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What is a Chain of Custody Form & Why Does It Matter?
Scott Mogensen
16 mins read

Becoming a CDL commercial driver means you must be subject to a drug test before you start employment with a new company – as well as at random points during your employment. Since a false positive or false negative could be disastrous for the driver or the safety of the public, a Chain of Custody Form (often abbreviated to CCF) is used to ensure that the chances of false results are minimized.

What is a Chain of Custody Form?

The Chain of Custody Form documents everyone who has handled a drug or alcohol specimen. For the transportation industry, the Chain of Custody form is used for the drug testing of new drivers, and the DOT (Department of Transportation) established this form to align with the Mandatory Guidelines for Federal Workplace Drug Testing Programs.

What is the Chain of Custody Form Used for?

The Chain of Custody Form is used to track all the people who handle and possess a sample between the time it’s collected and analyzed. When the DOT drug test Chain of Custody form is used, false positives and false negatives become much less likely since it’s much more difficult to tamper with the sample.

Chain of Custody Definition

“Chain of Custody” is defined as the paper trail or chronological documentation of a sequence of custody, transfer, control, analysis, and disposal of any physical or electronic evidence. While it’s commonly seen for drug testing, as we’ve seen with the DOT Chain of Custody form above, Chain of Custody forms are also used in supply chain management and criminal cases.

How is the DOT Chain of Custody Form Used?

There are 5 parts to the new DOT Chain of Custody forms, and each part must be filled out by a different party in the drug test process:

  • Part 1: the driver (called a donor)
  • Part 2: the employer
  • Part 3: the collector
  • Part 4: the testing facility
  • Part 5: the MRO (Medical Review Officer)

Step 1: Collection

The Chain of Custody form starts with the donor, which in this case, is the potential (or current) commercial driver. They produce their urine sample and document when it was taken on their copy of the Chain of Custody form. This sample is taken in a controlled environment because the bathroom must meet the following requirements:

  • There must be no available water sources
  • The toilet water must be stained blue so it cannot be used
  • There can’t be any cleaning products in the room (from soap to bleach)
  • The area must be inspected for possible contaminants and secured from hidden contaminants
  • The room cannot be accessed from any outside points

Step 2: The Sample is Collected

The Collector will watch the driver before and after the sample is given for any suspicious behavior, and must note anything they see down on the Chain of Custody form. Once they have the sample in their possession, they check the temperature of the sample as well as volume, coloring, and odor, and note down if they find any abnormalities. If they note anything strange with the sample, it will be sent to a more sophisticated facility for testing.

Before the sample is sent off to a testing facility, the donor must watch the collector pour their sample from the collection container into a specimen bottle and seal it. They’ll then give the donor a certification statement which must be read and signed. The sample will then be sealed and shipped to the testing facility.

Step 3: The Sample Arrives at the Testing Facility

The sample arrives at the testing facility, where it is tested. Once testing is completed, the Chain of Custody form is sent to the MRO.

Step 4: MRO Verification

The MRO receives the completed Chain of Custody form and examines it for any flaws. They then sign off the results and the process is complete.

What Can Get a Urine Drug Screen Chain of Custody Form Rejected?

The Chain of Custody form will be checked at every step of the process to ensure there can’t be any tampering. However, sometimes mistakes are made, which may get the form and test rejected. When this happens, the driver will have to be retested. The potential flaws are categorized as follows:

  • Correctable Flaws: these are honest mistakes that may happen, but shouldn’t seriously hamper the ability of the urine sample to be tested accurately – things like the collector forgetting to sign their name on the Chain of Custody form, for example. Some of these flaws can be overlooked entirely, while others will need to be corrected before testing can proceed.
  • Fatal Flaws: These are problems that force the sample to be rejected. This may be something like the sample arriving with no Chain of Custody form or signs of tampering.

Where Can I Find a Chain of Custody Form Template?

Fortunately, you don’t need to create your own Chain of Custody form for DOT drug tests. You simply use the new DOT Chain of Custody form issued by the DOT.

Where Can I Find a DOT Chain of Custody Form Example?

You can find a sample Chain of Custody form by clicking here. Note that copy 1 of the DOT CCF differs from the other 4 copies, as outlined below. Copy 2-5 all include a section for the Donor to sign.

  • Copy 1: Test facility copy
  • Copy 2: MRO copy
  • Copy 3: Collector copy
  • Copy 4: Employer copy
  • Copy 5: Donor copy

Where Can I Get the New DOT Chain of Custody Form?

You’ll need to contact a Department of Health and Human Services-certified (HHS) laboratory to obtain a new DOT Chain of Custody form. Click here to view a list of HHS-certified laboratories. You can also see an example of the DOT CCF here.

Can the Drug Screen Chain of Custody Form be Filled Out Online?

Since human error is the most common problem with Chain of Custody forms, many companies have started using an electronic Chain of Custody form, instead of a physical copy (often abbreviated to eCCF). This helps ensure there are no errors and speeds up the entire process.

As we talked about in a blog post in late September 2021, the DOT Chain of Custody form has changed as of August 30, 2021, but many companies are still making the mistake of using the old form. Using an electronic Chain of Custody form eliminates this problem.

How do I Know if I’m Using the old DOT CCF or the New DOT Chain of Custody Form?

