Recently, the U.S. Department of Transportation (DOT) has issued guidance on the revised 2020 Federal Drug Testing Custody and Control Form (CCF).
The revised Federal Drug Testing Custody and Control Form (CCF) was approved by the Office of Management and Budget (OMB) on August 17, 2020. The form is expected to start being shipped out by laboratories this summer. In this article, we will discuss some of the important information regarding the 2020 Federal CCF changes.
The previous versions of the CCF and ATF allowed the use of either the driver’s social security number (SSN) or employee identification number (EIN) when completing the CCF or ATF. However, effective January 6, 2020, FMCSA required that the commercial driver’s license number (CDL) must be used instead of the SSN or EIN when FMCSA-covered drivers’ positive drug or alcohol test results are reported to the Clearinghouse.
The majority of changes implemented in the revised CCF were created to accommodate the use of oral fluid specimen testing that had been recently approved for the Federal drug testing program. Although oral fluid drug testing has not yet been authorized for the DOT testing program, the guidance is projected to be released in the upcoming months to integrate it into the DOT program.
The changes for the revised CCF include the following:
· 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;
DOT-regulated employers and their service agents (collectors, laboratories, Medical Review Officers (MRO)) had been authorized to use the revised CCF starting on 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, DOT has recommended 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).
Importantly, the old CCF can be used until August 30, 2021, but after that date when using the old CCF it is necessary to complete an MFR per 49 CFR § 40.205(b)(2).
In addition, DOT recommends the monitoring of old CCFs to coordinate the delivery of the revised CCF with the testing laboratory.