New DOT Drug Testing CCF Form Required August 30, 2021 Or Cause Delays

New 2021 DOT CCF form

After August 30, 2021, using the old DOT CCF form will cause affidavits and result in delays. 

The Department of Transportation (DOT) announced the updated and revised Federal Custody and Control (CCF) for DOT drug testing is available now and must be used by August 30, 2021. This is a required component of the DOT drug testing program.

If an old Federal CCF form is used after August 30, 2021 a memorandum for record (MFR), or an affidavit will be required by laboratories before DOT urine specimens are tested, which will ultimately cause delays.

Laboratories receive thousands of specimens each night and lab technicians review all chain of custody forms to make sure each chain does not have missing information. When it is determined that a chain is not complete, the lab then determines whether the flaw is correctable or fatal.

If one of the seven fatal flaws are committed, the test is canceled and reported to the MRO as a fatal flaw.

One example of a fatal flaw is when the collector does not print their name and sign the chain.

In the case of a correctable flaw, the lab sends a memorandum of record (or affidavit) to the collector to be completed and sent back to the lab.

An example of a correctable flaw is when the lab receives an old CCF and requests an affidavit to be fixed. The lab cannot proceed with testing the sample until they receive the completed memorandum, which delays the overall resulting times.

Some common questions surrounding the New CCF Form

Who do these form changes affect?

  • Employers
  • Consortia/Third Party Administrators (C/TPAs)
  • Collection sites
  • Laboratories
  • Medical Review Officers (MROs)

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 these new DOT CCF forms. 

What should I do with the old CCF forms? 

As soon as you have the new DOT CCF’s, throw away the old DOT CCF’s, this is critical.

Where can I find official information on this? 

Go to: https://www.samhsa.gov/sites/default/files/workplace/2020-fed-ccf-proof.pdf

Where do I get the new CCF forms? 

Whoever manages your drug testing account, Lab or TPA can assist you so that you receive the new DOT CCF form before August 30, 2021.  Many labs are saying to order the new forms in July.

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 can I stay compliant with this change?

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

For more information, contact us at 888.260.9448 or info@cnsprotects.com.

 

How HHS Hair Testing Proposal Falls Short and When To Expect DOT Hair Testing

dot pre-employment hair testing

The Department of Health and Human Services (HHS) just wrapped up their 60-day comment period on their long-anticipated proposed hair testing guidelines.

Since 2015, when Congress mandated HHS to release hair testing guidelines, the Department of Transportation (DOT) and the trucking industry has increased random drug testing requirements due to the rise in rates of positive drug tests. The DOT also released a national drug testing results Clearinghouse Database to help reduce the number of safety-sensitive employees using controlled substances. Learn how to sign-up for the Clearinghouse

The industry is seeking additional drug testing methods, like hair and oral saliva testing, that can be used to prevent unsafe drivers on the roads as these methods are harder to cheat and provide a more complete drug testing history.

Learn more about Current DOT Drug Testing

Large fleets have long used hair testing for pre-employment testing, catching 5 to 10 times more drug users than industry standard urine testing. However, currently these positive results cannot be released to the drivers record per DOT regulations.

Once completed, the DOT will adopt HHS hair testing guidelines and eventually prevent these drivers from seeking a job with another fleet. As of right now,  the proposed guidelines fall short of what the trucking industry has been hoping for.

Let’s break this down.

Why use hair testing as an alternative testing method?

The biggest problem with urine testing is how many options there are to try and cheat a drug test. These methods include:

  • synthetic “fake” urine
  • watering down the urine, or
  • slipping in clean urine from someone else

While there are processes in place to catch individuals cheating the system, many people claim to have cheated and never been caught. Hair testing on the other hand is virtually impossible to cheat when done properly. There is no scientific proof that results can be manipulated by:

  • dying your hair
  • applying hair products
  • detox kits, or
  • any other misconceptions  about manipulating test results.

Additionally, the hair testing can detect drugs and alcohol in the system from a week to 90+ days, unlike urine testing, which only detects drugs and alcohol up to 7 days. Employers have long been using hair testing for pre-employment testing so they can better understand a potential new hire’s drug testing history.

“The scary part is, while a driver can be disqualified from driving from Werner Enterprises, they’re able to go to another carrier [that may not use hair testing] because hair testing isn’t recognized under federal regulations,” said Jamie Maus, vice president of safety and compliance at Werner Enterprises.

