The Custody and Control Form (CCF), is the chain of custody form that is used by collectors when obtaining a specimen to send to the laboratory for testing. The U.S. Department of Health and Human Services (HHS), Substance Abuse and Mental Health Services Administration (SAMHSA) issued a revised CCF on August 17, 2020. 

The new CCF has been updated mainly to accommodate the addition of using oral fluid specimens for drug testing which was approved for U.S. Federal Workplace testing but has not yet been authorized for the DOT drug testing program. 

This updated CCF is approved for use by DOT-regulated employers and their service agents, including collectors, labs, and Medical Review Officers (MRO), beginning Sept 1, 2020. However, the DOT is suggesting that laboratories do not send the new CCFs to DOT-regulated employers until after June 2021 or whenever the service agents’ supplies deplete, whichever comes sooner. This is not only to allow the service agents to use up the stock of CCFs they already have but also to avoid the confusion of having a CCF with oral fluid testing fields when oral fluid testing is NOT actually permitted. It is not known for sure when (or if) oral fluid testing for drugs will be permitted by the DOT but this at least allows for some time for everyone to get used to the CCF changes, and perhaps, for the DOT to catch up. 

There is no requirement to use the new CCFs until August 30, 2021 which means that until then you may continue to use the old CCFs WITHOUT attaching a Memorandum For Record (MFR). After the August 30, 2021 cutoff any old CCF which is used will require an MFR as per the 49 CFR §40.205(b)(2).

Besides the addition of Oral Fluid as a choice for a testing specimen and the info required for that, the new CCF has a few other updates including:

•  “CDL State and No” has been added to the donor identification (FMCSA only)
• A field for “other” has been added to the Collector Contact Info (for email)
• A field for the donor’s email has been added
• Removed the instructions for completing the CCF from the back of the form (instructions for completing the CCF are available here.

You can check out what the new CCFs look like here.