By Adam Hall, Staff Writer & Editor
The Merits of a Non-DOT Policy
Rules and regulations established by the Department of Transportation (DOT) are often regarded as the industry standard when it comes to workplace drug testing. While DOT regulations help create a strong foundation for company drug testing programs, adding a non-DOT policy enhances workplace compliance, making the overall drug testing program more effective.
Non-DOT testing is not limited to companies that only employ non-DOT individuals. In fact, even if a company solely employs DOT-covered individuals, that company can still benefit from additional protections inherent in having a non-DOT policy in place. Additionally, non-DOT policies apply to companies employing both DOT-covered and non-DOT personnel. This article will highlight some of the key advantages associated with non-DOT policies and discuss how those advantages can be applied in virtually any setting.
Expanded Testing Panels
A DOT drug test covers five different substances: marijuana, cocaine, PCP, opiates, and amphetamines. Although the DOT panel has improved in recent years to include additional metabolites under these categories, it is still considered a five-panel test and omits other commonly abused drugs. For example, barbiturates, benzodiazepines, and methadone are substances not included in a DOT test. By implementing a non-DOT policy, these substances and many more, such as nicotine or synthetic drugs, can be added to a test panel.
Depending on the needs of the organization, a non-DOT test panel can be tailor-made to fit those needs. This is especially useful for employers operating in many different locations and environments, which often come with unique demands as it relates to drug testing.
Alternative Testing Methodologies
Urine testing is the most common method of drug testing, but it is certainly not the only reliable method. Oral fluid testing and hair testing are also popular for workplace drug testing. However, utilizing these alternatives may not be possible without a non-DOT policy. Recent regulatory changes have opened the door for DOT-approved oral fluid testing, but those changes have yet to be implemented in a DOT setting. Hair testing remains solely a non-DOT option.
Oral fluid testing has grown in popularity as the testing outcomes are associated with recent use detection. Conversely, hair testing provides an extended look as drug use history, usually ranging from 60 to 90 days. Like the benefits of expanded testing panels, employers can determine what method of testing is best for their organization and include those requirements in their non-DOT policy.
An additional benefit of alternative testing methods is that any combination can be used in a non-DOT policy. For example, a company may require that all pre-employment tests are conducted with urine, but post-accident testing will be conducted using oral fluid. The variance in detection periods for each methodology can be leveraged to create sensible testing requirements.
Reasons For Testing
There are very specific reasons for a DOT test to occur, which include pre-employment, random, post-accident, reasonable suspicion, return-to-duty, and follow-up testing. While this list appears comprehensive, there are potential shortcomings associated with DOT reasons for testing. For instance, DOT regulations clearly define what an accident is. If an accident occurs on the job, post-accident drug testing is only authorized if the nature of the accident adheres to the DOT’s specific definition. Although this seems straightforward, it is reasonable to assume that impairment could play a role in accidents that do not fit DOT definitions. In other words, a non-DOT policy can further define when post-accident testing is required, in turn bolster deterrents for illicit substance use.
Aside from enhancing specific reasons for testing, non-DOT policies can be altered to accommodate unique company needs. For example, if a company chooses to exclude random testing from their policy, perhaps to cut costs, non-DOT policies provide the flexibility to do so. Keep in mind that non-DOT policies do not supersede DOT requirements; therefore, DOT-covered personnel cannot be excluded from DOT random testing requirements in this type of situation.
Conclusion
Non-DOT drug testing policies provide additional protections to employers, along with an opportunity to establish specific requirements outside of otherwise rigid regulations. Although there are additional benefits to implementing a non-DOT policy, the most significant advantages include extended panel options, alternative testing methods, and better-developed reasons for testing. Organizations that employ both DOT-covered and non-DOT personnel are still required to adhere to the rules and regulations of the Department of Transportation for those covered individuals. However, many organizations utilize both a DOT policy and non-DOT policy, which work in conjunction with one another to provide an effective drug testing program.
Prior to establishing a non-DOT policy, employers should check all state and local requirements, as there may be some limitations as to what an employer is authorized to include in their non-DOT policy.
