ASK ALICE
In each issue we will be answering questions submitted by members. If you have a question to be answered, please submit it to info@datia. org with Ask Alice in the subject line. Enjoy.
The likelihood of a collection site
having CCFs with inaccurate informa- tion increases with unexpected collection events (e.g., employee arrives unan- nounced for post-accident testing). If the specimen will be sent to a labora-
tory different than the one pre-printed on the available CCF, it becomes impor- tant for the collector to modify the CCF so that it reflects the name and address of the laboratory to which the specimen will actually be sent. It is also important for the collector to line through any pre-printed billing code and insert the appropriate one, if it is available. Finally, laboratories should honor
collection site requests to provide an ad- equate number of “blank” CCFs for use during unexpected collection events. It is important to note that the DOT permits overprinting or pre-printing of CCFs in an effort to streamline the entire testing process, not to limit the distribution of the forms to collection sites.
QUESTION:May the MRO’s address entered on the CCF be a post-office box number only?
ANSWER: No. The address must contain at least a number and street address. The reason for this requirement is that
QUESTION:Can a collector mark through pre-printed employer, MRO, collection site, and/or laboratory informa- tion on the CCF if that information is not accurate for a particular collection?
ANSWER: Yes. When the collector has no “blank” CCFs and the CCFs on-hand contain inaccurate pre-printed employer, MRO, collection site, and/or laboratory infor- mation, the collector is permitted to “line through” the inaccurate information and insert legibly the proper information.
CCFs are often delivered by courier or messenger services who do not deliver items to post-office box addresses. Te post-office box can be included, but not in lieu of the number and street address.
QUESTION:What actual address is re- quired for “Collection Site Address” in Step 1 of the CCF, and what telephone number should the collector provide?
ANSWER: The collection site address should reflect the location where the collection takes place. If the collection takes place at a clinic, the actual address of that clinic
46 datia focus
should be used: not a corporate or a “main office” address of the clinic/collec- tion company. If the collection takes place on-site at
the employer’s place of business (e.g., a bus terminal, a rail yard), the actual ad- dress of the employer site should be used. If the collection takes place in a “mo-
bile unit” or takes place at an accident site, the collector should enter the actual location address of the collection (or as near an approximation as possible, under the circumstances). The required collector telephone num-
ber should be the number at which it is most likely that the laboratory, MRO, or employer, if necessary, may contact the collector and the collector’s supervisor. Pre-printing certain information onto
the CCF is problematic if the informa- tion is subject to change.
QUESTION:Where can billing in- formation be entered onto the Federal Drug Testing Custody and Control Form (CCF)?
ANSWER: 40.45(c)(1) states that the CCF my in- clude billing information if the informa- tion is in the area outside the border of the form. Therefore, if account codes or collec-
tion site codes are entered, they must be placed outside the border, only. CCFs with this information pre-printed
inside the border (i.e., in the Step 1 box) may be used until the supply of these forms is exhausted. CCFs produced or re- ordered aſter February 15, 2002, must not have this information inside the border. No corrective action is needed nor will
a result be impacted if the CCF contains this information inside the border. How- ever, employers and service providers may be subject to enforcement action if this requirement is not met. ❚
Source: DOT Rule 49 CFR Part 40 Section 40.45 Q&A
summer 2014
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