DOT Drug Screen Compliance for Trucking Companies

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Drug screen compliance means every DOT drug test of your CDL drivers follows 49 CFR Part 40: a urine specimen collected by a qualified collector on the Federal custody and control form, a 5-panel test at an HHS-certified laboratory, and review by a Medical Review Officer before you get the result.

Then you keep the records and report what the rules require.

What does a DOT drug screen test for?

A DOT drug screen tests for five drug classes, the DOT 5-panel. Since January 1, 2018, the laboratory can confirm 14 specific drugs within those classes, including the prescription opioids most often misused.

Drug classWhat the laboratory confirms
MarijuanaTHC metabolite (THCA)
CocaineBenzoylecgonine (cocaine metabolite)
AmphetaminesAmphetamine, methamphetamine, MDMA, MDA
OpioidsCodeine, morphine, 6-AM (heroin), hydrocodone, hydromorphone, oxycodone, oxymorphone
PhencyclidinePCP
The DOT 5-panel drug test

The laboratory may not test a DOT specimen for anything else. If you want a broader company test, it has to be a separate collection on non-DOT paperwork, done after the DOT test, and it can never change a DOT result (49 CFR 40.13).

Fentanyl is not on the panel yet. DOT proposed adding fentanyl and norfentanyl on September 2, 2025, but as of October 2026 that rule is not final, and the cutoff table in 49 CFR 40.85 still lists only the five classes.

What type of drug test do trucking companies use?

Every DOT drug test of a truck driver today is a urine test. Part 40 has allowed oral fluid (saliva) testing since 2023, but an employer can only use it once HHS has certified at least two oral fluid laboratories, one for the primary specimen and one for the split.

HHS’s list published September 30, 2026 still shows no certified oral fluid laboratory. Because of that, a DOT final rule effective June 10, 2026 requires a directly observed urine collection in the cases where Part 40 calls for an oral fluid test.

An instant cup or a hair test your company chooses to run is a company test, not a DOT test. It must be kept separate from the DOT process, and a DOT result always stands on its own.

How does a compliant DOT drug test collection work?

A collection is compliant when the right person collects it on the right form and the specimen stays sealed and traceable until a certified laboratory tests it. Each point below is a Part 40 requirement, and the MRO checks the CCF for errors that can cancel a test.

  • A qualified collector. The collector needs qualification training and five consecutive error-free mock collections (49 CFR 40.33). A driver can’t collect their own specimen, and the driver’s immediate supervisor shouldn’t collect unless no other collector is available (49 CFR 40.31).
  • The Federal custody and control form (CCF). You must use it for every DOT drug test and never for a non-DOT test. The 2026 CCF took effect April 27, 2026; the 2023 version can still be used without extra paperwork through May 30, 2027.
  • A split specimen. Every DOT urine collection is split: at least 30 mL in the primary bottle and 15 mL in the split bottle, sealed in front of the driver, who initials the seals (49 CFR 40.71).
  • An HHS-certified laboratory. Only laboratories certified by HHS under the National Laboratory Certification Program may test DOT specimens (49 CFR 40.81).
  • Direct observation when required. Return-to-duty and follow-up drug tests must be collected under direct observation (49 CFR 40.67).

When and why each test is ordered (pre-employment, random, post-accident, reasonable suspicion, return-to-duty, follow-up) is covered on our substance abuse testing program page. For how fast a selected driver must report, see our guide to DOT random drug testing time limits.

What happens after the lab reports a result?

A Medical Review Officer (MRO), a licensed physician, reviews every result before it reaches you. On a laboratory positive, the MRO interviews the driver, and a legitimate medical explanation, such as a valid prescription, turns it into a verified negative (49 CFR 40.137).

  • Split specimen: after a verified positive, the driver has 72 hours from the MRO’s notice to ask for the split to be tested at a second laboratory (49 CFR 40.171).
  • Clearinghouse reporting: the MRO reports verified positive, adulterated, and substituted results within 2 business days. You report refusals you determine, alcohol results of 0.04 or higher, negative return-to-duty results, and completed follow-up testing by the close of the third business day (49 CFR 382.705). Our FMCSA Clearinghouse guide covers registration and queries.
  • The driver stops driving: a driver with a violation can’t perform safety-sensitive work for any DOT employer until finishing the Substance Abuse Professional return-to-duty process. Since November 18, 2024, states must also remove the CDL privilege within 60 days of being notified that a driver is prohibited (49 CFR 383.73).

