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 [email protected]. 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)

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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
[email protected].

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.

GAO's Mission

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References

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  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
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