The short version
- Confirm which roles are DOT-covered, which are policy-covered, and which are neither
- DOT drug tests always go through MRO verification; DOT breath alcohol results go from the technician directly to the DER; non-DOT results are handled the way your program defines
- DOT and non-DOT tests are kept completely separate, on different forms, with the DOT test always first (49 CFR 40.13)
- A non-DOT program is only as strong as the written policy behind it
- Review policy language with your HR and legal advisors before enforcement
