The U.S. Department of Transportation published a Notice of Proposed Rulemaking (NPRM) on September 2, 2025 (Federal Register Document 2025-16720) proposing to add fentanyl and its metabolite norfentanyl to the mandatory DOT drug testing panel under 49 CFR Part 40.
This follows the Department of Health and Human Services (HHS) updating its Mandatory Guidelines for Federal Workplace Drug Testing Programs in January 2025 to authorize fentanyl testing for federal workplace programs. DOT is required to align its Part 40 procedures with HHS guidelines.
Current status: This is a proposed rule only — fentanyl is NOT currently on the DOT drug testing panel. The public comment period closed October 17, 2025. As of this writing, no final rule has been published. DOT-regulated employers are not yet required to test for fentanyl.
Why this matters now: Fentanyl is now involved in the majority of U.S. overdose deaths. Supervisors should be aware that behavioral signs of fentanyl impairment — extreme sedation, pinpoint pupils, very slowed breathing — can appear in safety-sensitive employees even before it is on the testing panel. The reasonable suspicion process applies to all controlled substances, not just those on the DOT panel.
What employers should do: No action required at this time. MedTrac will notify all enrolled clients when a final rule is published and will update program documentation accordingly. Monitor transportation.gov/odapc for updates.
Federal Register Doc. 2025-16720: NPRM — Addition of Fentanyl to DOT Testing Panel
MedTrac monitors every DOT agency and the Federal Register continuously. When regulations change, we notify all enrolled clients immediately and update program documentation as needed. Our goal is to ensure you are never caught off-guard by a regulatory change.
Questions about how this update affects your compliance program? Contact MedTrac at +1 (203) 776-7771 or salesteam@medtracinc.com.
