Last updated : May 12, 2025
The Department of Transportation (DOT) has revised the Custody and Control Form used for DOT drug testing. The new DOT CCF forms are already available for use but the official start date is August 30, 2021.
Custody and Control Forms are a required component of the DOT drug test. The new DOT CCF forms are to be distributed by laboratories that are approved by the Substance Abuse and Mental Health Services Administration (SAMHSA). These laboratories are held to the strictest of standards regarding operations and maintenance. A laboratory must be SAMHSA-approved to analyze DOT drug tests.
There’s no passing the buck
Even though it’s the lab’s responsibility to distribute the new DOT CCF, it’s the employer’s responsibility to ascertain everything is in order regarding compliance issues. It’s a good idea to get in contact with your drug testing company to make sure the lab they use is ready to go with the new forms as of August 30th.
If an old DOT CCF form is used after August 30th, a memorandum for record (MFR) or an affidavit must be attached or the lab can not complete the drug testing procedure. Continuing to use the old form will cause the need for affidavits and hold-ups are likely to come into play.
It’s best to take the time to ensure that everything is ready to go prior to the start date. Old Custody and Control Forms should be destroyed.
Another option to consider is working with a third-party administrator (TPA). They can provide you with electronic ordering (eCCF). This completely eliminates the need for paper drug testing forms.
What changed?
There were two changes made to the DOT CCF.
They are:
- The form is now called the Federal Custody and Control Form.
- On Copy 1, Step 2, there was an addition of information about oral fluid testing. The old forms are set up for a urine drug test only.
Oral fluid drug testing was approved for use by government entities as an alternative for the urine drug test. Subsequently, it’s up to the individual administrations to decide whether or not they will allow it. The DOT hasn’t approved using oral fluid tests—yet.
The fact that changes were made to the Custody and Control Form leads one to believe oral fluid tests may be an option to use in the future instead of urine tests. For the time being, though, urine drug tests are the only approved DOT drug testing method.
Following the format
DOT regulations are strictly enforced. Make sure that your TPA, Consortium, or laboratory have the Federal Custody and Control Forms either in paper form or loaded and ready to file electronically.
Falling into noncompliance is more than a headache. Fines can make it a costly mistake as well.
