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DOT vs Non-DOT Drug Tests: Which One Do You Need?

If a Department of Transportation (DOT) agency rule requires testing for your job, your employer must order a DOT drug test under 49 CFR Part 40. A non-DOT test can't stand in for it. Every other workplace drug test is non-DOT, and the employer, the program and state law set its rules. This guide explains what makes a test DOT, how the two differ, and how to tell which one you need.

Updated October 16, 2026 · Checked against the official sources listed at the end

What makes a test a DOT test

49 CFR Part 40 tells everyone who conducts drug and alcohol tests required by DOT agency rules how to run them (40.1(a)). It covers transportation employers, safety-sensitive transportation employees and the service agents who work for them (40.1(b)).

The DOT agencies include the Federal Aviation Administration (FAA), the Federal Railroad Administration (FRA), the Federal Motor Carrier Safety Administration (FMCSA), the Federal Transit Administration (FTA) and the Pipeline and Hazardous Materials Safety Administration (PHMSA). The U.S. Coast Guard counts as a DOT agency for drug testing only (40.3). Each agency's own rules say which jobs must be tested. For truck and bus drivers, see our guide on who needs DOT drug testing.

Part 40 also works the other way. No one may give a DOT drug or alcohol test to a person who is not a DOT-regulated employee (40.13(h)).

What a DOT test screens for

A DOT drug test covers five drugs or drug classes (40.82):

Marijuana metabolites
Cocaine metabolites
Amphetamines
Opioids
Phencyclidine (PCP)

The federal custody form

Every DOT collection must be documented on the Federal Drug Testing Custody and Control Form, called the CCF (40.40(a)). A non-federal form can't be used for a DOT collection (40.40(b)).

The reverse is also true. An employer must not use the CCF for non-DOT tests, even with the DOT references crossed out (40.13(g)). So you can usually tell a DOT collection from the form: a DOT test uses the federal CCF, and a non-DOT test uses a different form.

Why a non-DOT test can't replace a DOT test

Part 40 keeps the two kinds of tests apart:

DOT tests must be completely separate from non-DOT tests in all respects (40.13(a)).
When both are done, the DOT test goes first. For urine, any leftover urine from the DOT test is thrown out and a separate specimen is collected for the non-DOT test (40.13(b)).
Labs must not test DOT specimens for anything beyond what the rules allow, such as extra drugs (40.13(c) and 40.82).
No one may change or disregard a DOT result because of a non-DOT result. For example, an employer can't set aside a verified positive DOT test because the employee brings a negative test from their own doctor (40.13(f)).

What non-DOT tests look like

A non-DOT test is any drug test that DOT rules don't require. The employer or program decides which drugs to test for. A non-DOT panel can include drugs a DOT test can't. Pact's 10-panel, for example, also screens for barbiturates, benzodiazepines, methadone, methaqualone and propoxyphene.

Part 40's procedures don't govern non-DOT tests. State laws may, and they differ from state to state. If you are an employer setting up a non-DOT program, check your state's rules and talk to your attorney. Pact's drug-free workplace pages summarize the rules state by state.

Which one do you need?

Job applicants: ask the employer which test it needs and whether it will order the test itself. If DOT rules cover the job, the employer must order a DOT test.
Students and healthcare workers: ask your program or employer. If it names a testing company, use that company.
Employers with both kinds of workers: run DOT tests only for DOT-covered employees, keep those tests separate, and use the federal CCF only for them.
Not sure if DOT rules cover a job? Ask the DOT agency that regulates your industry, or call Pact.

Common questions

What does non-DOT drug test mean?

It is any drug test that a DOT agency rule doesn't require. The employer or program chooses the drugs tested, and state law may set rules for it. It must not be done on the federal DOT custody form.

Is a 10-panel test a DOT test?

No. A DOT test covers five drug classes (49 CFR 40.82), and labs must not test DOT specimens for other drugs. A 10-panel tests for more drugs, so it is a non-DOT test.

Can I use a non-DOT test I already took for a DOT job?

No. DOT tests must be completely separate from non-DOT tests, and every DOT collection must use the federal CCF (49 CFR 40.13 and 40.40).

Can an employer use DOT forms for its non-DOT testing?

No. 49 CFR 40.13(g) bars using the CCF for non-DOT tests, even with the DOT references crossed out.

Can an employer give a DOT test to an office worker?

Not unless DOT agency rules cover that person. No one may give a DOT test to someone who is not a DOT-regulated employee (49 CFR 40.13(h)).

Does Pact sell DOT tests online?

No. The $40 order page is for non-DOT tests only. Pact runs DOT drug and alcohol programs for employers separately.