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How do I know what drivers to include in my drug pool?

Start with the work the driver may actually perform, not the letters on the license alone. FMCSA generally requires DOT drug and alcohol testing for drivers who operate commercial motor vehicles that require a CDL on public roads in the United States. That includes full-time, part-time, intermittent, backup, and international drivers when they perform covered work. FMCSA explains who is covered.

How to build your pool roster

  • List every role that may operate a CDL-required vehicle for your company, including occasional or backup drivers.
  • Check each person against the applicable DOT agency rules and the work they may be assigned. Do not assume that holding a CDL, by itself, answers the question.
  • Keep the roster current as covered drivers join, leave, or change duties. If a borderline role is unclear, have your program administrator resolve it before relying on the roster.
  • Keep any company-elected non-DOT testing in a separate pool from DOT testing. If another DOT agency applies, use that agency’s rules when setting up the pool.

Need help administering the testing program? See LBC Fleet’s drug-testing services. If you are evaluating software to track the roster and selections, review our DOT compliance software and ask us to demonstrate the current pool workflow, selection history, access controls, and export. Software can help organize records; it does not decide who is legally required to be in the pool.

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