Fentanyl Added, Poppy Seed Confusion Reduced: Breaking Down DOT’s Proposed Testing Updates

DOT proposes sweeping updates to its drug and alcohol testing program — including fentanyl testing, higher morphine cutoffs, and biomarker validations — to enhance safety and align with federal guidelines.

The Department of Transportation (DOT) has published a Notice of Proposed Rulemaking (NPRM) in the Federal Register outlining significant changes to workplace drug and alcohol testing programs.

These updates are designed to harmonize DOT regulations with the Department of Health and Human Services (HHS) Mandatory Guidelines and address the growing risks posed by fentanyl in the transportation industry.

Comment Deadline: October 17, 2025, at 11:59 PM EDT
Read the full proposal here: Federal Register Notice (PDF)
ODAPC Page: DOT Drug and Alcohol Policy Notices

Let’s take a closer look at important potential changes that may affect fleets and truck drivers.

1. Addition of Fentanyl and Norfentanyl to DOT Drug Testing Panels

Summary: DOT proposes to add fentanyl (urine and oral fluid) and norfentanyl (urine only) to the testing panel. Fentanyl, up to 100 times stronger than morphine, is a major driver of overdose deaths, with approximately 150 fatalities per day in the U.S.

Action Items:

• Update drug and alcohol policies to include fentanyl once finalized.
• Educate safety-sensitive employees about the change and associated risks.
• Work with testing providers to ensure panels will cover fentanyl and norfentanyl.

2. Adjusted Morphine Cutoffs for Urine Testing

Summary: The confirmatory cutoff for morphine will increase from 2,000 ng/mL to 4,000 ng/mL, eliminating unnecessary positive results from poppy seed ingestion. DOT will also remove the requirement for Medical Review Officers (MROs) to look for “clinical evidence” of illegal opioid use below 15,000 ng/mL.

Action Items:

• Inform MRO partners and supervisors of the revised thresholds.
• Update internal compliance manuals to align with the new cutoff levels.
• Educate employees that reasonable poppy seed consumption will no longer trigger a positive result.

3. Oral Fluid Testing Changes

Summary: DOT will align with HHS by eliminating the clinical exam requirement for codeine/morphine results between 15 ng/mL and 150 ng/mL when poppy seed ingestion is claimed. Results above 150 ng/mL will remain positive unless a legitimate medical explanation is provided.

Action Items:

• Update policies to reflect this streamlined process.
• Ensure collectors and MROs are informed of the new oral fluid review rules.
• Communicate to employees that oral fluid testing remains a valid and approved method.

4. Authorization of Biomarker Testing

Summary: DOT proposes allowing biomarker testing as an additional specimen validity test (SVT) to detect adulterated or substituted specimens. Biomarker testing will not yet be mandatory but will be an available tool as labs gain capabilities.

Action Items:

• Monitor developments with biomarker approvals.
• Begin discussions with testing providers about incorporating biomarker SVTs.
• Educate compliance teams about future implementation timelines.

5. Updated and New Definitions

Summary: DOT proposes to align definitions with HHS, including terms like “adulterated specimen,” “positive result,” and “substituted specimen,” while adding a formal definition for “biomarker.”

Action Items:

• Update policy manuals and training materials with the new terminology.
• Train HR and DER personnel on revised language to ensure consistency during audits.

6. Marijuana Nomenclature Changes

Summary: Terminology for marijuana metabolites will change:

• Urine testing: THCA → Δ9THCC
• Oral fluid testing: THC → Δ9THC

This is a labeling update only and does not change the testing process or thresholds.

Action Items:

• Ensure testing vendors and MROs adopt updated naming conventions.
• Update compliance documentation to match the new analyte terms.

7. Training and Collection Updates

Summary: Drug collectors, Screening Test Technicians (STTs), and Breath Alcohol Technicians (BATs) will be required to complete all training and mock collections within 30 days of starting their roles.

Action Items:

• Review training procedures for compliance with the 30-day rule.
• Create a tracking system to monitor completion timelines.
• Ensure mock collections are documented accurately for audit readiness.

8. Other Technical and Clarifying Amendments

Summary: The NPRM includes updates to clarify existing provisions, revise shy bladder/dry mouth procedures, and update documentation for Substance Abuse Professionals (SAPs).

Action Items:

• Review and update internal procedures for collectors, DERs, and SAPs.
• Ensure updated language is reflected in compliance audits and safety manuals.

Key Dates and Next Steps

• Comment Deadline: October 17, 2025
• Monitor ODAPC and DOT updates as the rule progresses to finalization.
• Submit feedback during the open comment period if these changes will impact your fleet operations or compliance processes.

CNS Drug and Alcohol Services

At CNS, we offer a comprehensive Drug and Alcohol Consortium Service and are a certified consortium and third-party administrator (C/TPA).

Our experts ensure that all DOT rules and regulations are followed, including the implementation of random drug tests for you and your drivers, updating your company drug testing policies, record retention and document purge management.

We take all the necessary steps and precautions to keep you and your drivers compliant with the DOT drug and alcohol testing requirements.

Need help reviewing your policies or want to join our consortium, fill out the form below.