Return-to-Duty Drug Testing for Your DOT Employees

The U.S. Department of Transportation (DOT) requires drug and alcohol testing for employees in safety-sensitive functions, such as commercial drivers/persons who operate commercial motor vehicles. When an employee fails one of these tests, they may still be able to undergo a process to return to their jobs. Part of this process involves passing a return-to-duty drug test, also known as an RTD test.

Here’s what you, as an employer, should know about DOT return-to-duty drug testing.

What is DOT Return-to-Duty Testing?

Failing a drug or alcohol test results in immediate dismissal from safety-sensitive positions for DOT-regulated employees. In certain cases, however, these employees can still return to duty if they complete the DOT return-to-duty process.

How Does the Return-to-Duty Process Work?

An employer must start the RTD process by providing the employee who failed the test a list of available DOT-qualified substance abuse professionals (SAPs),* even if the employee is fired, as per Federal Motor Carrier Safety Administration regulations 49 CFR Part 40 Subpart O.

If the employee wishes to return to duty, they will first undergo a SAP evaluation, where the SAP determines if it is safe for this employee to ever return to safety-sensitive duties and, if reentry to DOT-regulated positions is possible, what referrals, education, treatment plans, follow-up testing, and aftercare are necessary. The employee must have a negative return-to-duty test to confirm the employee is safe to return to DOT-regulated positions. The employee will then have to complete the follow-up testing plan as directed by the SAP.

The medical review officer (MRO) who reviews these test results—negative or positive—reports everything to the designated employer representative (DER). The employer is required to report negative return-to-duty test results to the FMCSA Clearinghouse, also known as the Drug & Alcohol Clearinghouse.

*For more information regarding SAPs and the return-to-duty process, please visit

What Counts as Failing a DOT Test?

There are many ways a person can fail a DOT test, including:

  • A CDL driver/DOT-regulated truck driver returns a positive result on a DOT drug test or alcohol test.
  • A driver does not take the test at all. In other words, refusal to test effectively means failing the test.
  • A driver returns a positive drug test result at any point during the return-to-duty process, including unannounced follow-up drug tests (there must be at least 6 of these tests during the first 12 months after returning to duty).
  • If a driver’s follow-up evaluation is not under direct observation, the test will be canceled by the MRO and a recollection will be necessary.

CCM Makes the Return-to-Duty Process Smooth

We do more than RTD tests. We also offer services, including:

  • Follow-up testing
  • Post-accident testing
  • Random drug testing
  • Pre-employment testing
  • Reasonable suspicion testing

Contact us today about the wide range of DOT and non-DOT tests we offer. We can also help you develop a strong drug and alcohol testing program for your workplace or help you craft the right education and treatment program for your employees to return to their safety-sensitive duties. Rest assured that our results are accurate, with all results being reviewed by an MRO.

Disclaimer – This article does not offer legal advice.