“Of the 5,000 positive hair tests in the last couple of years, only a handful of those also tested positive in urine, so only a handful of those would have been reported to the current Drug and Alcohol Clearinghouse or to other companies.”

“What was more surprising was the types of drugs we were picking up. The number one drug we see is cocaine, then amphetamines, and then opioids – marijuana is not even in the top tier.”

While critics of hair-testing claim it can result in false positives because certain drugs can be absorbed into the hair from secondhand smoke, or that it may offer racial bias in test results, hair-testing advocates say those concerns are unfounded and scientifically unproven.


Need more information?

Our DOT Compliance Specialists will give you a free estimate and can also answer any questions you have regarding DOT Compliance, Trucking Insurance or any other questions related to the Transportation Industry.

Why the HHS hair testing proposal falls short

The biggest problem with the proposed hair testing guidelines is that, if hair testing results come back positive, a second urine test is required to confirm the positive test result.

This means a urine specimen must be collected at the time of the hair test or an employee must give a urine specimen by an MRO when reviewing a positive hair test result.

Not only will this create scenarios where a driver could receive a positive hair test result and a negative urinalysis test result, it also creates other issues such as:

  • extra testing costs for confirmation testing
  • longer driver downtime while waiting for test results, and
  • complicated logistics of collectors or labs keeping an authorized second urine specimen for an undisclosed period of time while waiting for the MRO to determine if the specimen is needed for confirmation testing.

According to industry experts, hundreds of thousands of secondary urine specimens per day may need to be shipped to two completely different testing laboratories as some labs do not test both hair and urine and millions of these specimens will be collected, shipped, identified, and eventually discarded for no reason, significantly increasing testing costs to companies.

When can we expect DOT hair testing?

The HHS proposed hair testing guidelines were published in the Federal Register on September 10, 2020. After the 60-day comment period, which ended November 10, 2020, HHS will review all comments and can make additional changes to their proposal. This process could take months. 

When HHS releases their final proposed guidelines, the industry will need to wait for the Department of Transportation to go through its rulemaking process to allow the use of hair testing by motor carriers. While the DOT will likely adopt HHS guidelines, this process could take two years on its own.

However, Congress may try to push for immediate DOT adoption and the incoming Biden administration may apply pressure to speed up this process as well.


Drug and Alcohol Services

At CNS, we offer a comprehensive Drug and Alcohol Consortium Service and are a certified consortium and third-party administrator (C/TPA).

Our experts ensure that all DOT rules and regulations are followed, including the implementation of random drug tests for you and your drivers, updating your company drug testing policies, record retention and document purge management.

We take all the necessary steps and precautions to keep you and your drivers compliant with the DOT drug and alcohol testing requirements.

For more information, contact us at 888.260.9448 or info@cnsprotects.com.

Speed up DOT drug test results from collection site to labs

DOT drug test results

Need faster DOT drug test results?

With trucking’s high driver turnover and competitive job market, fleets risk losing top candidates if their hiring process is not efficient.

When an employer sends a potential hire to a collection site for a DOT drug test, the company hopes to receive the results quickly in order to get the new-hire through the hiring process as quickly as possible.

In an attempt to speed up the new-hire process, it is important for fleets to understand how drug test results can be delayed before finding solutions to get results faster.

The DOT drug testing process can be split into three areas: collection sites, labs, and—if a positive test result—the MRO, all of which can cause preventable delays in the entire process.

What are some causes of delays in drug test results?

Delays at collection sites

Delays caused at collection sites are usually caused by a simple collector mistake. For example, each sample should have the donor’s and the collector’s signature on the vial, and the collector may have forgotten. Also, the required forms may not have been filed at the collection site to have the errors fixed before lab testing of the samples can begin.

Beyond these simple collector errors, many smaller or remote collection sites do not send the urine samples to the labs on a daily basis. They may only have a courier come every two or three days before being shipped to labs for testing.

Also, many collection sites may not have a male or female collector available for an observed collection, forcing the donor to wait for that staff member to come in or being advised to find another collection site with proper staffing.

These delays could easily be avoided by working with a best-in-class collection site who use trained collectors, or using a drug and alcohol consortium who verifies quality collection sites in their network and, if a mistake is made, they continually follow-up on the status of the results. 

