Q: What if the ‘old’ Custody and Control Form (CCF) is inadvertently used after June 30, 2018?

Last year, the Office of Management and Budget approved a revised Federal Drug Testing Custody and Control Form (CCF) and authorized the continued use of the 2014 version of the CCF, or ‘old’ form until June 30, 2018.

DOT-regulated employers and their service agents (collectors, laboratories, Medical Review Officers) may not use the 2014 version of the CCF for U.S. Department of Transportation (DOT)-mandated drug test collections after June 30, 2018.

If, as a collector, laboratory, MRO, employer, or other person implementing these drug testing regulations, you become aware of the use of a non-Federal form or an expired Federal form, you must provide a signed statement (i.e., a memorandum for the record). It must state that the incorrect form contains all the information needed for a valid DOT drug test, and that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control. The statement must also list the steps you have taken to prevent future use of non-Federal forms or expired Federal forms for DOT tests.

For this flaw to be corrected, the testing of the specimen must have occurred at an HHS-certified laboratory where it was tested consistent with the requirements of 49 CFR Part 40. You must supply this information on the same business day on which you are notified of the problem, transmitting it by fax or courier.

If the correction does not take place, the test must be canceled.

This regulatory requirement can be found at https://www.transportation.gov/odapc/part40/40-205.

This was first published on May 9, 2018, by the DOT called “Reminder: Only the Federal Drug Testing Custody and Control Form approved on August 8, 2017, can be used after June 30, 2018.” Read the full reminder from DOT and other frequently asked questions.

We encourage you to switch to eCCF today for both Federal and non-federal testing. As an eCCF-approved laboratory, Quest Diagnostics uses the most current form.

Read our FAQs about regulated drug testing.

For more information about drug testing, visit our website or contact us online.

Note: The Federal CCF includes both DOT and HHS forms. If you use a CCF that is not DOT or HHS, your form is not expiring and may not be eCCF eligible.