One Test, Two Purposes: Combining Return to Duty and Pre Employment Drug Tests

If you’re a commercial driver returning to work after a DOT drug or alcohol violation, or an employer preparing to hire someone who has completed the SAP process, you don’t need to run two separate drug tests.

Under 49 CFR §382.301, one properly conducted test can count as both the pre employment and return to duty (RTD) test if it meets DOT requirements.

When You Can Combine the Tests

You can combine the RTD and pre employment tests only if:

1. The driver has completed the SAP process and is eligible for RTD testing
2. The test is conducted under direct observation
3. The test is marked as a return to duty test on the Custody and Control Form (CCF)

When done correctly, one test satisfies both the RTD requirement to resume safety sensitive duties and the pre employment requirement for starting work with a new employer.

Why the Label Matters

The difference lies in how the tests are conducted. Pre employment tests are not observed, while RTD tests must be. For that reason, the test must be labeled as “Return to Duty” on the CCF.

Employers should check the Return to Duty box on the form and ensure the test is performed under direct observation. This makes the result valid for both purposes.

What Happens If You Only Do a Pre Employment Test

A pre employment test by itself does not meet DOT requirements for return to duty testing. However, a correctly labeled and observed RTD test can count as both.

For employers, combining the two saves time, reduces costs, and keeps the program compliant when performed correctly.

Final Takeaway

Combining the RTD and pre employment test is a practical and compliant option when handled properly. The test must be observed, labeled as RTD, and conducted only after the driver has completed the SAP process and is cleared for testing.

This approach simplifies compliance, saves resources, and helps qualified drivers get back to work safely and efficiently.