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.
What This Course Covers
The course includes 60 minutes on the signs of drug use and 60 minutes on the signs of alcohol misuse. Topics include:
- Physical, behavioral, speech, and performance indicators of probable drug use and alcohol misuse
- How to base a decision on specific, current, and clear observations of appearance, behavior, speech, or body odor
- When and how to order a reasonable suspicion test and who to notify
- How to document observations so the decision can be defended
- Testing timelines for FMCSA alcohol tests, including the record required after 2 hours and the 8-hour cutoff
- Why the supervisor who decides on an alcohol test may not perform that test
- Removal from safety-sensitive duty, refusals, and the Substance Abuse Professional process
- Confidentiality and the employee's rights during the process
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.
Who Needs This Training
DOT agency rules require training for supervisors who may decide whether a safety-sensitive employee should be tested for reasonable suspicion.
- FMCSA. Under 49 CFR 382.603, every person designated to supervise drivers needs at least 60 minutes of training on alcohol misuse and 60 minutes on controlled substances use.
- FTA. Under 49 CFR 655.14, supervisors and company officers who make reasonable suspicion decisions need 60 minutes on drug use and 60 minutes on alcohol misuse.
- PHMSA. Supervisors who make reasonable cause drug decisions need one 60-minute period of training under 49 CFR 199.113. Those who make alcohol decisions need 60 minutes under 49 CFR 199.241. For reasonable cause drug tests, two supervisors, one of them trained, must agree on the decision under 49 CFR 199.105(d), and they may agree by phone. Operators with 50 or fewer covered employees need only one trained supervisor.
- USCG. Under 46 CFR 16.401, supervisory personnel need at least 60 minutes of training in total on the effects of drug and alcohol use and the behavioral cues that may signal it.
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.
Certificate and Compliance
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.