FAA Reasonable Suspicion Training for Supervisors is a 2-hour initial course for supervisors of safety-sensitive aviation employees, including flight crew, flight attendants, maintenance personnel, and dispatchers. It includes 60 minutes on indicators of probable drug use and 60 minutes on indicators of probable alcohol misuse, meeting the initial training minimums in 14 CFR Part 120. It also covers documentation and FAA testing procedures. The course was developed by attorney Andrew David Easler, Esq. A certificate is issued on completion.
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Published April 1, 2021
Andrew David Easler, Esq.
Course Author
Andrew David Easler, Esq.
Course Instructor
FAA Reasonable Suspicion Training for Supervisors is a 2-hour initial course that prepares aviation supervisors to recognize probable drug use and alcohol misuse and to make testing decisions under 14 CFR Part 120. It was developed by Andrew David Easler, Esq., an attorney focused on DOT drug and alcohol compliance.
FAA rules give supervisors a direct role in reasonable cause drug testing and reasonable suspicion alcohol testing. A supervisor who knows the signs and the process protects coworkers, passengers, and the employer.
The course includes 60 minutes on drug use and 60 minutes on alcohol misuse. Topics include:
Under 14 CFR 120.115, supervisors who make reasonable cause drug testing decisions need at least 60 minutes of initial training on the indicators of probable drug use. Under 14 CFR 120.223, supervisors who make reasonable suspicion alcohol decisions need at least 60 minutes of training on the indicators of probable alcohol misuse. This course covers both in one session.
The course is for supervisors of employees who perform safety-sensitive functions under Part 120, such as flight crew, flight attendants, maintenance personnel, dispatchers, and ground security coordinators. It also helps designated employer representatives and safety managers who support testing decisions.
FAA rules also require a reasonable recurrent training program for supervisors who make drug testing decisions in the years after initial training. The rule sets no fixed interval. FAA Advisory Circular AC 120-126 points to a 12 to 18 month schedule as best practice. Supervisors can meet that need with FAA Annual Recurrent Training for Supervisors.
Supervisors at FMCSA, FTA, PHMSA, and USCG regulated employers should take DOT Reasonable Suspicion Training for Supervisors, which follows their agency rules.
Supervisors finish the course with a clear process they can follow the first time they face a possible impairment situation on the job.
Supervisors and their managers can download a certificate right after the supervisor passes the online exam. FAA employers must document supervisor training in their testing program, so keep each record where it can be produced in an inspection.
Training should be finished before a supervisor takes part in any testing decision. A decision made without a trained supervisor can be hard to defend.
The course is available as online self-paced training, onsite instructor-led training, or SCORM courseware for use in third-party learning management systems.
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.
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by accurately identifying specific, contemporaneous physical, behavioral, and performance indicators of probable drug use, and recognizing the symptoms of alcohol misuse based on an employee's appearance, behavior, speech, and body odor.
by demonstrating working knowledge of the federal aviation regulations governing drug and alcohol testing in safety-sensitive roles, including 49 CFR Part 40 (DOT Procedures) and 14 CFR Part 120.115(c) and 120.217(d). Supervisors will understand key terms such as "safety-sensitive position," the 60/60 training mandate, and the appropriate protocols for documenting and reporting suspected substance use.
by applying FAA 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 aviation requirements.
by understanding supervisor responsibilities under FAA regulations, employee rights, Employee Assistance Program (EAP) requirements, confidentiality obligations, and the consequences of non-compliance for both the supervisor and the organization.
by completing required documentation accurately, maintaining proper records, and ensuring every action taken is transparent, legally defensible, and consistent with FAA testing protocols under 49 CFR Part 40 and 14 CFR Part 120.
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-Cannabis
Module 15
Signs and Symptoms of Marijuana Concentrates
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.
Hardware
Software
Other requirements
Supervisors at FAA-regulated employers who may decide whether a safety-sensitive aviation employee should be tested for drugs or alcohol. That includes supervisors of pilots, flight attendants, mechanics, dispatchers, and other covered roles. If a supervisor could be the person who notices signs of drug use or alcohol misuse and starts the testing process, they should complete this training before they make that call.
Supervisors who make reasonable cause drug testing decisions need at least 60 minutes of initial drug training under 14 CFR 120.115. Supervisors who make reasonable suspicion alcohol decisions need at least 60 minutes of alcohol training under 14 CFR 120.223. This course covers both in 2 hours.
Yes, for drug testing decisions. 14 CFR 120.115 requires reasonable recurrent training in the years after initial training. There is no recurrent requirement for alcohol. Supervisors can meet it with FAA Annual Recurrent Training for Supervisors.
At least two supervisors, one of whom is trained, must substantiate and agree with the decision under 14 CFR 120.109(d). An employer that is not a Part 121 certificate holder and has 50 or fewer safety-sensitive employees needs only one trained supervisor to substantiate the decision.
Yes. A reasonable suspicion alcohol test can be ordered by one trained supervisor. The observations must be made during, just before, or just after the employee performs safety-sensitive duties.
Specific, current observations of the employee's appearance, behavior, speech, or body odor. For drugs, performance indicators also count. Rumors or past history alone are not enough. Our courses teach supervisors to write down what they saw and heard, when it happened, and who else was present so the decision is clear and well supported.
Within 2 hours of the determination under 14 CFR 120.217(d)(4). If it takes longer, the employer must document why. After 8 hours, the employer stops trying and records the reason.
The employer must first decide whether the conduct is a refusal. Neither the TPA nor the collection site makes that final call. Once the employer determines the employee refused, the refusal is treated as a violation. Beyond any company policy consequences, the employee must be removed from safety-sensitive duties. They cannot return to any safety-sensitive function, with any employer, until they successfully complete the Substance Abuse Professional process.
No. FAA has its own rules under 14 CFR Part 120, including the two-supervisor drug rule and recurrent training. Use this course for FAA supervisors and DOT Reasonable Suspicion Training for Supervisors for FMCSA, FTA, PHMSA, and USCG.
Yes. Someone must manage the testing program and receive results. That role is covered in FAA Designated Employer Representative Training (DER). The supervisor makes the reasonable cause decision, and the DER handles results and the next steps that follow.
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