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DOT Oral Testing

Oral Testing
Oral Testing

If you are a commercial driver or safety-sensitive employee, you may already know the Department of Transportation (DOT) regulations governing DOT Oral Testing. One of the most recent developments in this area is Oral Testing. In this article, we will delve into the details of this new rule and what it means for drivers and employers alike.

What is the DOT Final Rule on Oral Testing?

The DOT Final Rule on Oral Testing, officially known as the "Revised Federal Drug Testing Custody and Control Form (CCF) Requirements," was announced in December 2019. This rule allows DOT-regulated employers to use oral fluid as an alternative to urine for drug testing, a significant change from the previous requirement of urine testing for drug screenings.

As of May 02, 2023, The Department of Transportation (DOT) is preparing its final rule amending its regulated industry drug testing program. The DOt's drug testing program will now include an oral test. With this change, there are a few things you need to know, such as when the final rule will be effective and who can implement the DOT-regulated oral test.

This DOT Final Rule Oral Testing will take effect on June 1, 2023. Even though it will take effect on June 1, 2023, it does not mean any drug testing facilities will begin to take oral examinations for DOT. In accordance with the DOT, the Department of Health and Human Services (HHS) must certify two laboratories. One laboratory must be the primary, and the second will serve for laboratory testing of split specimens.

To check if your laboratory is HHS-certified, you may do so through this link:

If your lab does not appear on the list, you must find a location with a certified lab to take the DOT oral test.

How Does Oral Testing Work?

Oral Testing, or oral fluid testing, involves collecting a saliva sample inside the employee's mouth using a swab. This sample is then tested for the presence of drugs. The quick and non-invasive process makes it convenient for employers and employees.

What Are the Benefits of Oral Testing?

There are several benefits to using oral testing for drug screenings. Some of the key advantages include:

  • Accuracy: Oral testing is highly accurate and can detect recent drug use within a shorter window compared to urine testing.

  • Convenience: The collection process is simple and can be done on-site, reducing the need for off-site testing facilities.

  • Deterrence: Oral testing may serve as a deterrent for safety-sensitive employees who may attempt to use drugs while on duty.

Combining Methodologies 

Employers now have the option to choose between oral fluid and urine testing for DOT drug testing. Oral fluid can be used for all required tests, except for FRA post-accident testing, during direct observation requirements, or when a second specimen collection is needed. If an employer decides to use a combined program, they must clearly define the circumstances under which each testing method will be used.

Both testing methods cannot be used as the first step; however, they can be combined if direct observation is required, mainly if a same-sex observer isn't available. Oral fluid must be available for directly observed collections for non-binary/transgender individuals.


It is crucial to follow the drug policies and procedures when administering testing to avoid any mistakes. Initially, you must choose the type of collection to issue, as you cannot collect both. This ensures consistency throughout subsequent collections within the same event. It is also important to designate oral fluid and urine laboratories separately, as not all labs have certifications for both specimen types.

Some labs only have certifications to collect oral, while others only have certifications to collect urine.

To ensure a smooth transition, it is essential to communicate any changes in testing policies to employees, even if a specific date is unavailable. Employees should be informed about upcoming changes, accounts should be set up, and employees should be notified accordingly.

When selecting a lab for testing, it is best practice to have a standing order with collection sites. This ensures that collection personnel know the type of collection required and when it should be performed. The DER should always be available to address any concerns related to standing orders during the collection process in case any problems arise.

It should be done if there needs to be a pivot to another specimen type during a collection event. At the same time, the donor is still present, following collection rules before concluding the process. It is vital to avoid terminating the collection and resuming the next day, as it may compromise the accuracy of the results.

Accurate contact information should be pre-printed on the forms to facilitate effective communication, and skilled collectors should be in place to perform the specimen collection accurately.


The Department of Transportation has significantly changed workplace drug testing by authorizing oral fluid as an alternative methodology. This reflects DOT's dedication to safer workplaces and a more efficient testing system overall. The anticipated amendment to the rule is expected to apply to PHMSA, and Homeland Security has also indicated that they will amend the rules for the use of oral fluid.

This change will impact many in the industry, including employers, employees, TPAs, collectors, etc. More updates are likely, and DISA can help you stay updated with industry news, laws, and regulations. Stay ahead to avoid being left behind!

This information is from the Department of Transportation website


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