Submit your comments by Friday, October 17.
NDASA has submitted its comments on the Procedures for Transportation Workplace Drug and Alcohol Testing Programs: Addition of Fentanyl to the Department of Transportation’s Drug-Testing Panel; Harmonization with Certain Items in the HHS Mandatory Guidelines for Urine and Oral Fluid; and Technical Amendments.
While NDASA recognizes the relevance and timeliness of the proposal to add fentanyl to the drug testing panel, the association encourages the Department of Transportation to also consider a number of factors before finalizing the rule in order “to ensure long-term program stability, cost efficiency, and scientific flexibility.”
These include:
1. The impact of expanding the drug testing panel on oral fluid testing readiness and flexibility.
2. As DOT evaluates the potential costs associated with expanding the drug testing panel, NDASA urges the department to also consider other program priorities. For example, NDASA has long advocated for mandatory training for Designated Employer Representatives, which the association believes is a sound investment to support workplace safety.
3. Ongoing collaboration and program support. NDASA supports and appreciates many of the proposed technical amendments in the proposal that “align with best practices long recommended by our association and represent meaningful progress toward a more consistent and modernized testing program.”
Read NDASA’s comments here.
In a Notice of Proposed Rule Making, posted on Tuesday, September 2, the U.S. Department of Transportation’s (DOT) Office of Drug and Alcohol Policy and Compliance (ODAPC) is proposing the addition of fentanyl and norfentanyl (a metabolite of fentanyl) to the DOT-regulated drug testing program.
According to DOT, adding fentanyl to its drug test panels “is in the interest of transportation safety, given compelling information regarding the number of overdose deaths in the United States involving fentanyl.”
This change would bring DOT-regulated drug testing into further alignment with the U.S. Department of Health and Human Services, which added fentanyl to its testing requirements in the January 16, 2025, revision of the Mandatory Guidelines for Federal Workplace Drug Testing Programs.
The addition would also bring DOT into compliance with the Omnibus Transportation Testing Act of 1991, which requires DOT to follow HHS “standards for all aspects of laboratory testing of controlled substances to ensure full reliability and accuracy in testing.”
The Department also proposes to amend and clarify certain provisions of part 40 to harmonize, as appropriate, with the current HHS Mandatory Guidelines for urine (UrMG) and oral fluid.
Make your voice heard!
The NPRM is available online at
https://www.federalregister.gov/documents/2025/09/02/2025-16720/procedures-for-transportation-workplace-drug-and-alcohol-testing-programs-addition-of-fentanyl-to
Comments on the proposal are due October 17, 2025 and can be submitted here. Join NDASA in submitting your comments. Your input matters!