Time DOT tests around end-of-year chaos

Posted December 3, 2015

As December begins and the holiday season approaches, motor carriers that are subject to U.S. Department of Transportation (DOT) drug and alcohol testing need to pay careful attention to the management of their programs. To come up short for the calendar year for the required number of completed DOT drug and alcohol tests is a violation of §382.305.

Many DOT drug and alcohol program managers find it challenging to work with fewer days than perhaps other testing cycles due to holidays, driver vacations, and company shut-downs during the last weeks of the year.

Unfortunately, the Federal Motor Carrier Safety Administration (FMCSA) does not give regulated entities an end-of-year grace period. It expects motor carriers to manage the timing of their DOT random test notifications wisely. The agency will not accept such excuses as being short-staffed or the busy season.

In order for a random drug test to be counted in 2015, the test must be performed in the calendar year and the Medical Review Officer (MRO) must issue his or her official result in 2015. This is based on the front matter of a final rule issued February 15, 1994, laying the foundation for 49 CFR Part 382.

A test, for example, performed December 30, 2015, may take a couple of days to process at the lab, leaving the MRO's test result dated January 4, 2016. It will not be counted toward your 2015 completed random tests.

J. J. Keller's Alcohol & Drugs: DOT Compliance Manual is an easy-to-use manual that can help you understand and comply with DOT's Alcohol & Drug Testing requirements, including 49 CFR Parts 382 and 40.

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