The DOT 5-Panel Drug Test: Substances and Cutoffs
The five drug classes on every DOT urine test, the analytes inside each one, and the federal cutoff concentrations that decide a positive.
- Five classes, fixed by 49 CFR Part 40
- Initial and confirmatory cutoffs from 49 CFR 40.85
- MRO review decides what reaches the employer
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The DOT Panel Is Five Classes, Fixed by Federal Rule
Every DOT urine test screens the same five drug classes. The panel is set in 49 CFR Part 40, not by your employer, your consortium, or your laboratory. You cannot add a substance because your insurer asked for it, and you cannot drop one because a driver objects. A six-, ten-, or twelve-panel is a separate non-DOT test, on a separate form, under your own policy.
- Marijuana — screened and confirmed on the THC metabolite (THCA), not the parent drug
- Cocaine — screened and confirmed on benzoylecgonine, the cocaine metabolite
- Opioids — codeine, morphine and 6-acetylmorphine, plus hydrocodone, hydromorphone, oxycodone and oxymorphone
- Amphetamines — amphetamine and methamphetamine, plus MDMA and MDA
- Phencyclidine (PCP)
Before 1 January 2018 the opioid class covered only codeine, morphine and 6-acetylmorphine. Four semi-synthetic opioids were added on that date: hydrocodone, hydromorphone, oxycodone and oxymorphone. A driver taking one of them used to produce a negative because the panel never looked for it. Now the laboratory looks, the Medical Review Officer verifies whether there is a valid prescription, and a verified prescription is reported as a negative result.
Cutoff Concentrations, Straight From 49 CFR 40.85
A test is not positive because a substance is present. It is positive because the concentration reaches the initial cutoff on the screen and then the confirmatory cutoff on the second, more specific test. Both numbers are federal and are listed in 49 CFR 40.85. Concentrations are in nanograms per millilitre.
| Initial test analyte | Initial cutoff | Confirmatory analyte | Confirmatory cutoff |
|---|---|---|---|
| Marijuana metabolites (THCA) | 50 | THCA | 15 |
| Cocaine metabolite (benzoylecgonine) | 150 | Benzoylecgonine | 100 |
| Codeine / morphine | 2000 | Codeine, morphine | 2000 each |
| Hydrocodone / hydromorphone | 300 | Hydrocodone, hydromorphone | 100 each |
| Oxycodone / oxymorphone | 100 | Oxycodone, oxymorphone | 100 each |
| 6-Acetylmorphine | 10 | 6-Acetylmorphine | 10 |
| Phencyclidine | 25 | Phencyclidine | 25 |
| Amphetamine / methamphetamine | 500 | Amphetamine, methamphetamine | 250 each |
| MDMA / MDA | 500 | MDMA, MDA | 250 each |
Where two analytes share one initial cutoff, 49 CFR 40.85 requires the immunoassay to be calibrated on one target analyte with at least 80 percent cross-reactivity to the other, or separate immunoassays must be run.
Validity Testing Is a Separate Check, Under 49 CFR 40.86 and 40.87
Alongside the drug panel, the laboratory checks whether the specimen is consistent with normal human urine. 49 CFR 40.86 requires validity testing; 49 CFR 40.87 sets what the laboratory must measure: creatinine on every specimen, specific gravity when creatinine falls below 20 mg/dL, pH, and at least one test for oxidising adulterants. This is the mechanism that catches dilution, substitution and adulteration — it is not part of the five-class panel, and citing 40.87 for cutoff levels is a common mistake.
What the Medical Review Officer Does With a Positive
A laboratory positive is not a failed test yet. The result goes to a Medical Review Officer, who contacts the driver and asks whether there is a legitimate medical explanation. A valid prescription for a substance on the panel is verified and the result is reported to you as a negative. The MRO may still report a safety concern to the employer where the medication could affect safe operation. The employer never receives the clinical detail behind that judgement.
Urine Is Not the Only Permitted Specimen
The five classes and the cutoffs above apply to urine. DOT added oral fluid as a permitted specimen type in a 2023 final rule, with its own cutoff table and its own collection procedure. The drug classes do not change with the specimen. What changes is the collection, the detection window, and which HHS-certified laboratories can run it.
DOT Panel Versus a Non-DOT Panel
Panel, cutoffs, chain of custody, laboratory certification and MRO review are all set by 49 CFR Part 40. Results that matter for Part 382 reporting flow to the Clearinghouse. Nothing about it is negotiable.
Any panel you choose, any specimen type, any trigger your policy sets. No Clearinghouse reporting. Nothing here satisfies a Part 382 obligation, and a Part 382 test cannot be repurposed to satisfy your own policy.
Common Questions About the DOT Panel
What drugs are tested for in a DOT drug screen?
Five classes fixed by 49 CFR Part 40: marijuana, cocaine, opioids, amphetamines and phencyclidine. The opioid class covers codeine, morphine and 6-acetylmorphine, plus hydrocodone, hydromorphone, oxycodone and oxymorphone, which were added effective 1 January 2018. The amphetamine class covers amphetamine, methamphetamine, MDMA and MDA.
Where are the DOT cutoff levels published?
In the table at 49 CFR 40.85, which gives both the initial screening cutoff and the confirmatory cutoff for every analyte. 49 CFR 40.87 is a different section covering laboratory validity testing, and is often cited for cutoffs by mistake.
Can an employer add a drug to the DOT panel?
No. The panel is fixed in 49 CFR Part 40 and an employer cannot add or remove a substance. Testing beyond the five classes is a non-DOT test under your own policy, run on a separate form, and it cannot be reported to the Clearinghouse.
Is a prescription a defence to a positive result?
A valid prescription verified by the Medical Review Officer results in a negative report to the employer. The MRO may separately raise a safety concern where the medication could affect safe operation of a commercial vehicle, without disclosing the clinical detail.
Does the panel change for an oral fluid test?
No. The same five classes apply. Oral fluid has its own cutoff table, its own collection procedure and a different detection window, but it does not change which drug classes are screened.
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