“Granting this Petition will certainly advance the FMCSA’s goal of reducing crashes, injuries, and fatalities and would, overall, improve safety on our nation’s roadways,” DiSalvi wrote.

“[The] advantages of hair testing should inure to the benefit of all carriers, not just the Trucking Alliance and a select membership,” Maus wrote. “The safety of our roadways, professional drivers, and the motoring public improves once all carriers have the option to submit positive hair test results to the Clearinghouse.”

Knight Transportation has screened for drugs by using hair testing since 2011 with new workers involved in “safety sensitive positions,” Sant wrote, and Swift Transportation has done so since 2018.

“Our company’s experience is that the FMCSA urinalysis does not detect illegal drugs very effectively,” Sant wrote. “Hair testing has been much more effective than urinalysis in detecting illegal drug use among truck drivers.”

In 2021, Knight-Swift had 37,000 truck driver applicants submit to a pre-employment urinalysis and hair drug test. During that period, “there were 1,472 truck drivers who were identified by the hair test for illegal drug use,” Sant emphasized in a bolded and underlined section of the comments. “But of this total only 153 tested positive using urinalysis!”

"I work in safety for a carrier with more than 150 units. We have been hair testing for six years now. For every positive urine test, there are eight or more positive hair tests. One individual applied to work here, was urine tested four times over the course of a year, passed all four urine but failed the hair tests. He was not hired," the business wrote.

“I believe drug testing through hair follicles is unnecessary and counter productive,” Southern Concrete Materials wrote. “The travelling public really only needs to know if a driver is impaired behind the wheel of his or her commercial vehicle. This seems more invasive. The trend should be toward saliva testing which would narrow the window down and help determine potential impairment after an accident.”

King wrote that she has two million safe miles but decried the proposal and "constantly tightening regulations" that already require five random tests each year.

“Safety is improved when hair testing is conducted. Here is why: where urinalysis can reveal drugs used in the past one to three days, hair testing can uncover drug use up to 90 days,” the association wrote. “A ‘lifestyle’ drug user who avoids or postpones a urine test for, say, five days will not have drug use detected. A hair test won’t be fooled by a similar short break in drug use.”

"Nothing in the federal statute prohibits FMCSA from implementing what Congress specifically directed the Secretary of Transportation to do – recognize hair testing as an acceptable alternative to urine testing,” Kidd wrote.

As part of a four-page response, he also suggested that Federal Motor Carrier Safety Administration doesn’t have to wait for the Health and Human Services Department to authorize hair testing for the administration to proceed.

"The Petition does not seek to circumvent forthcoming HHS drug testing guidelines. If the Petition is granted, Trucking Alliance carriers will continue to utilize both hair testing and a urinalysis until HHS issues a final rule,” he wrote.

"We acknowledge that a subset of the largest motor carriers has incorporated hair testing for drug use into their respective drug testing programs," Owen wrote. "That is their prerogative, a business decision the 11 petitioning carriers have made for themselves. NASTC has no quarrel with that. However, the large carriers’ underlying intent of the requested exemption would seem to be pushing toward making hair testing not merely a carrier’s voluntarily chosen supplement to urine drug testing of commercial truck drivers, but to supplant urine testing with hair testing. The 1 of 6 exemption request seems merely the latest in a long-time effort pushing a hair testing mandate on trucking. If this is indeed the true basis of the request, we would oppose it.”

“Given that the results of a federally impelled drug or alcohol test can have permanent impacts on the career of a covered individual it is of the upmost importance that such tests are not permitted unless the government has determined them to be of unimpeachable scientific validity and that all due process issues are resolved,” Scandaglia wrote.

“Our organizations remain concerned about privacy as it relates to hair testing, and impacts on equal employment opportunity for employees, contractors, and other stakeholders, including, but not limited to, commercial drivers. These equal employment opportunity concerns include both 1) the disparate impact that false positives may have on Punjabis, South Asians, and Sikhs who overwhelmingly have brown or black hair, and 2) the ramifications of faith-based accommodation requests for hair testing by observant Sikhs who maintain unshorn hair,” the organizations wrote.

"TCA argues that the relative lack of consequential action on hair testing directly contradicts mandates provided by Congress. In the Fixing America’s Surface Transportation (FAST) Act of 2015, Congress instructed the Department of Health and Human Services (HHS) to issue scientific and technical guidelines for hair testing. In 2018, in the SUPPORT for Patients and Communities Act, Congress again passed language mandating HHS to develop hair testing guidelines. On both occasions and in the seven years since, HHS has failed to satisfy these directives," Ward wrote.