Follow-Up Drug Testing

Maintain compliance with FMCSA & DOT at Sky Drug Testing

Follow-Up Testing Explained

At Sky Drug Testing, we provide reliable follow-up drug testing services to help you meet FMCSA and DOT requirements. If an employee has previously tested positive, refused a test, or violated drug and alcohol regulations, follow-up testing is crucial to ensure they're fit for duty and in compliance with federal law.

Follow-up drug testing refers to the ongoing testing after a driver has violated drug or alcohol regulations. After an initial violation, a driver is required to undergo a series of follow-up tests to ensure that they are staying drug-free and adhering to safety standards.

Under FMCSA and DOT regulations, a driver must complete the Return-to-Duty testing and submit to unannounced testing. Employers should ensure the completion of the Substance Abuse Professional's plan. All of this is found in the Department of Transportation's (DOT) rule, 49 CFR Part 40.

When Follow-Up Testing is Required

  • After a Positive Test or Policy Violation: If a driver tests positive for drugs or alcohol, or refuses a DOT-required test, they must complete the Return-to-Duty Program before resuming any safety-sensitive duties.
  • Follow-Up Testing Plan: After treatment or rehabilitation, a Substance Abuse Professional (SAP) will establish a customized follow-up testing plan for the driver, which the employer must implement and monitor.
  • Unannounced Testing: Follow-up tests are conducted at unannounced, random intervals and are in addition to any regular random or scheduled DOT tests.
  • Direct Observation: All Return-to-duty and follow-up test specimens must be collected under direct observation.

Substances Tested

Drug testing is typically conducted through urine analysis, screening for:

  • Marijuana (THC)
  • Cocaine
  • Opiates
  • Amphetamines
  • PCP

Alcohol testing is conducted separately, usually with a breathalyzer.

Why Follow-Up Testing Matters

Audits & Fines

  • If a driver has a violation, the follow-up plan set by the SAP must be carried out
  • Failure to do so, can lead to FMCSA audit violations and potential fines
  • We help by keeping accurate records to prove your compliance

Safety Scores & Ratings

  • Drug and alcohol violations can hurt your safety scores (CSA/SMS)
  • Higher scores can increase the risk of more inspections or investigations
  • Serious problems can lead to a worse safety rating-and in the worst case, your operations may be suspended until fixed

Insurance & Customer Contracts

  • Insurers and many shippers check your public safety data
  • Poor scores can mean higher insurance costs and lost contracts
  • Staying compliant helps to keep premiums down and the business opportunities open

Driver Employability & Licenses

  • If a driver fails to finish a follow-up plan, they remain prohibited in the Clearinghouse
  • States can downgrade CDL/CLP commercial privileges until the driver completes the required testing
  • Most employers will not hire a driver who is prohibited or downgraded

Compliance You Can Trust

We align each step with DOT guidance so you stay compliant during audits and investigations. Our technology streamlines follow-up testing documentation while our experts guide you through complex cases and ensure proper SAP plan implementation.

Follow-Up Drug Testing

Quick Facts

  • 49 CFR Part 40 compliant
  • SAP-directed testing
  • Direct observation required
  • Audit-ready documentation

Learn more: why it matters and how to be compliant

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Frequently Asked Questions All FAQs

Follow-up testing is required after a driver has violated DOT drug or alcohol regulations. It involves unannounced, random testing over a prescribed period following return-to-duty testing, as directed by a Substance Abuse Professional's (SAP) plan.

A qualified Substance Abuse Professional (SAP) establishes the follow-up testing plan after evaluating the driver. The plan specifies the duration (up to 5 years) and frequency of testing, which the employer must implement and monitor.

Follow-up testing can last up to 5 years from the date the driver returns to duty. The SAP determines the specific duration and frequency based on the individual case, with a minimum of 6 unannounced tests in the first 12 months.

Yes. All return-to-duty and follow-up tests must be conducted under direct observation as required by 49 CFR Part 40. This ensures the integrity of the specimen collection process.

If a driver fails a follow-up test, they must be immediately removed from safety-sensitive duties and undergo another SAP evaluation. They must complete the return-to-duty process again before resuming work.

Follow-up tests must be conducted at DOT-certified collection sites by trained collectors. The site must be capable of providing direct observation services as required for these types of tests.

Employers must maintain records of all follow-up tests, SAP evaluations, and compliance with the testing plan. These records must be retained for 5 years and be available for DOT audits and inspections.

While DOT regulations don't prohibit termination, employers must follow their own policies and applicable employment laws. However, the driver cannot perform safety-sensitive functions until completing the return-to-duty process.

If a driver fails to complete the follow-up testing plan, they remain prohibited in the FMCSA Drug and Alcohol Clearinghouse. This affects their employability and CDL status until compliance is achieved.

The follow-up testing plan follows the driver to their new employer. The new employer must implement and continue the SAP's prescribed testing plan. All follow-up testing records must be transferred to the new employer.

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