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DOT Drug and Alcohol Testing for City, County and Utility CDL Drivers

Short answer: yes. FMCSA's general safety rules exempt transportation performed by a state or a political subdivision of a state, but that exemption expressly does not apply to drug and alcohol testing. A city, county, road department, utility district or other public employer whose drivers need a CDL runs the same Part 382 program as a trucking company: a random pool, pre-employment tests, Clearinghouse queries and the records. Here is the rule and what it takes.

Updated October 15, 2026 · Checked against the federal regulations

The government exemption, and why it doesn't reach testing

49 CFR 390.3T(f)(2) exempts "transportation performed by the Federal government, a State, or any political subdivision of a State" from most of FMCSA's safety regulations. That is why many public works trucks don't carry a USDOT number.

Part 382 says the opposite for drug and alcohol testing: "The exceptions contained in § 390.3T(f) of this subchapter do not apply to this part" (49 CFR 382.103(c)). The CDL rules say the same (383.3(b)). So any public employee who needs a CDL to drive the vehicle is a covered driver, and the city, county or district is the employer.

Rather not run this yourself? Pact runs your random pool, Clearinghouse queries, driver records and medical cards: $25 a driver a month ($99 minimum), or $19 a month for an owner-operator. First month free, no setup fee, month to month. Sign up online · See a sample random draw record · Sample certificate of enrollment

Which drivers are covered

Anyone who drives a vehicle that needs a CDL: a single vehicle rated 26,001 pounds or more, a combination over 26,000 pounds towing a unit over 10,000 pounds, a vehicle built for 16 or more people including the driver, or a placarded hazmat vehicle (49 CFR 383.5).
Typical public jobs: dump trucks and snow plows on road crews, sanitation and recycling trucks, water and sewer utility trucks, street sweepers and equipment haulers.
Mechanics and supervisors who test-drive or move CDL vehicles on public roads are covered too when they need a CDL to do it.

Who is not under Part 382

Firefighters and emergency vehicle drivers, if your state uses the federal option to exempt them from the CDL (49 CFR 383.3(d)(2)). Check your state's CDL rules.
Transit drivers who are tested under the Federal Transit Administration's rules only (Part 655) are excluded from Part 382 (382.103(d)(1)). They are in the FTA program instead.
Military drivers covered by the military exception (383.3(c)).

What the program includes

A written policy and the supervisor training for reasonable-suspicion decisions (382.601, 382.603).
A negative pre-employment drug test before a new driver first drives (382.301).
Random testing at the yearly rates: 50% for drugs and 10% for alcohol in 2026, spread through the year (382.305).
Post-accident and reasonable-suspicion tests, plus return-to-duty and follow-up tests after a violation.
Clearinghouse queries: a full query before a driver first drives, and a query on every driver at least once a year (382.701).
Records kept for the required periods and ready for an audit (382.401).

How Pact handles a public employer

Pact runs the program as your consortium and C/TPA: the random pool and draws, Clearinghouse queries, driver records and the audit file, at $25 a driver a month ($99 minimum), month to month. We can send a W-9 and a certificate of insurance for your vendor file. If your purchasing rules need a quote in writing, call 901-666-6970 and you'll have it the same day.

Common questions

Do city and county CDL drivers need DOT drug testing?

Yes. The government exemption in 49 CFR 390.3T(f)(2) does not apply to Part 382 (382.103(c)), so public employees who need a CDL are in the drug and alcohol program.

Does a county road department need a USDOT number to drug test?

No. Many government fleets have no USDOT number because of the safety-rule exemption, but the testing rules still apply to their CDL drivers.

Are snow plow drivers covered?

Yes, when the plow needs a CDL. A state may waive the CDL for a substitute driver in a snow or ice emergency (383.3(d)(3)); regular plow drivers with a CDL are covered.

What random rate applies to government drivers?

The same as everyone in Part 382: 50% drug and 10% alcohol in 2026.

Are transit bus drivers in this program?

Not if your agency tests them under the Federal Transit Administration's rules (Part 655). Those drivers are excluded from Part 382 (382.103(d)(1)).

Sources

Related guides

Want this handled for you? Pact runs your random pool, Clearinghouse queries and driver records online: $25 a driver a month ($99 minimum), or $19 a month for an owner-operator. DOT drug test $69, breath alcohol $59, through Pact's lab network or your own lab. First month free, no setup fee, month to month. Sign up online · Owner-operators · How many random tests do I owe? · Watch how it works · Sample random draw record · Sample certificate of enrollment · 901-666-6970