DOT Program Management

What is DOT Testing?

DOT testing refers to federally regulated drug and alcohol testing required for safety-sensitive employees in transportation industries. These tests are mandated by the U.S. Department of Transportation (DOT) to ensure public safety and maintain a drug- and alcohol-free workforce. DOT testing follows strict procedures outlined in 49 CFR Part 40.

Agencies That Require DOT Testing:

The following agencies enforce drug and alcohol testing for safety-sensitive positions:

FMCSA – Federal Motor Carrier Safety Administration
FAA – Federal Aviation Administration
FRA – Federal Railroad Administration
FTA – Federal Transit Administration
PHMSA – Pipeline and Hazardous Materials Safety Administration
USCG – United States Coast Guard* (follows DOT testing rules but operates under the Department of Homeland Security)

Required DOT Tests:

The DOT testing process must begin prior to the hiring of any employee and must continue throughout the employee’s time with the company. Because of this, there are a number of tests that DOT-covered employers are legally obligated to conduct with their employees. Here are the types of different tests required under DOT legislation.

Drug History Checks

The first DOT requirement is a drug and alcohol background check on all potential employees. DOT employers must obtain the last 2 years of drug and alcohol test history from previous employers. It is important to note, however, that individual agencies may have additional requirements. The FMSCA demands a 3-year history while the FAA demands records from the last 5 years of drug and alcohol test history.

In 2020, the FMSCA’s Commercial Driver’s License (CDL) Drug and Alcohol Clearinghouse went live allowing employers to access an employee’s entire drug and alcohol testing history.

Pre-Employment Testing

All of your potential new employees who fall under DOT regulations must undergo a pre-employment drug test prior to being hired. A negative test result must be received from these employees before they begin working for you, although exemptions may be made for new hires who were tested in the past 6 months or were involved in a random drug screening in the past 12 months.

Random Testing

DOT requires that random testing be conducted on 25 to 50% of employees, depending on the specific agency that governs your workplace. DOT further requires that random testing be truly random using a scientifically approved method.

Post-Incident Testing

This testing is mandated under very narrowly defined circumstances for DOT governed employees and generally applies to situations where your employee is cited or where the accident results in injury or death.

Reasonable Suspicion Testing

DOT is very specific that reasonable suspicion testing cannot be based on a hunch or guess made by you or your supervisors. It must be based on observations of acute signs, such as current behavior, speech or appearance. DOT also requires that supervisors receive a minimum of one hour each of alcohol and drug abuse reasonable suspicion training. Several agencies further require that a minimum of two supervisors confirm the symptoms prompting reasonable suspicion testing.

Return-to-Duty Testing

DOT employees who fail drug tests must submit to a return-to-duty test prior to returning to a safety-sensitive position. They are also subject to random tests at least 6 times in their first year after returning to duty. You must, however, provide your employees who fail their drug tests with a list of Substance Abuse Professionals (SAPs) in your area who will assess the employee and can dictate additional randomized testing if they feel the situation warrants it.

Follow-Up Testing

Employees who test positive for drug use can be subject to follow-up drug tests for up to five years, depending on the recommendations made by the SAP.

Complete DOT Program Management, Made Easy

Managing a DOT-compliant program can be complex—but it doesn’t have to be. SureHire offers end-to-end support for companies and owner-operators, handling everything from random testing consortium administration to Clearinghouse requirements. Our team ensures every step of the process is seamless, accurate, and aligned with federal regulations.

We also partner with highly experienced DOT compliance consultants who bring decades of industry expertise to guide employers through audits, policy development, training, and ongoing program oversight. With SureHire, you gain a trusted partner dedicated to simplifying compliance, reducing administrative burden, and keeping your program running smoothly.

Types of DOT Drug & Alcohol Tests:

• DOT Breath Alcohol – These tests must be conducted by specially trained Screening Test Technicians (STTs) or Breath Alcohol Technicians (BATs) but only BATs are allowed to conduct confirmation tests. Confirmation tests are conducted following any positive tests. SureHire utilizes breath alcohol devices that are approved Evidential Breath Measurement Devices (EBD).
• DOT 5 Panel – The 5-panel test is the test mandated by DOT regulations. The 5-panel test will identify the most commonly abused prescription and illicit drugs, if present, including:
  • Marijuana (THC)
  • Cocaine
  • Amphetamines
  • Opioids
  • Phencyclidine (PCP)