While the Federally Regulated Drug Testing CCF must be used exclusively for DOT and DHHS drug screen collections, there are extenuating circumstances when a Non-Federally Regulated form of CCF may be used. For example, when a post-accident collection must be made and the collector (for a variety of reasons) is unable to obtain a Federally Regulated CCF. In this situation, a Non-Federally Regulated CCF may be used.
The use of a Non-Federally Regulated CCF for a Federally Regulated collection is not a reason for the laboratory to refuse to test the specimens nor the Medical Review Officer (MRO) to release the results. The use of a Non-Regulated CCF for a Federally Regulated drug screen is a "correctable flaw."
If a Non-Federally Regulated CCF or an expired Federally Regulated form is used, the collector must provide a signed statement (eg, a Memorandum for Record) stating that the incorrect form contains all the information needed for a valid DOT or DHHS drug test, and that the incorrect CCF was used inadvertently or as the only means of conducting a test. For example, the collector might state that the site had depleted its stock of Federally Regulated CCFs, more had been ordered, but had not arrived. Consequently, the only CCF forms available were Non-Federally Regulated CCF but all required information needed to perform testing is on the form. The Memorandum for Record (MOR) must also enumerate the steps the collector has taken to prevent future use of Non-Federally Regulated or expired CCF forms for Federally Regulated drug screen collections. This information must be supplied to the testing facility either with the specimen or on the same business day that the collector is notified of the problem. If not sent with the specimen, the MOR may be transmitted to the testing facility by either fax or courier.
