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The Department of Transportation (DOT) is proposing new rules to update its drug testing guidelines, specifically revising cannabis terminology to align with the U.S. Department of Health and Human Services (HHS). This change aims to differentiate between delta-9 THC (found in marijuana) and delta-8 THC (from hemp). The DOT would now refer to delta-9 THC as such, and its metabolite as delta-9 THCC instead of THCA. The new filing also suggests adding fentanyl to drug testing panels for federally regulated transportation workers.

Federal Transportation Department To Update Marijuana Terminology Around THC To ‘Harmonize’ With Health Agency

Sep 4, 2025

Kyle Jaeger

Marijuana Moment



The Department of Transportation (DOT) is proposing a new rule to update
its drug testing guidelines, revising terminology around cannabis in a way
that provides more specificity related to THC.

In a notice published in the Federal Register on Tuesday, DOT said it is
proposing the rule change to “harmonize” with cannabis terminology adopted
by the U.S. Department of Health and Human Services (HHS) earlier this year.

“In the urine and oral fluid drug testing panels, HHS revised the drug
analyte name and abbreviation nomenclature specifically for the marijuana
metabolite,” the notice says. “The change was made to be consistent with
current scientific nomenclature.”

Previously, HHS referred to delta-9 THC merely as “THC,” with no further
specification. That failed to distinguish between delta-9 THC—which is
found in marijuana—and delta-8 THC, an increasingly prominent psychoactive
cannabinoid that can be produced from federally legal hemp.

Now DOT is following suit, while noting that the “nomenclature change does
not affect the testing process for marijuana, but instead, just affects how
laboratories and [medical review officers] are to refer to the marijuana
analyte.”

HHS previously used “THCA” to refer to a marijuana metabolite,
delta-9-tetrahydrocannabinol-9-carboxylic acid. That conflicts with the
more common meaning of “THCA” within the cannabis space, where it typically
refers to delta-9 tetrahydrocannabinolic acid—a non-psychoactive that can
be converted to delta-9 THC through heating.

If the proposed rules at DOT are finalized, delta-9 THC will be referred to
as such. And the department would refer to the THC metabolite as delta-9
THCC rather than THCA. The update would apply to workplace drug testing of
federal employees.

Separately, the new DOT filing also moves to add fentanyl and its
metabolite norfentanyl to drug testing panels for federally regulated
transportation workers.

There’s a 45-day public comment period for interested parties to weigh in
on the policy proposal.

Other federal agencies have already adjusted how they refer to—and
define—various cannabinoids. For example, the Drug Enforcement
Administration (DEA) said last year that THCA (referring to delta-9
tetrahydrocannabinolic acid), should be counted as part of a cannabis
product’s total delta-9 THC.

“The ‘decarboxylation’ process converts delta-9-THCA to delta-9-THC,”
Terrence Boos, chief of DEA’s drug and chemical evaluation section, wrote
in that DEA guidance. “Thus, for the purposes of enforcing the hemp
definition, the delta-9 THC level must account for any delta-9 THCA.”

As a result, “cannabis-derived THCA does not meet the definition of hemp,”
he concluded, “because upon conversion for identification purposes as
required by Congress, it is equivalent to delta-9-THC”

How to classify cannabinoids—and how exactly to measure the 0.3 percent
delta-9 THC limit that distinguishes hemp from marijuana under federal
law—is expected to be addressed in the next Farm Bill.

*Photo courtesy of Chris Wallis/Side Pocket Images.*

The post Federal Transportation Department To Update Marijuana Terminology
Around THC To ‘Harmonize’ With Health Agency appeared first on Marijuana
Moment.

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