FRA Reasonable Suspicion and Post-Accident Toxicological Testing Training for Supervisors is a federally required course that satisfies two distinct FRA training requirements under 49 CFR Part 219. The first is reasonable suspicion training for supervisors who may order a drug or alcohol test based on observed behavior, and the second is post-accident toxicological testing training for supervisors responsible for making testing determinations following a railroad accident or incident.
Developed by Andrew David Easler, Esq., an attorney and nationally recognized authority on DOT drug-free workplace compliance, this course meets the training requirements for supervisors of safety-sensitive railroad employees under 49 CFR Part 219 and the DOT drug and alcohol testing procedures under 49 CFR Part 40, and is valid in all 50 states, Canada, and any country that follows US DOT rules.
Supervisors will learn how to recognize the physical, behavioral, and performance indicators of probable drug use and alcohol misuse, understand the qualifying criteria for post-accident toxicological testing under 49 CFR Part 219 Subpart C, fulfill their role in post-accident collections, and properly document and report all observations and testing decisions in compliance with FRA regulations.
Available as online self-paced training, on-site instructor-led training, or SCORM courseware for use in third-party learning management systems. Certificates are available for immediate download upon completion.
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Published July 25, 2019
Andrew David Easler, Esq.
Course Author
Andrew David Easler, Esq.
Course Instructor
FRA Reasonable Suspicion and Post-Accident Toxicological Testing Training for Supervisors is a self-paced online course created by Andrew David Easler, Esq., an attorney and nationally recognized authority on DOT drug and alcohol compliance and drug-free workplace law.
This course covers two federally required training areas that are unique to FRA-regulated supervisors. The first is reasonable suspicion training, which teaches supervisors how to identify specific, contemporaneous, and articulable observations of an employee's appearance, speech, behavior, and body odor that establish the legal basis for ordering a drug or alcohol test under federal railroad regulations. The second is post-accident toxicological testing training, which covers the qualifying criteria, procedures, documentation requirements, and supervisor responsibilities that apply when a railroad accident or incident triggers a mandatory testing event under 49 CFR Part 219, Subpart C.
Reasonable suspicion is a documented, fact-based determination grounded in specific, immediate, and explainable observations of an employee's appearance, speech, behavior, or body odor that suggest potential substance abuse. For example, a supervisor may observe bloodshot eyes, slurred speech, an unsteady gait, unusually aggressive behavior, a noticeable change in work performance, or the smell of alcohol. When these observations are properly documented and reported, they establish the legal basis for ordering a drug or alcohol test under federal railroad regulations.
Post-accident toxicological testing is a separate and distinct obligation that applies when a railroad accident or incident meets the qualifying criteria outlined in 49 CFR Part 219, Subpart C. Supervisors must understand which events trigger mandatory testing, how to determine whether the criteria are met, what their specific responsibilities are in initiating and overseeing post-accident collections, and how to accurately document and report the results. Failure to initiate testing when required or to initiate testing incorrectly can expose the railroad and the supervisor to significant regulatory liability.
Federal railroad regulations require supervisors of safety-sensitive railroad employees to be trained in both reasonable suspicion determinations and post-accident toxicological testing procedures under 49 CFR Part 219 and 49 CFR Part 40 before they can fulfill these responsibilities. This course meets and exceeds those requirements by teaching supervisors how to make accurate, defensible determinations in both contexts while remaining fully compliant with FRA regulations. Completing this training also helps protect your organization from legal liability by ensuring supervisors follow the correct process every time.
Training certificates earned through this course are recognized in the United States, Canada, and any country that adheres to US DOT regulations, including supervisor training requirements for FRA-regulated employers operating under the DOT drug and alcohol testing program.
After successfully completing the online exam and post-accident toxicological testing exam, both learners and their managers can immediately download certificates directly from the platform.
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.
Questions about your course? Our US-based trainers help learners, managers, and supervisors by phone or email during business hours and respond quickly.
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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.
Buy two or more credits and get a free manager account. Invite employees, track completions, and keep training records in one place.
