The Office of the National Rail Safety Regulator (ONRSR) has introduced significant updates to drug and alcohol testing requirements for NSW rail operators – marking a meaningful shift in over a decade. These reforms create greater flexibility for operators, modernise testing practices, and align NSW with national approaches to risk‑based drug and alcohol management.
NSW Rail Operators Can Now Use Oral Fluid Testing
From 1 November 2025, operators in NSW are permitted to use oral fluid testing to meet both random and post‑incident testing obligations. This change stems from an amendment to Regulation 28 of the Rail Safety National Law National Regulations, which removed the requirement to use urine testing exclusively.
Operators may now choose the testing modalities that best align with the risks in their operations including oral fluid, urine, and breath analysis.
Greater Flexibility in Designing Risk‑Based Testing Programs
The updated framework emphasises risk‑appropriate, multi‑modal testing rather than a restricted, prescriptive approach. Operators can tailor testing types to reflect tasks, safety‑critical responsibilities, and impairment risk.
This aligns with ONRSR’s guidance encouraging operators to assess their risks and update their Drug and Alcohol Management Programs (DAMPs) accordingly.
Oral Fluid Testing Must Now Be Reported to ONRSR
Regulators have introduced new reporting obligations requiring rail operators to notify ONRSR of certain oral fluid test results within 7 days to align with existing requirements for urine and blood testing. This means an oral fluid reading that detects the presence of a “prescribed drug” (THC, methamphetamine, MDMA) can form the basis of ONRSR enforcement.
Random Testing Requirements Remain the Same
Despite these new options, NSW‑specific requirements remain in force, including:
- Random testing of at least 25% of rail safety workers annually (commercial operators only)
- Mandatory post‑incident testing within the defined timeframes
These obligations must be integrated into any updated, multi-modal testing program.
Why These Changes Matter
These updates move NSW rail safety regulation into a more contemporary, fit‑for‑purpose model. Oral fluid testing enables:
- Better alignment with impairment risk, detecting recent use
- Faster onsite collection, reducing workforce disruption
- Lower privacy and invasiveness burden compared to urine collection
Under the revised rules, operators can now build a multi‑modal program that addresses real‑world operational risks and improves defensibility following incidents.
What NSW Rail Operators Need to Do Next
(and Great Actions for All Organisations)
Under the updated requirements, operators must:
- Review and update their Drug and Alcohol Management Program (DAMP)
- Conduct a risk assessment to determine appropriate testing types
- Ensure collectors are authorised persons under RSNL
- Use approved devices and approved laboratories
- Update internal reporting and compliance procedures
Simply meeting the minimum random testing requirement is not sufficient. Operators must demonstrate effective, risk‑aligned mitigation.
Supporting NSW Operators Through the Transition
Alcolizer Technology is already supporting NSW operators to update their policies, procedures, and testing programs in line with the revised requirements. We provide:
- Certified and Compliant oral fluid, urine, and breath testing solutions
- Authorised collectors across Sydney and regional NSW
- Policy and DAMP updates aligned to ONRSR
- Toxicologist support and defensible reporting
- 24/7, 365 days, incident response
Learn more about how our team supports organisations across New South Wales here.
The ONRSR updates provide much‑needed flexibility for NSW rail operators while strengthening the effectiveness of workplace drug and alcohol management. By adopting a risk‑based approach and integrating oral fluid testing, operators can enhance safety, compliance, and operational resilience.