Random Testing Is Not Follow-Up Testing. Here’s Why That Matters

In the DOT world, there are several types of drug and alcohol testing: pre-employment, reasonable suspicion, return-to-duty, random, and follow-up testing. Some people mistakenly think random testing can replace follow-up testing.

Let’s be clear: Random testing can never be substituted for follow-up testing.

Random testing is truly random. It applies to safety-sensitive employees who are subject to DOT testing and must be included in the employer’s random testing program throughout the year.

Follow-up testing is targeted and occurs after a DOT violation. It is required by the SAP as part of the return-to-duty process for a specific employee.

Why You Can’t Swap Them

Even though both involve testing, they serve different purposes:

1. Random testing supports workplace-wide deterrence
2. Follow-up testing monitors individual compliance and supports public safety

They are not interchangeable, and DOT auditors will not treat them as equivalent.

Saying “we already tested them randomly” is not a defense if you fail to complete required follow-up tests. DOT can view that as a serious compliance issue.

Real-World Reminder

If an employee returns to duty after a violation, they still remain in the employer’s random testing pool, as required.

But if the SAP mandates 6 follow-up tests within 12 months, those tests are separate and must be completed exactly as outlined by the SAP. Even if the employee is selected randomly, the follow-up testing plan does not disappear or get satisfied automatically.

Final Word to Employers

DOT testing is not one-size-fits-all. Do not try to combine testing categories that were never designed to be merged.

When in doubt:

1. Treat follow-up tests as a separate requirement
2. Manage them separately from random selections
3. Document everything accurately and consistently