DOT drug-testing program checklist
A collection appointment is only one part of a compliant program. Use this educational checklist to identify the people, policies, testing events, service agents and records your organization should review.
Updated July 24, 2026 • Educational information, not legal adviceEmployer responsibility matters. DOT states that regulated employers are responsible for developing and implementing successful workplace drug and alcohol programs. Outsourcing functions does not transfer the employer’s regulatory responsibility.
- 1
Confirm that your employees are covered
Identify the DOT agency and safety-sensitive functions that apply. For FMCSA programs, covered CDL drivers include full-time, part-time, intermittent, backup and international drivers operating CMVs subject to CDL requirements on public roads.
- 2
Designate a knowledgeable employer representative
Identify the Designated Employer Representative who can receive results, make required decisions, direct collections and communicate with service agents. Keep current contact information available during all operating hours.
- 3
Maintain a written policy and driver education
FMCSA employers must provide a written controlled-substances and alcohol-misuse policy containing the required information and maintain each driver’s signed receipt of the materials.
- 4
Train supervisors before they make testing decisions
Supervisors designated to supervise covered CDL drivers generally need at least 60 minutes on alcohol misuse and 60 minutes on controlled-substances use so they can recognize relevant physical, behavioral, speech and performance indicators.
- 5
Use the correct testing reason
Covered programs include pre-employment, random, reasonable suspicion or cause, post-accident, return-to-duty and follow-up testing. Do not substitute one reason for another or mix DOT and Non-DOT testing.
- 6
Verify collection-site and service-agent readiness
Confirm that collectors, technicians, laboratories, Medical Review Officers and other service agents meet the requirements for their roles. Employers remain responsible for program compliance even when tasks are outsourced.
- 7
Keep DOT and Non-DOT programs separate
DOT specimens, forms and processes cannot be used as a combined company-policy test. Point-of-collection instant drug tests, hair tests and nail tests are not authorized as DOT drug tests.
- 8
Manage random testing throughout the year
Use a scientifically valid selection method, ensure each covered employee has an equal chance of selection and spread unannounced testing reasonably throughout the calendar year. Check the current annual minimum rates for the applicable DOT agency.
- 9
Handle violations through the required process
A covered employee with a DOT violation cannot return to safety-sensitive work until completing the Substance Abuse Professional and return-to-duty process. Follow-up testing is prescribed by the SAP and follows the employee as required.
- 10
Complete Clearinghouse and recordkeeping duties
FMCSA employers must perform required Clearinghouse queries and reports, maintain confidential records and preserve program documents for the applicable retention periods.
What Test First can support
Test First Premier Partners can assist DFW employers with DOT and Non-DOT collections, scheduled mobile testing, pre-employment screening, time-sensitive response, consortium support, reasonable-suspicion supervisor training and driver refresher education. The employer remains responsible for determining coverage and applying the correct rule.
Official sources
Use the current regulation and agency guidance for authoritative requirements.