Changes to Custody and Control Forms

Starting September 1, 2021, DOT-regulated employers will have to use the revised Federal Drug Testing Custody and Control Form.

The revised CCF was approved by the Office of Management and Budget last year on August 17, 2020. CCFs were shipped out this summer to drug testing laboratories to ensure that they were available by the start date to avoid causing delays.

Previous CCF versions allowed the driver’s social security number (SSN) or employee identification number (EIN) to be used for identification purposes when completing the form. Recent updates changed this procedure so that the commercial driver’s license number (CDL) must be used instead of the SSN or EIN when positive drug or alcohol test results are reported to the Clearinghouse.

Most of the changes starting this month were designed to accommodate the use of oral fluid specimen testing that had recently been approved for the Federal drug testing program. Oral fluid drug testing is predicted to be authorized and integrated for the DOT testing program in the next few months.

Here are the most important changes to the CCF:

On all Copies, 1-5, Step 1: “CDL State and No.” Added to donor identification (used for FMCSA only);
On all Copies, 1-5, Step 1: the field of “Other” (i.e., e-mail address) was added to the Collector Contact Info area;
On Copy 1 only, Step 5a: Removed the analyte names and checkboxes; moved the results checkboxes; and added a line for the certifying scientist to record the positive analyte(s) and concentration(s) if a positive result is recorded;
On Copies 2-5 only, Step 5: Added a line for the donor to print their e-mail address;
On Copy 5: Removed the instructions for completing the CCF from the back of the form. Instructions for completing the CCF are now posted on the SAMHSA and ODAPC websites.

The old CCF can be used until August 30, 2021. After that date, you must complete an MFR when using an old CCF per 49 CFR § 40.205(b)(2). DOT also recommends monitoring old CCFs to coordinate the delivery of the revised forms with testing laboratories.