Question 1

1) Who is covered by DOT drug testing rules?

Accepted Answer

DOT testing applies to safety-sensitive transportation employees (including contractors and, when covered by modal rules, volunteers) and the employers and service agents who support testing. The how-to procedures are in 49 CFR Part 40; each DOT agency (e.g., FMCSA, FAA, FRA, FTA, PHMSA, USCG) has its own coverage rules.

Question 2

2) What does the DOT 5-panel test for?

Accepted Answer

Marijuana (THC), Cocaine, Amphetamines (including methamphetamine; with MDMA analytes), Opioids (codeine, morphine, 6-AM for heroin, plus semi-synthetic opioids hydrocodone/hydromorphone/oxycodone/oxymorphone), and Phencyclidine (PCP).

Question 3

3) Is oral fluid testing allowed for DOT?

Accepted Answer

DOT authorized oral fluid in 2023, but employers may only implement it when at least two HHS-certified oral-fluid laboratories are listed. Until that condition is met, DOT testing remains urine (except FRA post-accident tox, etc.).

Question 4

4) When are DOT drug or alcohol tests required?

Accepted Answer

Common reasons include pre-employment (drugs), random (drugs andâ€”depending on the modeâ€”alcohol), post-accident, reasonable suspicion/for-cause, return-to-duty, and follow-up.

Question 5

5) What is a refusal to test under DOT?

Accepted Answer

Examples include failing to appear, leaving before completion, failing to provide a specimen without a valid medical explanation, adulterating or substituting, not following direct observation instructions when required, or not permitting a monitored/observed collection when directed. See Part 40 for the full list.

Question 6

6) What happens after a positive drug test or refusal?

Accepted Answer

The employee must be removed from safety-sensitive duties and complete the DOT return-to-duty process with a qualified SAP, including a negative RTD test and a prescribed follow-up testing plan.

Question 7

7) Does DOT allow medical or recreational marijuana? What about CBD?

Accepted Answer

No. Marijuana is a Schedule I substance; DOT does not authorize use for any reason. CBD products may contain THC or be mislabeled; employees use them at their own risk and may test positive.

Question 8

8) What are the 2025 DOT random testing rates?

Accepted Answer

Per ODAPC: FMCSA 50% drugs/10% alcohol; FAA 25%/10%; FRA 25% drugs & 10% alcohol for covered service and MOW; FRA Mechanical 50% drugs/25% alcohol; FTA 50%/10%; PHMSA 50% drugs (no alcohol randoms).

Question 9

9) Who can collect DOT specimens?

Accepted Answer

Collectors must meet Part 40 Subpart C requirements and follow the DOT Urine Specimen Collection Guidelines (current edition) and applicable modal rules.

Question 10

10) What does the laboratory and MRO do?

Accepted Answer

HHS-certified labs test specimens per Part 40 Subpart F. A Medical Review Officer (licensed physician) serves as an independent gatekeeper who verifies results and considers legitimate medical explanations, per Part 40 Subpart G.

Question 11

11) What documents/form are used?

Accepted Answer

For drugs, DOT uses the Federal Drug Testing Custody and Control Form (CCF). For alcohol, approved Evidential Breath Testing devices and ATF are used as specified by Part 40 and device lists.

Question 12

12) What are employer responsibilities under FMCSAâ€™s Clearinghouse?

Accepted Answer

FMCSA employers must register, conduct a full pre-employment query on CDL drivers, run annual queries, report violations/refusals, and record negative RTD results and follow-up completion. Drivers must register to provide electronic consent for full queries.

Question 13

13) Are drivers required to register for the Clearinghouse?

Accepted Answer

Not automatically. Drivers must register to give electronic consent for full (including pre-employment) queries and to view their records.

Question 14

14) Can employees use hemp/CBD products?

Accepted Answer

DOT warns CBD use can still result in a positive THC test due to mislabeling or THC content. Safety-sensitive employees should exercise caution.

Question 15

15) Where can employers find the official rules and updates?

Accepted Answer

ODAPC hosts Part 40, FAQs, guidance, random rates, and official notices; eCFR contains the regulation text; the Federal Register posts rulemakings; FMCSA sites cover Clearinghouse and motor-carrier-specific requirements.

DOT Drug Testing FAQ

DOT Drug Testing: Top 15 FAQs

1) Who is covered by DOT drug testing rules?

2) What is in the DOT 5-panel?

3) Is oral fluid testing available now?

4) When are DOT tests required?

5) What counts as a refusal to test?

6) What happens after a positive or refusal?

7) Is medical or recreational marijuana permitted? What about CBD?

8) What are the 2025 random testing rates?

9) Who may collect DOT specimens?

10) What do the lab and MRO do?

11) What official forms/devices are used?

12) What must FMCSA employers do in the Clearinghouse?

13) Do drivers have to register for the Clearinghouse?

14) Can employees use hemp/CBD products?

15) Where do I find the official rules and updates?

References (Official Sources)