DOT Drug and Alcohol Testing Compliance Checklist

Are you in compliance with DOT regulations? Every DOT covered motor carrier should have the following information on file to ensure DOT compliance.
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Pre Employment Test – Before a driver can perform safety sensitive work for an employer they must test negative on a DOT pre-employment drug screen. Any driver hired after January 1, 1996 and did not have a pre employment test must be tested. File pre-employment drug test results from MRO in separate secure drug testing file accessible only to the DER and alternate DER.

Previous Employer Inquiry – When a new driver is hired, a previous employer inquiry is sent to all former employers where the driver was a DOT covered driver covering the 3 years prior to date of application. Driver must sign release portion of form before previous employers are contacted. Regulations require that a diligent effort is made to obtain this information. We suggest you document every attempt to obtain this information. If driver did not work as DOT covered driver prior to working at your company, document previous employer inquiry form as such and file in Driver Qualification File. Per 391.23(g), previous employers must respond to this inquiry within 30 days.

Evidence of Random Testing Program - RSS Monthly Employer Report and corrections, kept in general drug testing compliance file or use the website service at www.randomselection.com (contact RSS to be set up to update online).

Notice of Random Selection - All records relating to the random selection process (notice, Employer Copy of CCF, result) kept in general drug testing compliance file.

Random Testing - All drivers working full-time, part-time, intermittent or standby must be in your random selection pool. File all Random DOT Drug Test and Breath Alcohol Test results in Driver Qualification File. If a driver has been out of your random pool for more than 30 days, the driver must be pre employment tested, and test negative before operating a commercial motor vehicle.

Return to Duty Testing - (After a Positive Drug or Breath Alcohol Test) - No driver having tested positive can be permitted to perform safety sensitive work until they are released by DOT qualified Substance Abuse Professional and test negative on a Return to Duty drug and/or breath alcohol test (BAT). File drug/BAT test result in secure drug testing files with positive test paperwork and the Substance Abuse Professional’s release to work.

Follow Up Tests – Following a positive test result, DOT requires a minimum of 6 follow up tests within the first 12 months of return to safety sensitive work unless the Substance Abuse Professional (SAP) requires further testing. DOT allows up to 60 months of follow up testing if required by SAP.

Driver Education/Awareness - All drivers must receive awareness materials/education on substance abuse issues. The Fit for Work DOT Driver’s Employee Handbook and the form “Notice to Employee for Drug Testing Requirements…” used in conjunction with the company policy will meet the DOT requirements. File signed “Receipt and Certification of Driver Awareness Materials” Form in Driver Qualification File.

Supervisory Training - All supervisor/managers who will make reasonable cause decisions must have at least one hour of training in drugs and one hour in alcohol. The employer must maintain a roster of supervisors trained or a copy of certificates of training with an outline of the training process. These records should be kept in general drug testing compliance file.

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