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Start Using Revised Custody and Control Form by August 30


The U.S. Department of Transportation (DOT) published a reminder notice on August 10th that employers and service agents must start using the revised Federal Drug Testing Custody and Control Form (CCF) by August 30, 2021.

Employers and service agents (collectors, laboratories, medical review officers) must use the CCF for DOT-regulated drug tests. 

Revised CCF

The CCF was revised to accommodate the use of oral fluid specimens for the federal drug-testing program. However, it is important for employers and service agents to know that oral fluid testing is not authorized in the DOT’s drug-testing program. 

The Office of Management and Budget, which approved the revisions to the CCF, allowed employers to continue using the old form until Aug. 29, 2021. Employers or service agents that use the old form after Aug. 29, 2021, will have to complete a memorandum for the record (MFR) or the test will be canceled.

An MFR is a signed statement declaring that an incorrect form was used inadvertently, or as the only means of conducting a test in circumstances beyond the employer’s control. The MRF declares that the incorrect form contains all the information needed for a valid DOT drug test.

Employer Responsibilities

DOT-regulated employers and service agents should review their drug testing reporting and recordkeeping procedures and practices to ensure the revised CCF is used by Aug. 30, 2021.

Material posted on this website is for informational purposes only and does not constitute a legal opinion or medical advice. Contact your legal representative or medical professional for information specific to your legal or medical needs.

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