No Certified Labs Yet for Oral-Fluid Testing: What Employers Must Know

The U.S. Department of Transportation (DOT) introduced a final rule allowing oral-fluid (saliva) testing under 49 CFR Part 40, as explained in DOT Oral Fluid Testing: What Employers Need to Know in 2025. But as of now, there are still no laboratories certified by the Department of Health & Human Services (HHS) to handle oral-fluid specimens for DOT-regulated programs (transportation.gov).

This delay affects every employer managing safety-sensitive positions under DOT regulations. Here’s what’s happening, why it matters, and how QuickScreen can help you stay compliant until certification is complete.

Why the Certification Delay Matters

Oral-Fluid Testing: Approved but Not Yet Active

In May 2023, DOT’s final rule authorized oral-fluid testing as an alternative to urine under Part 40 (federalregister.gov). However, implementation depends on at least two HHS-certified laboratories being active, one for primary and one for split specimens. Until that requirement is met, employers cannot use oral-fluid testing for DOT purposes.

Where Things Stand Now

According to the DOT’s current listing, “there are no HHS-certified oral-fluid drug-testing laboratories.” (transportation.gov) This means urine remains the only approved testing method for compliance. Analysts from Working Partners note that certification delays have slowed the industry’s ability to roll out oral-fluid testing at scale.

Why Employers Should Pay Attention

Compliance risk: Policies that already include oral-fluid language may now conflict with current DOT guidance.
Training clarity: Collectors need updated instruction on what to do when oral-fluid collection isn’t authorized.
Safety oversight: Safety-sensitive employers must ensure accurate, compliant testing under existing standards.

What Employers Should Do Right Now

1. Continue Using Urine Testing as Standard

Until HHS labs are certified, urine remains the only compliant option for DOT testing. Review your policy to confirm that this method is listed as your default procedure.

2. Update Policy Language

Include a note such as: “Oral-fluid testing will be implemented once HHS-certified labs are operational; until then, urine testing remains in effect.”
For proper refusal documentation, see What Happens When an Employee Refuses a Drug Test.

3. Train Supervisors and Collectors

Ensure your team understands that oral-fluid testing, although approved, is not yet valid under DOT rules. Training should reinforce current urine collection standards, observation procedures, and accurate documentation practices.

4. Plan for Transition Ahead of Time

When HHS certifies two labs, the rule will activate quickly. Stay connected with QuickScreen for regulatory alerts, policy templates, and readiness checklists.

How QuickScreen Helps Employers Stay Ready

QuickScreen simplifies compliance by:

Reviewing your existing policies for oral-fluid language conflicts
Updating policy templates for both current urine testing and upcoming oral-fluid use
Providing training for collectors and Designated Employer Representatives (DERs)
Monitoring HHS certification progress and notifying clients as soon as labs are approved
Offering audit-ready documentation for DOT inspections

Oral-Fluid Testing Is Coming, But It’s Not Here Yet

Without certified laboratories, DOT-regulated employers must continue using urine testing until further notice. Updating your policy and training now prevents confusion, audit findings, and compliance risks later.

Contact QuickScreen To review your testing program and prepare for seamless adoption when oral-fluid testing becomes fully operational.