DOT Guidance on the Revised Federal Drug Testing Custody and Control Form

This guidance document discusses changes to the revised Federal Drug Testing Custody and Control Form (CCF), which was approved by the Office of Management and Budget (OMB) on August 17, 2020.  The revised CCF can be viewed here.

How will I know the difference between the old CCF and the revised CCF?

The old CCF is the one that has been used under the DOT-regulated program since 2017.

Most of the changes adopted in the revised CCF were made to accommodate the use of oral fluid specimens for the Federal drug testing program.  Oral fluid drug testing is not authorized in DOT’s current drug testing program.

In addition to the changes regarding oral fluids, the revised CCF also includes the following changes:

  • Copies 1-5, Step 1:  Added “CDL State and No.” to donor identification (FMCSA only);
  • Copies 1-5, Step 1:  Added “Other” (i.e., 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;
  • Copy 5:  Removed instructions for completing the CCF from the back of the form. Instructions for completing the CCF are posted on the SAMHSA and ODAPC websites.

When can I begin using the revised CCF?

DOT-regulated employers and their service agents (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, we recommend 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).

As a collector, can I still use the old CCF after September 1, 2020?

  • Yes. OMB authorized, and you may choose to use, the old CCF until August 30, 2021.  When using the old CCF between September 1, 2020, and August 30, 2021, a memorandum for the record (MFR) is not required.  If you use the old CCF after August 30, 2021, you must complete a MFR per 49 CFR § 40.205(b)(2).
  • Beginning September 1, 2020, you may use the revised CCF.  However, after August 30, 2021, you are required to use the revised CCF.  
  • We recommend that you monitor your existing supply of old CCFs and coordinate the delivery of the revised CCF with the testing laboratory.

If I use the old CCF between September 1, 2020, and August 30, 2021, do I need to do anything differently?

No.  The new information required to be provided on the revised CCF (i.e., collector and donor e-mail addresses) may be, but is not required to be, included when using the old CCF.

ODAPC Guidance Document #: ODAPC DRG05

[1] This guidance does not have the force and effect of law and is not meant to bind the public in any way. This guidance is intended only to provide clarity to the public regarding existing requirements under the law.

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