What DOT’s Proposed Fentanyl Testing Update Means for Employers
Federal drug testing rules like this don't shift very often, which is why DOT's latest proposal has drawn so much attention across the transportation industry. When changes do happen, they usually signal a broader shift in how regulators are thinking about safety, risk, and real-world drug use.
That's exactly what's happening now.
The U.S. Department of Transportation (DOT) has proposed an update to its workplace drug and alcohol testing program that would add fentanyl and norfentanyl to the federally required drug testing panel. While the rule is not final yet, it represents a significant step toward modernizing DOT drug testing standards.
For employers, compliance teams, and safety-sensitive workers, this proposal raises important questions: what DOT tests for today, what may change, and when those changes could take effect.
Listen to article
The Current State of DOT Drug Testing
To understand why this proposal matters, it helps to start with how DOT drug testing works today.
DOT drug testing applies to employees in safety-sensitive positions regulated by federal agencies such as the FMCSA, FAA, FRA, FTA, PHMSA, and the U.S. Coast Guard. These rules govern testing for pre-employment, random selection, post-accident, reasonable suspicion, return-to-duty, and follow-up testing.
All DOT drug tests must follow strict federal standards outlined in 49 CFR Part 40, which define which substances are tested, how specimens are collected, and how results are reviewed by a Medical Review Officer (MRO).
What Opioids Does DOT Test for Right Now?
One of the most common questions employers and drivers ask is: What opioids does DOT test for?
Currently, DOT drug tests include the following opioids:
-
Codeine
-
Morphine
-
Heroin (identified through 6-acetylmorphine, or 6-MAM)
-
Oxycodone
-
Oxymorphone
-
Hydrocodone
-
Hydromorphone
These substances were added over time as opioid misuse became more prevalent and better testing technology became available. However, despite fentanyl's role in the current opioid crisis, it is not yet included in the DOT drug testing panel.
Does DOT Test for Fentanyl?
As of now, the answer is no.
Right now, DOT drug tests do not check for fentanyl or norfentanyl. This means fentanyl is that fentanyl is not detected in standard DOT drug testing.
This gap between current testing panels and modern drug trends is exactly what prompted DOT to propose a change.
Why DOT Is Proposing to Add Fentanyl
Fentanyl is a synthetic opioid that is far more potent than codeine or morphine. Its increased availability has contributed to a sharp rise in overdose deaths nationwide.
DOT's proposal is not framed as a response to a single issue, but rather as part of a broader effort to keep transportation safety programs aligned with current risks. DOT specifically points to "compelling information regarding the number of overdose deaths in the United States involving fentanyl" and explains that updating the DOT drug testing program to include fentanyl is being proposed "in the interest of transportation safety."
Another important factor is regulatory consistency. The U.S. Department of Health and Human Services (HHS) already includes fentanyl in its mandatory drug testing guidelines. DOT's proposal would harmonize its rules with those existing federal standards, reducing inconsistencies between testing programs.
DOT Adding Fentanyl to the Drug Panel: What's Actually Being Proposed
The proposed rule would formally add fentanyl and norfentanyl to the DOT drug testing panel. Norfentanyl is the primary metabolite used to confirm fentanyl use, helping ensure accurate and reliable results.
In addition to adding fentanyl, the proposal includes technical updates designed to align DOT testing procedures with HHS requirements. These updates address definitions, cutoff levels, and other regulatory details that affect how drug testing is conducted and interpreted.
It's important to note that this proposal does not immediately change testing requirements. Until a Final Rule is issued, DOT drug tests remain unchanged.
When Will DOT Drug Tests Include Fentanyl?
Timing is one of the biggest unknowns.
DOT published its Notice of Proposed Rulemaking (NPRM) in September 2025 and allowed public comments through October 2025. During this period, employers, industry groups, testing laboratories, and other stakeholders were invited to submit feedback.
Before fentanyl testing becomes mandatory, DOT must also review all public comments left on the NPRM. Then, a Final Rule will be published confirming which changes are being adopted as well as an effective date.
