Frequently we receive calls asking for information and pricing for our DOT drug and alcohol refresher training. In many cases it is clear that the individuals making the request want a trimmed down course that they expect will be shorter and less thorough than the regular Collector and BAT courses. Is it possible to have a “trimmed down” refresher course that meets DOT’s minimum refresher training requirements?
Refresher Training Requirements
49 CFR Part 40 regulations outline refresher training requirements for both drug and alcohol testing. Paragraph 40.33 of the federal regulations specifies refresher training requirements for Specimen Collectors while paragraph 40.213 covers requirements for Breath Alcohol and Screening Test Technicians. Both sections note that refresher training must occur no less frequently than every 5 years from the date you completed your initial training. Both sections also stipulate that refresher training meet the requirements set forth under “qualification training” and “proficiency demonstration” paragraphs (also identified as paragraphs (b) and (c) in both sections). But what does qualification training and proficiency demonstration cover for Specimen Collectors and BATs?
Specimen Collector Refresher Training
The “qualifications training” referenced above refers to the initial training that a collector must receive. The regulations state that Specimen Collectors must be trained on the steps to completing a collection, proper completion and transmitting of the CCF, problem collections, fatal flaws, correctable flaws and how to correct problems in a collection. Students must also be trained on the collector’s responsibility for maintaining the integrity of the collection process, donor privacy and specimen integrity and security.
“Proficiency demonstration” also refers to the initial collector training: the requirement for the five consecutive and error-free mock collections, which are specifically identified in sub-paragraph (c) (1).
In short, refresher training covers the same material as initial training, and is not any different than initial training.
BAT Refresher Training
A first reading of the regulations suggests that the requirements for BAT refresher training are similar to collector refresher training – the regulations state that refresher training must meet the same regulatory requirements as initial BAT training that includes qualification training and proficiency training. The wrinkle is that the regulations state that “Qualification training” must be in accordance with the DOT Model Curriculum course. In addition to spelling out the seven required topics, the Model Curriculum also spells out the amount of time each topic must take, for both initial training and refresher training.
For example, the Model Curriculum states that initial qualification training covering the topic “conducting a screening test” should take 90 minutes to complete. However, for refresher training that same topic may be covered in 30 minutes. “Preparing for testing” should take 50 minutes for initial training, but may only take 30 minutes when covered for refresher training. Although the DOT identifies duration differences between initial and refresher training, it doesn’t tell you what information may be omitted to reduce that time.
Why We Just Do Training
Our initial training courses and refresher courses for Collectors and for BATs are one and the same; we don’t offer a shorter “refresher” course for collector or for BATs. We don’t ever make the assumption that a student received all the required information the first time or even retained that information after 5 years. Five years is enough time to forget a thing or two or even develop bad habits. On many occasions we have heard trainees who are re-certifying as BAT or Collector, especially if taking our courses for the first time, remark about things they learn in our course that they didn’t learn the in their initial course. Refresher training should be designed and administered to keep trainees sharp and in command of their skills. That is our aim as trainers to begin with, and it stands to reason that students returning for refresher training receive the same robust, high quality training program as students receive at their initial training.