Delays at the lab

Once the donor provides a sample, it is quickly sent to a drug testing lab for testing. Labs receive thousands of these specimens daily and each one must have their chain of custody form reviewed for accuracy.

Many of the flaws are correctable and an affidavit or memorandum is sent to the collector to be corrected and sent back. Once a completed chain of custody form or required signatures are received for the specimen sample, the specimen then goes through an initial base screen test.

If the drug test results is negative, no further testing is needed and the employer is quickly notified of the negative result. Negative results are often received within 24-48 hours.

If a non-negative result is found in the initial base screen test, the sample goes through a Gas Chromatography – Mass Spectrometry (GCMS) test process that includes breaking down the urine sample.

A delay in results from the lab can happen if the GCMS test does not affirm a negative or positive result. If this is the case, the specimen goes through another GCMS test process until an affirmative negative, positive, negative-dilute or positive-dilute result is given.

According to most labs, each round of GCMS testing is a batch of other specimens and each batch only gets ran once per 24 hours. If this happens, the delay of this donor’s drug test is unavoidable.

If a positive test is affirmed, the results are sent to a Medical Review Process (MRO). The MRO review process can take over a week to complete as the MRO attempts to reach the donor, has an initial interview with the donor, and, if the donor claims a prescription could have caused a false-positive, the MRO follows a procedure to verify the prescription.

Speed up the hiring process with fast DOT drug test results

Compliance Navigation Specialists ensure that the hiring process runs as efficiently as possible in order to speed up the pre-employment process. Not only do we help with your consortium, collection site and MRO services, we take it one step further.

Our Proactive Safety Management (PSM) program is the most comprehensive service we offer, covering all of your needs to manage your business, including driver qualification files, consortium management, ELD management, vehicle maintenance and more.

Many companies are finding it increasingly hard to maintain proper systems to make sure they are staying compliant throughout the year. We are your best solution, to support or act as, your safety department for a fraction of what it costs to hire a DOT Safety Director.

We pride ourselves in being flexible for our clients and working with all types of carriers from busy owner operators to larger fleets. CNS will be a valuable asset by keeping your company safe, compliant, aware of regulatory changes, proactive in all phases of potential risks, as well as profitable.

Learn more of what is included in our complete PSM program

For more information, contact us at 888.260.9448 or info@cnsprotects.com.

DOT Rules on CBD Usage and Truck Drivers

CBD usage

Can truckers use CBD oils?

The use of cannabidiol (CBD) and related products has trended in recent years. It’s common now to see many products labeled with CBD as an ingredient.

However, it’s important to remain aware of FDA regulations concerning CBD, and the DOT stance on the use of CBD for drivers.

Is CBD considered marijuana or not?

The classification of a product as marijuana depends on the concentration of tetrahydrocannabinol (THC) in the product. Anything containing more than 0.3% THC is classified as marijuana.

Cannabidiol (CBD) products do contain levels of THC, sometimes above or below the marijuana classification levels.

DOT drug testing: Required for marijuana, not CBD

The DOT requires drivers to test for marijuana, but not for CBD. However, the labeling of CBD products can be misleading. If the product contains a higher than 0.3% cannabidiol concentration, it would fall into the category of marijuana.

Drivers taking a marijuana drug test after using a CBD product with higher levels of THC would end up testing positive for marijuana.

>>> What to know about a DOT drug test <<<

CBD usage and labeling confusions

Because the FDA (Food and Drug Administration) doesn’t certify levels of THC in CBD products, there’s very little way to tell if the labels are accurate. A person could end up unknowingly using a product that falls into the marijuana classification.

The FDA reminds the public that “it is currently illegal to market CBD by adding it to a food or labeling it as a dietary supplement.” Many companies have received FDA warning because their products exceed the CBD levels listed on their label.

Check out our industry library resources of 15 videos, 2 ebooks, industry links, and CNS In The News content.

Therefore, it’s entirely possible that CBD product you’re using COULD in fact, be classified as a marijuana product.

This creates a dangerous situation for people who require drug testing, including safety-sensitive drivers.

DOT, Marijuana and Cannabidiol (CBD)

Because the DOT does not allow the use of marijuana for any reason, drivers who use a CBD product could unintentionally run afoul of DOT regulations.

If a driver tests positive for marijuana, but was only using a CBD product, this claim will not be allowable. Laboratory-confirmed marijuana positive results will stand regardless of the drivers claim of CBD product usage.

