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NEW Custody and Control Form (CCF) for Federal Drug Testing Approved – Effective August 8, 2017

The Office of Management and Budget (OMB) has approved the use of the 2017 Federal CCF as of August 8, 2017.  However, if you have a current supply of the 2014 forms, you may continue to use them through June 30, 2018.

The new version of the CCF contains minor changes, including removing the checkbox in front of:  “DOT – Specify DOT Agency”.  (This way, collectors will not have to check both this box and the box in front of the specific Operating Administration that covers the employee being tested.)
The 2017 CCF also includes the additional drugs which will be tested under the Federal Drug Testing Program — oxycodone, oxymorphone, hydrocodone and hydromorphone.  This is also known as the “expanded opioids panel”.

It is likely that many collection sites and specimen collectors will need to continue using the older forms, since the majority of laboratories have already printed an abundance of the 2014 forms that they will want to use up before sending the new (2017) Custody and Control Forms to collection sites.

Collectors: When using the old (2014) CCF, you will simply fill out the form the same way you have been doing so, according to Federal Regulations.  You do not need to make any changes to your documentation or procedure at this time.  [FYI:  The laboratories will need to make remarks on each CCF they receive whenever a collector sends in a 2014 form, but this does not affect the role of the specimen collector at this point.]

Starting July 1, 2018, collectors should STOP using the old (2014) CCF for documenting specimen collections for Federal drug testing.  If you do use an old form after June 30, 2018, the situation will be treated as a ‘correctable flaw’.  [This means you must fill out a Memorandum for Record/Affidavit outlining your error, so that a paper trail exists regarding your use of the expired custody and control form.]

You may read more details and guidance about the new form on the DATIA website here:  https://www.datia.org/datia/Guidance_2017_CCF_Final.pdf
And, if you have never done so, all collectors should also review the resources available for urine collectors on the Department of Transportation (DOT) website at: 
https://www.transportation.gov/odapc/collectors

The above DOT website link contains a Urine Specimen Collection Guidelines handbook that all collectors should study.  The new handbook pertaining to the 2017 CCF should be available soon, so keep checking back.  The new version of the Guidelines publication will also contain information about the additional changes (effective October 1, 2017)  to the Federal Rules for specimen collectors and DOT drug testing.

To review the full, new Regulations that are expected to take effect on October 1, 2017, and learn how the new Rules will affect YOUR job, you may read the Notice of Proposed Rulemaking (NPRM) here:  https://content.govdelivery.com/attachments/USDOT/2017/01/23/file_attachments/748866/FR_20170123_NPRM_Opioids.pdf

As always, for the most up-to-date and comprehensive training, contact Certified Training Solutions at 307-640-5859 or visit us on the web at www.CertifiedTrainingSolutions.com
We offer Specimen Collector training and certification for DOT drug testing, as well as breath alcohol technician (BAT) and screening test technician (STT) training/certification.  Take a look at our online training course details and outlines at the following web addresses:

https://www.certifiedtrainingsolutions.com/dot-specimen-collector-training.html

https://www.certifiedtrainingsolutions.com/breath-alcohol-technician-bat-training.html
 
 
 
 
The information presented here is meant to provide general information and guidance. Information is deemed reliable but not guaranteed.  Legal advice must be provided in the course of an attorney-client relationship specifically with reference to all the facts of the particular situation under consideration. Such is not the case here, and accordingly, the information presented here must not be relied on as a substitute for obtaining legal advice from a licensed attorney and/or the U.S. Department of Transportation Office of the General Counsel.  When in doubt, check with your corporate legal counsel and/or the U.S. Department of Transportation Office of the General Counsel or an agent of the operating agency that covers your industry.  Certified Training Solutions is not responsible or liable for any loss or damage relating to the use of the information in this article. Before relying on the material in any important matter, users should carefully evaluate its accuracy, currency, completeness and relevance for their purposes, and should obtain any appropriate professional advice relevant to their particular circumstances.

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