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Electronic Chain of Custody: DOT approval and what it means for employers

The alcohol and drug testing industry is in the process of moving ahead with changes that will produce a faster turnaround for test results. After being paper-heavy for decades, a new rule that came into effect this week means the push for an electronic chain of custody process is on and DriverCheck is perfectly positioned to pass along these improvements.

With an e-chain of custody process, all paperwork completed at the collection site during the testing process is done electronically instead of manually. No paperwork will reduce the potential for error and will mean real-time alcohol and POCT results.

Implications for DOT-Regulated Employers

On April 13th, the U.S. Department of Transportation’s (DOT) rule regarding the use of electronic versions of the Custody and Control Form (eCCF) came into effect. This rule, by allowing the use of eCCFs, officially opens the doors to an e-chain of custody process for DOT-regulated employers. This option will be available once laboratories and alcohol and drug testing providers are capable of implementing this process.

The DOT will not require the use of eCCFs; this rule simply expands the definition of the CCF to include both paper and electronic forms (the eCCF will mirror the paper CCF and will include an electronic signature), as long as procedures and controls are put in place to ensure the authenticity, integrity, and confidentiality of electronic records. For example, authority checks should be completed to make certain only authorized individuals can access the electronic system.

The standards for security and confidentiality were previously developed by the U.S Substance Abuse and Mental Health Services Administration. To ensure those standards are met, laboratories applying for approval to use eCCFs (through the Department of Health and Human Services (HHS) National Laboratory Certification Program (NLCP)) will be required to provide a detailed plan and proposed standard operating procedure to the U.S. Substance Abuse and Mental Health Services Administration (SAMHSA). DriverCheck’s designated laboratory is currently working through this approval process, so stay tuned!

Implications for Non-DOT Regulated Employers

Currently, there is no rule regulating the use of an electronic chain of custody process in the non-DOT regulated alcohol and drug testing industry in Canada. However, it is possible the DOT rule on eCCFs will be mirrored in non-DOT testing standards (e.g. the Canadian Model for Providing a Safe Workplace), including the standards described above around security and maintaining confidentiality. This has yet to be determined.