On September 2, 2025, the Department of Transportation (DOT) announced plans to expand its mandatory drug testing panel by adding fentanyl (a synthetic opioid) and its metabolite, norfentanyl (the inactive byproduct created when the body breaks down fentanyl), to the panel.
If finalized, this would mark the first entirely new drug class added to the DOT testing panel in years. Currently, the panel tests for marijuana, cocaine, opiates (including expanded opiates added earlier), amphetamines, and PCP.
The proposal affects employers managing employees whose impairment could affect their safety and the safety of those around them (safety-sensitive positions), as well as those covered by a DOT operating administration, such as:
- FMCSA (trucking and motor carriers)
- FAA (aviation)
- FRA (railroads)
- FTA (mass transit)
- PHMSA (pipelines)
- USCG (maritime)
Fentanyl would be added to both urine and oral fluid testing; however, Norfentanyl would be added to the urine panel only. Oral fluid testing would remain unavailable until the Department of Health and Human Services certifies at least two labs to conduct it.
A final rule is expected in 2026. The rule would align DOT testing with the HHS Mandatory Guidelines for Federal Workplace Drug Testing. According to the CDC, roughly 70 percent of U.S. overdose deaths in 2023 involved illegally manufactured fentanyls, including a resurgence of carfentanil.
Other proposed changes include:
- Shifting the laboratory confirmatory cutoff for morphine in urine from 2,000 ng/mL to 4,000 ng/mL.
- MROs will no longer need to verify clinical evidence of illegal opioid use to confirm a positive codeine or morphine result.
- Revising the panel footnotes to reflect the current criteria for alternate technology in initial testing.
- Revising the definitions of key terms, including "biomarker," "adulterated specimen," "cutoff," and "negative result," to align with current HHS guidelines.
For those overwhelmed by the constant changes in the law or those evaluating the impact this would have:
- KRESS’s Drug Testing services are here to help guide you and ease the pressure of managing each applicant or requirement set.
- KRESS oil and gas screening and construction background checks are designed around the layered requirements specific to these industries. The packages are also customizable, ensuring you can meet all your needs.
- Our state-by-state compliance guide provides you with a summary of laws, recent changes, and information to help you stay up to date with laws and regulations
Frequently Asked Questions
When does the DOT fentanyl drug testing rule take effect?
No date has been confirmed; however, a final ruling is expected in 2026.
Is fentanyl already on the DOT drug testing panel?
No. As of April 2026, fentanyl and norfentanyl are proposed additions only. Some labs already test for fentanyl voluntarily or as part of other programs.
Do oil and gas companies have to follow DOT drug testing rules?
Only companies covered by a DOT operating administration and that manage employees in safety-sensitive positions (positions where an employee's impairment could affect their safety and the safety of those around them).
What is norfentanyl, and why is it being tested?
Norfentanyl is the inactive byproduct created in the liver when the body breaks down fentanyl. It can be detected longer than fentanyl and confirms active use.
Will the DOT fentanyl rule increase positive drug tests?
It may increase positive drug tests. Fentanyl is a synthetic opioid officially used to treat severe pain. Even in small amounts, it is more potent than many other opioids. It is also addictive, which has led to its widespread use in the illicit drug supply market.