Interpretation Response #PI-95-019
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
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Office of Drug Enforcement and Program Compliance
49 CFR Part 40 Interpretation
Question: May a laboratory, receiving a DOT urine specimen collected using the splitsample method of collection, redesignate the specimen bottles in cases where the collector has obviously mislabeled the bottles?
Response: Section 40.25(f)(B) states, in part, that the collector "...pours the urine into two specimen bottles. Thirty (30) ml shall be poured into one bottle, to be used as the primary specimen. At least 15 ml shall be poured into the other bottle, to be used as the split specimen."
In the situation where the collector has labeled the smaller-volumed bottle as the primary specimen (i.e., "A") and the larger-volumed bottle as the split specimen (i.e., "B"), the DOT would allow the (primary) laboratory receiving the specimens to redesignate the bottles. The bottles must be redesignated prior to the opening of either bottle. On the appropriate bottle, the laboratory shall mark through the "A" and write "B," then initial and date the change. A corresponding change shall be made to the other bottle by marking through the "B" and writing "A," and initialing and dating the change. A notation shall be made on the original chain of custody (Copy 1) and on the split-specimen copy (Copy 3). Additional corrective action should take place, whereby the collector is notified of the error to prevent its being repeated in future collections.