DOT-regulated drug tests should only be administered to FMCSA-regulated drivers in one of the following categories:

• CDL holders
• CLP holders
• Drivers that SHOULD have either a CDL or CLP (check with employer)

Employers: Please share this notice with your collection site managers, designated employer representatives, employees (new and current), and Consortium/Third Party Administrators.

Please keep in mind:

• Employers are required to include the driver’s CDL or CLP number on the CCF form (Step 1, Section C) for DOT-regulated drug testing.
• Employers should make sure that drivers are not given a Federal CCF for non-DOT testing.

Collection Sites: Collection site managers must ensure all collectors are properly trained to know when to conduct a DOT-regulated drug test.

• Identify the correct DOT Agency on the CCF (Step 1, Section D: FMCSA, FAA, FRA, FTA, PHMSA, or USCG).
• If FMCSA is the DOT Agency identifed on the CCF, the collector must ask if the driver holds a CDL or CLP.
• If the driver indicates they do not hold a CDL or CLP, the collector should contact the employer to verify whether to conduct a non-DOT or a DOT-regulated test.
• If the employer tells the collector that the driver does not hold a CDL or CLP but is nevertheless subject to DOT testing, the collector should proceed using the Federal CCF for the driver. The collector should enter an alternative identifer, such as the driver’s SSN or employee ID number (Step 1, Section C).
• If the driver produces a CDL or CLP, the collector should proceed with the collection process in accordance with the procedures currently set forth in the DOT regulations.
• Finally, collectors should verify that the CLP or CDL number provided by the employer on the Federal CCF matches the CDL or CLP number shown by the driver.

COLLECTION SITE MANAGERS:

Please follow the procedures as outlined below to verify whether a DOT-regulated test or non-DOT test should be administered to FMCSA-regulated drivers.