Frequently Asked Questions

Employers are lawfully allowed to implement in-house drug testing programs (with some exceptions) to maintain a safe and drug-free workplace. Compared to outsourcing, in-house drug and alcohol testing can be more efficient and financially beneficial.

Legal and Practical Advantages of On-Site Drug Testing

In-house drug testing provides an immediate and flexible approach to ensuring a drug-free environment in the workplace. It's important to understand the distinction between DOT and non-DOT drug testing:

1. DOT (Department of Transportation) Drug Testing: This pertains to specific regulations the U.S. Department of Transportation sets. It is mandatory for certain safety-sensitive positions, primarily in the transportation industry, such as truck drivers, pilots, and railroad workers. DOT tests have strict protocols regarding the drugs tested for, the testing methods, and how results are reported. On-site or instant screening is never allowed for DOT drug tests. An employer can run its own DOT collection site with qualified collectors, but every DOT specimen must be tested at an HHS-certified laboratory (49 CFR 40.210), and a Medical Review Officer must verify the result before any action is taken.

2. Non-DOT Drug Testing: These tests are not bound by DOT regulations and can be tailored to an organization's needs. While they ensure a safe and productive work environment, they don't have the stringent requirements of DOT tests. Instant on-site screening can be used for non-DOT tests where state law allows it. A non-negative screen should be sent to a laboratory for confirmation before any action is taken, and some states require this.

Drawbacks of Outsourced Drug Testing

Using an external lab can be cumbersome and expensive. It involves coordinating with the lab, incurring service costs, and potentially dealing with timing challenges for post-incident tests. In an accident, for example, waiting for a lab technician to arrive may delay testing, and substances like alcohol might no longer be detectable. After-hours services can also lead to significant additional charges.

Economic and Operational Benefits of In-House Testing

In-house testing, however, addresses these issues. By training existing staff to conduct these tests, employers get timely results at a fraction of the cost. For instance, running a urine test in-house costs approximately $15 instead of an average of $60 at an external lab. Over time, this difference can result in substantial savings, especially for a company that conducts regular screenings.

The lower cost is due to eliminating the need for an on-site technician visit from the lab, which adds to the expense of outsourced services. Also, given the scarcity of these labs, their prices can be pretty high. Once state-specific protocols and additional procedures are added, the costs can exceed the base amount.

Immediate Action for Safety

Most importantly, on-site testing facilitates rapid response when safety is concerned. If a non-DOT screen returns a non-negative result, immediate safety steps can be taken while the laboratory confirms it, as company policy and state law allow. For DOT tests, an employee may not be removed from safety-sensitive duty based on an unverified drug test result (49 CFR 40.21). This level of responsiveness is not achievable with external testing, where waiting for results could pose unnecessary risks.

A urine drug screen, also known as a UDS, is a type of test used to detect the presence of certain drugs in someone’s system. It is a relatively simple process that involves providing a sample of urine for testing.

Urine drug screens measure the amount of specific drugs or metabolites in an individual’s urine. The substances that are being measured are usually illicit substances such as opiates, cocaine, marijuana and amphetamines — but they can also be legal medications (such as Xanax).

The screening process is typically quick and easy - it only takes several minutes to perform the actual test - but results may take up to 24-48 hours depending on the laboratory used for analysis. Urine tests do not reveal exact levels of intoxication; rather they indicate whether or not any drug was detected at all.

UDS tests have become increasingly popular due to their accuracy and reliability when it comes to identifying potential substance abuse issues among individuals who need monitoring because of work requirements or involvement with law enforcement agencies. Employers often require these types of tests among employees who belong in certain professions such as pilots, medical practitioners and those working with hazardous materials; while courts may conduct UDS screenings on repeat offenders or individuals placed under probationary terms supervised by parole officers.

Overall, a urine drug screen provides an accurate reading on whether drugs were present at some point leading up to the day they took the test - though there is no guarantee that it will capture recent consumption due to how quickly one metabolizes different substances after consumption!

A urine test, also known as a urine drug test, involves analyzing a person's urine sample to detect the presence of certain drugs or their by-products. This type of test is commonly used in the workplace, by sports organizations, and in the criminal justice system to determine whether someone has recently used drugs.

Urine drug tests can detect many drugs, including amphetamines, cocaine, marijuana, opioids, and phencyclidine (PCP). The specific drugs tested depend on the individual's situation and the reason for the test. For example, a pre-employment drug test may screen for a different set of drugs than a test conducted as part of a criminal investigation.

