The use of a Driver's license is NOT required or mandated under 49 CFR 655, only 382. For FTA & other modes it remains 100% the employer's choice.
So, why does FDTSI still encourage the use of a Driver's License for Donor identification?:
Title 49 CFR Part 40.61(c) requires the sample Collector/BAT to proper identify each Donor, in one of three ways:
- Valid Driver's License, or
- Employer issued Picture Identification, with the employee's full name and full Employee ID Number, or
- D.E.R., face to face, verification of each Employee's name and employee's full ID Number, before starting a collection.
OK, now we know there are a few options for the employer to choose from, when it comes to properly identifying your employee before testing.
Let's explore the employer's options.......
EMPLOYER ISSUED Identification/Employee ID Numbers:
This only works if each employee always has their employee ID in their possession. If Employee ID Cards are issued by the Employer, the ID Card must have a clear COLOR photo of the Driver, the ID must list the Driver's Full Employee Identification Number and the Driver's FULL LEGAL NAME. We all know, many employees don't always carry their employee ID on their person, or will make excuses about losing it, or delay the collection process by stating they left it in their car (this is a come tactic giving the Donor to obtain a clean urine and/or obtain adulterants from their glovebox). Employee ID Numbers are great, but many Drivers simply don't readily carry them, and ID cards can easily be changes or tampered with to reflect a different person, other than the driver selected (Cut & Paste Pictures and/or name). NOT Very secure.
D.E.R. VERIFICATION OF IDENTITY:
This is obviously a pain in the rear! The D.E.R. would be required to physically stand in front of the Donor, face-to-face, and tell the Collector, on each and every Breath and Urine Drug Test to verify the Donor's identity. Pictures, Zoom or mass identification is not acceptable, it must be on each, single collection event. Can you imagine, standing around with our Collector to identify each Donor, one by one, just before the Collector accepts the Donor for testing? What a waste of value time and resources!
DRIVER'S LICENSE Identification:
The use of the Donor's Driver's license for verifying the Donor's identification is the easiest and most preferred method. Let us explain why....
- Title 49 CFR Part 40.61(c) allows employers to use the Driver's License as a preferred form of identifying the Donor, prior to testing.
- Unlike Employee ID Cards, a Driver's License is not easily altered or fraudulently reproduced.
- A Driver's license is an easy way for the Collector to verify the identity of the Donor presented (Picture comparison, the Donor's "legal name" & Date of Birth).
- A Driver's License is considered "Public Record" and holds no privacy protections, unlike the use of Social Security Numbers (FCRA).
- Using the Driver's License Number as the "Donor's ID Number" helps the Collector confirm he is testing the Correct person, by comparing the Driver's License name & Driver's License number to the written Random Test List.
- Best of all? DOT, FTA and State Law REQUIRES all Driver's to possess and carry their state issued Driver's License at ALL TIMES! (12951CVC). So, you will never have to accept the excuse or adulteration/substitution tactic that Donor's ploy... "I have it in my car".
OUR RECOMMENDATION:
The employer should require all employees to carry their Drivers License on their person at all times, or while on company property or while operating any Company controlled vehicle. Furthermore, require all Employees to present their Driver's license upon demand of management or Collection Site personnel.
We hope this helps explain why the use of your Employees Driver's License is the best method to identify your Donors.