Avoiding CBD usage is the best precaution

Drivers risk getting a marijuana positive test from the use of CBD products. Since employees subject to the DOT drug testing regulations are forbidden from using marijuana, great care must be taken with CBD products. Exercise caution about using CBD products. Because the labeling is often inaccurate, there are many unknowns about the actual levels of CBD in the products.

Remember positive drug tests remain on your record for three years. A positive test can require additional driver retraining and fines. A driver’s employment and income could be put in danger.

Why run the risk of having a positive drug test on your driving record? Avoiding the use of CBD products keeps your record clean, and keeps you worry-free when taking mandatory drug tests.


Drug and Alcohol Services

We offer a number of services related to drug and alcohol requirements

If you have any concerns regarding CBD usage or any other questionable prescription medications, we can answer any questions you have.

For more information, contact us at 888.260.9448 or info@cnsprotects.com.

DOT Random Drug Testing Percentage Rate Increase (2020)

DOT Random Drug Testing

50% increase for DOT random drug testing

Each year, the FMCSA evaluates the rate of positive testing results for controlled substances. Depending on the reported figures, they modify their testing percentage rates.

For 2020, according to the FMCSA’s notice of program change, the testing percentage rate for controlled substances has increased to 50% of the average number of driver positions.

This new testing rate increase affects drivers of commercial motor vehicles (CMVs) requiring a commercial driver’s license (CDL).

Final rule regarding DOT random drug testing rates

When the number of positive tests for controlled substances in a calendar year increase to equal or greater than 1%, the FMCSA must also increase the minimum annual random testing percentage rate.

The rates increase on January 1 of the following calendar year. This accounts for a delay in application of this final rule to a full year after results are reported.

The results of the 2018 FMCSA Drug and Alcohol Testing Survey showed a 1% increase in the rate of positive tests for controlled substances. As a result, the percentage rate for DOT random drug testing increased from 25% to 50 % of the average number of driver positions. This increase went into effect on January 1, 2020.

The testing rates for alcohol will remain the same, which is 10% of the average number of driver positions.

Increased testing rates equals increased industry cost

It is estimated that the cost of additional testing will add between $50 to $70 million more to industry costs.

With the new 2020 testing rate, approximately 2.1 million random controlled substances tests will be conducted, doubling from the previous years’ 1.05 million tests.


Drug and Alcohol Services

We offer a number of services related to drug and alcohol requirements

If you have questions or need help with your drug and alcohol program, call (888) 260-9448 or email at info@cnsprotects.com.

DOT drug test: Who, what, when and how


As directed by the Federal Motor Carrier Safety Administration (FMCSA) and the Department of Transportation (DOT), all CDL drivers and their employers are required to follow the rules related to DOT drug tests.

Who is given a DOT drug test?

Drivers of commercial motor vehicles (CMVs) are required to take a drug test and their employers must ensure their drivers are tested before operating a CMV.

Below is a full list of those required to be tested.

  • employers of CDL drivers operating CMVs on public roads
  • CDL drivers who operate CMVs on public roads
  • interstate motor carriers
  • intrastate motor carriers
  • federal, state, and local governments
  • civic organizations (disabled veteran transport, boy/girl scouts, etc.)
  • faith-based organizations

What substances are tested?

The DOT requires testing of alcohol and five drug classes, including:

  1. Marijuana
  2. Cocaine
  3. Opiates
  4. Amphetamines or methamphetamines
  5. PCP

Alcohol tests will identify alcohol in the system at .02 BAC and more.                      

Motor carriers can also implement a separate testing program in addition to, and distinct from, the required DOT testing program, under which they are able to test for other drugs.

What types of DOT drug tests are there and when are they given?

DOT drug and alcohol tests are given in several different scenarios, including:

  1. pre-employment – before starting work as a CDL driver and operating a CMV
  2. post-accident – drug and alcohol tests may be required after an accident depending on the circumstances. Learn when post-accident drug tests are required.
  3. random – random testing programs are required by law for all DOT-regulated motor carriers
  4. reasonable suspicion – if a driver appears to be under the influence of drugs or alcohol, an area in which supervisors must be trained in identifying.
  5. return-to-duty – required of drivers who tested positive, refused, or violated the law
  6. follow-up – required of drivers who tested positive, refused, or violated the law

>>> DOT Random Drug Testing Percentage Increase <<<

What is the DOT drug testing process?

