Using Outdated Chain of Custody Forms (CCFs) Will Delay Results

In order for drug test collections to be performed, a five-part paper chain of custody form must be used. The U.S. Department of Transportation (DOT) is reminding DOT regulated employers and their service agents (collectors, laboratories, Medical Review Officers) to use the revised Federal Drug Testing Custody and Control Form (CCF) after June 30, 2018.

The ‘old’ CCF is the one that has been used under the DOT-regulated program since 2010.  The revised CCF includes the following changes:

• In Step 1D: Removal of the checkbox, the letters “DOT” and hash line in front of the text “Specify DOT Agency”
• In Step 5A: Addition of four new analytes: oxycodone (OXYC), oxymorphone (OXYM), hydrocodone (HYC), and hydromorphone (HYM), and Removal of the analyte methylenedioxyethylamphetamine (MDEA).

If an old CCF Form is Used 

If a non-Federal form or an expired Federal form is used:

• The lab must set the specimen aside and then send a memorandum of record to the collection site
• The lab cannot continue testing until they receive this signed memorandum back
• The collector at the collection site 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 statement must also list the steps taken to prevent future use of non-Federal forms or expired Federal forms for DOT tests

If the correction does not take place, the test must be canceled.

To avoid these types of delays in receiving results, employers should call their collection sites or their consortium/third party association (C/TPA) that is handling their drug testing program to make sure that the collection sites are using the updated form.

Using electronic Chain of Custody Forms (eCCFs) Guarantees an Updated CCF

With the widespread use of eCCFs comes a guarantee that the chain of custody form will stay updated and that no potential delays in receiving results from the use of an old form are made.

Automated registration of the applicant and the use of eCCFs reduces the number of errors and legibility issues, as well as eliminates the need to inventory paper testing forms. It also ensures a more accurate data transfer between the employer, collector, and laboratory.

CleanFleet’s own collection sites are using eCCFs and, for our Consortium Members, our thousands of partner clinics nationwide are being vetted for eCCF capability. Ensure that your drug testing program is taking advantage of eCCFs by calling your lab or C/TPA to make sure they have the capability to use this new technology.