Fentanyl in the Workplace: Why Employers Should Pay Attention Now
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Introduction
Fentanyl is no longer just a public health crisis. It is increasingly a workplace issue as well.
For employers, the concern is not only the devastating impact fentanyl has had nationwide, but also what its growing presence means for workplace safety, employee performance, drug testing policies, and supervisor preparedness. Recent federal action and updated drug testing guidance have made the issue even more relevant.
Why Fentanyl Presents a Workplace Risk
Fentanyl is a synthetic opioid originally developed for legitimate medical use, but it is approximately 100 times more potent than morphine and 50 times more potent than heroin as an analgesic. Because of that potency, even a very small amount can have serious or fatal consequences.
According to the National Institute for Occupational Safety and Health (NIOSH), which is part of the Centers for Disease Control and Prevention (CDC) within the U.S. Department of Health and Human Services (HHS), approximately half of adults who misused opiates in 2021 had full- or part-time jobs. For employers, that can mean addiction-related performance problems, increased absenteeism, on-the-job errors, accidents, and even overdoses occurring at work.
What the Latest Drug Testing Data Shows
The data suggests fentanyl is becoming more relevant during active employment, not just at the hiring stage.
Quest Diagnostics reported that fentanyl positivity in the general U.S. workforce was 15% higher in 2024 than in 2023. Even more striking, random testing positivity for fentanyl was reported to be 707% higher than pre-employment positivity, suggesting employees may be turning to fentanyl after being hired. Over the past five years, random fentanyl positivity has been 400% higher than pre-employment.
That pattern is unlike what is typically seen with many other drugs and should be a serious concern for employers, especially those with safety-sensitive positions.
Why the Fentanyl Threat is Becoming More Complicated
Fentanyl rarely appears in isolation anymore.
Quest also reported that 60% of fentanyl-positive tests contained another substance, with xylazine and medetomidine among the predominant adulterants. Marijuana and fentanyl co-positivity rose from 10% in 2020 to 22% in 2024, while amphetamine and fentanyl co-positivity rose from 11% to 16%.
This matters because adulterants such as xylazine and medetomidine can change how impairment presents and complicate interpretation of results. These substances are associated with severe sedation, atypical withdrawal symptoms, and increased medical risk. For employers, that means workplace drug threats continue to evolve faster than many policies and training programs do.
What Employers Should Watch For
Any substance that impairs alertness, judgment, and coordination is a workplace concern, but fentanyl raises particular alarms because of its potency and sedative effects. An employee under the influence of fentanyl, or in withdrawal from it, may experience confusion, extreme drowsiness, slow breathing, slurred speech, poor coordination, and reduced concentration. Supervisors may also observe behavioral signs such as isolation, increased absences, unusual breaks, and a decline in work quality.
In overdose situations, signs may include unresponsiveness, respiratory distress, pinpoint pupils, and blue or gray skin, lips, or fingernails. These situations are medical emergencies and require immediate action.
The Legal and Regulatory Landscape is Shifting
Federal policymakers took two major steps in 2025 that employers should be aware of.
First, Congress passed the Halt All Lethal Trafficking of Fentanyl Act or the HALT Fentanyl Act, permanently classifying fentanyl-related substances as Schedule I under the Controlled Substances Act and reinforcing penalties related to trafficking. Second, the Substance Abuse and Mental Health Services Administration (SAMHSA) updated the federal drug testing panels, effective July 7, 2025, to add fentanyl and nor fentanyl to mandatory urine and oral fluid testing panels used in federal workplace programs.
The SAMHSA change does not currently apply to programs regulated by the U.S. Department of Transportation (DOT), but it signals a broader federal recognition that fentanyl must be addressed through testing and prevention, especially in safety-sensitive settings. DOT is actively evaluating the inclusion of fentanyl in its regulated drug testing programs. A Notice of Proposed Rulemaking (NPRM) has been issued proposing to align DOT testing panels with updated SAMHSA guidelines and potentially add fentanyl in the future. While not yet finalized, this step demonstrates that DOT is taking action to address the growing impact of fentanyl.
What Employers Should Do Now
Now is the time for employers and drug testing providers to revisit their policies and procedures.
Questions worth asking include:
- • Does your policy explicitly list fentanyl as a covered substance if you are testing for it?
- • Have employee notices and consent forms been updated to reflect fentanyl testing?
- • Are laboratory and MRO processes aligned with fentanyl confirmation and reporting?
- • Are supervisors trained to recognize signs of fentanyl use, impairment, and overdose?
- • Do your reasonable suspicion and post-accident procedures reflect the growing risks associated with fentanyl?
Conclusion
Fentanyl is not just another drug trend. It is a fast-moving workplace safety issue with legal, operational, and policy implications.
Rising positivity rates, complex polydrug patterns, and new federal action all point in the same direction: employers should not wait until an incident occurs to act. Reviewing your policy, training supervisors, and evaluating whether your testing program reflects current risks are practical steps that can help employers respond before fentanyl becomes a crisis inside the workplace.
Have questions about workplace drug screening best practices, ClearStar’s team is ready with answers. Contact us to learn more.
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