DOT drug tests are federally regulated with strict guidelines for specific transportation industries, ensuring uniformity and compliance across safety-sensitive positions. These tests follow the Department of Transportation (DOT) standards, which include specific procedures, chain-of-custody protocols, and the use of HHS-certified laboratories to screen for substances like marijuana, cocaine, opioids, amphetamines, and PCP.

Non-DOT drug tests are governed by individual company policies and state laws, providing more flexibility in testing procedures and the range of substances screened. Non-DOT tests can include a broader spectrum of drugs, such as benzodiazepines and barbiturates, tailored to the specific needs and regulations of the employer.

Training in drug and alcohol testing is required for DOT collectors (49 CFR 40.33) and strongly recommended for non-DOT collectors to ensure drug screen compliance with both DOT and non-DOT. Training teaches collectors the specific procedures for DOT-regulated industries to maintain proper chain-of-custody, maintain compliance with federal regulations, and safeguard public safety. For non-DOT settings, adequate training also helps establish consistent and effective testing protocols that align with company policies and state laws. This training ensures the accuracy and reliability of test results, supports workplace safety, and minimizes legal risks by ensuring adherence to established guidelines and procedures.

The difference between DOT and non-DOT drug tests lies primarily in the regulatory standards and the industries they apply to:

Regulatory Authority:

• DOT Drug Tests: These tests are regulated by the Department of Transportation (DOT) and are mandated for employees in safety-sensitive positions within transportation industries, such as trucking, aviation, railroads, transit, and pipelines. The regulations are outlined in 49 CFR Part 40.
• Non-DOT Drug Tests: These tests are not regulated by the DOT. Instead, they are conducted according to company policies and state laws. Non-DOT tests apply to employees in industries outside the scope of DOT regulations.

Testing Procedures:

• DOT Drug Tests: Follow strict procedures and guidelines set by the DOT, including specific testing protocols, chain-of-custody requirements, and the use of HHS-certified laboratories. The test typically screens for five substances: marijuana, cocaine, opioids, amphetamines, and PCP.
• Non-DOT Drug Tests: The procedures vary widely depending on the employer's policies and state regulations. These tests can screen for a broader range of substances beyond the DOT's five-panel test, including additional drugs like benzodiazepines, barbiturates, and others.

Documentation and Reporting:

• DOT Drug Tests: Require detailed documentation and reporting to ensure compliance with federal regulations. Positive results must be verified by a Medical Review Officer (MRO), who reports them to the employer’s Designated Employer Representative (DER) (49 CFR 40.167(b)). For FMCSA-regulated drivers, the MRO also reports verified positives to the FMCSA Drug and Alcohol Clearinghouse (49 CFR 382.705). FAA has a similar rule for employees who hold airman medical certificates, whose verified positives the MRO also reports to the Federal Air Surgeon (14 CFR 120.113(d)).
• Non-DOT Drug Tests: Documentation and reporting are determined by the employer's policy and applicable state laws. There may be less stringent documentation requirements compared to DOT tests.

Consequences of Positive Results:

• DOT Drug Tests: Positive results can lead to immediate removal from safety-sensitive duties, mandatory evaluation by a Substance Abuse Professional (SAP), and completion of a return-to-duty process before resuming safety-sensitive functions.
• Non-DOT Drug Tests: Consequences of positive results vary by employer and state law. Employers may have more flexibility in handling positive tests, including disciplinary actions, rehabilitation programs, or termination.

Frequency of Testing:

• DOT Drug Tests: Employees are subject to various types of testing, including pre-employment, random, post-accident, reasonable suspicion, return-to-duty, and follow-up testing, all following DOT guidelines.
• Non-DOT Drug Tests: Testing frequency and types depend on the employer's policies. While some companies may adopt testing categories similar to the DOT, others may have different requirements.

DOT drug tests are federally regulated with strict guidelines for specific transportation industries. In contrast, non-DOT drug tests are governed by individual company policies and state laws, offering more flexibility in testing procedures and substances screened.

Fentanyl is a potent synthetic opioid drug approved by the Food and Drug Administration as an analgesic (pain relief) and anesthetic. It is approximately 100 times more potent than morphine and 50 times more potent than heroin as an analgesic and was first developed in 1959 and introduced in the 1960s as an intravenous anesthetic.

It is legally manufactured and distributed in the United States. Licit fentanyl pharmaceutical products are diverted via theft, fraudulent prescriptions, and illicit distribution by patients, physicians, and pharmacists. According to the Drug Enforcement Administration (DEA), most fentanyl on the illicit market comes from clandestine manufacturing (DEA Fentanyl Drug Fact Sheet, December 2025).

