designed to defeat drug
    tests. While all urine collection sites followed DOT protocols by asking
    GAO undercover investigators to provide identification, investigators
    successfully used bogus driver's licenses to gain access to all 24
    sites--demonstrating that a drug user could send someone to take a drug
    test in their place using fake identification. In addition, 22 of the 24
    selected urine collection sites did not adequately follow the remaining
    protocols GAO tested. For example, 75 percent of the urine collection
    sites GAO tested failed to restrict access to items that could be used to
    adulterate or dilute the specimen, meaning that running water, soap, or
    air freshener was available in the bathroom during the test. The table
    below provides information about the high failure of selected protocols
    for the 24 collection sites tested.

    Failure Rates for Selected DOT Protocols GAO Tested

    Selected DOT urine specimen collection                Percentage of the 24
    protocol                                      collection sites that failed
    Secure the facility from all substances that
    could be used to adulterate or dilute the
    specimen                                                                75
    Secure all sources of water in the restroom                             67
    Ask the employee to empty his/her pockets and
    display items to ensure no items are present
    that could be used to adulterate the specimen                           42
    Check the temperature of the specimen                                   19
    Place a bluing agent in the toilet or secure
    it with tape                                                            17

    Source: GAO.

    GAO also found that drug masking products such as adulterants, dilutants,
    and substitutes were widely available on the Internet. After purchasing
    drug masking products from Web sites, GAO investigators used adulterants
    at four of the collection sites and substitute synthetic urine at another
    four sites without being caught by site collectors--demonstrating that
    these products could easily be brought into a collection site and used
    during a test. Even in one case where a collection site followed all DOT
    collection protocols regarding administration of the test, investigators
    were still able to substitute synthetic urine for their sample. Every drug
    masking product went undetected by the drug screening labs. Provided the
    adulterant GAO used would be able to mask drug use as advertised, a drug
    user would likely be able to use the substances GAO tested to obtain a
    passing result on his or her test. According to officials GAO interviewed
    at the Substance Abuse and Mental Health Services Administration (SAMHSA),
    companies that make drug-masking products are aware of government test
    standards and devise products that prevent laboratories from detecting
    them. SAMHSA is required to provide information to laboratories on how to
    test the validity of the urine specimens, publicly providing detailed
    information on lab testing procedures on its Web site.

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    References

    Visible links
      32. http://www.gao.gov/cgi-bin/getrpt?GAO-05-653T
      33. http://www.gao.gov/cgi-bin/getrpt?GAO-08-220T
      34. http://www.gao.gov/cgi-bin/getrpt?GAO-08-225T
      35. http://www.gao.gov/cgi-bin/getrpt?GAO-08-225T
      36. http://www.gao.gov/
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