FAA Annual Recurrent Training for Supervisors is an online refresher of approximately 1 hour for aviation supervisors who have completed initial reasonable suspicion training. It was developed by Andrew David Easler, Esq., an attorney focused on DOT drug and alcohol compliance.
Supervisors who make reasonable cause decisions use those skills rarely, which makes regular refreshers valuable. This course reviews the signs, the decision process, and the documentation steps so supervisors stay ready.
What This Course Covers
The course refreshes the core skills from initial training and brings supervisors up to date. Topics include:
- Physical, behavioral, and performance indicators of probable drug use
- Physical, behavioral, speech, and performance indicators of probable alcohol misuse
- The reasonable cause drug testing rule in 14 CFR 120.109(d). At least two supervisors, one of them trained, must substantiate and agree with the decision, with a one-supervisor exception for employers that are not Part 121 certificate holders and have 50 or fewer safety-sensitive employees.
- Reasonable suspicion alcohol testing and the 2-hour and 8-hour timelines in 14 CFR 120.217(d)
- How to document observations clearly and promptly
- Removal from duty, refusals, and the Substance Abuse Professional process
- Rule changes since the supervisor's last training
Recurrent training also gives supervisors a chance to review real situations they may have faced since their last course. Talking through what went well and what could improve makes the next decision clearer. Short, regular refreshers tend to work better than waiting until a supervisor feels unsure.
The course is self-paced, so supervisors can complete it around shift schedules and travel.
Who Needs This Training
Under 14 CFR 120.115, employers must implement a reasonable recurrent training program for supervisory personnel who make reasonable cause drug testing determinations in the years after initial training. The rule does not set a fixed interval or length. FAA Advisory Circular AC 120-126A calls a 12 to 18 month schedule a best practice, and this course of about 1 hour fits a yearly cycle.
The recurrent requirement applies to drug testing decisions. The FAA alcohol training rule in 14 CFR 120.223 requires initial training only, though most employers refresh both topics together.
This course is for supervisors at FAA-regulated employers who still make testing decisions for safety-sensitive aviation employees. It does not replace initial training. New supervisors should first complete FAA Reasonable Suspicion Training for Supervisors.
The course is written for FAA rules. FMCSA, FTA, PHMSA, and USCG require initial supervisor training only, covered by DOT Reasonable Suspicion Training for Supervisors.
Certificate and Compliance
Supervisors and their managers can download a certificate right after the supervisor passes the online exam. FAA requires employers to document all supervisor training in their testing program. Keep each completion record in the supervisor's file so it is ready for an inspection.
A lapse in recurrent training can lead to findings in an FAA inspection and can make a testing decision easier to challenge. Setting one yearly date for all supervisors is a simple way to keep everyone current.
The course is available as online self-paced training, onsite instructor-led training, or SCORM courseware for use in third-party learning management systems.