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Are You Meeting This DOT Recordkeeping Requirement?
Mariah Barr
6 mins read

Chain of custody forms are one of the most important federal records to keep in your digital driver files.

Whether you call them “Chain of Custody forms" or "Custody and Control forms," they are essential to any DOT-regulated company's compliance.

Not only are these forms a required component of the DOT drug and alcohol testing process, but they also involve numerous recordkeeping requirements that must be met by motor carriers and companies like yours.

Auditors will often request the forms during compliance reviews – yet many carriers aren't sure what to do with them after their drivers' DOT drug tests are complete. Filing them in a secure, digital location is the best way to ensure you don't put your company at risk for recordkeeping violations or hefty fines. 

Get Your Free DOT  Recordkeeping Checklist

If you don’t have one already, it’s critical that you have a DOT recordkeeping solution in place that includes your drivers’ Custody and Control forms (CCFs). That way, you don't have to worry about using the most up-to-date forms or retaining them for the appropriate amount of time.

Below, we'll cover the purpose of CCFs, the benefits of electronic CCFs (eCCFs), and how the right DOT compliance services can help you keep up with your eCCF recordkeeping requirements.

Chain of Custody Forms Explained

Chain of Custody forms serve as paper trails for drug and alcohol specimen tests. They track the entire collection process, from the moment a specimen is received, to its transfer, analysis, and disposal. According to federal law, these forms must be clear, complete, and concise to ensure accurate results that can be quickly reported and acted on. These forms also serve as legal evidence that reported test results are actually those of a given donor.

These forms also enable Medical Review Officers (MROs) to report positive drug and alcohol violations to the DOT Clearinghouse – a requirement that started in 2020. To make this possible, the Custody and Control form was recently updated to include the driver’s commercial driver’s license (CDL) number. This is now used instead of the driver’s EIN or SSN for identification purposes.

Advantages of Electronic Chain of Custody Forms

Electronic Chain of Custody forms (eCCFs) simplify the process of sending employees for tests by eliminating paper handoffs  not to mention human legibility and transcription errors. If there are mistakes on your paper forms, they may be rejected, and your drivers' tests could be canceled. 

Switch to Digital Drug Testing Forms Now

Electronic forms also allow drug test collections to happen quickly. Working with a third-party administrator (TPA) that uses eCCFs as part of their DOT compliance services streamlines the testing process, from the initial test order to the final result delivery. Since electronic forms can be tracked, you're consistently informed through each step.

Chain of Custody Form Recordkeeping Requirements

When the DOT requires you to use a certain form, it also requires you to keep it in a secure location for a specific period of time. Here are the CCF-related documents you must keep, and for how long.

  • CCFs/MRO results from negative or canceled tests - 1 year from the document date
  • CCFs/MRO results from positive tests - 5 years from the document date
  • Refusal to test records - 5 years from the document date
  • CCFs/MRO results from return-to-duty and follow-up tests (positive and negative) - 5 years from the document date

Click here for a complete checklist of DOT recordkeeping requirements you need to know to prepare for your next compliance review.

Switching to Electronic Chain of Custody Forms

Using DOT compliance software, like Foley’s intuitive platform, makes the transition to eCCFs easy for companies like yours. Once your drivers are enrolled in our DOT drug and alcohol testing program, all forms are automatically stored in the drivers' files, which are accessible from any device. You'll never have to think about whether you’ve maintained all of your drivers’ DOT drug testing records.

With Foley’s DOT compliance services, eCCFs are automatically sent to testing facilities and updated throughout the process. Foley customers also receive real-time test status notifications.

And if you're looking for a DOT pre-employment drug testing solution, take a look at our new hiring, screening, and onboarding software, Dash. Consolidating your hiring and compliance programs is easier than ever.

Remember: custody and control forms are an FMCSA recordkeeping requirement, and you may be asked to provide them during audits. Prepare your company and be compliant!

Foley is here to help with your drug and alcohol testing. Get a free software demo now to ensure you're meeting all federal testing and recordkeeping requirements. Fill out the form below to get started!

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