Why does the Federal Drug Testing Custody and Control Form list the donor’s social security number and employee identification number as acceptable identification numbers if drivers must be identified by their commercial driver’s license number?

The Federal Motor Carrier Safety Administration (FMCSA) requires drivers to be identified by their commercial driver’s license (CDL) number because the Drug and Alcohol Clearinghouse uses the CDL number to associate drivers with positive drug or alcohol test results that are entered into the Clearinghouse. The Federal Drug Testing Custody and Control Form (CCF) is used by agencies other than the FMCSA, however, e.g., the Federal Aviation Administration (FAA), whose employees do not have a CDL number and are not subject to the Drug and Alcohol Clearinghouse and can therefore be identified by social security number (SSN) or employee identification number (EIN).