In industries regulated by the federal government, maintaining a drug-free workplace isn’t just a recommendation — it’s a legal requirement. Ensuring the accuracy, integrity, and accountability of every drug test is essential, especially in sectors where safety is critical. At the heart of this process lies the Federal Drug Testing Custody and Control Form (CCF) and the concept of the chain of custody.
Whether you’re an employer, HR professional, safety manager, or employee subject to testing, understanding this form and the chain of custody process can help protect your organization from compliance issues, legal risk, and unsafe practices.
What Is the Federal Custody and Control Form (CCF)?
The Custody and Control Form is a standardized, multi-part document required for federally regulated drug testing programs — such as those overseen by the Department of Transportation (DOT) and other government agencies. It documents every step in the handling of a urine specimen, from collection through testing and final result reporting.
It’s important to clarify that the CCF isn’t a drug test itself. Rather, it supports the drug test by documenting the chain of custody — the complete and unbroken history of the specimen’s handling.
Why Is the Chain of Custody Important?
The chain of custody refers to the formal process of tracking and documenting the collection, transfer, testing, and storage of a drug test specimen. This meticulous documentation is vital for:
Ensuring sample integrity: Preventing mix-ups, contamination, or tampering.
Maintaining legal defensibility: Offering a clear, traceable history of the sample’s journey.
Protecting employers and employees: Ensuring results are accurate and reliable in hiring, disciplinary, or legal actions.
Without a properly executed CCF and an unbroken chain of custody, a test result may be considered invalid or inadmissible in court or employment decisions.
Who Uses the Custody and Control Form?
The CCF is mandatory in federally regulated testing programs, particularly for:
Commercial motor vehicle drivers (CDL holders)
Pilots and aviation workers
Railroad and transit employees
Maritime industry personnel
Pipeline and hazardous materials workers
Federal employees under the Drug-Free Workplace Act
Many private companies outside of federal mandates also choose to use the CCF and chain of custody drug test procedures to ensure high-quality, legally sound drug testing.
Key Components of the Custody and Control Form
The CCF includes five separate copies, each distributed to different stakeholders:
Copy 1 – Laboratory Copy: Sent to the lab with the specimen.
Copy 2 – Medical Review Officer (MRO) Copy: Used for reviewing and confirming results.
Copy 3 – Collector’s Copy: Retained by the collection facility.
Copy 4 – Employer Copy: Given to the employer for records.
Copy 5 – Donor Copy: Provided to the person being tested.
Information documented on the form includes:
Donor identification and consent
Collection site and collector details
Sample temperature and volume
Specimen ID numbers and seals
Date/time of each handling step
Final test results and MRO review
This detailed record ensures the process is transparent, traceable, and compliant with federal standards.
The Federal Drug Testing Process: Step-by-Step
Understanding the step-by-step process helps illustrate the importance of the CCF and chain of custody:
1. Identification and Preparation
The donor arrives at the testing site and provides valid photo identification. The collector begins completing the CCF and explains the testing process.
2. Specimen Collection
The donor provides a urine sample in a secure environment. The collector immediately checks the temperature and volume to ensure validity.
3. Sample Splitting and Sealing
The sample is split into two containers: Bottle A (primary) and Bottle B (split sample). Both are sealed with tamper-evident tape and labeled with barcodes that match the CCF.
4. Chain of Custody Initiated
The collector and donor both sign the CCF. Any handoffs, such as to couriers or lab personnel, are documented with names, dates, and times.
5. Laboratory Testing
The lab screens the sample and performs confirmation testing if necessary (e.g., using GC/MS methods). The lab fills out its portion of the CCF.
6. MRO Review
The Medical Review Officer, a licensed physician, reviews the test results. If results are positive or unusual, the MRO may contact the donor for an explanation before reporting the final result to the employer.
Paper vs. Electronic CCF (eCCF)
Traditionally, the CCF was a physical paper form. However, many organizations are now using the Electronic Custody and Control Form (eCCF), which digitizes the entire process.
Benefits of eCCF include:
Fewer administrative errors
Faster result reporting
Streamlined compliance audits
Improved data security
The DOT fully authorizes the use of eCCF for all federally regulated drug testing programs, making it a modern and efficient solution.
Consequences of a Broken Chain of Custody
Even a minor error — such as a missing signature or incorrect seal — can break the chain of custody. Consequences may include:
Test result invalidation
Re-testing delays
Legal disputes or grievances
Non-compliance penalties for employers
That’s why it’s essential to train all personnel involved in the drug testing process on proper CCF usage and documentation procedures.
Final Thoughts
The Federal Drug Testing Custody and Control Form and the chain of custody process are not just bureaucratic steps — they are critical tools in ensuring fair, accurate, and legally defensible drug testing. In DOT-regulated industries, where safety and compliance are non-negotiable, the CCF offers peace of mind to both employers and employees.
Whether you’re a small business owner, a transportation safety manager, or a worker in a regulated industry, understanding the role of the CCF can help you stay compliant and confident in your testing program.