Comment from Assurance Screening and Solutions LLC

I am submitting this comment in response to Docket No. FMCSA-2026-0562 regarding the proposed information collection on techniques for preventing and enforcing controlled substance and alcohol violations among non-CDL commercial motor vehicle (CMV) drivers. In my professional experience working closely with commercial motor vehicle operations and compliance, I regularly interact with drivers operating vehicles over 10,000 pounds that do not require a CDL. Based on this experience, I strongly believe that non-CDL CMV drivers should be subject to drug and alcohol testing requirements that are similar, if not identical, to those imposed on CDL drivers. These non-CDL drivers operate vehicles that present significant safety risks due to their size and operational demands. From a public safety standpoint, there is little distinction between a CDL and non-CDL CMV when considering the potential consequences of impaired driving. These vehicles share the same roadways and pose similar risks to the motoring public, including families and communities. Additionally, non-CDL CMV operators are already required to comply with many other FMCSA safety regulations. The absence of a standardized drug and alcohol testing requirement creates a regulatory gap that undermines the overall effectiveness of the safety framework. This inconsistency can lead to uneven enforcement, reduced accountability, and increased risk exposure. From an enforcement and compliance perspective, aligning drug and alcohol testing requirements across CDL and non-CDL CMV drivers would: Improve consistency in regulatory enforcement across jurisdictions Reduce ambiguity for carriers and compliance professionals Enhance roadway safety by addressing a known risk factor Support proactive prevention rather than reactive enforcement I encourage FMCSA to consider expanding drug and alcohol testing requirements to include non-CDL CMV drivers or, at a minimum, to develop a standardized and enforceable framework that addresses this gap. Closing this regulatory loop would strengthen safety outcomes and better reflect the realities of modern commercial motor vehicle operations. Thank you for the opportunity to provide input on this important matter. Respectfully, Traci Mangual