What is a Chain of Custody Form?

Everyone in the transportation industry should be aware of the procedures mandated by its governing body, the Department of Transportation. One such system is the chain of custody form (commonly abbreviated to CCF) for drug test results for drivers. By issuing a federal forensic drug testing custody and control form, collected specimens can be carefully monitored for any potential tampering. A federal drug testing custody and control form allows you to know who handled a specimen from the point of collection in a drug test until the final result is delivered. Today, we’re going to break down what is a chain of custody form, drug test processing, and why you should switch from analog delivery to digital to save your business money and be able to hire drivers faster.  

What is a Chain of Custody Form? 

A chain of custody form is an official document that creates a paper trail of everyone who’s handled a particular specimen. Within transportation, you’ll encounter chain of custody drug testing forms whenever you request that an applicant for an open position get a screening. Referring to a DOT chain of custody drug test, the process is to notate the custodianship of a specimen from the point of collection until a medical review officer has analyzed and delivered the results. The risk of false results drops sharply when this form is accurately filled out. The DOT has established this framework in accordance with the Mandatory Guidelines for Federal Workplace Drug Testing Programs. A chain of custody form ensures that the process is followed and conducted correctly.  

The 5 Copies of a Chain of Custody Form

There are usually five copies to a federal chain of custody form, listed as:

• Copy 1 – Test Facility
• Copy 2 – MRO
• Copy 3 – Collector
• Copy 4 – Employer
• Copy 5 – Donor

Collection

The process begins with a donor providing the collector with their sample. The collector has several duties to ensure the integrity of the test. Once the specimen is collected, it is documented on the CCF.

Test Facility

Once the collector delivers the specimen to the lab, it then goes through another review process to identify potential flaws that may have occurred during the testing process. If the flaw is correctable, they attempt it. Otherwise, it’s rejected. After testing is completed, they send it to the MRO with Copy 1 filled out. 

MRO

The MRO will once again go through the chain of custody form, looking for any flaws. The test will either be verified or rejected. If verified, the MRO will interview the donor and send the results to the employer.  

Chain of Custody Procedures

The chain of custody begins with the collector. Before they begin the collection process with the donor, they must:

• Restrict and secure any accessible water sources
• Ensure that all toilet water is stained blue
• Remove any soap or cleaning agents from the room
• Inspect the area for any possible contaminants 
• Ensure that the room is free from hidden access points
• Secure the area from hidden contaminants
• Recheck the area for continued integrity

During the collection process, the collector must be aware of the donor’s behavior and appearance. Anything out of the order will be recorded. If the donor clearly demonstrates they are attempting to tamper with the specimen, the collector records the behavior and will then need to follow SOP (standard operating procedures).  After receiving the specimen, the collector will check the temperature, volume, coloring, odor, and whether there are any anomalies. If anything outside of an acceptable range is present, the test will not be sent to an Instrumented Initial Testing Facilities (IITF) but rather to an HHS-certified laboratory for testing. If the donor was not able to produce a specimen, the collector will record this as well. After the donor watches the collector pour the specimen from the collection container into the specimen bottle and seals it, the donor will be instructed to read the certification statement. Once read, the donor will be expected to sign the document. If they refuse, this will also be recorded on the CCF.  The specimen is then sealed with the CCF and shipped out.   

Flaws in the Chain of Custody Form

As you can see, the CFF is thoroughly checked throughout the process. However, at any point in the system, a flaw can occur. These flaws are categorized to determine if it’s correctable or if it warrants rejecting the specimen. They are as follows:

Correctable Flaws 

For example, if the collector forgot to sign their name on the CFF. If the collector submits a signed form that the specimen details are accurate, then testing can proceed.

Fatal Flaws

This would include a specimen not having an attached CFF. In this case, the specimen will be rejected.

Flaws that Need to be Corrected to Proceed

Flaws of this nature tend to be clerical, such as inputting a mixed-up social security number. Once corrected, the testing can continue.

Flaws that Don’t Need to be Corrected to Proceed

This type of error can be the result of a courier’s name being incorrect on the CFF. This doesn’t necessarily require correction and the testing can proceed. However, actions may be taken against the courier.

Chain of Custody Form Error Causes

The reason behind any of these issues is usually the result of human error. Usually, it’s the omission or mislabeling of information on the CFF. These types of errors are usually correctable and won’t hamper the testing procedures. However, there are instances of tampering or intentional mishandling of the test specimen.  In the case of intentional tampering, everyone in the chain, from the courier to the MRO, needs to stay vigilant to spot these errors.  

What is ECCF?

To help combat the most common issue of human error, many companies have turned to an electronic chain of custody form (ECCF.) An ECCF is a digital version of the traditional, five-part copy custody and control form. An ECCF still takes over the function of the CCF when annotating the chain of handling regarding drug tests. However, by using an ECCF, you gain the benefit of speed when processing information between relevant parties while avoiding some of the more common mistakes when dealing with the 5-part copy in paper format. Tenstreet’s Pulse MD tool allows you to use an ECCF to process drug test results. Read on to learn how this tool can help your business hire drivers faster.

Benefits Of ECCF

There are several benefits when switching over to ECCFs. Instead of manually handling paperwork, you have access to all of the necessary information through a secure digital interface. Some of the more significant benefits include:

• No more hardcopy paperwork
• The software enforces proper procedures and protocols with clear and concise instructions reducing the potential for mismatched specimens
• Error prevention and faster turnaround times on test results
• Reduction of error due to illegible handwriting
• Documentation is secured yet quickly accessible to the relevant parties
• The donor’s information and testing results are digitally recorded at the first point of contact
• Less human interaction is required when handling documentation, further reducing potential error or damaging of the CCF
• Less overhead costs while using the system
• A significant decrease in affidavits and errors
• Eco-friendly as paper isn’t used for printing
• Tests can be scheduled online
• Donor information can be submitted prior to their arrival at the collections site
• Specimens can be tracked from collection through reporting

What to Expect When You Roll Out ECCF

The first thing that will pose a potential obstacle will be the pushback you receive from those in the chain of custody. The reason behind this is that many of the recruiters, HR personnel, and managers may feel that it’s faster to just sign off on a piece of paper. By switching to an ECCF system, they will need to spend a few minutes inputting data into the online form. While this process isn’t long in and of itself, it takes longer than writing it by hand on a copy.  However, this time spent entering the data needs to be compared against the whole process. By converting to a digital format you’re saving time from looking up paperwork, identifying mismatched specimens, and navigating a collection site that uses a different paper chain.  One way that companies have saved themselves the trouble of filling out the online form is by sending an ECCF link to the donor. Through the link, the donor can fill out their own personal information. A side benefit of this method is that it can notify the donor of a nearby collection center that they may have been unaware existed. Another pushback you may face is that the transition period will require additional work. For operations currently underway, the data already on CCFs will need to be re-entered under the ECCF system. However, this is also an opportunity to train your staff on the new system and showcase the highlights of the new user experience for the donor. It will also give them time to learn the process for common queries that result from switching to a digital system. Namely, users who:

• Aren’t familiar with computers
• Don’t have internet access
• Believe that they didn’t receive the appropriate link
• Don’t know which collection center is the right one

Regardless of the system you use, there will be some complications. However, with an ECCF system, they should be more manageable.

Learn More with Tenstreet

Tenstreet’s Pulse MD saves carriers time and effort by using its ECCF and integrating the process directly with drivers’ electronic files to make information storage seamless. If you’d like to learn more about Pulse MD can help your company and integrate seamlessly with your onboarding and safety processes, contact us at [email protected] or fill out the form below!