Is a Drug Test Part of a DOT Physical?

The DOT physical and DOT drug testing are separate requirements. In its notice on the Medical Examiner's Handbook, published January 22, 2024 at 89 FR 3892, FMCSA clarified that DOT-regulated drug and alcohol testing is not part of the physical qualification examination but may be conducted concurrently with the examination for pre-employment or other authorized purposes.

Part 40 addresses how the two can overlap. Under 49 CFR 40.13(d), when a DOT urine drug test collection is conducted as part of a physical examination required by DOT agency regulations, medical tests related to the physical, such as a glucose test, may be run on any urine left in the collection container after the DOT portion has been sealed into the specimen bottles.

Under 40.13(e), a non-DOT drug or alcohol test given as part of a physical examination to decide whether an employee is medically qualified for a license or certificate is not a DOT drug or alcohol test. The rule states that the results of such a test do not have consequences under Part 40.

A DOT drug test follows Part 40 procedures, including the federal Custody and Control Form, a trained collector, an HHS-certified laboratory and MRO review. Some clinics offer both the physical and a DOT drug test collection at the same visit. Collection sites can be found in the MyDrugTesting.com directory by searching by location and service.

Sources: 89 FR 3892, 49 CFR 40.13