What Employers Need To Know About DOT Drug and Alcohol Testing

What types of DOT tests must I conduct?
You must give employees the following kinds of tests, when called for by DOT Agency and USCG rules:
Pre-employment
Random
Reasonable Suspicion / Reasonable Cause
Post-Accident
Return-to-Duty
Follow-up
Here are explanations about each type of test:
PRE-EMPLOYMENT
Drug Tests: You are required to: (1) Conduct a pre-employment drug test; and (2) Receive from the MRO a
negative test result on the pre-employment drug test for a person prior to hiring or prior to using that person in
a safety-sensitive position for the first time. This requirement also applies when a current employee is
transferring from a non-safety sensitive position to a safely-sensitive job for the first time.
Alcohol Tests: Unless you are regulated by the USCG, you may conduct pre-employment alcohol testing
under DOT authority, but only if two conditions are met: (1) The pre-employment alcohol testing must be
accomplished for all applicants [and transfers], not just some; and (2) The testing must be conducted as a postoffer
requirement – meaning you must inform the applicant that he or she has the job if he or she passes a DOT
alcohol test.
The FAA has specific “prior-to-hire” and “transfer into safety-sensitive function”
requirements. They also require employers to receive MRO written confirmation of
negative pre-employment drug test results. Check FAA regulations for details.
The FRA has a one-time pre-employment drug test requirement for each employee
subject to the “Hours of Service” laws. Check FRA regulations for details.
The FTA requires employees who have been removed from the random testing pool
and out of work for 90 or more days to have pre-employment tests upon return.
The USCG requires employees who have not been subject to random drug testing
for at least 60 days of the last 185 days to be pre-employment tested.
What Employers Need to Know About DOT Drug and Alcohol Testing – October 1, 2010
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