An important date is coming up for employers, hiring managers, and HR professionals. The current version of the Federal Drug Testing Custody and Control (CFF) forms expires June 30, 2018.
Simply put, this means that neither DOT-regulated employers nor their service agents (labs, collectors or Medical Review Officers) can use the “old” CCF form for mandated DOT drug testing after June 30, 2018. The old CCF form dates back to 2010.
The revised form has been updated in two ways:
- Step 1D is a superficial change. It removes the checkbox, the letters DOT and the hashtag where it asks “Specify DOT Agency.”
- Sept 5A adds four new substances - hydrocodone (HYC), hydromorphone (HYM), oxycodone (OXYC) and oxymorphone (OXYM). It also removes methylenedioxyethylamphetamine (MDEA).
What will happen if you inadvertently use the old form after June 30, 2018? If you realize that an old form has been submitted but it contains all of the required information for a DOT drug test, then you need to submit a signed statement known as a memorandum for the record stating that the old form was accidentally used or was the only form available because of circumstances beyond your control. In your statement, it should also include the steps that your company has taken to assure that the correct form is used in the future. Further requirements include that the test was conducted in accordance with 49 CFR Part 40 rules at an HHS-certified laboratory. You must provide this statement on the same day as you receive notice and send it via fax or courier.
It’s important to point out that not using the correct forms will result in additional paperwork and extensive delays in getting employees back to work.
To obtain the new forms, contact your USA Mobile Drug Testing representative, and once you have them, you need to ensure that all forms, both in the office and in drivers vehicles are removed and destroyed.
Now is a good time to for hiring professionals and Human Resources managers to review the new Department of Transportation rules that went into effect in 2018. The new CCF reflects the changes so you might want to update your department in a meeting before the first of July. Virtually all of the changes were prompted by the opioid crisis and adds the semi-synthetic prescription pain medications that are at the forefront of the crisis we face in the United States today. The 2018 law adds hydrocodone, hydromorphone, oxycodone and oxymorphone (commonly known as Dilaudid, Lortab, Norco, OxyContin, Percocet and Vicodin) to the substances being tested in addition to amphetamines, cocaine, codeine, heroin, morphine and phencyclidine (PCP). These four synthetic prescription painkillers are the prescription drugs most likely to be abused.
A review of your drug testing policies and procedures would be wise now as your company transitions to utilizing the new CCF reporting form. If you haven’t updated your drug policy since these new substances were added, update your written policy and provide every employee with a copy.
Now is the time to ensure that you’ll have the new CCF report forms before the June 30, 2108, deadline.