Do marijuana cards, CBD, or prescriptions change a DOT drug test result?

A medical marijuana card or CBD never excuses a marijuana positive. A valid prescription for a drug on the panel can, but only through the MRO.

  • Marijuana: in April 2026 the DEA moved FDA-approved marijuana products and marijuana under a state medical license to Schedule III. In a May 2026 official answer, DOT said this changes nothing for testing: state-licensed marijuana is not an FDA-approved drug, cannot be prescribed, and medical marijuana cards, physician recommendations, and dispensary receipts are not a legitimate medical explanation.
  • CBD: DOT tests for marijuana, not CBD, but CBD labels can understate THC. Per DOT’s CBD notice, using a CBD product is not a legitimate medical explanation, and the MRO will verify the result as positive.
  • Prescriptions: the MRO may not second-guess a legally valid prescription. Separately, a driver may use a non-Schedule I controlled substance on duty only if a licensed practitioner familiar with the driver’s medical history prescribed it and advised it won’t affect safe driving (49 CFR 382.213).

Which drug testing records must you keep, and for how long?

Retention depends on the result, not on a single rule for every form. Records must be kept in a secure place and produced at your principal place of business within two business days of an FMCSA request (49 CFR 382.401).

RecordsKeep for
Verified positive drug results, alcohol results of 0.02 or higher, refusals, SAP evaluations and referrals, program administration records, annual summaries5 years
Collection process records, including random selection documents and the documents behind post-accident and reasonable suspicion decisions2 years
Negative and canceled drug results, alcohol results under 0.021 year
Training records for supervisors and driversWhile they perform the duties, plus 2 years
FMCSA drug and alcohol record retention (49 CFR 382.401)

Your copy of each CCF goes with the test result it belongs to. You must also run a full Clearinghouse query before a new driver’s first safety-sensitive work and a query on every driver at least once a year (49 CFR 382.701). Keep the results with the rest of each driver qualification file.

How Simplex helps you stay drug screen compliant

We help you keep a DOT drug testing program that holds up in an audit, as part of our compliance programs for trucking companies:

  • Arranging DOT drug tests for new and current drivers.
  • Random drug and alcohol testing for owner-operators through our consortium.
  • Working out how many random tests your company needs each year.
  • Keeping your drug testing records organized and ready for an auditor.

An honest caveat: a consortium or third-party administrator can run much of the process, but the program stays yours. A service agent can’t act as your designated employer representative (49 CFR 40.3) and generally can’t decide whether one of your drivers refused a test or whether to order a reasonable suspicion or post-accident test; those calls are yours, except for owner-operators (49 CFR 40.355).

Use the form below with your USDOT number and how many drivers you have. Our team will review how your drug screens are handled today and what needs fixing.

Frequently asked questions

What is drug screen compliance in trucking?

It means your DOT drug tests follow 49 CFR Part 40 and FMCSA’s Part 382 from collection to recordkeeping: a qualified collector, the Federal custody and control form, a split urine specimen, an HHS-certified laboratory, MRO review, Clearinghouse reporting, and records kept for the required periods.

What type of drug test do trucking companies use?

DOT drug tests of truck drivers are urine tests checked for the DOT 5-panel: marijuana, cocaine, amphetamines, opioids, and PCP. Oral fluid testing is authorized but not yet available, because HHS has not certified any oral fluid laboratory as of September 30, 2026.

Is fentanyl part of the DOT drug test?

Not yet. DOT proposed adding fentanyl and norfentanyl to its drug testing panels on September 2, 2025, but as of October 2026 the rule is not final, so the DOT panel is still the 5-panel test.

Does a medical marijuana card excuse a positive DOT drug test?

No. DOT’s May 2026 official guidance says an MRO cannot verify a marijuana positive as negative because of a state-licensed marijuana product, even after the DEA’s April 2026 rescheduling, and medical marijuana cards or physician recommendations do not count as a legitimate medical explanation.

How long must a trucking company keep drug test records?

Five years for verified positives, refusals, alcohol results of 0.02 or higher, and SAP records; two years for collection process records; and one year for negative and canceled drug results, under 49 CFR 382.401.

Sources

The rules and figures on this page come from these official sources, checked on October 5, 2026.

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