Transportation Industry Compliance Guide
DOT, FMCSA, and state compliance requirements for carriers, logistics companies, and transportation employers.
Overview
Transportation is the most heavily regulated industry for occupational health compliance. FMCSA, FAA, FRA, FTA, and PHMSA each impose specific drug and alcohol testing, medical certification, and fitness-for-duty requirements for safety-sensitive employees. Unlike other industries, federal DOT requirements preempt state cannabis protections, meaning transportation employers must maintain zero-tolerance policies regardless of state law.
Key Compliance Areas
The federal DOT drug and alcohol testing program (49 CFR Part 40) is the backbone of transportation compliance. All safety-sensitive employees must undergo pre-employment, random, post-accident, reasonable suspicion, return-to-duty, and follow-up testing. CDL holders must maintain valid DOT medical certificates through the FMCSA National Registry. Hours-of-service regulations intersect with fatigue management and fitness-for-duty concerns. The Clearinghouse database requires employers to query driver records for drug and alcohol violations before hiring and annually thereafter. State-level regulations may add requirements for intrastate carriers, but cannot weaken federal standards.
Key Requirements
- 1Maintain DOT drug and alcohol testing program compliant with 49 CFR Part 40
- 2Ensure all CDL drivers hold current DOT medical certificates from National Registry examiners
- 3Query the FMCSA Clearinghouse before hiring and annually for all CDL holders
- 4Maintain random testing pool meeting DOT minimum rates (50% drug, 10% alcohol)
- 5Designate a qualified Designated Employer Representative (DER) for testing program management
- 6Implement return-to-duty and follow-up testing protocols for positive results
- 7Document reasonable suspicion training for all supervisors of safety-sensitive employees
Recent Updates for Transportation
Recent Regulatory Updates
Latest compliance changes affecting workplace health programs
FMCSA Revokes TRUCKSTAFF ELD — Carriers Must Replace by August 23, 2026 (49 CFR Part 395)
FMCSA removed TRUCKSTAFF ELD (model TRKSF, identifier TRS227) from its list of registered electronic logging devices for failing to meet the minimum requirements in 49 CFR Part 395, Appendix A to Subpart B. Motor carriers using the device must revert to paper logs or logging software immediately and install a compliant registered ELD before August 23, 2026, after which drivers still using the revoked device will be cited for operating without an ELD and placed out-of-service under CVSA criteria.
DOL Cancels 2026 Civil Penalty Inflation Adjustment — OSHA Maximum Penalties Stay at 2025 Levels (91 FR 31358)
For the first time since annual adjustments began under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, the Department of Labor will make no inflation adjustment to its civil monetary penalties for 2026 — OSHA maximum penalties remain at 2025 levels. The Bureau of Labor Statistics did not publish October 2025 CPI-U data because of the appropriations lapse, and the statute permits no alternative calculation, so OMB memorandum M-26-11 directed agencies to continue applying 2025 penalty amounts. The Department plans a thorough review of its civil penalties in 2027.
FMCSA Revokes 12 Electronic Logging Devices — Carriers Must Replace by July 20, 2026 (49 CFR Part 395)
FMCSA removed 12 devices from its list of registered electronic logging devices — including 888 ELD, DRAGON E, ACTION ELD, Mondo ELD HOS, FIRST ELD, MTL ELD, USPower ELD, Sam Freight ELD, DSGELOGS, COBRA ELD, and GT USA ELOGS — for failing to meet the minimum technical requirements in 49 CFR Part 395, Appendix A to Subpart B. Motor carriers using a revoked device must revert to paper logs or logging software now and install a compliant registered ELD before July 20, 2026, after which drivers will be cited for operating without an ELD and placed out-of-service under CVSA criteria. FMCSA has removed 79 non-compliant devices since January 2025.
FMCSA Launches Motus — New U.S. DOT Registration System With Biometric Identity Verification
FMCSA rolled out Motus, the U.S. DOT Registration System, replacing the legacy network of loosely connected registration applications for motor carriers, brokers, freight forwarders, and other regulated entities. Motus introduces mandatory identity verification using government-issued IDs and digital facial scans plus third-party business validation, targeting the "chameleon" and reincarnated carriers that exploited the old low-validation framework. Carriers need a Login.gov account to access Motus and must use the same account previously tied to their FMCSA Portal access to retain their registration data.
