Notice: Federal Drug Testing Custody and Control Form (CCF)

On May 2, 2023, the Department of Transportation (DOT) published a final rule in the Federal Register (88 FR 27596). This final rule, among other items, amends the DOT’s regulated industry drug testing program to include oral fluid testing.

When is the final rule effective?

• The final rule is effective June 1, 2023.
• Remember:  DOT oral fluid testing cannot be implemented until HHS certifies two laboratories (one to serve as a primary laboratory and a second to serve as a split-specimen laboratory).

Can the 2017 version of the CCF still be used only for urine collections?

• Yes, DOT-regulated employers and their service agents (collectors, laboratories, Medical Review Officers (MRO)) are authorized to use the 2017 version of the CCF only for urine collections until August 31, 2023.
• If you use the 2017 version of the CCF a Memorandum for the Record (MFR) is not required through August 31, 2023.  A MFR will be required after August 31, 2023
• The 2017 version of the CCF must not be used for oral fluid collections.

Is there a new CCF because oral fluid testing is being added? 

• No.  The current (2020) version of the CCF includes the option to collect and test either a urine or an oral fluid specimen, so no new CCF is needed.
• Become familiar with the 2020 version of the CCF so you know what sections are always filled out and what sections are only filled out for urine testing or only filled out for oral fluid testing. (e.g., In Step 2 check whether it is an oral or urine collection.)

What should a laboratory do about collector errors related to oral fluid device expiration dates?

• If you receive an expired device, you must reject the specimen for testing.

• If the collector failed to enter the expiration date or was entered incorrectly in Step 4 of the CCF, the laboratory must reject the specimen unless the laboratory is able to determine the expiration date by inspecting Bottles A and B.  The laboratory will note the correct date and proceed with the testing process.

What contact numbers does the collector enter on the CCF?

• You must ensure the phone number in Step 1.G., connects directly to you and/or your supervisor, and not a general call center.
• Fax numbers may be included, but are not required, on the CFF.

Can I use the same CCF if I switch to a different collection methodology?

• No, you must use a new CCF and document the reason for the change in the Remarks section.

NOTE:   This document informally summarizes some of the important effects of the rule, but it is not a substitute for the rule and should not be relied upon to determine legal compliance with the rule.  ODAPC encourages affected entities, including employers and service agents, to review the final rule.