Yes. An owner-operator who employs only himself or herself as a CDL driver must meet both the employer and driver requirements of Part 382, including random testing in a pool of two or more covered employees (49 CFR 382.103(b)).

In practice, owner-operators join a consortium run by a C/TPA, an independent company. Med-Stop is not a consortium or C/TPA. An owner-operator must also designate a C/TPA to report his or her own violations to the Clearinghouse (49 CFR 382.705(b)(6)).