DOT Guidance on Compliance with Drug and Alcohol Testing Regulations

March 26, 2020

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The Office of Drug and Alcohol Policy and Compliance (ODAPC) released updated guidance on Drug and Alcohol Testing to help with your drug and alcohol testing program compliance during the COVID-19 crisis. This Guidance includes important information about your organization’s testing program obligations and addresses pre-employment, random testing and practical considerations. Please be sure to review the entire Guidance carefully, including the footnotes:

Some key points highlighted in the Guidance include:

  • Applicable pre-employment drug testing and training is still required. Applicable Department of Transportation (DOT) Agency Rules for FAA, FMCSA, FTA, PHMSA, FRA and Coast Guard pre-employment drug testing requirements MUST be followed prior to the performance of safety sensitive functions, including the receipt of a negative drug test report from the Medical Review Officer (MRO) as per the particular DOT Agency Rule.
  • For random programs, employers must continue to make a good faith effort to complete random testing requirements. If there are no facilities available or drivers are not comfortable completing a test, the DOT does understand that compliance may not be possible in the current environment. However, the reasons for your decision to not conduct required testing MUST be documented in your program files.
  • Best Practices for DOT Random Drug and Alcohol Testing guidance can be reviewed at: Testing Brochure.pdf


First Advantage suggests that your organization:

  • Check with the collection site to determine whether or not the site can perform drug specimen and/or alcohol testing the same day or just before the applicant or employee is sent to the collection site/clinic/patient service center.
    • DOT employers are responsible for making the decision as to whether testing is feasible. The circumstances associated with why the testing could not be completed, including those related to COVID-19 challenges such as the unavailability of a collection site or driver-related health or safety considerations should part of the documentation placed in your organization’s program records.
    • Service Agents, including C/TPA’s like First Advantage or MROs are not permitted to excuse testing or excuse the performance of any required testing.

First Advantage will continue to keep you updated on DOT rules when or if they change. Please reach out to your Account Manager for additional information.

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