Regulations allow the testing as of June 1, but this testing likely may not be an option until late 2023 or early 2024.
Why the Delay in Testing Implementation?
Saliva-based drug tests cannot begin until:
- Two separate laboratories have received government approval to process oral-fluid specimens (none are approved yet); and
- Collectors have been trained to use whichever saliva collection devices the labs will allow.
The Health and Human Services (HHS) approval process for laboratories takes several months.
Pros & Cons of Saliva Drug Testing
Large and small fleets must decide whether saliva testing is suitable for drivers.
Fleets should consider the following when weighing their options:
- The true cost of testing. It remains to be seen whether saliva tests will cost more or less than urine tests. The overall cost may be cheaper when you factor in some of the benefits of saliva testing, such as eliminating cheating and using a saliva test when a driver cannot provide a urine sample (eliminating the need for a medical exam). Ask your service agents to compare fees as you decide whether saliva testing fits your operation.
- The window of detection. Oral-fluid drug testing detects more recent use, making it more advantageous for post-accident and reasonable suspicion tests. It may not be as suitable for other test types, such as pre-employment or random when determining whether a driver is a chronic/habitual drug user. If you use oral-fluid drug testing, consider a hybrid model in your overall program that takes advantage of both test types.
- Cheating. Oral-fluid drug testing offers fewer opportunities to tamper with the specimen or otherwise cheat on the test. Every oral-fluid specimen collection is directly observed.
- Privacy. Compared to urine collections, oral-fluid testing is not as intrusive. In part, this means drivers may be less hesitant to undergo a test.
Preparing for the Switch
If you decide to use oral-fluid drug testing, fleets must perform some tasks in preparation, such as:
- Update your company’s DOT testing policy to indicate the following:
- Which test types apply to saliva-based testing, and
- Which test types apply to a urine sample.
- Provide existing CDL drivers with a revised DOT drug and alcohol policy/educational materials, letting them know what to expect at the collection site. Collect a new signed receipt from them after distribution.
- Train the designated employer representative (DER) on oral-fluid drug testing procedures, including which test types require the testing method based on policy. The DER must communicate to the collection site whether the drug test should be a urine or saliva-based sample.
- Find the right service agents. If saliva-based drug testing works for your company, you need to:
- Confirm that your collection site offers oral-fluid drug testing or seek out another vendor.
- Contract with an HHS-certified lab to process oral-fluid drug tests.
- Contract with a certified medical review officer who verifies oral-fluid drug tests.
Even though the option of oral-fluid testing is months away, now is the time to decide whether it is a fit for your operation.
You should immediately line up service providers, train your staff, and update your policies. Create a plan to help move forward once the green light is given for testing.