Chain of Custody

Effective Date: [06/21/2026]
Last Updated: [06/21/2026]

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1. Purpose

 

This Chain of Custody (COC) Policy establishes the procedures and standards followed by Battle Tested Specimen Collections to ensure the integrity, security, and legal defensibility of every specimen collected. A properly maintained chain of custody is the foundation of a legally valid drug test and protects the rights of donors, employers, and the Collector. This policy applies to all DOT and Non-DOT specimen collections performed by Battle Tested Specimen Collections.

 

 

2. What is Chain of Custody?

 

Chain of custody is the documented process that tracks a specimen from the moment of collection through laboratory analysis and result reporting. It establishes an unbroken, documented record of every person who handled the specimen and every transfer of possession. This documentation ensures that:

— The specimen belongs to the identified donor
— The specimen has not been tampered with or contaminated
— The specimen was collected, handled, and transported in accordance with applicable regulations
— The result can be legally defended if challenged

 

 

3. Required Documentation

 

3.1 DOT Collections — Federal Custody and Control Form (CCF)
All DOT-mandated drug screen collections must use the official Federal Custody and Control Form (CCF) as required by 49 CFR Part 40. The CCF is a five-part carbonless form that travels with the specimen and documents every step of the collection process.

Battle Tested Specimen Collections uses the electronic chain of custody (eCCF) system provided by our laboratory partners — FormFox for DISA Global Solutions collections and eChain for MedTox collections. Electronic CCFs meet all DOT requirements and provide real-time documentation.

 

3.2 Non-DOT Collections
Non-DOT collections use a Non-Federal Custody and Control Form or the laboratory's designated collection form. The same chain of custody principles apply to Non-DOT collections to ensure specimen integrity and result validity.

 

3.3 Rapid / Instant Drug Screen Collections
For Non-DOT rapid drug screen collections the Collector documents the collection using an appropriate chain of custody record. Non-negative rapid screen specimens sent for laboratory confirmation must be transferred to a laboratory CCF before shipment.

 

 

4. Collector Responsibilities

 

The Collector is responsible for maintaining an unbroken chain of custody from the moment the donor presents for collection through the point of laboratory submission. Collector responsibilities include:

 

4.1 Pre-Collection
— Verify the donor's identity using a valid government-issued photo ID before beginning the collection
— Document the donor's name, ID type, and ID number on the CCF
— Ensure the collection location meets DOT privacy and security requirements for urine collections
— Inspect the collection area for potential adulterants or substitution materials
— Provide the donor with the required collection kit in a sealed, tamper-evident condition
— Instruct the donor to leave personal belongings outside the collection area

 

4.2 During Collection
— Remain in control of the specimen at all times after the donor provides it
— Immediately check the specimen temperature — must be between 90°F and 100°F within 4 minutes of collection for urine specimens
— Inspect the specimen for unusual color, odor, or other signs of adulteration
— Document any unusual observations on the CCF
— Pour the specimen into the appropriate specimen bottles in the presence of the donor
— Apply tamper-evident seals over the specimen bottle caps in the presence of the donor
— Have the donor initial the tamper-evident seals on the specimen bottles

 

4.3 Post-Collection
— Complete all required fields on the CCF accurately and legibly
— Have the donor sign the CCF certifying the specimen is theirs and was collected as described
— Provide the donor with their copy of the CCF (Copy 5)
— Place the sealed specimen and CCF in a tamper-evident shipping bag
— Seal the shipping bag in the presence of the donor
— Submit the specimen to the laboratory promptly in accordance with laboratory shipping requirements
— Retain the Collector's copy of the CCF for records

 

 

5. Donor Responsibilities During Collection

 

To maintain chain of custody integrity donors are required to:

— Present a valid government-issued photo ID
— Provide a specimen in the manner directed by the Collector
— Not bring personal items into the collection area unless permitted by the Collector
— Initial the tamper-evident seals on the specimen bottles
— Sign the CCF certifying the specimen is theirs
— Not attempt to interfere with, adulterate, or substitute the specimen

 

 

6. Temperature Check Protocol

 

Specimen temperature is a critical chain of custody verification step. For urine specimens:

— The specimen temperature must read between 90°F and 100°F within 4 minutes of collection
— If the temperature falls outside this range the Collector must note the discrepancy on the CCF
— The Collector may conduct an observed collection of a second specimen if the temperature is outside range
— A temperature outside the acceptable range is documented as a potential specimen validity issue and reported to the MRO
— The Collector does not make a determination of adulteration — that determination is made by the laboratory and MRO

 

 

7. Observed Collections

 

An observed collection may be required in the following circumstances:

— The donor's specimen temperature is outside the acceptable range
— The Collector observes conduct suggesting the donor is attempting to adulterate or substitute the specimen
— The donor has a previous verified adulterated, substituted, or invalid result
— The collection is a return-to-duty or follow-up test under DOT regulations
— An employer specifically authorizes an observed collection under Non-DOT policy

Observed collections are conducted by a Collector of the same gender as the donor. An additional observed collection fee of $20.00 applies. The donor will be informed that the collection is being observed and the reason will be documented on the CCF.