Final data from the CDC National Center for Health Statistics show 79,384 drug overdose deaths in the United States in 2024. Of these, 47,735 involved synthetic opioids other than methadone, a category that includes fentanyl, fentanyl analogs and tramadol. That was down from 72,776 in 2023 (NCHS Data Brief No. 549, January 2026).

What are the common street names?

• Apache
• China Girl
• China Town
• Dance Fever
• Friend
• Goodfellas
• Great Bear
• He-Man
• Jackpot
• King Ivory
• Murder 8
• Tango & Cash

What does it look like?

The FDA Orange Book currently lists two types of fentanyl prescription products as marketed in the United States: transdermal patches and injectable fentanyl citrate, including Sublimaze (FDA Orange Book). Clandestinely produced fentanyl is encountered either as a powder or in counterfeit tablets and is sold alone or in combination with other drugs such as heroin or cocaine.

How is it abused?

Fentanyl can be injected, snorted/sniffed, smoked, taken orally by pill or tablet, and spiked onto blotter paper. Fentanyl patches are abused by removing their gel contents and then injecting or ingesting these contents. Patches have also been frozen, cut into pieces, and placed under the tongue or in the cheek cavity. Illicitly produced fentanyl is sold alone or in combination with heroin and other substances and has been identified in counterfeit pills, mimicking pharmaceutical drugs such as oxycodone. DEA reports that fentanyl identifications reported to its National Forensic Laboratory Information System peaked in 2023 at over 182,000 and fell to over 152,000 in 2024 (DEA Fentanyl Drug Fact Sheet).

What is the effect on the body?

Fentanyl, similar to other commonly used opioid analgesics (e.g., morphine), produces effects such as relaxation, euphoria, pain relief, sedation, confusion, drowsiness, dizziness, nausea, vomiting, urinary retention, pupillary constriction, and respiratory depression.

What are the overdose effects?

Overdose may result in stupor, changes in pupillary size, cold and clammy skin, cyanosis, coma, and respiratory failure leading to death. The presence of triad of symptoms such as coma, pinpoint pupils, and respiratory depression are strongly suggestive of opioid poisoning.

Which drugs cause similar effects?

Drugs that cause similar effects include other opioids such as morphine, hydrocodone, oxycodone, hydromorphone, methadone, and heroin.

What is the legal status under the federal Controlled Substances Act?

Fentanyl is a Schedule II narcotic under the United States Controlled Substances Act of 1970 (21 CFR 1308.12).

Is fentanyl part of DOT drug testing?

HHS added fentanyl to the authorized drug testing panels for federal workplace programs in a notice published January 16, 2025, which took effect July 7, 2025. Fentanyl was added to both the urine and oral fluid panels, and its metabolite norfentanyl was added to the urine panel (90 FR 4662).

DOT testing follows its own rule in 49 CFR Part 40, so the HHS change did not by itself add fentanyl to DOT tests. On September 2, 2025, DOT published a proposed rule to add fentanyl and norfentanyl to the Part 40 drug testing panel, and the comment period closed October 17, 2025 (90 FR 42363).

As of October 2026, DOT has not published a final rule, and the Unified Agenda lists the final rule date as to be determined (RIN 2105-AF26). Fentanyl is not yet part of the DOT drug testing panel, and DOT-regulated employers continue to test for the drug classes listed in 49 CFR 40.82 until a final rule takes effect.

Official Sources

• 90 FR 4662 (Federal Register)
• 90 FR 42363 (Federal Register)
• Unified Agenda, RIN 2105-AF26 (reginfo.gov)
• 49 CFR 40.82 (eCFR)
• 21 CFR 1308.12 (eCFR)

The Substance Abuse and Mental Health Services Administration (SAMHSA) is a U.S. Department of Health and Human Services branch that leads public health efforts to advance the nation's behavioral health and reduces the impact of substance abuse and mental illness in America. SAMHSA also manages the HHS Mandatory Guidelines, which set drug testing procedures and cut-off levels for federal workplace drug testing programs. DOT sets its own cut-off levels for DOT tests in 49 CFR Part 40.

A variety of drug tests are available, each testing for different types and numbers of drugs. For instance, a 4-panel drug test typically screens for marijuana, cocaine, opiates, and amphetamines. A 9-panel drug test adds barbiturates, benzodiazepines, methaqualone, methadone, and propoxyphene. These non-DOT panels are not set by SAMHSA or DOT, so the laboratory or test maker chooses their cut-off levels. The test method (urine, oral fluid, hair) also affects the cut-off level.

