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How Are DOT Drug Tests Different From Non-DOT?

Most of us know that a drug screening test is typically a part of pre-employment requirements. This checks for illegal drugs (or their metabolites) in a person’s body.

Depending on the industry you are working in, your employer may require you to undergo a DOT drug (or alcohol) test specifically. Let’s look at what makes this screening procedure different from a non-DOT test.

What Is a DOT Drug Test?

This test is regulated by the government — the Department of Transportation (DOT), to be exact. It applies to individuals and private corporations that are under the authority of the DOT and its operating administrations :

  • Federal Motor Carrier Safety Administration (FMCSA)
  • Federal Aviation Administration (FAA)
  • Federal Railroad Administration (FRA)
  • Federal Transit Authority (FTA)
  • Maritime Administration (MARAD)
  • Pipeline and Hazardous Materials Safety Administration (PHMSA)

People Required To Take DOT Drug Tests

Those who hold positions that are considered “safety-sensitive” are required to undergo DOT drug screening. Employees with such jobs handle the safety of others and their own. Hence, they cannot be under the influence of drugs as it can impair their performance and put lives at risk. Examples of these occupations are:

Under the Federal Aviation Administration (FAA)

  • Flight crew members (Corporate or General Aviation Pilots)
  • Flight attendants
  • Flight instructors
  • Aircraft dispatchers
  • Aircraft maintenance personnel
  • Ground security coordinators
  • Aviation screening officers
  • Air traffic controllers
  • Operations control specialists

Under the Federal Motor Carrier Safety Administration (FMCSA)

  • Drivers with CDL (Commercial Driving License) who operate CMVs (Commercial Motor Vehicles) on public roads
  • Employers of CDL drivers
  • Interstate motor carriers
  • Intrastate motor carriers
  • Drivers employed by federal, state, and local governments
  • Drivers for civic organizations (boy/girl scouts, veterans associations, etc.)
  • Drivers for faith-based organizations

Under the Federal Railroad Administration (FRA)

  • Roadway workers and contractors
  • Conductors
  • Brakemen
  • Switchmen
  • Signalmen
  • Train dispatchers
  • Railway engineers
  • Locomotive engineers
  • Control operators

Under the Federal Transit Authority (FTA)

  • Operators of revenue service vehicles
  • Operators of non-revenue service vehicles used in transit operations
  • Dispatchers, controllers, and maintenance personnel of revenue service vehicles
  • Armed security personnel
  • Any supervisor who may be called upon to perform any of the duties above

Under the Maritime Administration (MARAD)

  • Ship captains
  • Crew members that directly affect the safe operation of a vessel

Under the Pipeline and Hazardous Materials Safety Administration (PHMSA)

  • Pipeline operators
  • Pipeline maintenance personnel
  • Emergency response personnel

For employees that do not fall under the “safety-sensitive” category, they take a standard drug screening test. The procedures and requirements may vary depending on their respective employer and state, as will be discussed in the succeeding sections.

The Type of Specimen Used

Urine is the standard specimen used for DOT drug tests. For non-DOT screening, hair and saliva samples are more common.

The Form Used

For DOT tests, only the Federal Drug Testing Control and Custody Form (also called CCF) is used to collect information. Forms for non-DOT drug tests vary depending on the state, the employer, and the company conducting the procedure. A CCF cannot be used for a non-DOT test.

Requirements and Prohibitions

Safety-sensitive employees regulated by the DOT are required to submit to drug testing in the following circumstances:

  • Pre-employment — before a candidate gets hired or started with the employer
  • Random testing — employees are randomly selected without prior notice
  • Post-accident — done to those involved in an accident
  • Reasonable suspicion — if someone is believed to be under the influence of drugs while at work
  • Return-to-duty — for those who failed the DOT drug test
  • Follow-up — conducted after return-to-work

For employees that are not under the authority of the DOT, they will be required to undergo a drug screen only for some of these situations, not for every instance. Most non-DOT employers do not implement random and follow-up testing.

DOT regulations prohibit a safety-sensitive worker from refusing a drug test. The following are examples of conduct that are considered as refusal.

  • Not appearing for your scheduled test
  • Leaving the collection site before the process is complete
  • Providing a specimen that is confirmed to be adulterated or substituted
  • Possessing any device that can interfere with the collection process
  • Refusing a second test (when necessary)

The Collection Procedure

The testing procedure for DOT is more stringent than that for non-DOT tests. It was designed to prevent loopholes. Here is an overview of the DOT drug testing process.

1.The employee is notified to appear for the drug test.

2.The employee reports to the collection site on the scheduled date and time.

3.Identification is verified. Pockets will be emptied if necessary.

4.The employee will take a sealed testing kit (provided) and proceed to the designated (private) area  for urine collection.

5.If attempts to adulterate or substitute the specimen are found, the employee will be accompanied by an observer in the collection area to verify the validity of the sample.

6.Once 45+ mL of urine is collected, this will be submitted by the employee directly to the collector.                                  He/she should watch as the collector check the sample’s temperature and pour it into two separate bottles (A and B).

7.The employee should also witness the collector seal bottles A and B before signing the papers.

8.Bottle A will be sent to a medical review officer (MRO).

9.Upon notice by the MRO, the employee has 72 hours to have bottle B tested by another certified laboratory if he/she desires.

10.The MRO will verify the results and notify the employer.

If the Employee Tests Positive or Refused Testing

The employee will be immediately removed from the safety-sensitive position. He/she cannot resume performing such a job unless the following are accomplished:

  • Get evaluated by a substance abuse professional (SAP)
  • Complete a counseling or treatment program as recommended by the SAP
  • Provide a negative drug test result (return-to-duty testing)