McCraren Compliance

New DOT Drug Testing CCF Form Required

First published by DOT

The Revised Federal Drug Testing Custody and Control Form

must be used beginning August 30th, 2021[1]

Important Dates

We will conform to the dates HHS has instructed its certified laboratories to use as follows:

August 29, 2021 – Last date to use the ‘old CCF’.

August 30, 2021 – The date you must use the ‘revised CCF’.  If you use the ‘old CCF’, you must complete a Memorandum for the Record (MFR), otherwise the test will be canceled.

What happened?

On August 17, 2020, the Office of Management and Budget (OMB) approved a revised Federal Drug Testing Custody and Control Form (CCF).  In addition, OMB authorized the use of the old form through August 29, 2021.  You can view the revised CCF here.

When using the ‘old CCF’ from September 1, 2020 through August 29, 2021, a MFR is not required.

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 drug testing program.

What’s happening now?

As of August 30, 2021, DOT-regulated employers and their service agents [collectors, laboratories, Medical Review Officers] must use the ‘revised CCF’.

Where can an employer or a collector obtain the revised CCF?

Contact your Department of Health and Human Services (HHS)-certified laboratory to obtain the revised CCF.  A list of HHS‑certified laboratories can be found here.

As an employer or collector, what should I be doing now?

As an employer or collector, monitor your existing supply of ‘old CCFs’ and coordinate the delivery of the ‘revised CCF’ with your HHS-certified laboratory.  Some laboratories may have already contacted you or provided you with information about the delivery of the ‘revised CCF’.

[1] This guidance does not have the force and effect of law and is not meant to bind the public in any way. This guidance is intended only to provide clarity to the public regarding existing requirements under the law.

Last updated: Tuesday, August 10, 2021


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