Here are the DOT cut-off levels for urine and oral fluid (49 CFR 40.85 and 40.91), the hair cut-off levels proposed by HHS, and fentanyl, which HHS added for federal agency testing:

Notes:

• Urine and oral fluid values are the DOT cut-offs in 49 CFR 40.85 and 40.91.
• DOT oral fluid testing cannot begin until HHS certifies oral fluid laboratories. As of September 30, 2026, HHS has certified none, so DOT tests remain urine tests.
• Fentanyl values come from the HHS Mandatory Guidelines (90 FR 4662, effective July 7, 2025) and apply to federal agency testing programs. DOT proposed adding fentanyl in September 2025 but has not finalized that change.
• Hair values are cut-offs proposed by HHS in 2020 (85 FR 56108). They are not final, and DOT does not allow hair testing (49 CFR 40.210).

Expanded non-DOT panels often add the drugs below. These drugs are not part of the HHS or DOT panels. The values shown are common laboratory cut-offs, and laboratories and test makers may use different values.

In light of the variations in cut-off levels and the specifics of different testing protocols, it becomes even more crucial to have thorough training in conducting both DOT and Non-DOT drug testing. Proper training ensures collectors are qualified for these varying standards and can apply and adhere to them accurately. This knowledge allows for the correct administration and interpretation of tests, increasing the reliability of results, and also ensures that the rights and privacy of the tested individuals are safeguarded and that the testing process complies with all legal and ethical standards. Being trained adequately in conducting drug tests is not only about acquiring a skillset but also underpins the integrity, fairness, and effectiveness of the entire drug testing process.

Fentanyl cutoffs

HHS added fentanyl to the federal workplace drug testing panels effective July 7, 2025 (90 FR 4662), and republished the current panels on March 13, 2026 (91 FR 12308). In urine, the initial test cutoff for fentanyl is 1 ng/mL, and the confirmatory cutoffs are 1 ng/mL for fentanyl and 1 ng/mL for norfentanyl. In oral fluid, the initial test cutoff for fentanyl is 4 ng/mL and the confirmatory cutoff is 1 ng/mL. These are the HHS cutoffs for federal agency programs. DOT has proposed adding fentanyl to its panel but has not issued a final rule (90 FR 42363).

Performing a DOT drug test involves specific procedures and protocols to ensure accuracy, confidentiality, and compliance with the U.S. Department of Transportation (DOT) regulations. The most important requirement is proper training to conduct drug and alcohol testing.

Here are the key requirements for conducting a DOT-regulated drug test:

1. Collection Site:

   • The collection site must be secure and private. It should be equipped to prevent tampering with specimens.
   • Ensure there is a facility for washing hands, and the person being tested must show that they have nothing on them that could alter the sample.
   • The same applies to specimen collectors who conduct mobile drug testing.

2. Qualified Personnel:

   • Only a trained and qualified collector can handle and oversee the collection process. The collector must understand the current federal drug testing regulations and guidelines.

3. Chain of Custody Form (CCF):

   • A CCF is required for every sample. This document tracks the specimen by documenting every step from collection to laboratory testing, ensuring no tampering has occurred.

4. Collection Procedure:

   • The tested employee must provide a specific amount of urine in a collection container.
   • The collector checks the specimen for temperature and signs of tampering shortly after collection.
   • The specimen is then poured into two bottles (A and B) and sealed.

5. Laboratory Testing:

   • Only Substance Abuse and Mental Health Services Administration (SAMHSA) certified laboratories can test DOT drug samples.
   • The initial test is an immunoassay. If this test is positive, the laboratory performs a confirmation test using mass spectrometry, such as Gas Chromatography/Mass Spectrometry (GC/MS) or Liquid Chromatography/Tandem Mass Spectrometry (LC-MS/MS).

6. Tested Substances:

   • The U.S. Department of Transportation (DOT) mandates testing for these five classes of drugs to ensure the safety and well-being of the traveling public and employees engaged in safety-sensitive positions within the transportation industry. Here's a breakdown of why each class of drug is included:

     • Marijuana:

       • Effects: Marijuana can impair motor coordination, judgment, and reaction times.
       • Relevance: Employees under the influence of marijuana can pose significant safety risks in transportation settings, potentially causing accidents due to delayed decision-making or misjudgment of situations.

