When did DOT authorize the use of the eCCF?
The Office of Drug and Alcohol Policy and Compliance issued a final rule on April 13, 2015 that allows employers, collectors, laboratories, and Medical Review Officers to use the electronic version of the Federal Drug Testing Custody and Control Form (eCCF) in the DOT-regulated drug testing program. The final rule was effective April 13, 2015. The final rule can be viewed at http://www.gpo.gov/fdsys/pkg/FR-2015-04-13/pdf/2015-08256.pdf.
Can I use an electronic version of the paper CCF (eCCF)?
You can begin using the eCCF only when the employer’s laboratory has been approved through the Department of Health and Human Services (HHS) National Laboratory Certification Program to use a specific eCCF and the employer has decided to use the eCCF.
Where can I find a listing of laboratories approved to use the eCCF?
HHS will post a list of approved laboratories at http://www.samhsa.gov/workplace/resources/drug-testing/eccf-approved-list.
Is the collection process any different when I use the eCCF?
Nothing has changed in the collection process. When you use an eCCF, you will still collect and document the same information as you would when using the paper version of the CCF. The only difference is how you document the information (in an electronic format) and the medium in which you distribute the form (e.g., electronically or combination of electronic and paper). For example, you may need to print Copy 1 – Test Facility Copy and/or Copy 5 – Donor Copy.
When using the eCCF, is it a completely paperless process?
The eCCF process for each laboratory may differ. The process may or may not be completely paperless. The laboratory and/or its eCCF provider will familiarize you on the use of its approved eCCF in the collection process. For example, the use of tamper evident specimen bottle seals with their eCCF; what supplies you may need; and what, if any, copies of their eCCF need to be printed.
Have any of the record retention requirements changed related to the use of the eCCF?
There are no changes to the records retention requirement. The records you keep have not changed. The length of time you keep those records has not changed. The only thing that has changed is the format (e.g., electronic vs. paper) – see §40.73(a)(9).
When using the eCCF, are there any security and confidentiality measures I need to implement?
The requirement to establish adequate security and confidentiality measures to ensure that confidential employee records are only available to authorized persons has not changed. This includes protecting the physical security of records, access controls, and computer security measures to safeguard confidential data in electronic databases (see §40.351(e)).
If you have questions about how to ensure that you are meeting the required security and confidentiality measures for the particular eCCF that you are using, consult with the laboratory or its eCCF provider.