New DOT Chain of Custody Form (CCF) Required July 1, 2018

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On January 1, 2018, the Department of Transportation made changes to its drug testing panel that modify 49 CFR Part 40. The final ruling aligns the DOT panel with the Department of Health and Human Services (DHHS) panel changes that went into effect on October 1, 2017.

The revised change mandates that DOT regulated programs test for additional Schedule II substances including hydrocodone, oxycodone, hydromorphone and oxymorphone. It also added methylenedioxyamphetamine (MDA) as an initial analyte and removed testing for methylenedioxyethylamphetamine (MDEA).

DOT will still refer to the updated drug panel as a 5 panel but opiates will now be referred to as opioids. Adding these semi-synthetic opioids is intended to help address the nationwide epidemic of opioid abuse and help detect a broader range of drugs being used illegally.

As part of the changes, the Office of Management and Budget (OMB) revised the Federal Drug Testing Custody and Control Form (CCF). While the panels were automatically updated on January 1, 2018, you do not need to start using the new chain of custody forms until July 1, 2018. If old CCFs are used after Jun 30, 2018 a memorandum must be completed for the records per §40.205(b)(2).

What is the difference between the new and old CCF?
In Step 1D: there are minor cosmetic changes including removal of the checkbox, the letters “DOT” and hash line in front of the text “Specify DOT Agency”

In Step 5A: the addition of the four new analytes and removal of the methylenedioxyethylamphetamine (MDEA)

What should I do to prepare for the new form?
You can continue using your old forms until July 1, 2018. LabCorp customers will receive a small quantity of the new forms automatically in the coming months which will be shipped to the address listed on the chain of custody form. Quest Diagnostics will not be shipping the new forms, but you can reach out to Quest directly for these forms or your third-party drug testing partner.


Dr. Todd Simo

Dr. Simo is the Chief Medical Officer and the Managing Director of Transportation at HireRight. He served as HireRight’s Medical Director starting in 2009 and was promoted to Chief Medical Officer in 2015. Dr. Simo was also appointed to the role of Managing Director of Transportation in 2018. Dr. Simo came to HireRight with a decade of experience in the medical consulting arena. Before that he was Medical Director at an occupational health clinic in Virginia and owned a consulting firm providing medical director services to employers across the United States.

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