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What Employers Need to Know About Fentanyl

The fentanyl crisis poses a growing, possibly lethal threat to workplace safety. As fentanyl concerns continue impacting workplaces, HR teams should introduce reliable screening processes that support hiring decisions, reduce risk, and promote ongoing employee well-being.

This guide outlines critical details about fentanyl, including what it is and how to test for it

What Is Fentanyl?

Fentanyl is a potent synthetic opioid used to treat severe pain. Since this anesthetic is 50 to 100 times stronger than morphine, doctors typically provide it to people who have developed a tolerance to other common pain medications.

While this medication is highly effective for pain treatment in medical environments, fentanyl is also increasingly present in the illegal drug market, where manufacturers mix it into counterfeit pills and other substances, such as heroin and cocaine. Since it is colorless, odorless, and tasteless, it can resemble many other drugs.

Unfortunately, fentanyl is potent enough to cause an overdose, especially when people take it unknowingly. As a central nervous system depressant, it can make people stop breathing, with potentially severe consequences, including coma and death. In 2023 alone, approximately 72,000 drug overdose deaths in the U.S. involved illegally manufactured fentanyl.

Impact of Fentanyl on Workplace Safety

Illicit fentanyl can lead to severe, adverse workplace safety implications.

  • Increased accident risks: Fentanyl use can lead to severe impairment, which can manifest in disorientation, slowed reaction times, and decreased physical coordination, increasing the risk of accidents, errors, and injuries, particularly in safety-sensitive responsibilities. 
  • Overdose risks: People who come to work under the influence of fentanyl or take fentanyl at the workplace could experience an overdose, which may affect employee morale and disrupt business operations. 
  • Threat to workforce safety culture: Undetected use of fentanyl and its resultant safety risks can undermine employee trust in a company’s commitment to wellness.  

Fentanyl Testing and Legal Compliance

Federal standards and proposed requirements related to fentanyl testing continue to evolve. Employers in regulated industries should monitor for these updates.

1. Health and Human Services Mandatory Guidelines

Effective July 7, 2025, the U.S. Department of Health and Human Services added fentanyl to the authorized testing panel for federal workplace drug testing programs. This change allows federal agencies to include fentanyl in testing under HHS guidelines and may inform how private employers reevaluate their testing policies.

2. DOT's Notice of Proposed Rulemaking

On Sept. 2, 2025, the Department of Transportation published a Notice of Proposed Rulemaking to amend its drug testing program to include fentanyl and norfentanyl. This proposal aims to harmonize DOT regulations with the mandatory federal workplace drug testing guidelines outlined by the HHS.

While this rule has not yet taken effect, employers in DOT-regulated industries should monitor the proposal and evaluate its potential impact on future testing policies.

Fentanyl Testing and Legal Compliance

Left unchecked, illicit fentanyl use can expose your organization to several business risks. Mitigating these requires a multifaceted approach, with fentanyl testing policies tailored to your workforce, risk profile, and compliance obligations. 

  • Compliance: As federal, DOT, and state-specific rules evolve, employers in regulated or safety-sensitive environments may face increased compliance risk if they rely on outdated or inconsistently applied testing policies.
  • Liability: If a fentanyl-impaired employee causes a workplace incident and the employer had no documented testing program in place, the legal exposure can be significant, including workers’ compensation claims and negligence lawsuits.
  • Reputation: A single high-profile workplace incident linked to fentanyl can damage an organization’s brand, affect client relationships, and impact talent acquisition in competitive hiring markets.

How to Test for Fentanyl in the Workplace

Use this step-by-step guide to implement a fentanyl testing program for your workplace. 

1. Choose a Testing Method

Urine testing is more common and generally more cost-effective for initial screening. However, oral fluid testing gives employers added flexibility when building a compliant fentanyl testing program.

2. Add Fentanyl to Your Existing Drug Panel

Older, standard five- and 10-panel drug tests generally do not include fentanyl. Consequently, you should work with your screening provider to expand to a testing panel that detects fentanyl and norfentanyl, its metabolite.

3. Implement Comprehensive Testing Triggers

Employers should consider these triggers when building a compliant drug testing program.

  • As part of the hiring process, conduct pre-employment testing to screen potential candidates, especially those applying to safety-sensitive positions. 
  • Random testing involves unannounced and unpredictable testing of employees selected through a neutral, documented process to deter illicit drug use. 
  • If a trained supervisor observes specific, documented signs of impairment in an employee, a test may be necessary based on reasonable suspicion. 
  • A fentanyl test can determine whether substance impairment contributed to a workplace incident, injury, or near-miss. 
  • Administer drug tests to employees who return to their duties after violating a substance use policy.

4. Verify Results Through a Certified MRO

If an employee’s fentanyl test returns a positive or inconclusive result, a medical review officer should confidentially contact them to determine whether they have a legitimate prescription for opioids. The goal is to avoid unfairly penalizing employees who use legally prescribed and obtained pain medications.

Why Expert Screening Matters

Adding fentanyl to a workplace testing program can create new compliance, documentation, and workflow challenges. Here’s how Wolfe helps employers address those challenges.

  • Compliance support: Regulations around fentanyl testing continue to change across federal, DOT, and state-specific programs. Wolfe helps employers stay informed about evolving requirements and maintain defensible documentation, reducing the risk of inconsistent or noncompliant testing practices.

  • Built-in technology: Our proprietary platform, WolfeONE, provides HR managers with a centralized system for managing drug testing, background checks, and compliance documentation. With WolfeONE, HR teams can order drug and background screens, manage DOT compliance solutions and DQF files, store documents, access results, and follow each test’s progress.

  • Infrastructure: Wolfe provides the testing infrastructure that many HR teams don’t have in-house, including chain-of-custody support, audit-ready documentation, and a dedicated in-house MRO team.  

Hire More Confidently with Wolfe

Employers have a critical duty to create and maintain workplace safety standards, and you can count on Wolfe to help you uphold this commitment. With 40-plus years of screening experience, PBSA-accredited provider status, and FCRA-aligned workflows, Wolfe helps employers create consistent programs that support compliance, reduce risk, and improve the candidate experience.

To get started, request support for fentanyl testing and workplace screening compliance.

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