A reminder to drug and alcohol screening businesses, collectors, TPAs and other involved in drug screening: If you conduct U.S. Department of Transportation mandated testing, the 2017 federal Custody and Control Form expires at the end of August 2021. The new (2020) CCF will be the standard form for use after this time.
However, this does NOT mean you can’t use the older CCF for your collections, if that is what you have available. You may still use the expired CCF, when you attach a collector’s memorandum for record or MFR to the CCF. The MFR will prevent the test from being cancelled due to use of an incorrect form. So if you have a file cabinet filled with 2017 CCFs, don’t recycle them yet. But do have MFRs ready to be attached to the CCF so you are prepared and your tests aren’t cancelled.
The MFR must contain the following information:
- All relevant collection information including collector’s name, date, collection site, specimen ID number, contact information, etc. (For Federal Motor Carrier Safety Administration (FMCSA) testing include the donor’s driver’s license number and issuing state.)
- An explanation for the use of the expired CCF, stating that it was the only means available for conducting federal testing and that it includes all information required for a valid DOT drug test.
- Signature certifying the information provided.
NDASA has developed a sample MFR that our members can use. If you create your own MFR, we suggest that you use similar language as consistency will help ensure that you provide all information required to ensure acceptance of the test by federal authorities despite use of the older CCF.