U.S. DOT issues guidance on revised Federal Drug Testing Custody and Control Form

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The U.S. Department of Transportation has issued guidance answering several commonly asked questions about the new Federal Drug Testing Custody and Control Form.

WASHINGTON — The U.S. Department of Transportation (DOT) today issued guidance discussing changes to the revised Federal Drug Testing Custody and Control Form (CCF) that was approved Aug. 17. Click here to view the DOT-issued guidance.

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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. The guidance also notes additional changes to the CCF; click here to view those changes.

DOT-regulated employers and their service agents (collectors, laboratories and medical review officers, or MRO) are authorized to use the revised CCF beginning Sept. 1. To avoid confusion about whether oral fluid testing is authorized in the DOT program, and to allow existing supplies of old CCFs to be depleted, DOT recommends that laboratories not mail 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).

Collectors can use the revised CCF beginning Sept. 1; however, usage of the revised CCF is not required until Aug. 30, 2021. When using the old CCF between Sept. 1, 2020, and August 30, 2021, a memorandum for the record (MFR) is not required. However, if an old CCF is used after August 30, 2021, collectors must complete an MFR per 49 CFR § 40.205(b)(2).

DOT stipulates that the Aug. 31 guidance does not have the force and effect of law and is not meant to bind the public in any way; it is intended only to provide clarity regarding existing requirements under the law.

Click here for detailed information from the Department of Health and Human Services Substance Abuse and Mental Health Services Administration about using the new CCF.

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