What DOT Employers Need to Know About Marijuana Rescheduling
Over the past year, there's been a lot of conversation about marijuana policy at the federal level. Between executive orders, agency updates, and ongoing coverage of the rescheduling process, it's understandable that employers and workers alike are paying closer attention.
The Department of Transportation (DOT) addressed the situation directly. DOT issued a clear notice explaining that while marijuana rescheduling is being discussed at the federal level, its drug testing rules have not changed. For safety-sensitive transportation roles, the expectations remain the same.
However, with all the buzz around this topic, social media posts, news coverage, and chatter, how rescheduling marijuana possibly affects things can still seem confusing. Let's walk through what the DOT notice outlines, what the marijuana rescheduling process actually involves, and what all of this means right now.
Listen to article
Table of Contents
Does DOT Test for THC?
One of the most common questions right now is simple: Does DOT test for THC?
As of today, the answer is still yes, and that hasn't changed.
Even as the federal government explores changes to cannabis law, the Department of Transportation continues to require drug testing for marijuana (THC metabolites) for employees in safety-sensitive positions. That includes commercial drivers, pilots, railroad workers, school bus drivers, transit operators, and others whose jobs affect public safety.
In December 2025, the DOT's Office of Drug and Alcohol Policy and Compliance issued a formal notice acknowledging that the President had directed the Department of Justice (DOJ) to complete the federal marijuana rescheduling process. But the DOT marijuana notice made one thing absolutely clear: until marijuana is officially rescheduled at the federal level, DOT marijuana testing rules remain exactly the same.
That means:
-
Safety-sensitive employees are still prohibited from using marijuana.
-
Marijuana is still part of the required drug test panels under DOT regulations.
-
Laboratories, Medical Review Officers (MROs), and Substance Abuse Professionals continue to operate under the same standards.
-
There are no changes yet to testing procedures, enforcement responsibilities, or workplace consequences.
Why Marijuana Rescheduling Keeps Making Headlines
You've probably seen a spike in marijuana rescheduling news, and for good reason. The conversation about cannabis reform at the federal level is one of the most active policy topics in Washington today.
In December 2025, the President signed an executive order directing the Department of Justice to complete the process of rescheduling marijuana to Schedule III (from Schedule I) under the Controlled Substances Act (CSA).
Here's what that means in federal policy terms:
-
Schedule I drugs are defined as substances with no currently accepted medical use and a high potential for abuse. Marijuana has occupied this category since it was first placed there decades ago.
-
Schedule III drugs are considered to have accepted medical use and a lower potential for abuse, similar to certain prescription medications.
The President's order essentially told the Department of Justice (including the Drug Enforcement Administration) to speed up the administrative rulemaking process that would move marijuana into Schedule III, which would recognize that marijuana has a medical use.
Has Marijuana Been Rescheduled Yet?
This is the part that often gets lost in headlines and social media posts: No, marijuana has not been rescheduled as of today.
That executive order triggered, or renewed, the federal administrative process, but it did not automatically reclassify marijuana. Like most federal rulemakings, this one involves multiple steps, public comment periods, scientific review, and formal publication before it becomes legally effective.
Until all those procedural steps are complete, marijuana remains a Schedule I controlled substance.
What the Marijuana Rescheduling Timeline Actually Looks Like
If you're hoping for a firm marijuana rescheduling timeline, no federal agency has published an official completion date.
Even after the executive order, the agencies responsible for rescheduling marijuana (primarily the Department of Justice and the DEA) must:
-
Draft proposed changes to the controlled substances schedules,
-
Open them up for public comment and review,
-
Publish final rules that have regulatory effect.
Until all those formal steps are complete, the law and every federal policy that depends on the law remain unchanged.
What Marijuana Rescheduling DOT Really Refers To
What this means in plain language is: "How the federal process to reschedule marijuana intersects with the Department of Transportation's marijuana testing rules."
And the short answer is: so far, it hasn't changed anything.
DOT confirmed that until rescheduling is final, its drug testing regulations, including marijuana testing, remain in full effect. DOT also said it will continue to monitor the process and update the industry if anything actually changes.
That's an important point: DOT is not rewriting its standards right now. The agency is monitoring the federal rescheduling process and keeping its industry informed.
Why DOT Is Being Cautious, and What Could Change
It's reasonable to ask: if marijuana were moved to Schedule III, wouldn't that automatically change how the Department of Transportation treats it in drug testing programs?
No.
At present, DOT's drug testing requirements are based on federal transportation safety statutes and DOT regulations, which explicitly identify marijuana as a prohibited drug for safety-sensitive employees. Marijuana remains classified as a Schedule I substance under federal law, and DOT has stated that its drug testing rules remain unchanged.
If marijuana were formally rescheduled to Schedule III, that change by itself would not amend DOT regulations or immediately alter testing requirements. For now, there is no change in DOT policy. Until federal law or DOT regulations are formally revised, DOT-regulated employers must continue to follow existing marijuana testing requirements.
What This Means for DOT Marijuana Testing
So where does that leave us today? The practical reality is straightforward:
✔ DOT marijuana testing remains fully in effect.
Safety-sensitive employees are still required to undergo drug testing that includes marijuana.
✔ Marijuana use is still prohibited for safety-sensitive roles.
Even if marijuana is legal in your state or prescribed for medical use, DOT testing rules still prohibit its use for safety-sensitive positions.
✔ State marijuana laws don't override federal DOT requirements.
Even if you live in a state where cannabis is legal, federal rules for safety-sensitive workers still apply.
✔ Employers must continue following existing DOT testing rules.
That includes pre-employment, random, reasonable suspicion, post-accident, return-to-duty, and follow-up testing protocols.
✔ Nothing changes automatically with rescheduling itself.
Even after rescheduling is final, DOT would still need to update its regulatory guidance. As of now, the DOT drug test remains exactly the same.
The Bottom Line
Marijuana rescheduling is a real federal process that's underway, but it hasn't crossed the finish line yet. Until it does:
-
DOT drug testing rules stay exactly where they are.
-
Safety-sensitive employees are still tested for marijuana.
-
Employers must continue enforcing existing policies.
-
Nothing changes automatically just because rescheduling is being discussed.
Frequently Asked Questions
Will DOT stop marijuana testing once marijuana is rescheduled?
Not automatically. The DOT has clarified that its testing rules won't change until federal law and related regulations are formally updated — and that hasn't happened yet.
Has marijuana already been rescheduled?
No. While there's an active federal process to move marijuana from Schedule I to Schedule III, it remains in Schedule I until the rulemaking steps are complete.
Why does the Trump administration want to reschedule marijuana?
The Trump administration's effort to reschedule marijuana is aimed at updating federal drug policy to better reflect current medical research, state-level laws, and public consensus. By moving marijuana from Schedule I to Schedule III under the Controlled Substances Act, the administration has said it wants to acknowledge accepted medical use, reduce barriers to scientific research, and modernize regulations that have remained largely unchanged for decades — while stopping short of fully legalizing marijuana at the federal level.
Does state legalization affect DOT drug testing?
No. Federal DOT testing rules apply regardless of state laws on marijuana.
What does marijuana rescheduling mean for safety-sensitive employees?
Right now, very little. The rules are unchanged. But once rescheduling is finalized, DOT and other agencies may need to take further action to clarify.
Should employers update their policies now?
Employers should review and communicate policies to make sure everyone understands current rules, but there's no legal requirement to drop marijuana testing yet.