The DOT has a strict process for administering drug tests and the steps are the same for all six types.

  1. Go to the collection site with a valid ID and provide a sample before leaving.
  2. Provide your urine sample in the designated collection area. The collection process will be private unless required, as in a return-to-duty or follow-up test.
  3. When finished with the sample, provide the container to the collector and observe as they split the sample into two containers, seal them with tamper-evident tape and allow you to sign the tape before you leave.
  4. Provide your contact information and verify your name and date of birth so the Medical Review Officer (MRO) can get in touch with the results.

Drug and alcohol testing

Where does a driver get a DOT drug test?

Compliance Navigation Specialists works with Quest Diagnostics and have over 10,000 locations available for testing, whether it is necessary after an accident or for a pre-employment screening.

We also offer a comprehensive Drug and Alcohol Consortium Administration Services (C/TPA) for companies that are regulated by Federal and State government.

If you have any questions, call 888.260.9448 or email at info@cnsprotects.com.

DOT post-accident drug test requirements


As a DOT-regulated motor carrier, it is extremely important to ensure all CDL drivers are in top physical and mental condition while operating these highly complex and powerful commercial motor vehicles. Driver awareness of post-accident drug test requirements is also crucial.

Although we do everything possible to prevent accidents, there are times when circumstances are beyond our control, making the post-accident steps one of the most important pieces of knowledge for a CDL driver. A driver’s responsibilities do not stop at the site of the accident.

What are the different types of DOT drug tests?

There are several situations in which a DOT drug test is required, including:

  1. pre-employment – before starting work as a CDL driver
  2. post-accident – applies to certain situations following an accident
  3. random – random testing program require by law for all DOT-regulated motor carriers
  4. reasonable suspicion – if a driver appears to be under the influence of drugs or alcohol
  5. return-to-duty – required of drivers who tested positive, refused, or violated the law
  6. follow-up – required of drivers who tested positive, refused, or violated the law

When is a post-accident drug and alcohol test required?

Drug and alcohol tests are not required after every accident. A CDL driver is required to take a post-accident drug test if:

  • the accident results in one or more fatalities
  • injury was incurred that required medical treatment away from the scene and the driver received a citation (Note: no citation = no drug and alcohol test)
  • any vehicle is towed, and the driver received a citation (Note: no citation = no drug and alcohol test)

Also, it is important to note that a driver is still liable to take a drug and alcohol test if a citation issued within 32 hours of the accident. If a citation is issued after the 8 hour mark, the motor carrier must make a note saying “a citation was not issued until this time, which was after the 8 hours for alcohol testing.”

How much time do I have to get a post-accident drug test?

A driver has 2 hours in which an alcohol test should be completed, however it must be completed within 8 hours. If the driver goes over the 2-hour mark, they must provide an explanation as to why there was a delay and the motor carrier must provide a written explanation and keep in their company files.

Check out our industry library resources of 15 videos, 2 ebooks, industry links, and CNS In The News content.

A drug test needs to be completed as soon as possible; however, it must be completed within 32 hours. At times there might be a delay in the issuance of a citation, however as long as the citation is issued with 32 hours, a drug and alcohol test is required.

Drivers often run into issues with meeting these timeframes because they will be kept at the scene of an accident for several hours or an investigation must be completed to determine if the driver was at fault.

What if I miss the maximum time frame allowed?

If a driver does not get his post-accident drug test before the maximum allowed time, the company needs to make a note in their files as to the reason why, however it is too late and the company will be out of compliance and face fines and audit penalties, so completing the drug test within the allowed time is imperative.

What about on-site tests, such as a DUI test or breathalyzer?

If an officer conducts a DUI test or a breathalyzer at the scene of an accident, a driver is still required to follow protocol and get an official drug and alcohol test within the allotted time frames. An on-site test by an officer will not fulfill the required DOT post-accident drug test as these tests do not follow DOT rules and regulations.


Drug and alcohol testing

Where does a driver get a DOT drug test?

Compliance Navigation Specialists works with Quest Diagnostics and have over 10,000 locations available for testing, whether it is necessary after an accident or for a pre-employment screening.

For post-accident alcohol testing, CNS will coordinate a location for you.

We also offer a comprehensive Drug and Alcohol Consortium Administration Services (C/TPA) for companies that are regulated by Federal and State government.

If you have any questions, call 888.260.9448 or email at info@cnsprotects.com.