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DOT auditors are responsible for making sure employer are in compliance with the federal regulations for DOT drug and alcohol testing.

We’ve compiled a DOT audit checklist that represent most of the records a DOT Agency and USCG auditor, inspector, or investigator will usually request and review during a program review.

Keep in mind that DOT Agency and USCG regulations may have additional and more specific record review requirements.

DOT Audit/Inspection/Investigation/Compliance Records Review Checklist

Policies, Plans, and Reports

  • Alcohol and drug testing policies and instructions for implementing your program
  • Previous two MIS annual reports either submitted to DOT, or prepared and retained
  • Copies of written consent forms you sent to obtain 40.25 drug and alcohol information from previous
    employers, and the responses received from those employers
  • Copies of written consent forms you received from prospective employers for 40.25 information, and
    documentation of your responses
  • Semi-annual statistical summary reports from laboratories
  • List of all employees hired or transferred into safety-sensitive service for the past two years, including
    documentation of previous employer records check
  • List of all employees with a non-negative test result in the last five years
  • Proof that you have received a “Driver Not Prohibited” result for pre-employment FMCSA Clearinghouse queries for FMCSA employees hired since January 6, 2020
  • Proof that you have conducted annual limited queries for all existing FMCSA employees at least once every 12 months.

Employee and Supervisor Training Records

  • Educational materials for employees
  • Documentation showing how education materials were made available to employees
  • List of supervisors responsible for making reasonable suspicion and reasonable cause determinations
  • Supervisor training documentation
  • Under FRA, supervisor post- accident training lesson plans, course materials, and attendance lists

Random Testing Records

  • Information about the type of method used to select employees for testing
  • Names of all employees in the random testing pool for each selection period that the DOT Agency or
    USCG will review
  • Names of all employees selected for testing
  • Names of all employees actually tested
  • CCFs and ATFs showing employees were tested within the selection period
  • For each selected employee not tested, documentation showing why the collection did not occur
  • Records of collections by location, by date (or day of the week), and by time of the day (or shift)
  • Proof that testing occurred throughout all shifts and all workdays, in other words – testing was
    unpredictable
  • For railroads, your approved Drug and Alcohol Random Testing Plan

Drug Testing Custody and Control Forms for all DOT Tests

  • Pre-employment
  • Random
  • Reasonable suspicion, including supervisor justification documentation
  • Reasonable cause, under FAA, FRA, and PHMSA, including supervisor justification documentation
  • Post-accident, including documentation showing criteria were met
  • Return-to-duty
  • Follow-up

Testing Forms for all DOT Tests

  • Pre-employment, if applicable
  • Random, under FMCSA, FAA, FRA, and FTA
  • Reasonable suspicion, including supervisor justification documentation
  • Reasonable cause under FRA, including supervisor justification documentation
  • Post-accident, including documentation showing criteria were met
  • Return-to-duty
  • Follow-up
  • Correctable and non-correctable flaw documentation

Employee Return to Duty Records

  • SAP Initial Evaluation reports
  • SAP Follow-up Evaluation reports, including follow-up testing plans
  • Employee ―Return to Duty and ―Second Chance Agreements, when applicable
  • Return-to-duty and Follow-up testing compliance documentation
  • Lists of qualified SAPs that you give to those who violate the regulations

Service Agent Documentation

  • Lists of service agents and their contact information
  • Written agreements and contracts with service agents, if applicable
  • Credentials, training, and examination or proficiency documentation