The Office of the Secretary of Transportation (OST), U.S. Department of Transportation has proposed adding fentanyl testing to the DOT drug testing panels for both urine and oral fluid testing. This would also include norfentanyl (a metabolite of fentanyl), which would be added to the urine testing only.
Fentanyl is a synthetic opioid that the Food and Drug Administration (FDA) approved as an analgesic (pain reliever) and anesthetic. According to the FDA, fentanyl is 100 times more potent than morphine and 50 times more potent than heroin as a pain reliever. Over 150 people a day die from synthetic opioids such as fentanyl; even an amount as small as two milligrams can be deadly.
The Centers for Disease Control (CDC) reported that drug overdoses increased 520% from 1999 to 2023. The CDC also reported that in 2023 around 105,000 people died from a drug overdose and that opioids were involved in about 76% of those overdoses.
The new testing requirements for both urine and oral fluid testing will have a one mg/mL cutoff for both fentanyl and norfentanyl. The lab reporting requirements for these substances would also be updated.
While the proposal may pass, it remains to be seen if/when the new regulations would be implemented. After all, hair follicle testing was mandated in 2012, but has yet to be implemented.
Oral fluid testing was authorized by the Department of Transportation (DOT) in May of 2023, but the DOT did not make sure adequate laboratory infrastructure was in place before they approved the method. There is a requirement for a minimum of two certified labs before the oral method can be used. Because no labs have yet been certified by the Department of Health and Human Services (HHS), the oral fluid option cannot be used even though it was approved.
Just as the previously approved methods have struggled with implementation, fentanyl testing will also have to overcome challenges. The capacity to test for fentanyl and norfentanyl must be developed by every HHS certified laboratory.
Medical Review Officers (MRO’s) will require training in the new procedures and protocols, and updates to laboratory information systems and processes for chain of custody and reporting are needed.
The testing for fentanyl and norfentanyl will add to the cost of drug testing.
The Office of the Secretary of Transportation (OST), U.S. Department of Transportation is accepting comments on the proposal until October 17, 2025. There are several options for submitting comments; however, only one of the options is to be used for submittal. You can find the options and more information on the proposal here.
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Sources: freightwaves.com, federalregister.gov, dea.gov, cdc.gov