Do Organizations Need Device-Maker BAT Training for DOT Alcohol Testing?

Clinics and employers sometimes assume Breath Alcohol Technician (BAT) training must come from the maker of the evidential breath testing (EBT) device on the shelf. Part 40 sets the instructor and proficiency rules. Device-maker factory courses are one way to meet them. They are not the only way for BAT qualification training.

What 49 CFR 40.213 requires

To act as a BAT or Screening Test Technician (STT) in the DOT alcohol testing program, a person must meet 49 CFR 40.213. Qualification training must follow the DOT Model BAT or STT Course or an equivalent curriculum (40.213(b)(1)). It must include proficiency on the alcohol testing procedures and on the particular ASD or EBT devices the technician will use (40.213(b)(2)).

The instructor must meet 40.213(b)(4) by regularly conducting DOT alcohol tests as an STT or BAT (as applicable) for at least a year, or by conducting that training under Part 40 for a year, or by successfully completing a train-the-trainer course.

After that training, BATs must complete seven consecutive error-free mock tests. STTs must complete five consecutive error-free mock tests (40.213(c)). The mocks must use the devices the technician will use on the job (40.213(c)(2)). Another person who meets the (b)(4) instructor paths must monitor the mocks in person or by real-time observation and interaction and attest in writing that they were error-free (40.213(c)(1)). Refresher training is required at least every five years (40.213(e)).

What Intoximeters says about factory instructor courses

Intoximeters publishes a Training and DOT BAT Procedures FAQ. On the question "Do I need to be trained as an instructor by Intoximeters to train Breath Alcohol Technicians for DOT workplace testing?" Intoximeters answers no, provided the instructor was trained by someone with at least one year of experience performing DOT tests or someone who has passed a train-the-trainer class, and provided the instructor follows the DOT Model Course or an equivalent curriculum.

That same Intoximeters FAQ separates calibration from BAT instruction. It states that anyone who calibrates the equipment must have a manufacturer certificate under 49 CFR 40.233, and that Intoximeters requires anyone who trains Calibration Technicians to keep a current Intoximeters Instructor certification. BAT qualification training is not the same as manufacturer-authorized calibration technician training.

Calibration remains a manufacturer-linked function

49 CFR 40.233(c)(5) requires that inspection, maintenance, and calibration of an EBT be performed by the manufacturer or by a maintenance representative certified by the manufacturer or by a state health agency or other appropriate state agency. That rule is about device care. It does not rewrite the 40.213 instructor paths for training BATs to run tests.

What organizations should verify

• The instructor meets 40.213(b)(4).
• Mocks use the same device models the site will deploy, with seven error-free BAT mocks or five error-free STT mocks.
• Documentation is available to employers and C/TPAs under 40.213(g).
• Calibration technicians, if used on site, have the manufacturer or state authorization required by 40.233.

Related collector and alcohol paths: how to become a Breath Alcohol Technician, who can monitor DOT mock collections, and initial training for collectors, BATs, and STTs.

Organizations can enroll teams through a Training Manager account in DOT Breath Alcohol Technician Training, DOT Alcohol Screening Test Technician (STT) Training, or Alco-Screen 02 STT Training. Sites that want an in-house alcohol instructor can use DOT Breath Alcohol Technician Train-the-Trainer.