DOT COMPLIANCE • EMPLOYER RESOURCES

DOT Oral Fluid Testing

Understand the federal requirements, plan your collection instructions, and submit standing orders for review by Carolina Testing.

Create & Submit DER Standing OrdersReview DOT Requirements

EMPLOYER COLLECTION INSTRUCTIONS

Authorize your company’s DOT oral fluid standing orders

This form records the company DER’s signed instructions for routine tests and problem collections. It is intended for use with the required HHS-certified laboratory arrangements, qualified collectors, and conforming collection devices in place. FAA-covered employers must meet the applicable U.S. laboratory requirements.

The DER must personally complete the authorization and signature below. Carolina Testing will verify DER authority, reconcile existing orders, and confirm the accepted effective date. Mandatory DOT and MRO directions take precedence over specimen preferences.

Complete & Sign Standing Orders

49 CFR PART 40

The requirements behind a DOT oral fluid test

Part 40 governs how a DOT drug test is performed. The employer’s agency rules still determine who is covered, when testing is required, and the program’s other obligations.

Observed collection & split specimens

Oral fluid is collected under direct observation. The process includes the required 10-minute wait, a Federal Custody and Control Form, and a split specimen for primary and possible reconfirmation testing. Collection, sealing, documentation, and shipment must follow Part 40.

§40.72 — preparation · §40.73 — collection and completion

Employer instructions & DER authority

The employer sets specimen preferences within the regulations; the employee does not choose the test type. A DER is an employer-authorized employee who can make required testing decisions. A service agent cannot act as the DER. Keep the DER’s contact details current and provide clear standing orders.

§40.3 — DER definition · §40.65 — standing orders for recollection

Problem collections

Out-of-range urine temperature or suspected tampering requires immediate recollection under the prescribed observed-urine or oral-fluid process. Collectors consult the standing order or contact the DER. Insufficient urine or oral fluid follows §40.193, including permitted specimen switches, time limits, and any required medical evaluation. Insufficient volume alone is not automatically a refusal.

§40.65 — specimen problems · §40.193 — insufficient specimen

Direct observation: the 2026 rule

Return-to-duty and follow-up testing requires direct observation. When a same-sex urine observer is unavailable, §40.67(g) specifies DER coordination and the transition to oral fluid. While oral fluid is unavailable, arrange an appropriate observer or alternate observed-urine site.

Once the second laboratory is certified, an ODAPC notice will identify an 18-month transition period. Read the current rule for readiness requirements and when oral fluid must be used.

§40.67 — current observation and transition requirements

AGENCY-SPECIFIC REQUIREMENTS

Apply the rules for your transportation program

A specimen preference does not change required testing reasons, deadlines, random rates, reporting, or return-to-duty obligations.

Program Governing agency rules Planning note
FMCSA 49 CFR Part 382 Covered commercial drivers; preserve Clearinghouse and employer testing obligations.
FAA 14 CFR Part 120 The two HHS-certified oral fluid laboratories must be in the United States (§40.67(g)(5); §120.123(a)).
FRA 49 CFR Part 219 FRA Subpart C post-accident toxicology has separate blood/urine requirements. These standing orders do not replace that process.
FTA 49 CFR Part 655 Apply the transit employer’s covered-function and testing requirements.
PHMSA 49 CFR Part 199 Apply the pipeline operator’s drug and alcohol program requirements.
USCG 46 CFR Parts 16 and 4 USCG is within Homeland Security; Part 40 treats it as a DOT agency for drug testing only. Maritime alcohol requirements are separate.

Official agency directory and regulation links →   FRA post-accident specimen requirements →

FOR DESIGNATED EMPLOYER REPRESENTATIVES

Complete & sign your standing order

The company’s DER must personally sign. Enter the company and DER information, select an instruction for every applicable situation, confirm DER authority, then draw your signature and enter the date signed. A service agent cannot sign as the DER.

Use the form below to request new instructions, replace existing orders, or request revocation. Submit a separate request for each agency. Staff will verify your authority, review the instructions and collection arrangements, then confirm accepted orders and their effective date in writing.

Submission is not activation. For an immediate collection decision, an urgent change, or revocation, contact Carolina Testing directly. Do not use this form to report employee results or medical information.

Requests are sent to craig@carolinatesting.com. See our Privacy Notice. Keep the submission receipt and the final written activation with your program records.

Employer and DER details

Submit one request per DOT agency. No employee or medical information.
The DER must be reachable for collection instructions.
Select one agency. FRA Subpart C post-accident toxicology is excluded from these orders.
MM/DD/YYYY. A requested date does not activate orders. For revocation, identify the existing order in the notes and contact staff directly.

Routine collection instructions

Oral fluid selections are contingent on DOT availability and written Carolina Testing activation. Urine remains the fallback while oral fluid is unavailable. Return-to-duty and follow-up urine tests must be directly observed.
Agency-required tests cannot be waived. Select Not applicable only if this testing reason does not apply to your covered program.
Agency-required tests cannot be waived. Select Not applicable only if this testing reason does not apply to your covered program.
Agency-required tests cannot be waived. Select Not applicable only if this testing reason does not apply to your covered program.
Agency-required tests cannot be waived. Select Not applicable only if this testing reason does not apply to your covered program.
Agency-required tests cannot be waived. Select Not applicable only if this testing reason does not apply to your covered program.
Agency-required tests cannot be waived. Select Not applicable only if this testing reason does not apply to your covered program.

Problem collections and mandatory procedures

49 CFR 40.65, 40.67 and 40.193 control. Do not terminate or delay a required collection merely because the preferred specimen type is unavailable.
Switch only at the point permitted by 49 CFR 40.193(a), using a qualified collector and a new CCF. If the urine procedure is continued and its time limit expires, stop and notify the DER for the required MRO/physician process; this order does not authorize bypassing that process.
Required immediate recollection and handling of the original specimen must follow 49 CFR 40.65.
Applies when the DER directs a required observed collection under 49 CFR 40.67. Follow applicable DOT and MRO instructions; specimen preferences cannot waive observation or delay a required collection. Oral fluid requires regulatory availability and written staff activation.
Follow 49 CFR 40.67(g). When oral fluid is unavailable, contact the DER to arrange a same-sex observer or an acceptable observed-urine site. Once oral fluid is available and required under the transition rules, use oral fluid at a qualified site; mandatory rules override any contrary selection.
Any switch must comply with 49 CFR 40.193(a). If the oral-fluid time limit expires, stop and notify the DER for the required MRO/physician process. Preserve direct observation when required.

No same-sex urine observer available: Follow 49 CFR 40.67(g). While oral fluid is unavailable, contact the DER to arrange a same-sex observer or an acceptable site for observed urine. Once oral fluid is available and applicable transition provisions permit or require it, this request authorizes oral fluid at a qualified site. Mandatory rules override contrary preferences.

Do not include employee names, results, medical information, SSNs, or passwords. Identify any existing order being replaced or revoked. Staff will resolve conflicting instructions before activation.
Must be the same person identified as DER above and the person signing below.
Clear Signature
I am the DER named above and personally sign these standing orders for the employer. I authorize Carolina Testing to follow my selected collection instructions and consent to an electronic signature and electronic records. Mandatory DOT and MRO instructions control. These orders remain in effect from the accepted effective date until replaced or revoked in writing.
MM/DD/YYYY. Your submission timestamp is also recorded.

Need help planning your program?

We can help clarify your collection instructions and coordinate the next steps with your DER and testing providers.

Contact Carolina TestingExplore DOT Compliance

Regulatory overview reviewed October 12, 2026. Official regulations and agency instructions control; confirm current laboratory and operational availability before scheduling.