DOT Issues Guidance on the Revised 2020 Federal Drug Testing Custody and Control Form

As of March 2022, this blog post references the current required DOT Custody and Control Form (CCF) for DOT and Federal drug testing.

Instructions for Completing the Federal Drug Testing Custody and Control Form for
Urine Specimen Collections

The 2020 Federal Drug Testing Custody and Control Form (CCF) was revised and recently approved by the Office of Management and Budget (OMB) on August 17, 2020. It is currently in use. Below you will find more information on the current DOT CCF form and the 2020 Federal CCF changes.

The revised custody and control form can be viewed here:

The official DOT guidance for the new CCF form:

There are several changes to the Federal Custody and Control Form (CCF). Here is what has changed and how you will know the difference between the 2017 CCF and the revised 2020 CCF. Note: The revised 2020 form not actually available from the Labs until starting March of 2021.

Most of the changes adopted in the revised CCF were made in order to accommodate the use of oral fluid specimen testing that was recently approved for the Federal drug testing program.  Oral fluid drug testing is not yet been authorized for the DOT testing program but we expect guidance to be coming soon for the integration of oral fluid testing into the DOT program.

Here are the changes for the revised CCF:

  • On all Copies, 1-5, Step 1:  “CDL State and No.” Added to donor identification (used for FMCSA only);
  • On all Copies, 1-5, Step 1:  the field of “Other” (i.e., e-mail address) was added to the Collector Contact Info area;
  • On Copy 1 only, Step 5a:  Removed the analyte names and checkboxes; moved the results checkboxes; and added a line for the certifying scientist to record the positive analyte(s) and concentration(s) if a positive result is recorded;
  • On Copies 2-5 only, Step 5:  Added a line for the donor to print their e-mail address;
  • On Copy 5:  Removed the instructions for completing the CCF from the back of the form. Instructions for completing the CCF are now posted on the SAMHSA and ODAPC Websites. Those can be found here:  and ODAPC

When can I begin using the revised CCF?

DOT-regulated employers and their service agents (collectors, laboratories, Medical Review Officers (MRO)) are authorized to use the revised CCF beginning September 1, 2020 but laboratories have not yet made these available.  To avoid confusion regarding whether oral fluid testing is authorized in the DOT program, and to allow existing supplies of old CCFs to be depleted, laboratories will likely not mail any of the revised CCFs to DOT-regulated clients or their service agents until sometime in 2021 (or until supplies of the old CCFs have been depleted).

As a collector, can I still use the old CCF after September 1, 2020?

Yes. OMB authorized, and you may choose to use, the old CCF until August 30, 2021.  When using the old CCF between September 1, 2020, and August 30, 2021, a memorandum for the record (MFR) is not required. NOTE: After August 30, 2021, you are required to use the revised CCF. If you use the old CCF after August 30, 2021, you must complete a MFR per 49 CFR § 40.205(b)(2).  

We recommend that you monitor your existing supply of old CCFs and coordinate the delivery of the revised CCF with the testing laboratory. The laboratories will continue to issue the old CCFs until they are ready to roll out the 2020 Revised CCF.

Keep up to date at and remember to subscribe to the ODAPC listserve.

2020 DOT Federal CCF with hand signing
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