Last updated : May 19, 2025
If you employ a safety-sensitive workforce, you are well aware that the Department of Transportation (DOT) expects protocol to be followed to a “T.” Failure to do so could result in costly penalties and fines that mount up quickly the longer you remain out of compliance. Fortunately, they don’t expect you to handle every aspect of the mandates yourself. Take drug testing, for instance, working with a TPA takes your employee drug testing process completely out of your hands.
According to the Federal Motor Carrier Safety Administration (FMCSA), the DOT allows safety-sensitive employers to work with a Third-Party Administrator (TPA). While there are no specific qualification requirements for a TPA, “the expectation is that they know all of the employer requirements and responsibilities under 49 CFR Part 40 and Part 382, including the related requirements of Part 383 (CDL Licensing), Part 391 (Driver Qualifications), and Part 392 (Driving of Commercial Motor Vehicles). Employers hire C/TPAs to keep them safe and in regulatory compliance.”
Employers need to choose carefully, though, because, ultimately, they are held responsible should the TPA make any errors regarding procedures and policies. And, we already mentioned those stiff fines and penalties—
What does a TPA do?
Well, in a word, everything. Employers turn over their entire drug testing program to a company that offers a TPA service, like ours, for instance, and it takes over from there. However, it’s the employer’s responsibility to ensure the company is aware of DOT drug testing protocol and will keep you in compliance.
We’ve compiled a checklist to help you find the TPA that’s right for you.
Specimen collection
Currently, the DOT only accepts urine specimens; however, the mouth swab test, otherwise known as the oral fluids test, has been approved as an alternative to the urine drug test. There’s a holdup with using this test method, though. We need at least two SAMHSA-approved laboratories to process specimens. Laboratories in the running must meet the administration’s high standards to qualify.
Moreover, in May of this year, hair testing guidelines are to be published for review. Initially, the DOT requested that the hair test replace the urine test entirely. Hair tests provide a 90-day window of recorded drug use because the metabolites grow out of the hair follicle into the center of the hair shaft. It creates a permanent record of use.
Many trucking companies conduct two employee drug tests for that reason. The DOT urine test because they must. The hair follicle test because it provides information about habitual drug use.
You may be looking forward to using one of these test methods. Ensure the TPA you work with is looking to the future and is ready for the upcoming changes.
Trained collectors
It’s a good idea to run over a quick checklist regarding the company’s specimen collectors, breath alcohol collectors (BATs), and screening test technicians (STTs).
It can include:
- Services offered—In addition to the test methods provided and inquiring about the calibration of alcohol testing devices, you may be interested in having them test on-site rather than sending employees to an off-site facility. Can they accommodate you?
- Result turnaround—How quickly can you expect to hear results?
- Location—If off-site, are they easy to find? Is the neighborhood safe? Is ample parking available?
- DOT-compliant supplies—This is huge, of course.
- Direct Observation procedures
- Ask for references—They should be willingly provided.
Visit the site
We also suggest making a pop-in visit to the facility. You can learn a lot that way. Remaining in compliance is on the line here after all! You don’t want to partner with a company that “talks a good talk” but is lazy about walking the walk.
If you’re unfamiliar with the DOT testing process, you can view it on the DOT’s site. Make an appointment to meet with a company representative. Some employers request to view a mock collection procedure.
If you decide to do that, watch to see if these 10 steps—laid out in the DOT video—are followed:
- Employee ID check—This should be the first step of the testing process.
- Pocket check—Test subjects are to empty their pockets and wash their hands next.
- Access Control—Ensure that only authorized personnel are in the collection area.
- Specimen control—The collector must always keep both the specimen and the accompanying paperwork secure.
- Water security—Are water sources turned off in the collection area? It prevents the chance of urine dilution.
- Bluing agents—Are they used in the toilet?
- Cleanliness check—There shouldn’t be any cleaning supplies in the restroom used for testing to prevent tampering.
- Foreign substances—Is there anything in the area that could be used to compromise the test’s integrity?
- Secure areas—Do they inspect for hidden contaminants on ledges, in trash bins, and other nooks and crannies if necessary?
- Employee monitoring—Does a technician remain vigilant in keeping an eye on the test subject to catch any behavior that may be out of the ordinary?
In addition, make a note of the waiting area when you arrive. If it’s packed, odds are your employees will get bogged down in the waiting process, too. Time is money—just saying.
Build a relationship
You should establish ongoing communication with your TPA. Do they make you aware of changes to the DOT drug testing process? How about reaching out to inquire about changes that need to be made in the random test pool data basis?
All those little things add up to a lot as far as remaining in compliance with DOT mandates. Moreover, you’re measure of trust in the abilities of your TPA grows. That means a bit of peace of mind for you—and you should grab on to that experience whenever you can!
