Effective Date of New DOT Chain of Custody Form – September 30th 2011

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NOTE: For Users of DOT Compliant Drug Testing  
After September 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 turn-around-time.  Additional information on this change is provided below.

For Existing EBI DOT Drug Testing Clients
To Order Forms Contact: DTCS@ebiinc.com or 1.800.324.7700 x.507

Chain of Custody Form
The Interim Final Rule (IFR) issued by The Department of Transportation in September of 2010 included the issuance of an updated Federal Drug-Testing Custody-and-Control Form (CCF).  The Department of Health and Human Services (HHS) made an effective date of this new form to be October 1, 2010.  The HHS also extended the use of the old CCF until September 30, 2011.

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 September 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 is committed to providing employers with valuable education, news and resources around background screening, drug testing, occupational healthcare and employment eligibility.  All content provided by EBI is published for the convenience of its readers and should never be deemed as legal guidance or advice.  Always consult your legal counsel for specific advice on local laws and industry regulations.

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