Guidance Issued for DOT-Regulated Employers Regarding Drug and Alcohol Testing Requirements

In light of the COVID-19 pandemic, the DOT and the FMCSA have issued guidance on compliance with DOT drug and alcohol testing programs, in effect until June 30, 2020.

DOT Guidance on Compliance with DOT Drug and Alcohol Testing Regulations

Disruptions caused by the COVID-19 national emergency are interfering with, and in some cases, may be preventing, employer and driver compliance with current DOT drug and alcohol testing requirements. The following guidelines regarding compliance of such requirements are in effect until June 30, 2020:

  • Make a reasonable effort to locate necessary resources, including collection sites, Breath Alcohol Technicians (BAT), Medical Review Officers (MRO) and Substance Abuse Professionals (SAP).
  • Consider mobile collection services for required testing if fixed-site collection facilities are not available.
  • If unable to conduct testing, document why the test was not completed.
  • If possible, conduct training or testing at a later date.
  • If testing is not possible due to the unavailability of testing resources, underlying modal regulations continue to apply. For example, without a negative pre-employment drug test result, the subject would not be able to perform any DOT safety-sensitive functions.
  • Be sensitive to employees who indicate they are not comfortable to go to a clinic or collection site when evaluating the circumstances of a refusal to test. Certiphi Screening has addressed the safety of clinics and collection sites during the COVID-19 pandemic in this article.
  • Revisit back-up plans to ensure they are up to date and effective for the current outbreak conditions.

In every event, you should continue to follow DOT Agency requirements and underlying modal regulations.


FMCSA COVID-19 Drug & Alcohol Testing Guidance

The FMCSA has published recommended actions for FMCSA-regulated employers who are unable to conduct testing during this time.

NOTE: In every case as a best practice, you should document in writing specific reasons why you were unable to conduct the tests, and any actions taken to mitigate the effect of the disruption, including trying to locate an alternative collection site or other testing resource. In the event of a DOT audit, you will need to explain why testing parameters were not met.

Type of Test

If unable to conduct testing:

Random testing

If random testing for a particular testing period or quarter is unable to be met, you should make up the tests by the end of the year.

Pre-Employment Testing

You cannot allow a prospective employee to perform DOT safety-sensitive functions until you receive a negative pre-employment test result, unless excepted by 49 CFR 382.301(b).

Post-Accident Testing

If unable to administer an alcohol test within 8 hours following the accident, or a controlled substance test within 32 hours following the accident, document in writing as required.

Reasonable Suspicion Testing

In addition to documenting why the test could not be performed, also make sure to document the observations leading to the test.

Return-to-Duty (RTD) Testing

Until a negative result of an RTD test is acquired, the driver may not perform any safety-sensitive functions.

Follow-Up Testing

Conduct the test as soon as practicable after documenting the reasons why the testing could not be conducted as in accordance with the follow-up testing plan.


Posted: March 31, 2020

All Rights Reserved © 2020 Certiphi Screening, Inc.
This document and/or presentation is provided as a service to our customers. Its contents are designed solely for informational purposes, and should not be inferred or understood as legal advice or binding case law, nor shared with any third parties. Persons in need of legal assistance should seek the advice of competent legal counsel. Although care has been taken in preparation of these materials, we cannot guarantee the accuracy, currency or completeness of the information contained within it. Anyone using this information does so at his or her own risk.

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