Overview of Federal Drug Testing Custody and Control Form Changes
In late 2017, the Department of Transportation (DOT) published a rule adding four semi-synthetic opioids to the drug testing panel. These semi-synthetic opioids which include hydrocodone, oxycodone, hydromorphone, and oxymorphone represent a substantial change to the DOT drug testing panel. Other notable changes in the rule included the addition of methylenedioxyamphetamine (MDA) as an initial test analyte and eliminated the testing for methylenedioxyethylamphetaime (MDEA).
The final rule, which went into effect on January 1, 2018, authorized the continued use of the old CCF through June 30, 2018, but requires the use of ONLY the new, revised CCF after June 20, 2018.
If a DOT-regulated employer uses the old CCFs after June 30, 2018, the lab will halt the testing process and require the completion of a ‘memorandum for the record.’ This additional documentation will add complexity to the testing process and create delays in testing and results.
DOT-regulated employers and their service agents (collectors, laboratories, Medical Review Officers (MRO)) are affected by this change and should begin using the new CCFs immediately.
How Can I Tell If I Am Using The Old CCF Or The New CCF?
Determining if you are using the old or new CCF is quite simple; 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).
What To Do Next
We strongly recommend that if you currently use the old CCFs, you order the new CCFs to begin use prior to June 20, 2018, to ensure the old form does not create testing delays.
If you need guidance or assistance, please call one of our specially trained staff members 1-866-843-4545.
What Will Happen If I Continue To Use The Old CCFs?
Even if we ignore the condition that if you continue to use the old Federal Drug Testing Custody and Control Forms beyond the June 30, 2018 implementation date, you will be violating DOT rules, there are other considerations. First, you might be required to submit additional documentation with each CCF. Next, because the old forms are missing the additional fields related to the four new analytes: oxycodone, oxymorphone, hydrocodone, and hydromorphone, you risk introducing a severe delay in the testing process. That delay could be damaging to your business.
Simply put. Take action now and order the new CCFs so that you can be in compliance with the DOT rules on June 30.
If you are interested in seeing an example of the new CCF, the revised CCF can be viewed here: https://www.nationaldrugscreening.com/show-blog.php?id=570