     • Cocaine:

       • Effects: Cocaine is a stimulant that can lead to euphoria, increased energy, alertness, and sensitivity to stimuli. However, it can also lead to paranoia, unpredictability, and impaired judgment.
       • Relevance: The erratic behavior and altered judgment due to cocaine can be hazardous in safety-sensitive roles. Its short-lived effects can also lead to sudden crashes in energy, which can be problematic for tasks requiring consistent alertness.

     • Amphetamines (including methamphetamines):

       • Effects: These stimulant drugs can increase focus and energy in the short term but can also lead to agitation, paranoia, hallucinations, and dangerous risk-taking behavior.
       • Relevance: While some people misuse amphetamines to stay awake and alert, the potential side effects, including erratic behavior and poor decision-making, can compromise safety in transportation environments.

     • Opioids (like heroin, codeine, morphine, hydrocodone, hydromorphone, oxycodone and oxymorphone):

       • Effects: Opioids depress the central nervous system. They can lead to drowsiness, impaired cognitive function, slowed reaction times, and respiratory depression.
       • Relevance: The sedative effects of opioids are especially concerning in transportation sectors, where a lapse in attention or slowed reaction can have catastrophic consequences.

     • Phencyclidine (PCP):

       • Effects: PCP is a hallucinogenic drug that can lead to distorted perceptions of reality, hallucinations, and aggressive or violent behavior. It can also result in numbness, slurred speech, and a sense of detachment.
       • Relevance: The severe cognitive distortions and potential for violent behavior under the influence of PCP make it incredibly risky in any setting, especially in safety-sensitive roles.

7. Medical Review Officer (MRO) Involvement:

   • Once the laboratory completes testing, the results are sent to an MRO. The MRO reviews the results, ensuring that legal or prescribed drug use hasn't caused any positive results.
   • If a test is non-negative (positive), the MRO contacts the employee to discuss the result before reporting it to the employer, giving the employee a chance to provide any relevant medical information.

8. Record Keeping:

   • Employers must maintain records of their drug and alcohol testing program, including test results, for a period determined by DOT regulations.

9. Confidentiality:

   • Test results and related information should be kept confidential and only released to those who need it to perform their duties.

10. Employee Rights:

    • If an employee tests positive, they can request a retest of the split specimen (Bottle B) at a different SAMHSA-certified laboratory.

11. Return-to-duty Process:

    • If an employee has a verified positive test or refuses to test, they need to see a Substance Abuse Professional (SAP) and complete the return-to-duty process, which includes an evaluation, possibly education or treatment, a return-to-duty test, and follow-up tests.

By adhering to DOT drug testing requirements, employers reinforce the integrity and trustworthiness of the testing process, underscoring their dedication to safety in the workplace.

Test Types by DOT Agency

The DOT agencies name similar test types in their own rules:

• FMCSA: pre-employment drug testing (pre-employment alcohol testing is optional), post-accident, random, reasonable suspicion, return-to-duty, and follow-up testing (49 CFR 382.301 to 382.311).
• FAA: pre-employment, random, post-accident, reasonable cause, return to duty, and follow-up drug testing (14 CFR 120.109), with the same alcohol test types in 14 CFR 120.217.
• FTA: pre-employment drug testing (pre-employment alcohol testing is optional), reasonable suspicion, post-accident, random, return to duty, and follow-up testing (49 CFR 655.41 to 655.47).

FRA and PHMSA use their own terms, and FRA adds post-accident toxicological testing (49 CFR Part 219). Testing procedures for each agency follow 49 CFR Part 40.

The contact details provided are for HHS-certified laboratories and Instrumented Initial Testing Facilities (IITFs) that meet the minimum standards for conducting drug and specimen validity tests on urine and oral fluid specimens. While these details can be used to contact the labs, it's essential to verify with each lab if these are the correct contacts for setting up a lab account to submit samples. View the SAMHSA Certified Lab List or contact SAMHSA directly by email at workplace@samhsa.hhs.gov or by phone at 240-276-2600.

To ensure accuracy, please follow these steps:

• Contact the lab directly using the provided phone numbers or addresses.
• Inquire specifically about setting up a lab account to submit samples.
• Verify if there are any additional requirements or specific contacts within the lab for account setup and sample submission.
• Always check the most recent updates or contact the labs to confirm the current and correct certifications for your specific needs.

The regularly updated list of certified Labs can also be found here.

No. Currently, there is no situation in which a Medical Review Officer (MRO) can verify a laboratory confirmed marijuana positive drug test result as negative when an employee claims the positive came from using a state-licensed marijuana product.

