New CCF With Oral Fluid Approved
We are coming up on a year since SAMHSA published their final Mandatory Guidelines for the use of oral fluid drug tests for Federal Workplace Drug Testing programs. The final guidelines published in October of 2019, paved the way for the use of lab-based oral fluid drug tests for Federal employees. An article, “An Overview of SAMHSA’s Oral Fluid Testing Guidelines, published in DATIA’s Focus magazine last Spring, predicts that 7% of federal drug tests will ultimately transition from urine to oral fluid within the first year of its implementation. That same article made a similar rate of adoption prediction for DOT employees once oral fluid drug testing is approved for DOT testing. I encourage you to read the article for more in depth insights on oral fluid testing.
The revised Federal Custody and Control Form to include the oral fluid test medium was approved by the Office of Management and Budget on 8/17/2020 and on 8/31/2020 the DOT published a guidance document discussing the changes and the continued use of the old form.
Federal CCF Approved Revisions
Here is a list of approved changes to the CCF that collectors should be aware of:
- Step 1 references the CDL state of issuance and number on line C where the technician enters the donor identification.
- Step 1 includes an “other” field to the Collector information, which can be used to document the collector’s email address.
- Step 2 allows the collector to specify urine or oral fluid as the testing medium. If oral fluid is the chosen testing medium, the collector must document a few things relative to the collection of oral fluid. For example, the testing technician must confirm if the device is within the expiration date and if the required volume of saliva was collected.
- The instructions for completing the CCF are removed on the back of copy 5 and are now posted on the SAMHSA and ODAPC websites.
Using the New CCF
At this time oral fluid drug testing is approved only for federal employees falling under the HHS, and is not yet approved for employees falling under the jurisdiction of the Department of Transportation (DOT). Service agents may continue to use the old CCF until 8/30/2021, at which time, they must fully transition to the use of the new form. According to the ODAPC website, the new CCF may be used beginning 8/1/2020. However, many labs do not yet have the new forms in their inventory or know when they will have them available. The ODAPC’s guidance document advises laboratories to delay mailing the revised CCFs to DOT-regulated clients and their service agents until after June 1, 2021. Delaying the availability of the revised CCF to DOT-regulated employers and their service agents avoids confusion regarding whether oral fluid testing is authorized in the DOT program, and it allows existing supplies of old CCFs to be depleted.