The new form has an option for oral fluid testing, whereas the old DOT CCF did not. If you look at Step 2 on the form, you’ll quickly see information in bold asking for the type of test and other points regarding the oral fluid test. If you don’t see that, you have the old form.

The New DOT Chain of Custody Forms Have an Option for Oral Fluid Testing. Can We Use That Instead of Urine Testing?

At this time, while the new DOT Chain of Custody forms include the option for oral fluid testing, they have not yet authorized oral fluid testing as a DOT drug testing method and so you cannot yet (as of November 2021) use it instead of urine testing. We’ll update you as soon as that changes.

Can I Use a Simple Chain of Custody Form Instead of the DOT CCF?

No, the DOT CCF form must be used by all employers when they test their employees or potential drivers, whether they’re testing before employment or as a random test. The only time when the new DOT CFF can temporarily not be used is in an emergency and the DOT CCF cannot be accessed.

Is it Better to Use a Physical Chain of Custody Form or an Electronic One?

As with so many aspects of our lives nowadays, moving from the physical urine Chain of Custody form to an electronic one (ECCF) is the best step. It reduces the risks involved with manual handling and speeds up the process. Here are some of the key benefits of using ECCFs over physical CCFs:

  • Reduces human error with hardcopy paperwork – it won’t accidentally get lost or destroyed, and fields that need filling out will not be able to be left blank
  • The software used for ECCFs guides everyone who comes into contact with the form on how to fill it out and what information is needed
  • Reduces the risk of mismatched specimens
  • Since there is no handwriting involved, all text is clear and there can’t be any miscommunication due to illegible handwriting
  • Documents are secure and easily accessed by the relevant parties
  • Less human interaction is needed, reducing the margin for error
  • Fewer overhead costs
  • More eco- and resource-friendly
  • Donor information can be filled out before they arrive at the collection site

How do I Start Using ECCF Forms Instead of Physical CCF Forms?

Instead of searching for and printing out physical DOT drug test Chain of Custody forms, you can work with a full DOT drug testing program like ours which will help you manage the process from start to finish, whether you have 10 drivers or 10,000. Our software manages everything from scheduling to filling out the ECCFs, which is so essential for managing the risk of errors and speeding up the entire process – saving you time and money. To find out more about our DOT drug testing program, click here.

What Does a DOT Drug Test Chain of Custody Form Contain?

The DOT CCF asks for information such as:

  • Donor SSN, employee ID, and/or other identifying numbers
  • Employer name, address, ID number
  • MRO name, address, phone number
  • Relevant DOT agency
  • Testing authority
  • Reason for the test (this will be pre-employment, random, reasonable suspicion, post-accident, return to duty, follow-up, or other)
  • Which drugs will be tested for
  • How the sample was collected and any remarks about the sample

After this, the CCF simply requires signing by each person in the Chain of Custody and the result of the drug test.

Is it Ever Okay to Use a Non-DOT Chain of Custody Form for a DOT Drug Test?

Only in extreme circumstances, such as after an accident or for a reasonable suspicion test and there’s not enough time to get the appropriate DOT CCF. With ECCFs that’s not a problem, but most of these circumstances will be in the hands of the law, and not employers, so it’s not something you need to worry about.

If you have any of the old DOT Chain of Custody forms, throw them away so you won’t accidentally use the old form.

How to Fill Out a Chain of Custody Form

You can find complete instructions for completing the Federal Drug Testing Custody and Control form here, but don’t fret – it’s not as intimidating or involved as it looks, especially for drivers and employers. If you are a Collector, check the instructions linked above. For employers:

  1. Enter the employer name, address, and ID number
  2. Enter the MRO name, address, phone number, and fax number (the Collector may do this step for you)
  3. Enter the Donor (AKA driver) SSN, Employee ID, or CDL state and number
  4. Specify the testing authority (either HHS or NRC)
  5. Specify DOT agency (FMCSA, FAA, FRA, FTA, PHMSA, or USCG)
  6. Specify the reason for the test (Pre-employment, random, reasonable suspicion, post-accident, return to duty, follow-up, or other)
  7. Specify drug tests to be performed (either THC, COC, PCP, OPI, and AMP, or THC & COC Only, or Other)
  8. Enter the collection site address and contact information

If using a physical copy, you’ll need to fill in this information on all 5 copies.

Your (potential) employee will also need to complete the donor section (step 5) on copies 2-5:

  1. Sign to certify that all details are correct
  2. Print their name
  3. Fill in the date
  4. Enter their email address
  5. Enter a daytime phone number and evening phone number
  6. Enter date of birth

The donor should then retain their copy (copy 5).

Once all this information has been entered, the rest of the form will be filled in by the Collector, Testing Facility, and MRO (Medical Review Officer).

Streamline Your DOT Drug Testing Workflow

Once you understand what the DOT CCF is, how it works, and how to fill it out, the process is simple. The biggest issue is usually the time it takes to do all the paperwork, especially when you have tens, hundreds, or even thousands of drivers. The best way to cut down on the time it takes to schedule tests and complete paperwork is to move to an online platform. Our DOT Drug Testing program streamlines the process and removes a large margin for error. To learn more about how it can work for you, click here.

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