Even after rescheduling, state-dispensed marijuana does not constitute an FDA-approved drug. Without FDA approval for a controlled substance, it cannot be prescribed. A legitimate medical explanation requires the use of a legally prescribed controlled substance in compliance with Federal laws governing such a prescription (49 CFR sections 40.137(a) and 40.141(b)).

Although the MRO may be presented with documentation such as state-issued medical marijuana cards, physician recommendations, certifications, or dispensary records or receipts, these documents do not satisfy Part 40 requirements for a legitimate medical explanation. Marijuana use under state marijuana programs or other non-prescription sources does not qualify as a legitimate medical explanation under 49 CFR section 40.137(a). In addition, marijuana use is not compatible with safety-sensitive functions.

Practical Use Cases

• Commercial Truck Driver: A driver in Colorado holds a state medical marijuana card and uses a licensed dispensary product for pain management. After a random DOT urine test returns positive for marijuana metabolites, the driver provides the card and purchase receipts to the MRO. The MRO cannot accept this as a legitimate medical explanation and must report the result as positive, triggering DOT return-to-duty requirements. 
• Transit Bus Operator: An employee in a safety-sensitive public transit role tests positive after recreational use of state-legal cannabis. The employee submits a physician's recommendation and dispensary records. Under Part 40, these documents are insufficient, and the MRO verifies the result as positive because state programs do not meet federal prescription standards.
• Pipeline Maintenance Technician: Following a post-accident test, a technician claims the positive came from legally purchased edibles in a recreational state. Even with proof of state-compliant purchase, the MRO has no authority to overturn the laboratory positive, as marijuana remains incompatible with safety-sensitive duties under federal rules.

Collection sites, clinics, and TPAs must track which Federal Custody and Control Form (CCF) version is in the kit and when older stock needs an accompanying memorandum for the record (MFR). DOT's Office of Drug and Alcohol Policy and Compliance (ODAPC) published a notice on the revised 2026 Federal CCF. The dates and collector duties below come from that notice.

Effective dates

• The revised 2026 Federal CCF may be used as a paper or electronic form. Its effective date is April 27, 2026. The OMB approval on the notice runs through April 30, 2029.
• DOT-regulated employers and their service agents (collectors, laboratories, MROs) are authorized to use the 2023 version of the CCF until May 31, 2027.
• Between April 27, 2026 and May 30, 2027, if the 2023 CCF is used, an MFR is not required.
• As of May 31, 2027, if the 2023 CCF is used, an MFR must be completed per 49 CFR 40.205(b)(2).

ODAPC recommends coordinating delivery of the revised 2026 CCF with the laboratory when existing 2023 stock is about to run out, rather than discarding usable forms early.

What changed on the form

According to ODAPC's notice, the revised CCF includes these layout and wording changes:

• In Step 1F (copies 1 through 5): drug analytes and checkboxes were removed, and the field label changed to "Other tests to be performed (specify):".
• In Step 4 (copy 1): the Split Specimen Device Expiration Date field moved to the right.
• In Step 5 (copies 2 through 5): the email line was lengthened and moved, the daytime and evening phone fields were replaced with a single Phone No. field, and the date of birth field was reworded as Birthdate and repositioned.

Do collectors complete Step 1F?

ODAPC's notice states that collectors do not need to complete Step 1F. The laboratory knows the drug testing panel from the account number on the CCF. Collectors should not enter the drugs to be tested in that field as a routine step.

There is no separate DOT "CCF course" requirement. Correct CCF completion is already part of urine collector qualification training under 49 CFR 40.33(b)(1), which requires instruction on all steps necessary to complete a collection correctly and the proper completion and transmission of the CCF. Sites updating staff on the 2026 layout can treat that as refresher content inside existing collector training, not as a new credential.

Site checklist

• Confirm which CCF version is in active kits and in storage.
• Plan the switch to 2026 forms with the laboratory before May 31, 2027 if 2023 stock will still be in use after that date.
• Brief collectors that Step 1F drug checkboxes are gone on the 2026 form and that they do not fill drug panels there.
• Keep current DOT urine collection procedure guidelines available to collectors. ODAPC updated the Urine Specimen Collection Procedures Guidelines in June 2026.

For how collector qualification and documentation fit around form changes, see qualified specimen collector requirements, what 49 CFR Part 40 covers, and when error correction training is needed.

Organizations updating collector staff can enroll through a Training Manager account in DOT Urine Specimen Collector Training or DOT Urine Error Correction Training.

