DOT Reasonable Suspicion Training for Supervisors is a 2-hour course for supervisors who make reasonable suspicion testing decisions for employees regulated by FMCSA, FTA, PHMSA, and USCG. It includes 60 minutes on the physical, behavioral, speech, and performance indicators of probable drug use and 60 minutes on the indicators of probable alcohol misuse, as required by 49 CFR 382.603. It also covers documentation and testing procedures. The course was developed by attorney Andrew David Easler, Esq. A certificate is issued on completion.
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Published March 1, 2022
Andrew David Easler, Esq.
Course Author
Andrew David Easler, Esq.
Course Instructor
DOT Reasonable Suspicion Training for Supervisors is a 2-hour course that teaches supervisors how to recognize the signs of drug use and alcohol misuse and how to make a sound reasonable suspicion decision. It was developed by Andrew David Easler, Esq., an attorney focused on DOT drug and alcohol compliance.
A reasonable suspicion test is one of the most sensitive decisions a supervisor makes. It must rest on what the supervisor actually sees, hears, and smells, and it must follow the testing rules in 49 CFR Part 40 and the employer's DOT agency regulations. This course gives supervisors the knowledge and the process to make that call with confidence.
The course includes 60 minutes on the signs of drug use and 60 minutes on the signs of alcohol misuse. Topics include:
Supervisors also learn the difference between reasonable suspicion and other test types. A post-accident test, for example, is triggered by the accident itself rather than by signs of impairment.
DOT agency rules require training for supervisors who may decide whether a safety-sensitive employee should be tested for reasonable suspicion.
This course meets each of these minimums in one 2-hour session. It is a good fit for supervisors and managers of CDL drivers, transit supervisors at FTA-funded agencies, pipeline and LNG supervisors, marine supervisors, and designated employer representatives, safety managers, and HR staff who make or support testing decisions.
Aviation and rail supervisors have their own rules. FAA supervisors should take FAA Reasonable Suspicion Training for Supervisors. Railroad supervisors should take FRA Reasonable Suspicion & Toxicological Testing Training, which also covers post-accident toxicological testing. Employers whose workers are not DOT regulated can use Non-DOT Reasonable Suspicion Training for Supervisors.
Learners receive a certificate when they complete the course and can download it right away. Employers should keep that record as proof the supervisor met the training requirement before making any reasonable suspicion determination.
FMCSA rules state that recurrent training is not required. FTA, PHMSA, and USCG rules set no recurrent requirement. Many employers still schedule refreshers to keep skills current. A decision made by an untrained supervisor can make a test hard to defend, so training should be finished before a supervisor is put in a position to make the call.
The course is available as online self-paced training, onsite instructor-led training, live virtual training, or SCORM files for use in your own learning management system.
DOT training for FMCSA, FAA, FTA, FRA, USCG, and PHMSA that meets or exceeds federal requirements. Accepted in all 50 states and anywhere DOT rules apply.
Every course is reviewed by attorneys and subject matter experts for accuracy, so you get training you can show employers, clients, and auditors with confidence.
Train on any computer, phone, or tablet. Courses stay open until you finish, so learners can work at their own pace with no deadline.
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Learners download their certificate as soon as they pass the exam. Managers can view and download certificates for their whole team from one account.
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Go beyond the course with books, guides, and free videos and posts on YouTube, LinkedIn, TikTok, and more covering drug testing, workplace safety, and compliance.
Built to meet or exceed the training requirements of federal regulatory agencies. Some roles may also need a federal license or registration from the agency.
Accurately identify physical and behavioral indicators of potential substance abuse, including bloodshot eyes, slurred speech, unsteady movement, erratic behavior, and changes in attendance or work performance.
Demonstrate working knowledge of the DOT regulations governing drug and alcohol testing in safety-sensitive transportation roles, including 49 CFR Part 40 (DOT Procedures), 49 CFR Part 382 (FMCSA), 49 CFR Part 219 (FRA), 49 CFR Part 655 (FTA), 14 CFR Part 120 (FAA), 46 CFR Part 16 (USCG), and 49 CFR Part 199 (PHMSA). Supervisors will understand key terms like "safety-sensitive position," the 60/60 training mandate, and the correct protocols for documenting and reporting suspected substance use across all relevant sub-agencies.
Apply DOT guidelines to real-world situations, including when and how to initiate a reasonable suspicion test, who to notify, and how to document observations accurately and in compliance with federal requirements.
Understand supervisor responsibilities under DOT regulations, employee rights, confidentiality requirements, and the consequences of non-compliance for both the supervisor and the organization.
Complete required documentation accurately, maintain proper records, and ensure every action taken is transparent, legally defensible, and consistent with DOT testing protocols.
