Kathy Close, Transportation Editor for J.J. Keller writes a bi-monthly Regulatory Forum column for Work Truck.  - Photo: J.J. Keller

Kathy Close, Transportation Editor for J.J. Keller writes a bi-monthly Regulatory Forum column for Work Truck. 

Photo: J.J. Keller

Two federally mandated driver forms were revised recently, and the new forms must be used for a motor carrier to be compliant.

One of these revised forms deals with DOT drug collections; the other with driver physicals.    

DOT Drug Testing Form

The Federal Drug Testing Custody and Control Form (CCF) is used to track a drug test from collection site to a laboratory to the medical review officer (MRO). The following changes identify the new form:

  • Spaces were added for recording a CDL driver’s license number and state of issuance. (The Federal Motor Carrier Safety Administration’s (FMCSA) testing rules require the entry of the driver’s license as the employee ID number in Step 1 of the CCF. 
  • The CDL information is needed to report results to the CDL Drug and Alcohol Clearinghouse.) New fields were added to allow for saliva testing in addition to urine. (Note: Saliva-based drug testing is not allowed for DOT testing until the department updates its testing procedures in Part 40.)
  • Instructions were removed from the back of the form. The instructions are available on a government website instead.

DOT-regulated employers, collectors, laboratories, and MROs were authorized to use the revised CCF beginning September 1, 2020, but were permitted to use the previous version until August 29, 2021. This additional time allowed for the depletion of existing supplies of the CCF. After this date, employers and their service agents must use the new form. 

Driver’s Physical Exam Form

The FMCSA made minor changes to the driver’s physical exam form (Medical Examination Report Form, MCSA–5875). The most notable change was the removal of a field asking driver gender. 

This form is used to record the results of medical exams performed in accordance with §391.43. Unlike previous updates to the form, there is no grace period allowing use of the old form. As a result, all driver physicals must be documented using the new form effective September 7, 2021.

Alert Staff to New Forms

Motor carriers must ensure an older version of a form is not mistakenly used beyond its respective deadline.

Motor carriers should provide reminders to employees who:

  • Schedule driver physicals,
  • Notify drivers of required drug testing, and
  • Order required forms.

Any obsolete forms should be discarded to avoid confusion and future errors.

Communicate with Service Agents

Many contracts require that the facility provide all required forms. When the error is on the collection site or the medical examiner’s office, the motor carrier is still held responsible for the mistake.      

As a result, motor carriers must make sure a service provider keeps up to date on the requirements, or the carrier may face a violation. 

For those carriers that have an agreement where forms are provided, they should contact the facilities to:

  • Make sure they are aware of the recent changes and have depleted or purged prior versions of the forms; and
  • Confirm all facilities within a network (if multiple locations are used) are aware and executing the changes.

What if an Incorrect Form is Used?

If, in the first few weeks or even months of implementation, incorrect forms are used, you should:

  • Address errors right away,
  • Contact employees and/or service providers about the error,  
  • Instruct motor carrier employees on the right forms to use, and
  • Explain the consequences of continued errors. 

For clinics and collection sites, the motor carrier has little control over the actions of someone else’s employees. If the problem persists, however, a motor carrier should be prepared to seek an alternate provider.

About the Author: Kathy Close is a transportation editor at J.J. Keller & Associates, Inc. Her areas of expertise include transportation security, DOT drug and alcohol testing, and driver qualification.

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