In 2019, a major legal ruling reshaped how truck driving schools handle DOT drug testing. Watson Enterprises of the Carolinas, LLC, filed a lawsuit challenging whether schools could require DOT pre-employment tests for student drivers. After nearly 20 years, the court ruled that driving schools are not considered employers under DOT regulations and therefore cannot order pre-employment drug tests for students.
According to the Federal Motor Carrier Safety Administration (FMCSA), a driving school can conduct a DOT drug test only under very specific conditions:
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The student is a paid employee of the school involved in commercial transportation, or
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The school leases a Commercial Motor Vehicle (CMV) to the student for commercial purposes such as moving goods or passengers for hire.
In most cases, these conditions don’t apply—meaning schools cannot require DOT drug tests for students before training.
What This Means for Maryland CDL Students
Instead, student drivers must manage their own compliance. This process involves:
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Enrolling with a Consortium/Third-Party Administrator (C/TPA).
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Purchasing a Query Plan and sending it to the C/TPA.
Once the C/TPA verifies that the student has no active violations in their Clearinghouse record, they can order a pre-employment test that meets DOT requirements.
For students or drivers who test positive or have an open violation, our team at Columbia Treatment Center, provides Substance Abuse Professional (SAP) evaluations and Return-to-Duty programs to help them meet all federal compliance standards and safely return to driving.
Our certified SAPs ensure that every evaluation, education course, and follow-up testing plan meets DOT and FMCSA regulations — keeping Maryland drivers and employers compliant.
