Last updated: January 23, 2023
The Department of Transportation outlines the process that all safety-sensitive employers must follow in regard to drug testing. The DOT chain of custody documents everyone who handles the test specimen along the way. To make things even more concrete, collectors, lab techs, and MROs record their part of the process on the Custody and Control Form (CCF).
The DOT chain of custody is in place to lessen the chance that an error can occur during the testing process. It helps protect the drivers as well as employers. Drivers who test positive for drugs may not get behind the wheel. Decreasing the risk of errors works to their advantage for sure because not being allowed on the road affects their livelihood in a negative way. The public is safer too. There is little doubt that someone driving while under the influence of drugs in their system could end in disaster.
The purpose of the CCF
The DOT created the CCF to align with the Mandatory Guidelines for Federal Workplace Drug Testing Programs. It’s used to record everyone who comes into contact with the test sample. False-positive or negative results are much less likely because it becomes very difficult to tamper with the sample.
The paper trail or chronological documentation of the process records custody, transfer, control, analysis, and disposal of any physical or electronic evidence. Employers use the chain of command for drug testing in both the safety-sensitive and general workforces. However, a chain of custody is also established 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 part is to be completed by a different party in the drug testing process.
They are:
- 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 to be 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 usually a commercial driver or someone in hopes of becoming a commercial driver. The collector records the driver’s information first thing. Then, they explain the 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 present in the room
- 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 looks for any suspicious behavior before and after the test. They note any observations on the CCF. When the driver returns the sample, the collector checks 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. The sample heads to the lab.
What happens 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 and meet 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 any flaws. If there aren’t any flaws, the MRO signs the CCF off as complete.
If the test result is positive or inconclusive, the MRO contacts the driver. It’s their job to determine if there is a valid reason for this result. A positive drug test result warrants immediate suspension of the driver. The MRO reports the results to the company 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, perhaps. Some flaws are overlooked entirely while others must be corrected before the testing process can proceed.
- Fatal flaws—force the sample to be rejected. It could be due to the sample 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. For that reason, the DOT now allows employers to submit an electronic CCF instead of a hard copy. It helps ensure against errors and speeds up the entire process.
It’s important to note that the DOT changed its Custody and Control Form last year. The new forms went into effect beginning September 1, 2021. The only change to the form was adding an option for oral fluid testing. However, at this time, the DOT hasn’t approved the use of the oral fluid test. Employers must continue to use the urine drug test but we’ll let you know if that changes!
Following the procedure
The CCF form is not difficult to complete. The DOT created it to make the chain of custody process easier to follow.
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) is going to cut down on 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.
Employers are responsible for any third-party agent authorized to handle the company drug testing program. It’s important to obtain a written contract that specifically lists in detail what the agency will provide. Overall, hiring a third-party agent (TPA) lightens your workload. It reduces the margin for error too. They’re familiar with the DOT chain of custody.
