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Should I be Using the New DOT Custody and Control Form?

The Office of Management and Budget (OMB) recently approved a revised Federal Drug Testing Custody and Control Form (CCF).  The revised CCF can be viewed at: http://www.reginfo.gov/public/do/DownloadDocument?objectID=73335901

There have been numerous questions about this new form. Here are a few of the most common:

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 January 1, 2018.
  • As a laboratory, to avoid confusion about opioids testing prior to January 1, 2018 for DOT-regulated clients, and to allow you to deplete your existing supplies of old CCF’s, we recommend as a best practice, that you not mail any revised CCFs to your DOT-regulated clients or their service agents until after January 1, 2018.

How will I know the difference between the revised and ‘old’ CCF?

The ‘old’ CCF is the one that has been used under the DOT-regulated program since 2010.

The revised CCF includes the following changes:

  • In Step 1D:
    • Removal of the checkbox, the letters “DOT” and hash line in front of the text “Specify DOT Agency”
  • In Step 5A:
    • Addition of four new analytes: oxycodone (OXYC), oxymorphone (OXYM), hydrocodone (HYC), and hydromorphone (HYM),
    • Removal of the analyte methylenedioxyethylamphetamine (MDEA).

After January 1, 2018, can the ‘old’ CCF still be used?

  • Yes, you may choose to use, the ‘old’ CCF until June 30, 2018.  When using the ‘old’ CCF between January 1, 2018, and June 30, 2018, a ‘memorandum for the record’ is NOT required.  After June 30, 2018, if you use the ‘old’ CCF, you must complete a ‘memorandum for the record’ per §40.205(b)(2).
  • After January 1, 2018, you may begin using the revised CCF.  However, after June 30, 2018, you are required to use the revised CCF.

You can read the DOT Notice here: https://www.transportation.gov/odapc/Notice_CCF_December_2017