Recently the Federal Motor Carrier Safety Administration (FMCSA) clarified the rules for student truck drivers for drug testing, FMCSA Clearinghouse and for required consortium random drug testing. On this page we will cover the following:
This information applies to student drivers in a training program that are affiliated with or operated by a motor carrier. Those student drivers employed by motor carriers should register in the Clearinghouse as a Driver.
Student Drivers and the FMCSA Clearinghouse
The FMCSA has made it clear that student drivers must register in the FMCSA Clearinghouse. The image below shows the instructions from the FMCSA Clearinghouse. Students must register in the Clearinghouse and must have made arrangements with a consortium/third-party administration (C/TPA) for an initial query and enrollment into a Random Testing Consortium. A student driver just like an owner operator must designate a C/TPA as part of their Clearinghouse registration process.
Instructions are available for student drivers to register in the Clearinghouse. Registration assistance is also available from https://clearinghouseservices.com/driver-clearinghouse-services/
Drug Test for Student Drivers
Before driving a commercial motor vehicle (CMV) at a truck driving school, the student driver needs a negative drug test result, the test reason would be pre-employment. A DOT drug test should only be performed when the student driver has their commercial learner’s permit (CLP) or CDL. Testing performed prior to the issuance of a CLP or CDL should be a Non-DOT drug test. Student drivers who do not have a CLP or CDL are not subject to the DOT drug and alcohol testing requirements.
Some truck driving schools may coordinate the initial DOT pre-employment testing for the student driver. Some truck driving schools may require students to get the testing completed on their own. National Drug Screening can help the truck driving schools or the student drivers directly handle all of the DOT drug and alcohol testing requirements.
If the truck driving training program is affiliated with or operated by a motor carrier, the motor carrier will handle the drug testing program for the students, the driver registration in the Clearinghouse is required.
Random Consortium for Student Drivers
A truck driving school ensures that the student driver has complied with the requirements of part 382 prior to allowing the student driver to operate a CDL vehicle. See 49 CFR 382.103. Student drivers while operating commercial motor vehicles must be enrolled in a random testing consortium. A random testing consortium is a pool of drivers eligible for random drug and alcohol testing programs.
A truck driving school may be operating as a consortium/third-party administrator (C/TPA) and managing and coordinating the random testing consortium. If the truck driving school is not operating as a consortium/third-party administrator (C/TPA) and managing and coordinating the random testing consortium; the student driver must reach out to a C/TPA and enroll into a random testing consortium. National Drug Screening is available to assist student drivers directly with enrollment into a random testing consortium.
How do Student Drivers Comply with the Clearinghouse
As mentioned above, student drivers must comply with the requirements of the FMCSA Clearinghouse. Those basic requirements include:
- 1. Register in the Clearinghouse as a Student Driver, instructions to register
- 2. Discuss with a C/TPA services for Clearinghouse Query and a Random Consortium Drug & Alcohol Testing program
- a. C/TPA should conduct the initial Clearinghouse Query
- b. C/TPA should provide the required driver education requirements
- c. C/TPA should enroll the student driver into a Random Consortium Drug & Alcohol Testing program
- d. C/TPA and/or their Medical Review Officer (MRO) shall report any drug & alcohol testing violations to the Clearinghouse
For expert assistance with the FMCSA Clearinghouse, a private company FMCSA Clearinghouse Services can assist you – https://clearinghouseservices.com/driver-clearinghouse-services/
Truck Driving School Operating as a C/TPA
In regard to the above requirements and procedures, a truck driving school may operate as consortium/third-party administrator (C/TPA) to coordinate and manage what is needed for the student drivers. In this case, the trucking company would register with the FMCSA Clearinghouse and then manage all of the requirements for the student drivers. These requirements would include:
- 1. Pre-employment DOT drug test once the student driver has commercial learner’s permit (CLP) or CDL
- 2. Initial query to the Clearinghouse, annual query of current students enrolled
- 3. Management of random drug and alcohol testing consortium
National Drug Screening offers comprehensive assistance to truck driving schools for them to become a C/TPA. A back-office service can help the trucking school with specimen collection sites, laboratory testing, medical review officer and reporting of results. This Reseller Program offers ongoing consultation, guidance, training and back-office support.
