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No, this is not permissible. If you conduct testing in all post-accident circumstances as a matter of company policy, it must be done using a non-DOT drug and alcohol testing forms and represented as non-DOT tests to the driver. The drug test results must be linked to a separate non-DOT lab account for reporting purposes.
The results of these non-DOT tests hold no DOT consequences. In addition, if circumstances change and a DOT post-accident testing is required, these non-DOT tests cannot be substituted to satisfy the DOT requirements. The driver must be sent again for another round of tests.
The collector must also be aware that they are not regulated tests so the appropriate forms are used. Many hear “driver” and assume in error they are automatically DOT-regulated tests.