Organizations that already employ DOT urine collectors often ask whether those staff can start DOT oral fluid collections without new training. They cannot. DOT treats urine and oral fluid collector qualification as separate paths.

Separate qualification rules

DOT's November 2024 Part 40 summary states that a qualified urine collector under 49 CFR 40.33 is not a qualified oral fluid collector under 49 CFR 40.35, and vice versa. A person who completed urine qualification and five urine mocks still needs oral fluid qualification training and oral fluid proficiency demonstrations before performing DOT oral fluid collections.

What 49 CFR 40.35 requires

To act as an oral fluid collector in the DOT program, 40.35 requires:

• Knowledge of Part 40, the current DOT Oral Fluid Specimen Collection Procedures Guidelines, and the DOT agency rules for the employers served (40.35(a)).
• Qualification training on Part 40 testing procedures, proficiency on each oral fluid device the collector will use, correct CCF completion, problem collections, fatal and correctable flaws, and integrity, privacy, and security duties (40.35(b)).
• Five consecutive error-free mock collections for each device the collector will use, with the scenarios listed in 40.35(c)(1), including checking and recording each device's expiration date on the CCF (40.35(c)).
• A monitor who meets 40.35(c)(2), or the temporary monitor flexibility in 40.35(c)(3) until one year after HHS publishes notice of the first certified oral fluid laboratory.
• Refresher training at least every five years (40.35(e)), error correction training when required (40.35(f)), and documentation available to employers and C/TPAs on request (40.35(g)).

Who may monitor mocks, including train-the-trainer paths, is covered in who can monitor DOT mock collections.

Laboratory availability (check before live DOT oral fluid testing)

DOT's page on HHS Certified Oral Fluid Laboratories states that DOT-regulated employers may begin oral fluid drug testing in the DOT program only when there are two HHS-certified oral fluid laboratories. The HHS list published September 30, 2026 states that no laboratories are certified for oral fluid testing. Employers should check DOT's page for the current count before scheduling live DOT oral fluid collections. Under a DOT rule effective June 10, 2026, a directly observed urine collection is used in situations where an oral fluid test would be required but oral fluid testing is not yet available (91 FR 25507). Collectors may complete device training and mocks before laboratories are certified, but DOT has warned that training on a device that is not later approved with an HHS laboratory package carries risk for the trainer and trainee.

Always verify the live status here: HHS Certified Oral Fluid Laboratories and Oral Fluid Collection Devices.

What employers and TPAs should do

• Keep urine and oral fluid qualification files separate for each collector.
• Do not assign DOT oral fluid collections to staff whose file only shows 40.33 urine qualification.
• Confirm device-specific mocks exist for every oral fluid device in use at the site.
• Re-check DOT's certified oral fluid laboratory list before the first live DOT oral fluid collection.

Related reading: how to become a DOT specimen collector, qualified specimen collector requirements, and what 49 CFR Part 40 covers.

Organizations preparing oral fluid capacity can enroll teams through a Training Manager account in DOT Oral Fluid Testing Training and DOT Oral Fluid Train-the-Trainer.

HHS publishes separate Mandatory Guidelines for urine and for oral fluid. The oral fluid guidelines were first published on October 25, 2019 (84 FR 57554) and revised on October 12, 2023 (88 FR 70814). DOT added oral fluid to 49 CFR Part 40 as an alternate methodology in a final rule published May 2, 2023 (88 FR 27596). The employer tells the collector which specimen type to collect (49 CFR 40.14).

Collection steps differ. A urine specimen is provided in private unless the collection is observed or monitored, and the collector checks the temperature within 4 minutes (49 CFR 40.63, 49 CFR 40.65). The urine specimen is at least 45 mL, split into a primary bottle of at least 30 mL and a split bottle of at least 15 mL (49 CFR 40.65, 49 CFR 40.71). For oral fluid, the collector inspects the mouth, waits 10 minutes, and maintains visual contact with the employee during the collection (49 CFR 40.72, 49 CFR 40.73). Each oral fluid bottle holds at least 1 mL of undiluted oral fluid (49 CFR 40.74). Once oral fluid testing is available, Part 40 lists an oral fluid test as an option when a same sex observer cannot be found for a directly observed urine collection (49 CFR 40.67).

