2025 Medical Review Officer Online Course with Live Discussion (Includes Digital Syllabus)-Tab 9: DOT Drug and Alcohol Testing Rules

Tab 9: DOT Drug and Alcohol Testing Rules

Pdf Summary

This document provides a comprehensive overview of the U.S. Department of Transportation (DOT) drug and alcohol testing rules, highlighting common elements across DOT agencies and notable differences. The anti-drug rules, initiated in 1988 and expanded by the Omnibus Transportation Employee Testing Act (OTETA) of 1991, mandate drug and alcohol testing for safety-sensitive transportation employees. Agencies like FAA, FMCSA, FRA, and FTA require both drug and alcohol testing, whereas PHMSA and USCG primarily mandate drug testing with limited alcohol testing.<br /><br />Prohibited conduct includes unauthorized drug use, verified positive tests, refusal to test (defined by 13 specific acts such as failing to provide specimens or tampering), and alcohol misuse during safety-sensitive duties or within specified timeframes. Consequences include immediate removal from safety-sensitive roles, referral to a Substance Abuse Professional (SAP) for evaluation, compliance with recommended treatment, successful return-to-duty testing, and follow-up testing.<br /><br />The document details agency-specific rules: FAA requires employer certification and imposes permanent bars for repeated violations; FMCSA uses the National Clearinghouse for driver drug test reporting; FRA has special post-accident testing and supervisory training; FTA includes training and certification compliance; PHMSA requires written policies and contractor monitoring without random alcohol testing; and USCG mandates periodic drug testing and allows alcohol testing only post-accident.<br /><br />Employers must maintain detailed records, conduct prior test result checks, and use strict procedures for random testing rates and timing. The Medical Review Officer (MRO) plays a critical role in verifying test results, managing split specimen analysis, handling positive, negative, refusal, or canceled test results, and safeguarding confidentiality. MROs also evaluate medication safety concerns impacting fitness for duty and report appropriately.<br /><br />Service agents like Third Party Administrators (TPAs) support testing programs but must maintain independence and confidentiality. Non-compliance by service agents can result in Public Interest Exclusions (PIE), prohibiting their use by employers. The document also includes MRO self-assessment questions to reinforce understanding of these regulations.

Keywords

DOT drug testing

alcohol testing regulations

safety-sensitive employees

FAA drug and alcohol rules

FMCSA National Clearinghouse

FRA post-accident testing

PHMSA drug testing policies

USCG drug and alcohol testing

Medical Review Officer responsibilities

Substance Abuse Professional referral