HOLLYWEED ITS A MOVEMENT

DOT To Update Cannabis Testing Language To Match Health Agency Standards

Michael Levin

The U.S. Department of Transportation (DOT) is moving to modernize its marijuana drug testing terminology, aligning with recent updates from the Department of Health and Human Services (HHS) to bring greater clarity around THC.

In a notice published in the Federal Register this week, DOT explained that the proposed changes are designed to “harmonize” terminology with HHS. While the rule would not alter the testing process itself, it will affect how laboratories and medical review officers refer to marijuana analytes.

Historically, HHS labeled delta-9 THC simply as “THC,” which failed to differentiate it from delta-8 THC, a psychoactive hemp-derived cannabinoid that has gained prominence in recent years. Under the update, DOT would adopt more precise language:

• Delta-9 THC will be referred to by name, not just “THC.”

• The marijuana metabolite once called THCA (delta-9-tetrahydrocannabinol-9-carboxylic acid) will now be referred to as delta-9 THCC to avoid confusion with “THCA” in cannabis culture, where it usually means delta-9 tetrahydrocannabinolic acid the non-psychoactive compound that converts to THC when heated.

The proposed change would apply to workplace drug testing of federal employees and regulated transportation workers. In addition, DOT is proposing to add fentanyl and its metabolite, norfentanyl, to federal drug testing panels.

Stakeholders have 45 days to submit public comments on the rule.

The move follows broader federal efforts to clarify cannabinoid definitions. Last year, the Drug Enforcement Administration (DEA) emphasized that THCA should count toward total THC content in cannabis products, because it converts into delta-9 THC through decarboxylation. That interpretation means cannabis-derived THCA cannot be considered hemp under the current federal definition.

How THC and related cannabinoids are classified and how the 0.3 percent THC threshold is measured remains a hot-button issue likely to be revisited in the upcoming Farm Bill.