Department of Transportation’s New Chain of Custody Form (CCF)

Posted: September 01, 2021

The Department of Transportation (DOT) has updated its Custody and Control Form, which is required as part of the DOT drug testing program. Effective August 30, 2021, the new Chain of Custody Form (CCF) must be used for all DOT/Federal testing. If an old Federal CCF form is used after August 30, 2021, a memorandum for record (MFR), or an affidavit will be required by laboratories before DOT urine specimens are tested, which will result in delays, frustration, and cancelled tests. What does this mean for our clients? We have compiled a few FAQs to help our clients navigate this situation. How will I know the difference between the old CCF and the revised CCF?  In addition to the changes regarding oral fluids, the revised CCF also includes the following changes so look for these in the revised CCF:

• Copies 1-5, Step 1:  Added “Commercial Driver License (CDL) State and No.” to donor identification (FMCSA only)
• Copies 1-5, Step 1:  Added “Other” (e-mail) to Collector Contact Info
• Copy 1, Step 5a:  Removed analyte names and checkboxes; repositioned results and checkboxes; and added a line for the certifying scientist to record the positive analyte(s) and concentration(s) if a positive result is recorded
• Copies 2-5, Step 5:  Added a line for the donor e-mail address

When can I begin using the revised CCF? 

• DOT-regulated employers and service agents (Info Cubic, collectors, laboratories, Medical Review Officers (MRO) are authorized to use the revised CCF beginning September 1, 2020).
• To avoid confusion regarding whether oral fluid testing is authorized in the DOT program, and to allow existing supplies of old CCFs to be depleted, the recommendation as a best practice that laboratories not mail any of the revised CCFs to DOT-regulated clients or their service agents until after June 1, 2021 (or until supplies of the old CCFs have been depleted).

Can collection sites still use the old CCF after September 1, 2020? 

• When using the old CCF between September 1, 2020, and August 30, 2021, a memorandum for the record (MFR) is not required.  
• If the old CCF is used after August 30, 2021, they must complete a MFR per 49 CFR § 40.205(b)(2). 
• Beginning September 1, 2020, the collection sites can use the revised CCF.

If you would like to read more information on this topic, click here or scroll down to Federal Drug Testing Custody and Control Form section. As always, feel free to give us a call at (877) 360-4636 for help with this or other compliance-related issues.