 

 

8. Specimen Shipping & Transfer

 

8.1 Packaging
All specimens are placed in tamper-evident shipping bags provided by the laboratory. The sealed shipping bag contains the specimen bottles and a copy of the CCF. The Collector signs and dates the shipping bag seal.

 

8.2 Transfer of Custody
When the specimen is transferred to a shipping carrier or courier the transfer is documented. The laboratory tracking number is recorded on the CCF where applicable.

 

8.3 Timing
Specimens are submitted to the laboratory as quickly as practicable after collection. Specimens that cannot be shipped same day are stored securely in a locked, climate-controlled environment until shipment.

 

8.4 Storage
In the event a specimen must be held prior to shipment it is stored in a secure, locked container away from extreme temperatures, direct sunlight, and potential contaminants. Storage time is minimized to preserve specimen integrity.

 

 

9. Electronic Chain of Custody (eCCF)

 

Battle Tested Specimen Collections utilizes electronic chain of custody systems where available:

 

FormFox — used for DISA Global Solutions employer accounts
— Guides the Collector through each step of the collection process digitally
— Reduces documentation errors
— Provides real-time collection status to employers and the laboratory
— Meets all DOT eCCF requirements

 

eChain (MyMedTox) — used for MedTox employer accounts
— Digital chain of custody workflow
— Integrated with MedTox laboratory processing
— Real-time status tracking available through the MyMedTox portal

 

Electronic CCFs have the same legal standing as paper CCFs when used in compliance with DOT and laboratory requirements.

 

 

10. Chain of Custody Errors & Corrections

 

10.1 Minor Errors
Minor documentation errors on the CCF that do not affect the integrity of the specimen may be corrected by the Collector by drawing a single line through the error, initialing, and dating the correction. Correction fluid or erasure is never used on a CCF.

 

10.2 Fatal Flaws
Certain CCF errors are considered fatal flaws that may invalidate the collection. These include:
— No Collector signature on the CCF
— No laboratory copy of the CCF
— The specimen ID number on the CCF does not match the specimen bottle
— No donor signature on the CCF (without a documented refusal)

In the event of a fatal flaw the Collector will document the error, notify the MRO and laboratory, and arrange for a recollection as directed.

 

10.3 Correctable Errors
Some errors can be corrected after the fact through a memorandum of explanation or affidavit. The Collector will cooperate fully with the MRO and laboratory to correct any correctable errors in a timely manner.

 

 

11. Refusal to Test

 

If a donor refuses to provide a specimen or refuses to complete the collection process the Collector will:

— Document the refusal on the CCF
— Note the time, date, and specific nature of the refusal
— Not attempt to force or coerce the donor to provide a specimen
— Notify the employer or requesting party that the collection was not completed due to refusal
— Submit the CCF documentation to the laboratory and MRO as directed

 

Under DOT regulations a refusal to test carries the same consequences as a verified positive result. The Collector does not make this determination — it is made by the MRO.

 

 

12. Record Retention

 

Battle Tested Specimen Collections retains chain of custody records in accordance with the following schedule:

Record TypeRetention Period

DOT collection records5 years minimum

Non-DOT collection records2 years minimum

Negative DOT results1 year

Non-negative / positive results5 years

Refusal to test documentation5 years

Observed collection documentation5 years

Records are stored securely and accessible only to authorized personnel. Record retention complies with 49 CFR Part 40 and applicable Washington State regulations.

 

 

13. Confidentiality of Chain of Custody Records

 

All chain of custody records and collection documentation are confidential. Records will not be disclosed to any unauthorized party. Authorized parties include the donor, the employer of record, the laboratory, the MRO, and regulatory authorities with proper authorization. This policy is governed by our Privacy Policy available at www.battletestedwa.com/privacy-policy.

 

 

14. Policy Compliance

 

All collections performed by Battle Tested Specimen Collections follow this Chain of Custody Policy in addition to:

— 49 CFR Part 40 — DOT Procedures for Transportation Workplace Drug and Alcohol Testing Programs
— HHS Mandatory Guidelines for Federal Workplace Drug Testing Programs
— Washington State applicable drug testing regulations
— Laboratory partner collection protocols and requirements

 

 

15. Contact Us

 

For questions about our chain of custody procedures or to report a concern please contact us:

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Battle Tested Specimen Collections
DBA of Battle Tested LLC
14900 Interurban Ave. S
Suite 271 #10005
Tukwila, WA 98168

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📞 (206) 939-0335
📧 info@battletestedwa.com
🌐 www.battletestedwa.com

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Veteran Owned & Operated | King County & South King County, Washington