Understanding DOT Drug Testing & Custody and Control Forms

For anyone working in a safety-sensitive position under DOT regulations, understanding drug testing procedures is crucial. One of the key components of this process is the Custody and Control Form (CCF), a federal document that plays a major role in tracking and verifying drug tests. Let’s break down why this form matters and how it impacts follow-up testing, employer recordkeeping, and specimen tracking.

Follow-Up Testing: A Critical Piece

If an employee has undergone DOT-required drug testing, follow-up testing may be required. The challenge comes when a new employer cannot obtain the previous follow-up test records from the employee's former employer. If that happens, the follow-up testing must start over from scratch, which can be a hassle for everyone involved.

Pro Tip: Employees should always keep copies of their Custody and Control Forms from previous tests. These documents prove follow-up testing history and help ensure the correct testing schedule continues without unnecessary repetition.

How Specimens Are Tracked

Some employees worry that drug testing is personally targeted or manipulated against them. However, that’s not how the system works.

Here’s what you need to know:

1. When a specimen is collected, it is not labeled with the employee’s name. Instead, it is assigned a unique barcode for tracking.
2. The specimen is then sent to the lab using this barcode, not any personal identifiers.
3. This process ensures privacy and accuracy, preventing any tampering or bias.

DOT vs. Employer Tests: What’s the Difference?

Sometimes, there’s confusion about whether a drug test falls under DOT regulations or an employer’s internal policy.

Example: A Federal Motor Carrier post-accident test without a citation is considered an employer test, not a DOT test.

One important detail to check is whether the test was performed using a federal Custody and Control Form (CCF). If it was, many Designated Employer Representatives (DERs) will process it as a DOT test, even if there’s debate over its classification.

Latest Updates & CDL Tracking

The most recent version of the DOT Custody and Control Form (released August 2020) includes a new identification method: CDL Numbers instead of Social Security Numbers, making the tracking process more secure and standardized for Federal Motor Carrier Safety Administration (FMCSA) employees.

One important rule: The employer must specify the correct regulatory agency (e.g., FMCSA, Pipeline and Hazardous Materials Safety Administration). A test cannot be marked as both FMCSA and Pipeline — it must be one or the other.

Testing Methods: Urine vs. Oral Fluid

Currently, all DOT drug testing is conducted using urine samples. The standard urine collection kit includes:

1. A sealed and wrapped collection bottle
2. Two shipping bottles for split samples
3. Leak-resistant shipping bags

If the urine sample is too low or leaks during transport, the test may be canceled, which creates major problems.

Key Rule:

1. Random drug tests: If canceled, they do not have to be repeated.
2. Return-to-duty and pre-employment drug tests: These cannot be canceled — the employer must have a result to proceed with hiring or reinstating an employee.

While DOT has not yet approved oral fluid testing, the CCF already includes a section for it, as oral fluid tests have been used for federal employees for years. DOT regulations will eventually be updated to align with federal employee testing standards.

Final Advice: Keep Your Forms Organized

Given how critical drug testing records are, Substance Abuse Professionals (SAPs) strongly recommend that employees store copies of their Custody and Control Forms in a personal file. Having these documents readily available can:

1. Prevent unnecessary repeat tests
2. Confirm compliance with follow-up testing schedules
3. Provide proof of DOT-related drug test results

Drug testing compliance may seem complicated, but staying informed and organized makes it much easier to navigate. If you’re in a DOT safety-sensitive role, make sure you understand how your tests are tracked, categorized, and recorded — it can save you from potential headaches down the road.