FMCSA Highlights Frequent Problem At Collection Sites in Notice

FMCSA Highlights Frequent Problem At Collection Sites in Notice

On Friday, September 9, 2022, the FMCSA sent out an email “A Notice for Federal Drug Testing Collection Sites & CDL Employers Regarding FMCSA Regulated Employees”.

The notice is basically a reminder that DOT-regulated drug tests should only be administered to FMCSA-regulated drivers in one of the following categories:

  • CDL holders
  • CLP holders (commercial learner’s permit)
  • Drivers that SHOULD have either a CDL or CLP (check with employer)

They remind employers that they are required to include the driver’s CDL or CLP number on the CCF form (Step 1, Section C) for DOT-regulated drug testing and mention that employers should make sure that drivers are NOT given a Federal CCF for non-DOT testing.

For collection sites, the notice stresses that collection site managers must ensure all collectors are properly trained to know when to conduct a DOT-regulated drug test.

But the process has not changed, so why the need for a mass email?

Basically, improper drug testing is becoming enough of a problem that causes delays, non-compliant drivers, and could lead to a harsher FMCSA response if it continues, especially in situations where employers send drivers through a CDL school.   

This is because getting a CDL involves several steps that include medical requirements and residency requirements besides knowledge and skills requirements.

After receiving a CLP, when the driver student enrolls to a CDL school or sent by an employer, they are subject to a pre-employment DOT drug test and are held under DOT drug testing regulations. The CDL school must have the drug test result loaded into the CDL Clearinghouse.

When the student driver receives their CDL and is hired for a new job or is added to the current employer’s DOT drug testing pool, they will be subject to another pre-employment drug test, even if the CDL training only lasted a month or two.

The notice wants to prevent employers from trying to cut corners by only sending the employee student driver to the clinic once to complete both required drug tests, which is a violation.

Collection Site Procedures

The FMCSA also wanted to remind employers and collection sites on proper DOT collection site procedures.

Collections sites should follow the procedures as outlined below to verify whether a DOT-regulated test or non-DOT test should be administered to FMCSA-regulated drivers.

Collection Site Procedures

Become a CNS Consortium member today

No matter if you are a single driver operation or have 15+ drivers in your fleet, we treat all our clients equally. Save time, money, and reduce stress by joining today.

Our experts ensure that all DOT rules and regulations are followed, including the implementation of random drug tests for you and your drivers. We take all the necessary steps and precautions to keep you and your drivers compliant with the DOT drug and alcohol testing requirements.

We also offer an online results portal where our consortium clients can order their own chain of custody forms for a drug test, search collection sites near a driver location, see the status of a chain of custody order and the results of the test, and download chain of custody forms for audit or other purposes.

For more information, contact us at 800.551.9816 or

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