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DOT Drug Testing Trends That All Fleet Managers Should Be Aware Of
Mariah Barr
7 mins read

Important updates on oral fluid testing, electronic custody and control forms, and the FMCSA Clearinghouse.

Keeping up with the latest DOT drug testing requirements can feel like a daunting task. That's why partnering with a third-party administrator like Foley makes a lot of sense. We'll always have your back.

Below, we've rounded up some of the biggest drug testing trends in 2024 that we're keeping a close eye on, including . . .

    The status of oral fluid testing with the DOT

    The expansion of electronic forms  

    Update to the new Custody and Control Form

    Recent DOT Clearinghouse updates

DOT Drug Testing Trends: Oral Fluid Testing

The FMCSA issued a Notice of Proposed Rulemaking in February 2022 "to amend its transportation industry drug testing program procedures regulations, 49 CFR part 40, to include oral fluid testing."

If approved, the rulemaking will give DOT-regulated companies more drug testing options. We've been getting lots of questions about oral fluid testing ever since it was included on the updated Custody and Control Form (more on this below).

Oral fluid testing offers several key advantages:

    Supervised mouth swabs make cheating next to impossible

    Employees don't need to go to a lab for testing

    Faster turnaround times

    Less expensive than urine testing 

    Similar look-back window to urine, but offers even more immediacy since it can detect certain drugs in as little as 30 to 60 minutes after ingestion

PRO TIP: Consider adopting oral fluid testing in addition to urinalysis as part of your drug testing policy for non-DOT jobs. This way, you'll be able to hit the ground running when DOT approval happens.

DOT Drug Testing Trends: Expansion of Electronic Forms

Although Custody and Control Forms have gone digital, other drug and alcohol testing forms are still on paper. The transfer of alcohol test results and affidavits may soon be electronic as well.

What is an electronic Custody and Control Form (eCCF)?

An eCCF is an electronic version of the five-paper Custody and Control Form. Forms are filled out and electronically sent to the collection site, eliminating the need for paper.

Why the push to electronic forms?

Electronic forms offer several key benefits:

  • Increased accuracy (no legibility issues)
  • No danger of lost or damaged forms
  • Greater security
  • Faster turnaround times – by as much as 25%
    Switch to Digital Drug Testing Forms Now

PRO TIP: Not all labs currently accept the electronic Custody and Control Form. So even if you go electric (and you should), you'll need to have paper versions of the new CCFs on hand for a while.

DOT Drug Testing Trends: Update on the New Custody and Control Form (CCF)

On August 17, 2020, the Office of Management and Budget (OMB) approved the revised Federal Drug Testing Custody and Control Form (CCF). Originally, carriers had until August 30, 2021, to adopt the new form. Because of pandemic-related staffing and supply shortages, however, the timeline to transition to the new forms was pushed back until August 31, 2023.

What changed:

  • Most of the changes on the revised CCF were to accommodate the use of oral fluid testing for non-DOT federal drug tests.
  • The new form also includes driver identification fields so that non-negative tests can be reported to the DOT Clearinghouse

PRO TIP: If you want to take advantage of oral fluid testing once it's approved, you'll want to switch to the new CCF now.

How can you tell if you're already using the new form?

If you can answer "yes" to the following questions, you're using the most up-to-date Custody and Control Form. (See the highlighted sections in the image below.)

  • Does Step 1 ask for the donor's SSN or CDL number?
  • Is "oral fluid" testing referenced in Step 2?

DOT Drug Testing Trends: Updates to the FMCSA Clearinghouse 

As of January 6, 2023 . . .

    Companies no longer need to reach out to prior employers to confirm three years' worth of Safety Performance History data

    Companies no longer need to keep external records of Clearinghouse queries

As of March 8, 2023 . . .

    The Clearinghouse will notify employers via email if there is a change to a driver's Clearinghouse record for up to 12 months following a pre-employment or annual Clearinghouse query. Info on a driver's record that would trigger the notification includes new drug or alcohol violations, removed violations, and updated return-to-duty status.

Are you compliant with the new  safety performance history requirements?

PRO TIP: Consider implementing MVR monitoring to avoid an 11-month gap in violation knowledge, especially for drivers who may work for multiple carriers. 

As of November 18, 2024 . . . 

✔ The CDLs and CLPs of drivers with "prohibited" statuses in the FMCSA Drug and Alcohol Clearinghouse will be revoked until they have completed the return-to-duty process. Read more about this update here.

DOT Drug Testing Trends: Now's the Time to Work with a Partner

As illustrated above, DOT-regulated companies have faced significant changes in drug testing regulations over the last few years—changes with many nuances that are easy to overlook.

If you're not currently working with a drug testing partner, now's the time to do so. Look for a partner with an excellent reputation AND an online compliance solution that . . ..

    Alerts you when drug tests are due (or results are in)

    Takes advantage of the eCCF process whenever possible

    Helps you find eCCF-enabled collection sites in your driver's area (when possible)

    Provides maximum data security

At Foley, we stay on top of industry changes so we can advise our customers about the ones that are relevant to their DOT drug testing program. Plus, we have a fully electronic drug and alcohol testing solution that's 100% DOT compliant.

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