A student in a Truck Driving School with a Commercial Driver’s License (CDL) or Commercial Learner’s Permit (CLP) is required to have a drug test and initial query in the FMCSA Clearinghouse. In addition, the student driver must be enrolled in a random testing consortium.
In this article we will cover:
Student Drivers and the FMCSA Clearinghouse
For the FMCSA Clearinghouse the student driver must register using the current commercial driver’s license (CDL) or commercial learner’s permit (CLP) information. This is required to view your Clearinghouse record and respond to query requests.
For students in a driver school not affiliated or operated by a motor carrier (employer), the student driver must designate their consortium/third-party administration (C/TPA). Do not designate a C/TPA in the Clearinghouse without first reaching out to them. Your driving school may or not be the consortium/third-party administration (C/TPA).
Bottom line the student driver must comply with FMCSA drug & alcohol testing regulations. This can be done with a consortium/third-party administration (C/TPA) or with the truck driving school this is registered as a consortium/third-party administration (C/TPA).
Check out our compliant services for DOT Drug & Alcohol Testing program for student drivers
Truck Driving Schools and the FMCSA Clearinghouse
Traditionally truck driving schools have required DOT drug and alcohol testing of students. These schools have also required random drug and alcohol testing programs. A new ruling has emphasized that there is not employer – employee relationship in a driving school program where the driver school is not affiliated or operated by a motor carrier (employer).
Student drivers should not be tested in the same employer drug testing account as the truck driving school instructors.
With this new ruling, the students are required to have a drug test and initial query in the FMCSA Clearinghouse. In addition, the student driver must be enrolled in a random testing consortium. This can be accomplished by the student in one of two ways:
- 1. The driving school has registered in the Clearinghouse and provides services as a consortium/third-party administration (C/TPA)
- 2. The student contracts directly with at consortium/third-party administration (C/TPA)
National Drug Screening, Inc is available to assist student drivers with their responsibilities to get an initial drug test and initial query in the FMCSA Clearinghouse along with getting enrolled into random testing consortium.
National Drug Screening is also available to assist truck driving schools to operate as a consortium/third-party administration (C/TPA) including registration in the FMCSA Clearinghouse. The truck driving school operating as a TPA will need two programs; one for their own employees (instructors) and one for the students.
Summary information on truck driving schools and students from FMCSA Clearinghouse
- Student drivers:
- Are not employees of a driving school unless hired by the school or lease a CMV from the school
- Student drivers in training programs that are not affiliated with or operated by motor carriers must Register as a Student Driver
- Designate a C/TPA for testing and reporting
- Student drivers are subject to 49 CFR Part 382 and need to have a written Substance Abuse Policy and Educational Materials on DOT Drug and Alcohol Testing as outlined in Part 382.601.
- Students are required to meet the drug and alcohol testing requirements for pre-employment and random and enroll in a random testing pool
- Before student drivers may operate CMVs on public roads with their CLPs, Clearinghouse pre-employment queries must be conducted:
- As the student driver’s designated C/TPA, the truck driving school may conduct the “pre-employment” query on behalf of the student driver.
- CDL training schools
- May serve as a C/TPA for the students, must register as the C/TPA
- Register as employer for their instructors
- Are the employer for the training school’s instructors and required to conduct pre-employment and annual queries on their instructors
- CDL training schools do NOT conduct Clearinghouse pre-employment queries on student drivers because the students are considered their own employers.
- Instructors:
- Register as drivers
CDL driving schools can request assistance from National Drug Screening to operate as a consortium/ third-party administrator (C/TPA) and or set up an in-house program for your own employees(instructors) – call 321 622 2020 or contact us.
