Updated: December 21, 2025
At PROCOM, we regularly speak with employers who have questions about the purpose, value, and execution of random drug and alcohol testing programs. These conversations often come down to one core concern: how to maintain a safer workplace while meeting regulatory and compliance expectations.
At its core, random drug and alcohol testing is about safety. Effective programs help reduce risk, support responsible operations, and protect both employees and employers. While liability should not be the sole driver of business decisions, audits and investigations often focus on whether safety programs were implemented and managed correctly.
This page explains how random drug and alcohol testing works in practice, what compliance requires beyond enrollment, and where employers commonly encounter issues.
Who Random Drug and Alcohol Testing Applies To
Random drug and alcohol testing applies to employers regulated under DOT agencies such as FMCSA, FAA, FTA, FRA, and PHMSA, as well as many non-DOT employers who maintain safety-sensitive policies.
These requirements fall under federal DOT drug and alcohol testing regulations, which define employer responsibilities across regulated programs.
This guidance is written for business owners, compliance managers, safety managers, and HR teams responsible for maintaining testing programs and responding to audits or reviews.
Random Testing Is Not the Same as Enrollment
One of the most common misconceptions is that enrolling in a consortium or testing program automatically manages random testing.
Enrollment provides access to a compliant testing pool. Execution is what determines compliance.
Execution includes how selections are generated, how employees are notified, how tests are completed, and how records are maintained. This distinction becomes critical during audits, when employers are asked to prove not just that testing occurred, but that it occurred correctly.
This confusion often occurs when employers are enrolled in a DOT consortium but do not have clear processes in place for how random drug and alcohol testing is managed day to day.
How Random Drug and Alcohol Testing Works in Practice
A compliant random testing program includes several operational components that must function together.
Random testing programs must also meet minimum annual testing percentages, which are published each year in the DOT-published annual random testing rates.
Employee Pool Management
Covered employees must be correctly added to and removed from the testing pool as roles change. Incorrect rosters are one of the most common compliance issues identified during audits.
Random Selection Process
Selections must be generated using a scientifically valid method. The timing of selections must be unpredictable, and records must show when and how each selection occurred.
Employee Notification
Once an employee is selected, they must be notified promptly and discreetly. Documentation of notification timing is critical, especially during audit reviews.
Test Completion and Results
Testing must be completed within required timeframes. Results, refusals, and follow-up actions must all be documented and retained according to regulatory requirements.
Recordkeeping
Random testing generates significant documentation. Selection reports, notifications, results, and follow-up records must be organized and accessible if requested by a regulator.
Why Random Testing Programs Fail Audits
Most audit failures are not caused by missed tests. They are caused by documentation gaps or inconsistent execution.
Common issues include:
- Employees performing safety-sensitive work who were not in the pool
- Missing or incomplete selection records
- Lack of proof showing when employees were notified
- Inconsistent testing timelines
- Poor record retention practices
- Missing or outdated DOT drug and alcohol supervisor training records
During an audit, regulators rely on records. If documentation cannot be produced, the testing is treated as non-compliant.
Documentation expectations and retention requirements are outlined under DOT Part 40 drug and alcohol testing procedures, which auditors use as a baseline during reviews.
How Random Testing Ties to DOT Audits
Random drug and alcohol testing is one of the first areas reviewed during a DOT audit. Auditors typically request multiple quarters of records to confirm consistency over time.
Employers who want a deeper understanding of audit expectations can review our guide on DOT audit readiness, which outlines what auditors review and how documentation is evaluated.
How PROCOM Supports Random Testing Programs
PROCOM supports employers by managing the operational side of random drug and alcohol testing programs. This includes helping employers maintain accurate rosters, structured selection records, and organized documentation that aligns with regulatory expectations.
Support commonly includes:
- Managing random selections
- Coordinating notifications and collections
- Tracking results and follow-up testing
- Maintaining audit-ready records
- Supporting MIS reporting when required
The goal is to reduce risk and help employers maintain consistent compliance year-round. This support is part of PROCOM’s broader drug testing and compliance services for regulated employers.
Colorado Example
A Colorado employer enrolled in a random testing program believed their obligations were limited to sending employees for testing when notified. During a compliance review, they were asked to provide prior selection records and notification documentation. While tests had been completed, supporting records were incomplete.
After implementing a structured random testing process with centralized documentation, the employer was able to demonstrate compliance clearly during future reviews.
This scenario is common and highlights why execution matters as much as enrollment.
Frequently Asked Questions About Random Drug and Alcohol Testing
Testing frequency depends on the regulating agency and published annual testing rates. Selections are typically conducted quarterly to ensure coverage throughout the year.
All employees performing covered safety-sensitive functions must be included. Employees must be added or removed promptly as job duties change.
No. Random testing must be unannounced and unpredictable to meet compliance requirements.
Retention periods vary depending on the type of record. Employers are expected to retain documentation long enough to satisfy audit requests covering prior years.
Missed tests must be addressed immediately. Documentation is critical, as untested selections are often flagged during audits.
Strengthen Your Random Drug and Alcohol Testing Program
A compliant random drug and alcohol testing program requires more than enrollment. It requires consistent execution, accurate documentation, and ongoing oversight.
PROCOM works with employers across Colorado to support random testing programs that stand up to audits and reviews. For in-person assistance, our teams in Glenwood Springs, Grand Junction, and Pueblo are available. You can also contact PROCOM’s team to discuss program support and compliance needs.