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.
by accurately identifying specific, contemporaneous physical, behavioral, and performance indicators of probable drug use and the symptoms of alcohol misuse based on an employee's appearance, behavior, speech, and body odor, establishing the legal basis for a reasonable suspicion determination under FRA regulations.
by demonstrating working knowledge of the federal railroad regulations governing drug and alcohol testing in safety-sensitive roles, including 49 CFR Part 40 (DOT Procedures), 49 CFR Part 219 (FRA), and the qualifying criteria outlined in 49 CFR Part 219, Subpart C. Supervisors will understand key terms such as "safety-sensitive position," the reasonable suspicion standard, and the mandatory testing triggers that apply to post-accident toxicological testing.
by applying FRA 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 railroad requirements.
by identifying which railroad accidents and incidents meet the qualifying criteria for mandatory testing under 49 CFR Part 219, Subpart C, understanding the supervisor's specific role in initiating and overseeing post-accident collections, and fulfilling all documentation and reporting obligations accurately and on time.
by understanding supervisor responsibilities under FRA and DOT regulations, employee rights, confidentiality obligations, the consequences of failing to initiate required testing, and the consequences of non-compliance for both the supervisor and the railroad.
by completing all required documentation accurately for both reasonable suspicion determinations and post-accident toxicological testing events, maintaining proper records, and ensuring every action taken is transparent, legally defensible, and consistent with FRA and DOT testing protocols under 49 CFR Part 40 and 49 CFR Part 219.
48 modules · 2 exams · 3 surveys
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
5-STEP Confrontation Format Immediate Action Required
Module 31
9-Step Confrontation Format-No Immediate Action Required
Module 32
Supervisor Tips
Exam
Supervisor Training Exam
Module 33
Introduction to Post-Accident Toxicological Testing
Module 34
General Conditions for Chemical Tests
Survey
General Conditions Knowledge Check
Module 35
Required Testing Events
Module 36
Conditions on Determinations
Module 37
Responsibilities of Railroads and Employees
Module 38
Drug and Alcohol Testing
Survey
PAT Testing Knowledge Check 2
Module 39
Post Accident Work and Recall
Module 40
Completing Post-Accident Toxicological Tests
Module 41
Reporting Tests and Refusals
Module 42
Analysis and Follow-Up
Module 43
Unlawful Refusals
Module 44
Appendix B and Quest Diagnostics
Module 45
Calculating Damages
Module 46
PAT Testing Criteria Chart
Module 47
PAT Testing Criteria Scenario 2
Survey
PAT Testing Knowledge Check
Module 48
PAT Testing Knowledge Check Answer
Exam
PAT Testing Final Exam
Built to meet training requirements in all 50 states.
Hardware
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Other requirements
Each supervisor responsible for regulated railroad employees. Working supervisors who are co-workers are excepted under 49 CFR 219.11(g). Railroads should confirm which of their supervisors fall under this requirement and make sure each one is trained before they make testing decisions.
Training on the signs and symptoms of alcohol and drug influence, intoxication, and misuse. It must also cover the criteria for FRA post-accident toxicological testing and the supervisor's role in those collections. Our courses cover both parts so supervisors are ready for a reasonable suspicion decision and for a qualifying accident.
About 3 hours. FRA supervisor training includes 2 hours on signs and symptoms and required post-accident toxicological testing training. This course covers both, with at least 1 hour on post-accident testing.
FRA runs its own post-accident testing program under Subpart C of Part 219. Supervisors must know which accidents qualify and what to do at the scene so specimens are collected correctly.
For alcohol, one trained supervisor can decide. A drug test requires two supervisors, at least one of whom must be on site and trained. These rules are in 49 CFR 219.303.
Specific, current, articulable observations of the employee's appearance, behavior, speech, or body odor. For drug tests, signs of chronic use or withdrawal can also count. Supervisors should record what they observed and when, since those notes support the decision if it is reviewed later.
Within 8 hours of the decision under 49 CFR 219.305. Supervisors should move quickly so the test is not lost.
No. The general DOT course does not cover FRA's post-accident toxicological testing content. Use this course for railroad supervisors and DOT Reasonable Suspicion Training for Supervisors for FMCSA, FTA, PHMSA, and USCG.
Yes. The railroad's program of instruction must be available to FRA on demand. Keep training records for every supervisor. Organized records make it easy to show which supervisors are trained and when they completed the course.
The railroad's designated employer representative handles results and removal from service. That role is covered in FRA Designated Employer Representative (DER).
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