Important Reminder: The 2017 version of the Federal Drug Testing Chain of Custody Form (Federal CCF), will expire on August 31st, 2023, and no longer be valid for DOT drug collection use. The new 2023 Chain of Custody Form is the same form as the 2020 version. This recent change in CCFs follows the advancement of oral fluid testing throughout the Department of Transportation (DOT) industry. If employers currently hold any copies of the 2017 CCF, they must use up or discard them by the expiration date. It is important to keep a copy of the instructions on the back of the 2017 version or refer to the Substance Abuse and Mental Health Services Administration (SAMHSA) website, as the 2023 CCF does not disclose any instructions for the donor. To further note the difference between the two forms, a few other revisions were made to include additional fields for a donor’s personal identifying information, such as CDL state, number, and email address. Additionally, the analyte names and checkboxes have been removed.
In November 2021, SAMHSA requested that the Office of Management and Budget (OMB) extend the opportunity for employers to use the 2017 version of Federal CCF when collecting a donor’s urine without an affidavit or memorandum for record (MFR). As reported to SAMHSA by DOT and the Department of Health and Human Services (HHS) certified laboratories, the requested extension was implemented due to a shortage of the necessary resources used to produce both the 2020 version CCF and specimen collection kits such as carbonless paper, label plastics, and various shipping materials were instead used to produce Covid-related items. While employers must still wait to implement oral fluid testing until two laboratories receive certification from the Department of HHS, they are required to use the new 2023 CCF form now, which includes disclosure of oral fluid testing during DOT-related drug testing programs.
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Sarah Ensch
