FRA Random Drug
Testing Compliance

Three categories, three sets of rates

FRA’s January 2026 notice kept the covered-service and maintenance-of-way drug rates at 25 percent and the mechanical drug rate at 50 percent. The change came on alcohol: the mechanical rate dropped from 25 percent to 10 percent, matching the other two categories.

Alcohol violation rates for all three categories were below 0.5 percent in both 2023 and 2024. The rates are minimums, and railroads and contractors may test at higher rates.

Why mechanical employees are on a different track

Mechanical employees became subject to FRA random testing in 2022. Under § 219.625, a newly added category starts at 50 percent for drug testing and 25 percent for alcohol, gets its own rates for at least three calendar years, and is revised after at least two years of MIS data. That’s why mechanical employees are still carrying a 50 percent drug rate while the longer-established categories sit at 25 percent.

How the rate moves

The FRA Administrator publishes a notice each year, with new rates effective January 1, based on MIS data from the two preceding calendar years. The drug rate is either 50 or 25 percent: it falls to 25 after two straight years with a positive rate under 1.0 percent, and returns to 50 if any year reaches 1.0 percent. The alcohol rate can be 50, 25 or 10 percent, with thresholds at 0.5 and 1.0 percent.

Who has to be in a pool

Subpart G uses the term “regulated employee.” Section 219.601 requires each railroad to make sure its regulated employees can be selected for random testing whenever they perform regulated service on the railroad’s behalf. The three categories in the rate table are covered service, which includes hours-of-service employees such as engineers, conductors and dispatchers, maintenance-of-way employees, and mechanical employees; Part 219’s own definitions control who falls in each, so check them for borderline job titles.

Contractor employees and volunteers can be placed in a railroad’s random testing program too. Under § 219.601, a contractor employee or volunteer may be included in more than one railroad’s program if the person isn’t already in a compliant program the railroad accepts under § 219.609, or if the railroad can’t verify that the person belongs to one.

An employee who falls under more than one DOT agency has to be selectable at or above the minimum rate of the agency that regulates more than 50 percent of the employee’s DOT-regulated functions. A railroad also may not place the same employee in more than one DOT random testing pool for its regulated service.

The pool rules in § 219.611

FRA is more prescriptive about the mechanics of a pool than the other DOT agencies. The rules in § 219.611 include these:

• Pool entries can be employee names or ID numbers, train symbols, or job assignments, but every entry in one pool has to be of generally consistent size and type.
• Field managers and supervisors can’t choose which employee is tested when an entry comes up.
• Each regulated employee must have an equal chance of selection on every draw.
• A pool must have at least four entries, and placeholder entries are prohibited. A railroad with fewer than four regulated employees can join a larger railroad or non-railroad pool.
• Employees must be added to a pool as soon as possible after hire or first transfer into regulated service.
• Pools must be updated at least monthly and kept free of outdated or inappropriate entries.
• Separate pools aren’t required for random drug and random alcohol selection.
• Employees who aren’t subject to FRA or other DOT random testing can’t share a pool with regulated employees.
• A regulated employee can share a pool with employees under another DOT agency only if every member of the pool is tested at the highest minimum rate that applies to any of them.

There’s also a de minimis rule. Employees who perform regulated service less than once a quarter on average don’t have to be randomly tested. If the railroad chooses to test them anyway, they have to be in a pool separate from regular performers. A railroad may keep more than one pool if it can show that the number and types of pools, or the way entries are built, don’t weaken the program.

Plans, contractors and service agents

Subpart G treats a random testing program as a plan, not just a practice. It includes sections on submitting and approving random testing plans (§ 219.605), the required content of those plans (§ 219.607), including contractor employees and volunteers (§ 219.609), and use of service agents (§ 219.621). Read those sections in full before you write or revise a plan; this page doesn’t substitute for them.

When a contractor or service agent performs random testing, it has to provide the testing records whenever the contracting railroad or FRA asks. The railroad still has to be able to show it complied with the subpart.

Records

Section 219.623 requires a railroad to keep random testing records for at least two years, as provided by § 219.901. The practical record for each draw is the same as anywhere else: the pool as it stood on the draw date, how the draw was made, who was selected, and when each person was notified and tested. Because pools have to be refreshed monthly, a dated copy of each month’s pool is the easiest way to prove the pool was current.

Where programs go wrong

• A pool falls below four entries, or someone adds placeholder entries to reach the minimum.
• Pool entries are mixed: some are named employees, some are train symbols, and the sizes don’t match.
• The pool is refreshed quarterly or after a hiring surge instead of monthly.
• A supervisor picks which person is tested when a job-assignment entry comes up.
• Mechanical employees are tested at the covered-service rate.
• The mechanical alcohol rate is still read from last year’s paperwork as 25 percent.
• Contractor employees are assumed to be somebody else’s responsibility, without verifying that they’re in an accepted compliant program.

Railroads that run other regulated work

Shortline and industrial railroads sometimes have CDL drivers or pipeline-adjacent operations that touch other agencies. The employee-by-employee rule and the single-pool rule above settle most of it, and the comparison page lays out each agency’s 2026 rates side by side. Passenger operators that contract with transit agencies should also see the FTA rules.