On August 17, 2020, the Office of Management and Budget (OMB) approved a revised Federal Drug Testing Custody and Control Form (CCF). In addition, OMB authorized the use of the old form through August 29, 2021.

As of August 30, 2021, DOT-regulated employers and their service agents [collectors, laboratories, Medical Review Officers] must use the ‘revised CCF’.

Changes to the Federal Drug Testing Custody and Control Form (CCF)

The new form has two noteworthy changes. One of the updates on the new CCF is the addition of the Commercial Driver’s License (CDL) state and number. This resides in Step 1C., along with donor Social Security Number (SSN) and employee I.D.

For collectors, the inclusion of the CDL number and state of issuance here will greatly assist medical review officers. The main goal of this is to make it easier to report drug and alcohol violations in the Drug & Alcohol Clearinghouse (DACH).

The agency also changed to accommodate the future use of oral fluid (saliva) specimens for DOT testing. The current drug testing program does not allow for oral fluid drug testing. Currently, all DOT drug tests are urine-based. Many, however, are expecting approval of oral fluid testing sometime next year.

Implementation of Updated Federal Custody and Control Form (CCF)

Beginning September 1, 2020, you may start using the revised CCFs. After August 30, 2021, the use of the revised CCF will be required. The agency recommends that laboratories do not mail the new CCFs to DOT-regulated clients until June 2021. This will give employers a chance to deplete their current CCF stock. Companies are strongly encouraged to familiarize themselves with the new CCFs before September 1, 2021.

What if I used an 'old' Federal Custody and Control Form (CCF)?

If, as a collector, laboratory, Medical Review Officer (MRO), employer, or other person implementing these drug testing regulations, you become aware of the use of a non-Federal form or an expired Federal form, you must provide a signed statement (i.e., a memorandum for the record or MFR). It must state that the incorrect form contains all the information needed for a valid DOT drug test, and that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control. The MFR statement must also list the steps you have taken to prevent future use of non-Federal forms or expired Federal forms for DOT tests.

Paper is the past - go green with eCCF!

Electronic Custody and Control forms (eCCF) for Federal drug testing programs is available today from TCS USA at no additional cost. Don’t hassle with another paper form expiring when eCCF is always a seamless and paperless transition.

Benefits of adopting eCCF:

• Send drug test authorization forms by email to donors

• Less storage of unused paper forms

• Decrease possibility of manual form fill errors and better legibility

• Consistent and predictable experience with this digital solution

Resources

• USDOT Revised Federal Drug Testing Custody and Control Form (CCF)

• USDOT Instructions for Completing the New Federal Drug Testing Custody and Control Form (CCF)

• Quest Diagnostics Memorandum for the Record (MFR) Form