Positive identification may include:
(1) a photo identification card issued by a Federal, state or local government (driver's license, passport, etc.)
(2) a photo identification card issued by the employer
(3) positive identification by the employer or employer representative
(4) any identification allowed by the government agency requiring drug or alcohol testing
Insufficient identification includes:
(1) identification by a co-worker or another safety-sensitive employee
(2) single non-photo identification (social security card, credit card, union card, etc)
(3) faxed or photocopied identification document
If a donor comes without positive identification, then the designated employer representative should be contacted. Collection should not proceed until positive identification has been established.
If the donor comes without positive identification and is an owner/operator or self-employed then:
(1) Ask for 2 pieces of identification with the donor's signature.
(2) The collection is performed.
(3) After the donor signs the certification statement on the chain of custody form the signature is compared with the two forms of identification.
(4) If the 3 forms of signature match then the specimen is submitted. A remark is made "Signature identification confirmed."
(5) If the 3 forms of signature are discrepant, then a remark is made "Signature identification unconfirmed." The collection is discontinued and the agency contacted.
If the donor is unable to provide a photo identification or two pieces of identification with signature and is an owner/operator or self-employed, then SAMHSA says the collection may proceed provided the collector can provide sufficient information in the "Remark" section for the MRO and agency to determine the validity of the specimen and the collection process. Alternatives may be to ask the person to return with proper identification or to take a photograph of the donor.
