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Applicability to part 382 student drivers and driver training schools
PostedMarch 31, 2025
UpdatedMay 22, 2025
Students without a CLP or CDL are not subject to DOT drug and alcohol testing rules.
→ If they test positive, the Return-to-Duty process does not apply.
If a student holds a CLP or CDL and is either:
- Employed by the school, or
- Operating a CMV in commerce provided by the school,
→ then DOT testing rules (Part 382) apply.
If the school isn’t the employer, the student is responsible for compliance, but the school can choose to verify it.
📄 Reference: 49 CFR § 382.103
📁 Document: FMCSA-D&A-382.103-FAQ004
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