DOT Extends The Use Of Old Chain of Custody Forms Until November 30th

DOT Extends The Use Of Old Chain of Custody Forms Until November 30th

By EBI Screening Expert

The U.S. Department of Transportation has issued its Interim Final Rule (IFR) issued by The DOT in September of 2010.  The intended effect of this final rule is to finalize the authority for use of the new Chain of Custody Form (CCF) and to make a technical amendment to its drug testing procedures by amending a provision of the rule which was inadvertently omitted.  The complete text of the amendments can be found at the Federal Register Federal Drug Testing Custody and Control Form; Technical Amendment“.  Among amendments to the Interim ruling; employers that fall under the DOT drug testing regulations, 49 CFR Part 40, can continue to use old CCF forms until November 30, 2011.  This extension will provide the DOT and employers more time to implement the use of the new forms.

NOTE: For Users of DOT Compliant Drug Testing  
After November 30, 2011 if an old CCF is used, labs must treat it as a correctable discrepancy and request a memorandum for record (MFR), which could affect your turnaround time.  Additional information on this change is provided below.

For Existing EBI DOT Drug Testing Clients
To Order Forms Contact: or 1.800.324.7700 x507

Chain of Custody Form

This reminder is being sent to all EBI readers that may utilize DOT compliant drug testing services.  Please be aware that the old CCFs may only be used through November 30, 2011.  It is our goal to keep readers informed of compliance and regulatory changes as part of our service and commitment to our clients.  In addition to the updated CCF, the DOT has also provided a list of instructional revisions when using the new form.  These revisions can be found below:

  1. Filling out Step 1-D on Copy 1 of the new CCF, which now includes the federal testing authorities – HHS, DOT, and Nuclear Regulatory Commission (“NRC”); and with further specificity for DOT Agencies – FMCSA, FAA, FRA, FTA, PHMSA, and the USCG;
  2. Filling out Step 5-A on Copy 1 of the new CCF, which now lists MDMA, MDA, and MDEA, as well as “Δ9-THCA” after “Marijuana Metabolite” and “BZE” after “Cocaine Metabolite” to specify the drug analyses;
  3. Filling out Step 6 on Copy 2 of the new CCF, which now has a line for the MRO to note the drug(s) for which a positive result is verified, and a new line item “other” for documenting other refusal-to-test situations – for example, when there is no legitimate medical explanation for the employee providing an insufficient amount of urine;
  4. Filling out Step 7 on Copy 2 of the new CCF, which now has a box the MRO is to check if a split specimen is reported as cancelled; and
  5. Completing the CCF on the reverse side of Copy 5.

EBI offers a wide variety of options when it comes to DOT drug and alcohol testing programs, from pre-employment, random, post-accident and mobile collection options for both regulated DOT and traditional testing.  With vast expertise and knowledge, EBI can help you develop a drug testing program to meet your specific needs, whether lab based or instant solution.

Employment Background Investigations, Inc. is committed to providing employers with valuable education and resources on changing legislation and cutting-edge and compliant solutions to meet federal, state, local and international mandatory requirements. If you found this information useful, select the button listed below and access more industry news, resources and tips from EBI, an NAPBS Accredited screening firm and global leader in the background screening industry.


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