FAA Drug Test Panel: Five Substances, Cutoffs, and MRO Review

The FAA drug test panel is the standard DOT five-panel urine screen, checking for marijuana, cocaine, opioids, amphetamines, and phencyclidine (PCP). Every safety-sensitive aviation employee takes the same test, run under 49 CFR Part 40 and 14 CFR Part 120.¹ Within each of those five categories, the lab looks for a parent drug and specific metabolites or chemical relatives, not just one compound.

The Five Categories and What Each Covers

Each panel targets a family of substances, not a single molecule.²

Marijuana: THCA, the metabolite the body produces after any form of marijuana use.
Cocaine: benzoylecgonine, cocaine’s primary metabolite.
Opioids: codeine, morphine, and 6-acetylmorphine (a heroin metabolite), plus the semi-synthetic opioids hydrocodone, hydromorphone, oxycodone, and oxymorphone.
Amphetamines: amphetamine, methamphetamine, MDMA, and MDA.
PCP: tested at both the screening and confirmation stages.

The opioid panel is the one that catches people off guard. Before 2018, DOT testing covered only traditional opiates like codeine and morphine. Since the expansion, common prescription painkillers can produce a laboratory positive; whether that positive becomes a reported violation depends on the Medical Review Officer’s review.

Cutoff Concentrations

A drug is not simply “detected.” Each substance has an initial screening cutoff in nanograms per milliliter (ng/mL). Anything that meets or exceeds that threshold goes to a more precise confirmatory test, usually at a lower cutoff. Only results that clear both stages are reported as positive.³

Marijuana (THCA): 50 ng/mL initial, 15 ng/mL confirmatory
Cocaine (benzoylecgonine): 150 ng/mL initial, 100 ng/mL confirmatory
Codeine/morphine: 2,000 ng/mL initial, 2,000 ng/mL confirmatory
Hydrocodone/hydromorphone: 300 ng/mL initial, 100 ng/mL confirmatory
Oxycodone/oxymorphone: 100 ng/mL initial, 100 ng/mL confirmatory
6-Acetylmorphine (heroin): 10 ng/mL initial, 10 ng/mL confirmatory
Amphetamine/methamphetamine: 500 ng/mL initial, 250 ng/mL confirmatory
MDMA/MDA: 500 ng/mL initial, 250 ng/mL confirmatory
PCP: 25 ng/mL initial, 25 ng/mL confirmatory

One quirk in the amphetamine panel: a methamphetamine positive requires amphetamine to also be present at 100 ng/mL or above. Without that secondary finding, the lab will not report a standalone methamphetamine result.³

CBD and State Marijuana Laws

Marijuana stays on the panel no matter what your state allows. The DOT has said plainly that until federal rescheduling is actually complete, marijuana use is unacceptable for any safety-sensitive employee.⁴ A state medical marijuana card or recreational legalization offers no protection against a positive DOT result.

CBD is the quieter risk. The DOT tests for THC, not CBD, but CBD products are not federally regulated for THC content, and independent testing has repeatedly found products above the 0.3 percent THC threshold on the label. If a CBD product causes a THC positive, the Medical Review Officer will verify it as positive. The DOT has stated that CBD use is “not a legitimate medical explanation for a laboratory-confirmed marijuana positive result.”⁵

The Medical Review Officer Process

A positive lab result does not go straight onto your record. Every result first goes to a Medical Review Officer, a licensed physician who reviews the finding and contacts you before anything is reported to your employer.

In the interview, the MRO tells you what the lab found and asks whether you have a medical explanation. A valid prescription requires documentation: a copy of the prescription, the labeled medication container, or a medical record showing the drug was prescribed during the relevant window. The MRO may call your prescriber or pharmacist to verify. If the explanation holds up, the MRO reports the result as negative.⁶

A prescription is not an automatic pass. If the MRO finds long-term use of a medication with high abuse potential without clear medical justification, the MRO must contact the prescribing physician to discuss whether continued use creates a safety concern. State medical marijuana authorizations do not qualify as legitimate medical explanations under DOT rules.⁵

What Counts as a Refusal

A refusal carries the same consequences as a verified positive, and the definition reaches further than most people expect. Under DOT rules, all of the following are refusals:⁷

Failing to appear for any required test (other than pre-employment) within a reasonable time after being directed
Leaving the collection site before the testing process is complete
Failing to provide a specimen
Refusing to allow observation or monitoring during a directly observed collection
Failing to provide a sufficient specimen when no medical explanation exists
Declining an additional test the employer or collector directs you to take
Failing to undergo a medical examination the MRO requires as part of verification

One narrow exception: leaving the collection site before a pre-employment test begins does not count as a refusal. Every other item on the list triggers the full consequences of a positive.

Consequences of a Positive or a Violation

A verified positive drug test, a confirmed alcohol result of 0.04 or greater, or a refusal all trigger the same path: immediate removal from safety-sensitive duties and a mandatory referral to a Substance Abuse Professional (SAP). You cannot return to any safety-sensitive role until that process is complete.⁸

The SAP evaluates you and prescribes education or treatment. When the SAP determines the program is complete, you must pass a return-to-duty drug test with a verified negative (or an alcohol test below 0.02). After you return, you face a minimum of six unannounced follow-up tests in the first 12 months, and follow-up testing can extend up to five years at the SAP’s discretion.

Airman Certificate Holders

If you hold a pilot certificate or airman medical certificate, the process adds steps. The MRO is required to ask whether you hold or need an airman medical certificate. If you do, the MRO must notify the Federal Air Surgeon within two working days of verifying the positive.¹ Before the SAP can recommend you for return to duty, you will need a new airman medical certificate issued by the Federal Air Surgeon, dated after the violation. Employers must also notify the FAA’s Drug Abatement Division within two working days if a certificated employee refuses to submit to testing.⁹

Permanent Disqualification

A second verified positive results in permanent disqualification from the safety-sensitive duties you held. There is no third chance. The same permanent bar applies to anyone who uses a prohibited drug while actually performing a safety-sensitive function, even on a first offense.¹

Reporting to the Pilot Records Database

Drug and alcohol violations follow you between employers. Employers must report positive tests, refusals, and return-to-duty records to the FAA’s Pilot Records Database, and those records must be kept for at least five years after reporting.¹⁰

The reported records include verified positive drug tests, alcohol results of 0.02 or greater, refusals (including substituted or adulterated specimens), SAP referrals, return-to-duty test results, and every follow-up test result. Future employers checking the PRD will see that history.¹⁰

1
eCFR. 14 CFR Part 120 Subpart E – Drug Testing Program Requirements
2
US Department of Transportation. DOT 5 Panel Notice
3
eCFR. 49 CFR 40.85 – What Are the Cutoff Concentrations for Urine Drug Tests
4
US Department of Transportation. DOT Notice on Testing for Marijuana
5
US Department of Transportation. DOT CBD Notice
6
SAMHSA. Medical Review Officer Manual
7
eCFR. 49 CFR 40.191 – What Is a Refusal to Take a DOT Drug Test, and What Are the Consequences
8
Federal Aviation Administration. Alcohol and Flying
9
eCFR. 14 CFR 120.111 – Administrative and Other Matters
10
Federal Aviation Administration. What Drug and Alcohol Testing Records Am I Required to Keep and for How Long