Once a Final Rule is published, DOT typically allows additional time for implementation. This gives employers and testing providers time to update policies, contracts, training, and laboratory processes.
So far, the NPRM has been published, and the comment period ended as of October 2025. No Final Rule has been published yet.
Will DOT Test for Fentanyl in Urine and Oral Fluid?
DOT's proposal is structured to align with HHS guidelines, which apply to both urine and DOT oral fluid testing. Although DOT has already finalized the oral fluid testing rule and officially allows saliva-based drug testing as a compliant alternative to urine testing, oral fluid testing has not yet started because there are currently no DOT-approved laboratories with federal certification to process specimens. While oral fluid testing remains a work in progress, DOT's long-term goal is to ensure consistency across all specimen types.
When implemented, fentanyl testing would apply wherever DOT drug testing is authorized, using federally approved methods and cutoff levels. This ensures accuracy and minimizes the risk of false positives or inconsistent results.
How This Change Affects Employers
For DOT-regulated employers, the proposed change carries several implications.
First, drug-free workplace policies will need to be reviewed and updated once fentanyl testing becomes mandatory. Policies that list tested substances will need to reflect the expanded drug panel.
Second, employers may see slight increases in testing costs. Adding additional analytes to a drug panel can increase laboratory processing costs, though the overall impact is expected to be modest.
Third, training and communication will matter. Supervisors, compliance staff, and employees will need clear guidance on what substances are prohibited and how DOT testing requirements have changed.
What This Means for Drivers and Safety-Sensitive Workers
For drivers and safety-sensitive workers, this proposal shows that DOT drug testing rules can and do change over time.
While fentanyl is not currently included in DOT drug testing, it could be added if the proposed rule is finalized. If that happens, substances that are not identified on a DOT drug test today may be included in future testing requirements.
Workers should understand that DOT drug testing is designed around safety, not punishment. The goal is to reduce impairment risks in environments where mistakes can have serious consequences.
The Bottom Line
Right now, DOT drug testing rules haven't changed. Fentanyl is not included in standard DOT drug tests, and employers are still required to follow the same testing requirements that are already in place.
What has changed is the conversation. DOT has proposed adding fentanyl and norfentanyl to the drug testing panel, and while that proposal is still working its way through the rulemaking process, it's something employers and safety-sensitive workers should be aware of.
There's no action required yet, but staying informed now can make things easier later if the rule moves forward. Understanding what's being discussed, why it's being considered, and where things stand helps avoid surprises and rushed changes down the road.
Frequently Asked Questions
Does DOT drug test look for fentanyl right now?
No. Under current rules, DOT drug tests do not screen for fentanyl or its metabolite, norfentanyl. Standard DOT drug testing panels focus on specific drug classes that have been federally approved, and fentanyl is not yet included on that list.
This means that a DOT-regulated drug test, whether it is a pre-employment, random, post-accident, reasonable suspicion, or follow-up test, would not identify fentanyl use today. Until DOT officially updates its testing requirements, fentanyl remains outside the scope of federally required DOT drug testing.
Is DOT adding fentanyl to the drug panel?
DOT has formally proposed adding fentanyl and norfentanyl to the DOT drug testing panel. This proposal was published as part of the federal rulemaking process and reflects DOT's effort to update its testing program in response to current safety risks.
However, it's important to understand that this change is not final. A proposal does not carry legal weight on its own. DOT must still review public comments, finalize the rule, and publish it before fentanyl testing becomes mandatory. Until that happens, DOT drug testing requirements remain unchanged.
When will DOT test for fentanyl?
DOT will begin testing for fentanyl only if the proposed rule is finalized. If that happens, a Final Rule is published in the Federal Register and an official effective date is established. There is no confirmed timeline yet.
Will fentanyl testing apply to all DOT tests?
Yes. If fentanyl testing is implemented, it would apply to all DOT-regulated drug testing types, not just select situations. In other words, fentanyl and norfentanyl would become standard components of every required DOT drug test, just like other opioids currently on the panel. Employers would be required to test for fentanyl consistently across all DOT-covered testing events.