FMCSA Migrates Carrier Registration from FMCSA Portal to Motus — Mandatory Portal Verification by May 14, 2026
FMCSA is replacing the legacy registration system with Motus and requires every regulated entity (motor carriers, brokers, freight forwarders, IEPs, hazmat shippers) to log into the FMCSA Portal by May 14, 2026 and verify company information, operation classification, contact details, and authorized users before the cutover. Portal accounts are disabled after 90 days of inactivity and archived after 12 months. Only the FMCSA Portal Company Official using the same Login.gov email will be permitted to claim the new Motus account on first login.
FMCSA Revokes Registration of Safe ELD and MYLOGS ELD Devices (49 CFR Part 395, Appendix A to Subpart B)
FMCSA removed Safe ELD (iOS and Android, ELD identifier ELD42A) and MYLOGS ELD (model MYLGS2, identifier MRS202) from the list of registered electronic logging devices for failing to meet the minimum technical requirements in 49 CFR Part 395. Motor carriers using either device must replace it with a compliant ELD by July 7, 2026 and revert to paper logs or logging software in the interim. After July 7, drivers using the revoked devices will be considered operating without an ELD and placed out-of-service under CVSA criteria.
OSHA Orders Canadian Pacific Kansas City to Rescind 20-Day Suspension of Worker Who Reported Train Collision — Federal Railroad Safety Act Whistleblower Finding
The OSHA Whistleblower Protection Program found that Canadian Pacific Kansas City Ltd. wrongfully suspended a Kansas City-based employee for 20 days without pay after they reported an August 2024 minor train collision at Knoche Yard to the Federal Railroad Administration. OSHA ordered CPKC to rescind the suspension, pay back wages plus interest, expunge the disciplinary record, and pay compensatory and punitive damages. The case underscores OSHA enforcement of Federal Railroad Safety Act anti-retaliation provisions for rail workers who report safety concerns.
FMCSA Strengthens Identity Verification for Drug & Alcohol Clearinghouse Users
FMCSA announced new identity verification requirements for the Drug and Alcohol Clearinghouse online database, which serves over 6 million users tracking commercial drivers prohibited from driving due to drug and alcohol violations. Medical Review Officers, Substance Abuse Professionals, third-party administrators, and employers must complete additional ID verification steps via IDEMIA. Future phases will extend requirements to most other Clearinghouse users; CDL holders are already verified through state systems.
OSHA Local Emphasis Program for Maritime Industries — Puerto Rico and US Virgin Islands (NYC-CPL-04-00-002)
OSHA Region 2 issued a Local Emphasis Program directing increased inspections and outreach for maritime industries in Puerto Rico and the U.S. Virgin Islands following heightened workplace safety concerns. The LEP targets shipyard, marine terminal, and longshoring employers, and complements existing federal maritime standards (29 CFR Parts 1915, 1917, and 1918). Employers in covered industries should expect programmed inspections.
OSHA Updates National Emphasis Program on Indoor and Outdoor Heat-Related Hazards (CPL 03-00-024)
OSHA revised its National Emphasis Program targeting heat-related workplace hazards, using 2022–2025 injury data to prioritize inspections across 55 high-risk industries. The update introduces reorganized appendices for evaluating heat programs and citation guidance, removes outdated numerical inspection goals, and directs compliance officers to conduct random inspections in high-risk industries on days when the National Weather Service issues heat advisories or warnings. Effective immediately for five years.
State-by-State CDL Hiring
Review CDL hiring requirements across all states, including DOT testing and medical certification guidance for transportation employers.
Open CDL Hiring GuideFrequently Asked Questions
Common compliance questions for transportation employers
Transportation Compliance by State
See transportation occupational health requirements — priority regulations, required exams, and forms — with a step-by-step workflow for each state.
Transportation Compliance Made Simple
BlueHive connects transportation employers to qualified occupational health providers who understand your regulatory requirements.