Understanding Revised CCF (Drug Testing Custody and Control Form)

Following the August 8, 2017 announcement by the Department of Health and Human Services (HHS) that the Office of Management and Budget had approved the revised Federal Drug Testing Custody and Control Form (CCF); there has been widespread misinformation with regards to the specific changes that have been made and the people to be affected by the said changes. This is particularly true with employers hiring safety-sensitive Department of Transportation (DOT) employees. The aim of this article is to put the record straight.

Understanding CCF

CCF is a document or paper trail showing the steps of collecting and analyzing a human specimen test. The steps include seizure, custody, transfer, control, and analysis. It also indicates the disposition of the electronic and physical evidence of the human specimen test. All drug tests must include the CCF to ensure the integrity of the process and the specimen under scrutiny.

What Are the Changes Made in the Revised CCF?

The just approved HHS revision has affected the following areas of the CCF.

1. The hash line in front of the text “Specify DOT Agency,” the letters “DOT,” and the checkbox have been removed in step 1D. This is clearly a cosmetic change.

2. In step 5A, four new analytes have been added. They include oxycodone, hydrocodone, hydromorphone, and oxymorphone. However, analyte methylenedioxyethylamphetamine (MDEA) has been removed. Clearly, these changes are substantive, and their effects are far-reaching.

What Are the Effects on DOT-Regulated Employees?

Earlier this year, DOT started the process of amending its regulations concerning drug testing. The aim was to harmonize their regulations with the HHS revised mandatory guidelines for drug test programs for urine testing. However, the Department of Transportation is yet to issue a final verdict to authorize the inclusion of new synthetic opioids in the revised testing. Consequently, if you are a DOT regulated employer, you really don’t have to use the revised CCF for testing in accordance to 49 CFR, Part 40. Nevertheless, If testing is done accidentally using the revised CCF but in a manner that is consistent with Part 40, the verification and the reporting done by the review officer will have to be consistent with Part 40.

The Takeaway

In a nutshell, the Non-DOT regulated employers can still use the old CCF until June 30, 2018. Furthermore, it is apparent that the DOT regulated employers do not have to use the revised CCF; they can continue using the CCF that has been in use since 2010. However, this may change in future once the DOT issues a verdict with regards to synthetic opioids tests.