What’s the Difference Between a DOT and Non-DOT Drug Test?
In order to best explain the differences between a DOT and non-DOT drug test, we first should clarify two terms often used in drug testing; regulated and non-regulated workplace testing. Having a firm grasp on the nomenclature is principal to administering the programs as intended.
Companies falling under the authority of one of the five Department of Transportation (DOT) agencies and with employees in safety-sensitive job positions are required to follow regulated workplace drug and alcohol testing practices at the behest of the federal government. Airlines and trucking companies are only two examples of companies that follow regulated workplace testing, also known as DOT testing, on employees working in safety-sensitive capacities. Non-regulated workplace testing is the category that describes everyone else and is also known as non-DOT testing.
In regulated workplace testing, companies follow the Department of Transportation’s procedures for conducting workplace drug and alcohol testing, often referred to as 49 CFR Part 40. This Federal regulation details when testing can be conducted, who may conduct a test, where testing can occur, what drugs should be tested, the specific steps for collecting a specimen, and the roles and responsibilities of involved parties.
All DOT drug tests test for the same 5 drugs; THC, cocaine, opioids, PCP, and amphetamines. At present, urine is the only approved testing medium and all urine specimens are sent to a HHS certified laboratory for analysis. A Federal Custody and Control Form must always be used to document the donor information, specimen collection, lab result and MRO information. A non-Federal CCF must never be used to document a DOT test.
Non-regulated, or non-DOT tests, can test for any number of drugs and are free to use testing mediums other than urine such as hair or saliva. A company may also choose to use rapid or instant drug test kits that provide results in minutes rather than send a specimen to a lab for analysis. Rapid drug tests are not allowed for use in DOT testing. However, because the DOT drug testing protocol has become the “gold standard” for drug testing, companies that wish to establish the most legally defensible drug testing program design their drug testing program to mimic the DOT regulations.
It is not uncommon for a company to send an employee for both a DOT and non-DOT test at the same time. In this scenario, the collector would collect and split the first urine specimen for the DOT test, following the proper DOT test protocols and documenting the information on the Federal CCF. After completing the DOT test, the collector would initiate a non-DOT test, collecting a second specimen from the donor, documenting the information on a non-Federal CCF. The collector should never collect a single urine specimen and split the specimen between the two test types. Knowing what is and is not allowed for both DOT and non-DOT testing further fortifies a company’s drug testing program so that test results can stand if presented in a court of law.
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