Understanding the Differences Between DOT and Non-DOT Drug Tests
Did You Know...
Drug and alcohol testing plays a critical role in workplace safety, especially in safety-sensitive industries regulated by the U.S. Department of Transportation (DOT). One area that often causes confusion is how DOT tests relate to non-DOT tests. Federal regulations clearly explain how these two types of testing must be handled—and why they can never be mixed. Here’s what employers, drivers, and service agents need to know.
DOT and Non-DOT Tests Must Always Be Separate
DOT drug and alcohol tests are strictly regulated and must be kept completely separate from non-DOT tests. This means the process, paperwork, specimens, and results for DOT testing cannot be combined with or substituted by non-DOT testing in any way. Even if an employee is taking both tests on the same day, each test must stand on its own.
DOT Testing Always Comes First
When a DOT and a non-DOT test are both required, the DOT test must be completed first. For urine testing, this is especially important. Any leftover urine from a DOT collection must be discarded, and a brand-new sample must be collected for the non-DOT test. Sharing specimens is not allowed.
DOT Specimens Have Strict Limits
DOT specimens may only be tested for substances specifically approved under DOT regulations. Laboratories are not allowed to test DOT specimens for additional drugs or use them for DNA or identity testing. This protects the integrity of the DOT testing process and ensures consistency nationwide.
Limited Exception During Physical Exams
There is a narrow exception when a DOT urine drug test is collected as part of a required DOT physical exam. In that case, certain medical tests—such as glucose testing—may be performed on any remaining urine left in the collection container after the DOT specimen bottles have been sealed.
Medical Tests Are Not DOT Tests
Drug or alcohol tests conducted strictly for medical qualification purposes—such as determining whether an employee is fit for a license or certification—are not considered DOT tests. As a result, those test results do not carry DOT consequences and cannot be used to replace or override DOT-required testing.
DOT Results Cannot Be Overruled
DOT test results always stand on their own. Employers are not allowed to ignore or change a verified DOT result based on non-DOT testing, even if an employee provides outside medical records or alternative test results. A DOT result is final under DOT regulations.
Proper Forms Must Be Used
DOT testing requires the official DOT forms, including the Custody and Control Form (CCF) and Alcohol Testing Form (ATF). These forms may never be used for non-DOT testing, even if references to DOT are crossed out. Likewise, non-DOT programs must use their own separate documentation.
Only DOT-Regulated Employees May Be Tested
Finally, DOT drug and alcohol tests may only be conducted on individuals who meet the definition of a DOT-regulated employee. Testing someone under DOT rules who is not covered by DOT regulations is strictly prohibited.
Why This Matters
Understanding these rules helps protect employers from compliance violations and ensures employees are treated fairly under federal law. Mixing DOT and non-DOT testing—even unintentionally—can result in serious regulatory consequences. Keeping testing programs clearly separated is not just best practice; it’s a legal requirement.
If you operate a DOT or non-DOT testing program, working with knowledgeable professionals can help ensure every test is conducted correctly, confidently, and in full compliance.
Call Us Today: 951-234-7999 to establish an efficient drug free workplace compliance program for your organization.
Source: § 40.13 How do DOT drug and alcohol tests relate to non-DOT tests?