DOT Drug Testing for Bus, Limo and Motorcoach Companies
Short answer: DOT drug and alcohol testing follows the CDL. A bus or van built for 16 or more people, counting the driver, needs a CDL, so its driver is in the Part 382 program. A limo or van built for 15 or fewer people usually doesn't need a CDL, so its driver isn't under Part 382, even when the company has a USDOT number for other FMCSA rules. Here is how to tell, and what the program takes.
Updated October 15, 2026 · Checked against the federal regulations
The 16-passenger line
Part 382 covers drivers who must hold a CDL under Part 383 (382.103). A vehicle needs a CDL for passengers when it "is designed to transport 16 or more passengers, including the driver" (Group C, 383.5), or when it weighs 26,001 pounds or more (Group B).
So motorcoaches, school-style activity buses run by charter companies, large shuttles and party buses built for 16 or more are covered. Stretch limos and sprinter vans built for 15 or fewer usually are not.
A USDOT number is not the same thing
For FMCSA's safety rules, a passenger vehicle is a commercial motor vehicle at a lower line: 9 to 15 passengers (including the driver) for compensation, among other tests (390.5). That brings a USDOT number, driver qualification files and hours-of-service rules, but not drug and alcohol testing. A company with both small vans and full-size buses has some drivers in the testing program and some out of it.
What the program includes
- A negative pre-employment drug test before a new driver first drives (382.301).
- A random pool at the 2026 rates: 50% for drugs and 10% for alcohol (382.305).
- Post-accident and reasonable-suspicion testing, and supervisor training for reasonable suspicion (382.303, 382.307, 382.603).
- Clearinghouse queries before a driver first drives and once a year after that (382.701).
- A written policy given to every driver, and records kept for the required periods (382.601, 382.401).
How Pact handles a passenger carrier
Pact runs the program for CDL drivers: the random pool, Clearinghouse queries, driver files and the audit binder, at $25 a driver a month ($99 minimum), or $19 a month for an owner-operator. First month free, no setup fee, month to month. Drivers who don't need a CDL can still be drug tested under your own company policy with a $40 lab test.
Common questions
Do limo drivers need DOT drug testing?
Only if the vehicle needs a CDL: built for 16 or more people including the driver, or 26,001 pounds or more. Most limos are built for fewer, so their drivers aren't under Part 382.
Do party bus drivers need DOT drug testing?
Yes, when the bus is built for 16 or more people including the driver; that takes a CDL, which puts the driver under Part 382.
Does a 15-passenger van need a CDL?
No, not by passenger count, since the CDL line is 16 or more including the driver (383.5). It may still be a commercial vehicle for FMCSA's safety rules when used for compensation.
What random testing rate applies to bus drivers?
The same as truck drivers: 50% drug and 10% alcohol in 2026.
Sources
- 49 CFR 383.5: Definitions (CMV for CDL purposes)
- 49 CFR 382.103: Applicability
- 49 CFR 390.5: Definitions (CMV for safety rules)
- 49 CFR 382.305: Random testing