DOT forms vs. Non-DOT forms
We’ve been getting a lot of questions recently about using DOT Alcohol Test Forms for non-DOT testing, and using Non-DOT Alcohol Test Forms for DOT testing. Here is what you need to know.
While the DOT Alcohol Test Forms look very similar to the Non-DOT Alcohol Test Forms, there are a few key differences in the wording in Step 2 and Step 3 that are very significant.
The certification in Step 2 of the DOT form reads “I certify that I am about to submit to alcohol testing required by U.S. Department of Transportation regulations…” Step 2 of the Non-DOT form omits this phrase.
Step 3 of the DOT form reads “I certify that I have conducted alcohol testing on the above named individual in accordance with the procedures established in the U.S. Department of Transportation regulation, 49 CFR Part 40, …” Step 3 of the Non-DOT form omits this phrase.
Q. Do I really need to get DOT Alcohol Test Forms and Non-DOT Alcohol Test Forms?
A. Yes. If you do DOT alcohol testing and also do testing conducted under a company’s own policy, then you need DOT and Non-DOT forms.
Q. Can I use a DOT form to record a non-DOT test?
A. No. It would be wrong to ask an employee who is taking a test under their company’s policy to sign Step 2 of the DOT form stating that the test is required by DOT regulations. A company creates potential problems in defending their test results if they use DOT forms to record alcohol tests conducted under their own company’s policy.
Q. Can I use a Non-DOT form to record a DOT test?
A. No. The DOT regulations explicitly prohibit this. If a form other than a DOT Alcohol Test Form is used to record a DOT alcohol test, the BAT must supply an affidavit stating that the form used has all the required information, and explain the steps they will take to prevent the use of an incorrect form in the future.
The use of a Non-DOT form to record a DOT test does not invalidate the test; however, continued disregard for conducting alcohol testing according to DOT regulations could cause sanctions to be levied against the company and/or service agent.
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