Chain of custody documentation is used to indicate the integrity of the path a drug testing specimen takes. They identify every person who has had their hands on the specimen, from the collector to the lab technician who conducts the tests on the specimen, and all points in between. Even the people who prepare and deliver the results are included in the official chain of custody documentation.
Because information collected in drug testing is so sensitive, the Department of Transportation, or DOT, requires an iron clad paper trail between samples collected, the testing process, and the delivery of results known as a Federal Drug Testing Custody and Control Form, often referred to as a CCF.
New requirements for DOT Chain of Custody Forms (CCF)
As of January 1, 2018, new rules went into effect for DOT drug testing requiring updated CCF forms. The use of the old forms was acceptable through June 30, 2018 even though the new rules were still in effect. As of July 1, 2018, only the updated chain of custody documentation is acceptable for DOT drug testing in most situations.
If an accident occurs and you submit the old form by accident, it will be accepted provided it delivers all the required information for DOT drug testing and you submit a subsequent signed statement, called a memorandum, for the record that details your accidental use of the old form or the necessity for using an older form along with steps the organization has taken to ensure future use of the correct form and only the correct form.
Additionally, testing must have been performed in compliance with the updated rules at a qualified laboratory and the statement must be provided on the same day you receive notice by fax or courier.
Who appears on a Chain of Custody Form?
The chain of custody form has five sections that must be filled out by specific people along the chain of custody of specimen materials.
- Part 1 – Filled out by the testing facility
- Part 2 – Filled by the medical review officer (MRO)
- Part 3 – Filled in by the collector
- Part 4 – To be filled in by the employer
- Part 5 – Filled out by the specimen donor being tested
The paper work doesn’t exist in a vacuum. It must, in fact, support the paperwork and testing supplies as well as the type of packaging used, specimen seals, etc. indicated in the CCF documentation.
What is the purpose of Chain of Custody Forms?
The forms were created in collaboration between representatives of the drug testing industry and the federal government to create a standardized method for ensuring the drug testing process for DOT drivers offers no room for corruption in the process and that authentic results are gathered for people seeking employment under the Department of Transportation’s oversight.
It is a legal document, and tampering with the documents or mishandling them carry stiff penalties under the law. Not only is the information on these documents private and confidential for the specimen donors, but the testing process is necessary to ensure safety for others on the road.
Ultimately, chain of custody documents provide a clear path for the testing process to ensure the samples were not tampered with and to trace any potential problems in the lineage of the samples should something happen to call the integrity of the sample into question or if the sample becomes damaged or tainted along the way.
This is especially the case when used with other supporting evidence the corroborates the lineage of the specimen as matching the documentation provided. This supporting evidence may come in a variety of forms along the way that are gathered and used to authentic the process at every step.
For all these reasons, and more, it is important for testing organizations to follow strict protocols when signing documents, labeling materials, and even shipping items that are part of the chain of custody paper trail for drug testing. By following the precise protocols, every person in the chain protects him or herself and the integrity of the entire chain of custody.