Laboratory cutoffs are lower for oral fluid. For marijuana, the urine cutoffs are 50 ng/mL initial and 15 ng/mL confirmatory for THCA, and the oral fluid cutoffs are 4 ng/mL and 2 ng/mL for THC (49 CFR 40.85, 49 CFR 40.91). Urine validity testing includes creatinine, pH, and oxidizing adulterants on each primary specimen (49 CFR 40.87). Oral fluid validity testing is optional. A laboratory may conduct it when a specimen shows abnormal characteristics, and it may include a biomarker such as albumin or IgG (49 CFR 40.92, 49 CFR 40.93).

An employer may use oral fluid testing only when at least two HHS-certified oral fluid laboratories exist. After HHS gives notice of the second laboratory, an 18-month grace period allows employers to continue directly observed urine collections (49 CFR 40.67). The HHS list published September 30, 2026 states that no laboratories are certified to conduct oral fluid drug testing (91 FR 61854).

Chain of custody is the documented record of who handled a drug test specimen and when. Part 40 defines it as the procedure used to document the handling of the urine specimen from the time the employee gives the specimen to the collector until the specimen is destroyed, using the Federal Drug Testing Custody and Control Form (CCF) (49 CFR 40.3). The Federal CCF is required for each collection under the DOT drug testing program, and a non-Federal form or an expired CCF may not be used (49 CFR 40.40).

At the collection site, the collector maintains personal control over each specimen and CCF throughout the collection process. To the greatest extent possible, the urine collection container stays in view of both the collector and the employee until it is sealed (49 CFR 40.43). In the presence of the employee, the collector places tamper-evident seals on the specimen containers and records the date, and the employee is asked to initial the seals. If the employee declines, the collector notes it in the Remarks line and completes the collection (49 CFR 40.71, 49 CFR 40.74). The collector then completes Step 4 of the CCF by printing a name, recording the date and time, signing the statement, and entering the name of the delivery service. The specimen is shipped to the laboratory within 24 hours or during the next business day (49 CFR 40.79).

The laboratory checks incoming specimens for fatal flaws. These include no CCF, no specimen submitted with the CCF, no printed collector name and no collector signature, two collections on one CCF, specimen ID numbers that do not match, and a broken or tampered seal or an insufficient specimen when the split cannot be redesignated. For oral fluid, an expired collection device is also a fatal flaw. The Medical Review Officer (MRO) cancels a test with a fatal flaw (49 CFR 40.83, 49 CFR 40.199). A missing collector signature on the certification statement is a correctable flaw that the laboratory attempts to correct (49 CFR 40.203).

Some errors do not cancel a test. Examples include a minor administrative mistake, such as an omitted middle initial, and an omitted or wrong courier name. Such errors may still subject an employer or service agent to enforcement action under DOT agency regulations or Subpart R of Part 40 (49 CFR 40.209).

SAMHSA states that most successful drug-free workplace programs have five key components: a written policy, employee education, supervisor training, drug testing, and an Employee Assistance Program (EAP) (SAMHSA, Drug-Free Workplace Employer Resources).

According to SAMHSA, the written policy at a minimum states the rationale for the policy, the expectations for employee compliance, the assistance options available to employees, and the consequences for violating the policy. SAMHSA describes the expectations for compliance as including who, what, when, and where.

Federal contractors have specific duties under the Drug-Free Workplace Act. A contractor other than an individual, on a contract above the simplified acquisition threshold that is not for commercial products or commercial services, agrees to publish a statement that prohibits the unlawful manufacture, distribution, dispensation, possession, or use of a controlled substance in the workplace and that specifies the actions taken for violations. The contractor also establishes a drug-free awareness program that informs employees about the dangers of drug abuse in the workplace, the policy, available counseling, rehabilitation, and employee assistance programs, and the penalties for drug abuse violations. Each employee on the contract receives a copy of the statement and agrees to notify the employer of a conviction for a workplace violation of a criminal drug statute within 5 days. The contractor notifies the contracting agency within 10 days after receiving that notice, imposes a sanction on or requires satisfactory participation in a drug abuse assistance or rehabilitation program by a convicted employee, and makes a good faith effort to maintain a drug-free workplace (41 U.S.C. 8102). The statute does not list drug testing as a requirement. Federal grant recipients have parallel requirements under 41 U.S.C. 8103, and 2 CFR Part 182 is the government-wide guidance that federal agencies implement for grants and other financial assistance.

Employers regulated by the Department of Transportation follow agency rules that include testing and supervisor training. For example, FMCSA requires that persons designated to supervise drivers receive at least 60 minutes of training on alcohol misuse and at least an additional 60 minutes on controlled substances use, which supervisors use to decide whether reasonable suspicion exists (49 CFR 382.603).