Last updated : March 24, 2025
The purpose of the Department of Transportation (DOT) chain of custody procedures is to ensure the integrity of the department’s numerous rules and regulations. These are in place to provide safe travel for the public traveling within the United States. Employers of the safety-sensitive workforce are mandated to follow the DOT’s policies and procedures to the letter to avoid costly penalties and fines.
For instance, the DOT outlines the process that all safety-sensitive employers must follow regarding drug testing. Employers of the safety-sensitive workforce and others involved in the procedure must adhere strictly to the DOT chain of custody process. Making things even more concrete, collectors, lab techs, and MROs record their part of the information on the Custody and Control Form (CCF).
This DOT chain of custody is in place to lessen the chance of errors during the testing process. It helps protect both drivers and employers. Drivers who test positive for drugs are immediately removed from duty. Decreasing the risk of error works to their advantage too because not being allowed on the road negatively affects their livelihood.
The CCF provides a trail
The DOT created the CCF to align with the Mandatory Guidelines for Federal Workplace Drug Testing Programs. Broken into sections, the form records the actions of everyone who comes into contact with the test sample. False-positive or negative results are less likely to occur because it makes it difficult to tamper with the sample.
The “paper” trail records physical or electronic evidence of the custody, transfer, control, analysis, and disposal of DOT drug test specimens. Employers use the chain of command for drug testing in the safety-sensitive and general workforces. Law administrators establish their own chain of custody for use in criminal cases or for supply chain management.
Breaking down the process
There are five parts to the DOT Chain of Custody forms. Each party that handles the specimen completes a specific area of the CCF as they perform their part in the drug testing process.
The specific sections to complete are as follows:
- Part 1 is driver (referred to as donor) information.
- Part 2 is employer information.
- Part 3 is collector information.
- Part 4 is the testing facility information and results.
- Part 5 is then completed by the Medical Review Officer (MRO).
There are four steps in the DOT drug testing process.
Collection
The CCF starts with the donor, who is either a commercial driver or someone hoping to become a commercial driver. The collector records the driver’s personal information upon their arrival at the designated test site. Then, they explain the entire process and provide the donor with a specimen cup. They accompany them to the assigned restroom.
The room must meet the following requirements:
- No available water sources
- Blue-stained water in the toilet
- No cleaning products are available
- Regularly inspected for possible contaminants
- No outside access from other points
The donor produces their urine sample and returns it to the collector. The collector records the time on the CCF.
The sample
The collector is watchful for any suspicious behavior before and after the test. They note any observations they make on the CCF. When the driver returns the sample, the collector documents the temperature to ensure it’s within the limits. They also note the volume, coloring, and odor recording any abnormalities observed. If anything seems out of order, the sample may go to a more sophisticated facility for testing.
The driver watches the collector pour their sample from the collection container into a specimen bottle. The collector seals the bottle with a strip. The driver, then, initials and dates it. The driver reads and signs a certification statement. They return to work and the sample heads to the lab.
What’s the process at the lab?
Only laboratories approved by the Substance Abuse and Mental Health Services Administration (SAMHSA) can process DOT drug tests. These laboratories undergo rigorous inspections to maintain extremely high standards.
When the sample arrives at the testing facility, it undergoes a simple test to determine if the result is positive or negative. A negative result completes the test. Positive results or those that raised a “red flag” for one reason or another undergo a second, more comprehensive test. This test determines the type of drug in the system and records the drug level found.
The CCF and test results go to the MRO next.
The Medical Review Officer
The company’s chosen MRO receives the form and examines it for flaws. If there aren’t any flaws, the MRO signs the CCF off as complete.
The MRO contacts the driver if the test result is positive or inconclusive. After speaking with the driver, it’s their job to determine if there is a valid reason for an inconclusive result. A positive drug test result warrants immediate suspension of the driver. The MRO reports the results to the company’s Designated Employer Representative (DER).
What causes a CCF rejection?
Each person in the chain of command inspects the CCF for errors or signs of tampering. Even so, sometimes humans make mistakes. If that’s the case, the driver must retest.
The two flaws that warrant retesting are:
- Correctable flaws—These are honest mistakes that happen occasionally, however, they shouldn’t hamper the ability of the lab to test the sample accurately. These include things like the collector forgetting to sign their name to the CCF. Some flaws are entirely overlooked while others must be corrected before the testing process can proceed.
- Fatal flaws—These flaws force the sample to be rejected. It could be due to the specimen arriving without a CCF form attached or due to signs of tampering.
Electronic recording
The DOT determined that human error was the most common problem with the DOT chain of custody process. Now the DOT allows employers to submit an electronic CCF (eCCF) instead of a hard copy. It helps ensure against errors and speeds up the entire process.
The DOT changed its Custody and Control Form to provide an option for oral fluid testing. However, employers must continue to use the urine drug test only. Currently, there aren’t any SAMHSA-approved laboratories to process the specimens. Of course, you can count on us to let you know when that changes!
Following the procedure
The DOT created the CCF to make the chain of custody process easier to follow and it’s simple to complete.
The most time-consuming part of the process is completing all the paperwork, especially if you employ hundreds or even thousands of drivers. Switching to the electronic CCF (eCCF) cuts the time factor. You can also move completely to an online platform. Many drug testing companies, like ours, for instance, offer programs that streamline the scheduling and testing process taking it completely out of your hands.
Employers are responsible for any third-party agent authorized to handle the company’s drug testing program. It’s important to obtain a written contract that specifically details what the agency provides. Overall, hiring a third-party agent (TPA) lightens your workload. Moreover, because they follow the DOT chain of command, it reduces the margin for error.