31 modules · 1 exam
Module 1
Introduction to Supervisor Training
Module 2
Drug Testing
Module 3
Consequences of Drugs
Module 4
Indicators of Drug Use
Module 5
Signs and Symptoms of Narcotics
Module 6
Signs and Symptoms of Fentanyl
Module 7
Signs and Symptoms of Heroin
Module 8
Signs and Symptoms of Morphine
Module 9
Signs and Symptoms of Oxycodone
Module 10
Signs and Symptoms of Stimulants
Module 11
Signs and Symptoms of Amphetamines
Module 12
Signs and Symptoms of Cocaine
Module 13
Signs and Symptoms of Depressants
Module 14
Signs and Symptoms of Marijuana Concentrates
Module 15
Signs and Symptoms of Marijuana-Cannabis
Module 16
Signs and Symptoms of Vaping
Module 17
Alcohol and Its Effects
Module 18
Alcohol and the Brain
Module 19
Alcohol and the Heart
Module 20
Alcohol and the Liver
Module 21
Alcohol and the Pancreas
Module 22
Alcohol and Cancer
Module 23
Alcohol and the Immune System
Module 24
Effects of Alcohol Summary
Module 25
Alcohol Testing
Module 26
Testing Under Reasonable Suspicion
Module 27
Drugs of Abuse Reference Sheet
Module 28
Reasonable Suspicion Testing Checklist
Module 29
Do's and Don'ts for Supervisors
Module 30
Step by Step Confrontation Format
Module 31
Supervisor Tips
Exam
Supervisor Training Exam
Built to meet training requirements in all 50 states.
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Other requirements
Supervisors who may decide whether a DOT-covered, safety-sensitive employee should be tested for reasonable suspicion. Under FMCSA rules, every person designated to supervise drivers needs the training. That includes supervisors at FMCSA, FTA, PHMSA, and USCG regulated employers.
FMCSA, FTA, and PHMSA supervisors need at least 60 minutes of training on the signs of drug use and 60 minutes on the signs of alcohol misuse. USCG requires at least 60 minutes in total. This course covers both topics in one 2-hour session.
Yes. Under FMCSA and FTA rules, the observations behind a reasonable suspicion test must be made by a trained supervisor or company official. Supervisors should finish the training before they are asked to make that call.
The decision has to rest on specific, current, and clear observations of the employee's appearance, behavior, speech, or body odor. Examples include slurred speech, an unsteady walk, or the smell of alcohol. Rumors, past history, or a general feeling are not enough.
It depends on the agency. Under FMCSA and FTA rules, one trained supervisor or company official can make the call. PHMSA requires two supervisors, one of them trained, to agree on a drug test, and they may agree by phone. Operators with 50 or fewer covered employees need only one trained supervisor. USCG rules call for two supervisors to observe the crewmember where practicable. Under FMCSA rules, the person who decides on an alcohol test may not perform that test.
Under FMCSA rules, the alcohol test should happen within 2 hours of the determination. If it doesn't, the employer must document why. After 8 hours, the employer stops trying to test and records the reason.
Yes. For FMCSA alcohol and drug tests, the supervisor must sign a written record of the observations within 24 hours or before the test results are released, whichever comes first. Good notes are what make the decision defensible.
The employer decides whether a refusal occurred. Once it does, the refusal is a violation with the same consequences as a positive test. The employee must be removed from safety-sensitive duty and given a list of Substance Abuse Professionals, and cannot return to safety-sensitive work for any employer until completing the SAP process.
Under FMCSA rules, an employee who shows signs of alcohol impairment cannot perform safety-sensitive duties until a test shows a concentration below 0.02 or 24 hours have passed since the determination. Many employers also remove the employee from duty while drug test results are pending.
For FMCSA, FTA, PHMSA, and USCG supervisors, the rules require initial training only. Many employers still schedule refreshers to keep skills current. FAA supervisors who make drug testing decisions also need reasonable recurrent training in later years. FAA Advisory Circular AC 120-126 points to a 12 to 18 month schedule as best practice. Our FAA Annual Recurrent Training for Supervisors covers it.
No. FAA has its own initial and recurrent requirements. FAA supervisors should start with our FAA Reasonable Suspicion Training for Supervisors.
No. FRA supervisor training includes signs and symptoms training and post-accident toxicological testing training. Railroad supervisors should take our FRA Reasonable Suspicion and Toxicological Testing Training, which covers both in about 3 hours. 49 CFR 219.11(g) sets the content of this training but not a length.
Use our Non-DOT Reasonable Suspicion Training for Supervisors, which is built for company drug-free workplace policies.
A reasonable suspicion test is based on what a trained supervisor observes about the employee. A post-accident test is triggered by the accident itself, under each agency's criteria, and doesn't require any signs of impairment.
No. Many employers have another manager or a designated employer representative arrange transportation. The employee should not drive to the collection site.
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