A Guide to DOT Pre-Employment Drug Testing

By Richard Pummell, Foley Carrier Services

Most hiring managers and business owners are aware that newly hired drivers “have to take a drug test.” And although pre-employment drug testing is a relatively uncomplicated procedure, there are specific requirements that must be met.

The importance of Pre-Employment Drug Testing cannot be overstated, and the goal of this article is to make sure that Department of Transportation-regulated business owners understand all aspects. This is the first in a series that will examine each specific DOT test type.

Pre-Employment (PE)
The Pre-Employment (PE) urine drug screen should be administered after the decision has been made to hire a driver, and is usually the last event in the hiring process.

Oftentimes, a “return-to-duty” drug test is incorrectly administered when re-hiring a driver who was previously employed, but it’s a PE test that must be completed. (A return-to-duty test is a very different type of test that will be addressed in a later article.)

Likewise, a PE must be administered when a current employee is moving into a driving position, or when an employee who has been on leave and excluded from a random drug and alcohol program for 30 days or longer returns.

PE Testing Criteria
Anybody who operates a vehicle with a Gross Vehicle Weight Rating or Combination Weight Rating of at least 26,001 pounds; or who transports hazardous materials that require placarding, is subject to DOT drug & alcohol testing and must take a PE test. This includes owner-operators and those who work for family-run operations.

Let the Driving Begin
The PE must be completed before a driver begins operating a CDL-required vehicle. But this doesn’t mean a driver can take the test and then hop in a truck and start driving. Before a driver can operate a vehicle, the entire testing process must be completed. This means the urine specimen has to be shipped to the laboratory, the DOT Medical Review Office (MRO) has to review the result and you must have a verified negative result in your hands.

It is important to note that after the PE is completed, the driver must then be added to a random drug and alcohol testing pool within 30 days.

What Happens if a Driver Already Took a PE Test?
Although there are circumstances in which previous PEs can be used, there are complex stipulations and requirements that must be met in order to do so. It is always recommended to complete new PEs any time a driver is hired or re-hired.

Where Does One Go to Take a PE Drug Test?
Most DOT-qualified collection sites are walk-in medical centers. At Foley, we provide clients with a network of collection sites that are located all across the country when they enroll in our drug & alcohol program.

The PE Came Back Positive. Now What?
If a test comes back positive, the driver may not begin operating for you, or any other DOT-regulated company, until the entire return-to-duty process has been completed.  (This process will be explained in a later article.)

Furthermore, the Federal Motor Carrier Safety Administration’s (FMCSA’s) new Drug & Alcohol Clearinghouse is going to make it almost impossible for drivers to apply at various companies without disclosing a past positive test.

Better Late Than Never
If for whatever reason a PE test is overlooked, it must be completed as soon as possible. An incomplete PE can cause serious problems in the case of an FMCSA audit. Not only will it lead to an automatic failure of your New Entrant Safety Audit, but it can lead to considerable penalties and fines during a Compliance Review.

Stay tuned for our next article, which will uncover the specifics of Random DOT Drug & Alcohol Testing.

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