No. Persons who do not possess CLPs or CDLs are not subject to the DOT drug and alcohol testing program requirements. Therefore, a drug test administered by the driving school on a student who does not possess a CLP or CDL does not qualify as a DOT pre-employment test. The student would not be subject to the DOT return-to-duty process.
Truck or bus driving schools/employers must include student drivers who possess CLPs or CDLs in the DOT testing program before such drivers operate commercial motor vehicles to complete their coursework to qualify as drivers. See regulatory guidance related to the Drug and Alcohol Program Applicability 49 CFR 382.103, Question 2