Drug Testing: Supply Chain Issues Cause Extension To Use Old Chain of Custody Forms

chain of custody forms 2021

On Nov 29, 2021, the Office of Management and Budget (OMB) has granted an extension for using the 2017 Federal Custody and Control Form (CCF) for urine specimens until August 31, 2023.

With this extension, either the 2020 Federal CCF or the recently expired 2017 Federal CCF may be used for urine specimens collected for federal workplace drug testing programs and those collected for testing under the Department of Transportation (DOT) regulations.

With this change, the use of the 2017 Federal CCF is now permitted (as of November 23, 2021) without a memorandum for the record (MFR).

Why is there an extension for the old CCF forms?

Due to a shortage of raw materials needed for the 2020 Federal CCF, the Substance Abuse and Mental Health Services Administration (SAMHSA) requested OMB approval for continued use of the 2017 Federal CCF.

Short supplies include the carbonless paper used for CCF and the resins and plastics used for the labels directly affixed to the form. Items used for specimen collection kits (e.g., cardboard, shipping materials) are also in short supply.

These shortages are attributed to the materials’ use for COVID-related activities. Additionally, it was noted there is only one supplier of the carbonless paper, and the supplier has indicated they will not be increasing its production.

Where do I get the new or old CCF forms? 

Whoever manages your drug testing account, Lab or TPA can assist you so that you receive the new or older DOT CCF forms. Most of our clients already have the new CCF form.

Another option is to work with a third-party administrator (TPA) that can provide you with electronic ordering (eCCF) with no paper drug testing forms.

How do I know if I have the old DOT CCF form or the new DOT CCF form?

The easiest way to know the difference is that Copy 1 Lab copy in Step 2 has information about ORAL FLUID testing. The old form does not mention Oral Fluid.

Is Oral Fluid testing now authorized?

No. DOT has not yet authorized Oral Fluid testing. Do not collect oral fluid using the new DOT CCF forms. 

How can I stay compliant with this change?

Our comprehensive Drug & Alcohol Consortium Administration Services (C/TPA) is available for companies that are regulated by Federal and State government.

When you select our Drug and Alcohol Consortium you receive professional guidance from one of our drug and alcohol experts who completely manage your consortium.

Our experts ensure that all DOT rules and regulations are followed, including the implementation of random drug tests for you and your drivers. We take all the necessary steps and precautions to keep you and your drivers compliant with the DOT drug and alcohol testing requirements.

We also offer an online results portal where our consortium clients can order their own chain of custody forms for a drug test, search collection sites near a driver location, see the status of a chain of custody order and the results of the test, and download chain of custody forms for audit or other purposes.

Our DOT Compliance Specialists can assist you with any questions you might have.

Questions about DOT Compliance, Licensing, Audits, Programs, etc.?

Our DOT Specialists are here to help!

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