All carriers must adhere to the DOT Drug & Alcohol Testing program rules. This article walks you through the steps to create a compliant program ahead of your New Entrant Audit.

An audit of a carrier’s Drug & Alcohol Program will include the following:

Driver Roster 

A list of all current drivers will be required. You will need to show a negative pre-employment test for each driver that was completed before the driver started driving in a safety-sensitive position.

For the above list of drivers for any hired on or after January 6, 2020, you will need to show Clearinghouse Queries. The DOT Clearinghouse allows you to conduct a query for drivers’ Clearinghouse records. You can visit here to query the DOT Clearinghouse.

Note that owner-operators (CDL-carrying carrier owners) are also subject to the Drug & Alcohol program. 

History of checks

For all currently employed drivers you will need to show the previous employer’s checks of drug & alcohol violation history, as well as proof that you distributed the drug/alcohol testing policy and educational materials to all drivers.

Supervisory Training 

All supervisors need “Reasonable Suspicion Training” to recognize the signs and symptoms of substance use. 

Drug & Alcohol Test Results – All positive results will be reviewed. Any driver with a positive test must have been removed from the safety sensitive position and referred to a Substance Abuse Professional (SAP). Many drug testing providers maintain an online portal to retrieve results.

Random testing compliance 

You will need to show that your drivers are enrolled in a random testing program, either a consortium or stand-alone random pool. Statistics for the random testing will be verified for the required percentages. The current random testing rate for FMCSA is 50% for drugs and 10% for alcohol.

Post-Accident testing 

Any accidents your company has had will be reviewed. Was the required post-accident testing completed?  FMCSA DOT post- accident testing should only be done under the following situations:

1. When there is one or more human fatalities
2. When at least one individual requires medical attention away from the scene AND the driver receives a citation for a moving violation.
3. When at least one vehicle incurs disabling damage so that it cannot be driven from the scene AND the driver receives a citation for a moving violation.

Final thoughts

Drug and alcohol testing compliance is essential for your company to ensure the safety of your drivers and the public. By adhering to the regulations set forth by the Department of Transportation, you can mitigate your risks and be well prepared for your New Entrant Audit. If you haven't already done so, you will need to take these proactive steps of documentation to ensure you are meeting regulatory standards.

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