The process of drug screening is a very controversial one that has experts debating on issues regarding validity and legality of such processes. To address these questions and doubts the Federal government has released strict and detailed lists of procedures for the drug test screening process. These tests are now commonplace in all branches of the government that serves as a deterrent to all employees and public servants. If such cases of drug addiction are confirmed and documented these tests serve as a diagnostic tool for the formulation of the proper approach for treatment and subsequent remission. Millions of Americans in the workplace have been determined to be addicted to prescription/restricted drugs along with drugs considered to be banned by the law.
This drive for the drug free workplace was further given a boost in the year 2000 when the President of the United States formed the Initiative for the Drug Free Community Support Programs along with the release of the revised Mandatory Guidelines for the Drug-Free Workplace released by SAMHSA in 1994. This increased the budget and scope of the drug abuse prevention and treatment programs that were currently being undertaken by the SAMHSA a division of the Department of Human Health and Services. It also boosted efforts by the community based treatment facilities which either grew in numbers to support the said decrees.
A typical chain of custody document would begin its life during collection of the sample for testing is done. This is when the test subject’s details are written as well as those of the collector with the respective times and dates. The complete list of contents that are included with the test specimen like packaging type, seals and other relevant information are also included for verification upon transport and turnover to the respective testing facility. The said chain of custody form is added onto as the test specimen travels from person to person that gives complete accountability of a test sample. Another important detail that is to be written on them would be they type of test that is to be performed which could be a simple alcohol and tobacco testing to the more serious drug screening processes. The party who is requesting for the said test is also written along with the organization’s representative. All phases of drug screening should be conducted in the best possible conditions for both federal and non-federal requirements. The so-called chain of custody form has been given a status of a legal document for it has the ability to invalidate a specimen that has been tampered with and that does not have the complete information written on it. Being a legal document, tampering or mishandling is subject to investigation and subsequent penalization in accordance with the law.
Upon transport, the document is again updated and again written to as it is received by the test laboratory. Upon reaching the laboratory, the specifics of the test that will be conducted with the time, date and signature of the person processing the sample are written. Upon the conclusion of the tests with the results finalized, this chain of custody document is copied and returned to the sender for interpretation and conclusion. The initials of the interpreting party, usually a physician is written and serves as the end of the lifecycle of the specimen upon his writing off on the said document. After processing, the said accomplished document is sent back to the testing facility for storage if so required by law. This would be the case for all federal employees where the law dictates that the samples be kept for a period of 1 (one) year from the conduction of the testing to give time for questioning and the filing of complaints in case the said results are refuted. Once a complaint is filed, the sample is then pulled out of storage for re-testing and again the document is updated for reference purposes.
As seen above, the said chain of custody form is not a form by itself but a process of accountability which leaves a historical trail of the processing a test specimen has been through that could provide essential information with regards to validity and legal issues. The Mandatory Guidelines for Federal Workplace Drug Testing Programs was intended for within the Federal Government but has been used as the pattern for subsequent application in the private sector which may or may not follow all the statutes of the said guidelines.
As a result of the need for chain of custody monitoring even FDA approved portable test kits that are used by private companies have provisions to strictly follow the stated laws. Urine samples are collected and documented for testing off-site in an accredited laboratory. The sample is sealed and placed inside either a box or plastic container that is again sealed for security prior to transport. The courier is also required to document the transfer of the sample or samples from source (requesting company) to the testing facility that will conduct the necessary tests requested. The samples can then either be tested immediately or stored in conditions stated within the collection guidelines till such time that the test can be conducted. Independent laboratories that are accredited to provide testing services are required by law to keep test and employee information for a minimum of two years after which destruction of the said records is allowed upon verification that none of them are subject to legal cases.
All of the processes involving the chain of custody document serves as assurance to the test subject that the specimen that was provided was handled and tested in the enumerated procedures of the federal Drug-free Workplace program. All information including the chain of custody form are considered to be highly private and confidential for both federal and private employees who undergo these tests. Even the results that are given by the MRO that are documented and reported are considered confidential as part of the stated regulatory guidelines.
Major differences in federal and Non-Federal Chain of Custody forms is that Federal CCF forms have 5 copies; Copy 1 is to be furnished for the Laboratory; Copy 2 for the MRO (Medical Review Officer); Copy 3 is for the Collector; Copy 4 is for the Employer and the last one for the Donor or test subject. This is a reflection of the full accountability principle defined by the revised Mandatory Federal Workplace Drug Testing Program. Non-federal applications require only 2 copies, one for the laboratory and one for the employer.