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PBSA Journal PAGE 18 JULY/AUG 2021 Except where otherwise indicated, articles are copyright © by PBSA 2021. All rights reserved. Continued on page 19 In drug testing processes, the Chain of Custody (COC) is a paper trail that follows the test sample from the collection stage to the delivery of the drug test results. Chain of Custody in Drug Testing By Ben Chan M any workplaces conduct drug tests to maintain a safe environment, while other companies conduct these tests for regulatory compliance. Some common scenarios for workplace drug testing include pre-employment, post- accident, or random and reasonable suspicion testing. In drug testing processes, the Chain of Custody (COC) is a paper trail that follows the test sample from the collection stage to the delivery of the drug test results. The COC tracks and documents each step in the drug testing process including the collection, control, transfer, and analysis of the drug sample. The COC has a standardized format, which was produced from the collaboration between the government and drug testing industry representatives (DATIA/SAPAA), which form a governing oversight group. From the point of sample collection, the COC guarantees that each sample is handled meticulously and only by the necessary parties. The COC mandates that all individuals who come into contact with the specimen are recorded by the provision of their signatures. Additionally, the COC requires the documenting of all the critical events throughout the drug testing process. The distinct and individualised labeling of the specimen allows for a clear and unique identification of the test sample while the use of a tamper-evident seal guarantees the security of the specimen throughout the test process. Processes Involved in the Chain of Custody The processes of the COC are outlined as follows: Step One: The Chain of Custody begins with the collector. The collector provides the collection container to the donor and instructs the donor to provide a specimen. During the collection process, the collector will observe the donor and is obligated to record any behaviour that is deemed suspicious. Step Two: The collector will check and record the temperature of the specimen within 4 minutes of receiving it from the donor. The collector will also visually inspect the specimen and document any unusual findings. Step Three: The donor will witness the collector transferring the specimen from the collection container into the specimen bottle. The collector will then affix the unique label and tamper-proof seal on the specimen bottle and the donor will provide his or her initials on the specimen bottle. Step Four: The collector will then complete the COC with the required information, prepare the specimen package for transfer, and will distribute the remaining copies of the COC as required. The COC would then be produced fivefold, with a copy going to each of the stakeholders who gain custody of the sample along with its paper trail throughout the drug testing process. Each of the five copies are intended for the following entities: Test Facility, Medical Review Officer, Collector, Employer and Donor. These 5 entities may be required to fill out specific sections on the COC and ensure that the information they provide is clear, concise, and complete. This is an important step for each of the parties involved as the declaration of incorrect or incomplete information could cause unwanted interruptions to the test processes and could jeopardise the integrity of the result, thereby having to reject the sample and restart the entire drug testing procedure. Throughout the drug testing process critical information will be added to the COC to allow for tracking and cross- checking, again helping to ensure that the integrity of the sample remains. In the event of a break from protocol or when an inaccuracy is identified, it would then be possible to pinpoint at which stage of the process this occurred and the parties involved. This also helps to ensure a high level of accountability. There are strict protocols to follow such as ensuring that the Specimen Identification Number entered on the form matches that of the number on the specimen bottle. This is one of the roles of the collector, to ensure that Specimen Identification Numbers are the same. If any discrepancies are found, the test facility or the laboratory would be required to declare the specimen Rejected for Testing. Another instance in which the specimen would not be admissible for testing is if the seal is discovered to be broken or mismatched before the administration of the test.

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