What a compliant program contains
- A written policy given to every driver with a signed receipt.
- Enrollment in a consortium/third-party administrator (C/TPA) if you have fewer than a handful of drivers — this gives you a random pool to draw from.
- A Designated Employer Representative (DER) named in writing.
- A certified Medical Review Officer (MRO) reviewing results.
- Two hours of supervisor training: 60 minutes on drugs, 60 on alcohol, for anyone who supervises drivers.
- FMCSA Clearinghouse registration with the company and each driver.
The six test types
| Test | When |
|---|---|
| Pre-employment | Verified negative before any safety-sensitive function |
| Random | 50% of average driver count for drugs, 10% for alcohol, annually |
| Post-accident | Fatality, or citation plus injury requiring treatment away from scene, or citation plus tow-away |
| Reasonable suspicion | Trained supervisor observes specific, articulable signs |
| Return-to-duty | After SAP completion, directly observed |
| Follow-up | Minimum 6 unannounced tests in 12 months, SAP-directed |
Clearinghouse duties
Run a full query before hiring any CDL driver, and a limited query annually for each driver you employ. Report refusals, positives and actual knowledge within three business days. Since the 2024 rule, a 'prohibited' status in the Clearinghouse also downgrades the driver's state CDL privileges.
Owner-operators must be enrolled in a consortium — you cannot randomly select yourself.
Questions people ask
- How much does a consortium cost?
- Typically $150–$300 per driver per year for enrollment, plus $60–$100 per test performed.
- Do I need supervisor training if I am the only employee?
- If nobody supervises anyone, there is no supervisor to train — but auditors expect the training as soon as you hire a second driver. Most owners take it anyway.