Frequently Asked Questions

Mock collection for drug and alcohol testing training through the course by following the instructions in your final assignment. A mock collection, also referred to as an "initial proficiency demonstration" or simply "mock," is conducted under the supervision of a qualified instructor. This exercise ensures you possess the necessary skills to collect specimens or perform tests accurately according to established procedures.

DOT allows the monitor to observe mock collections in person or by a means that provides real-time observation and interaction between the instructor and the trainee. That language appears in 49 CFR 40.33(c)(2) for urine collectors, 49 CFR 40.35(c)(2) for oral fluid collectors, and 49 CFR 40.213(c)(1) for BATs and STTs. A recorded video without live interaction does not meet the real-time observation and interaction rule. The monitor must still meet the experience or train-the-trainer paths in those sections and must attest in writing that the mocks were error-free. For who may serve as that monitor, see who can monitor DOT mock collections.

Mock collections are typically carried out via video conference. For these sessions, known as "dry" collections, you do not need another person present. On courses that ship training supplies, the supplies usually take 3-5 days to arrive, mock sessions can be booked as soon as the supplies are received, and the mocks begin after the online course is complete. On courses that don't ship supplies, mock sessions can be booked right after the online course is finished. A $150 cancellation or no-show fee per learner applies once a mock session is booked, unless the session is rescheduled at least 48 hours in advance. Please note that alcohol testing training supplies are not included in the training fee and must be purchased separately.

Learners will require a reliable internet connection, a computer, a webcam, and audio capabilities to enable the instructor to observe and communicate with them effectively.

During the virtual training, the instructor will guide you through the entire process, including:

• Accurately completing necessary paperwork
• Handling challenging scenarios such as dry bladder situations or test refusals
• Addressing any questions from other course sections
• Training on the proper chain of custody procedures
• Discussing relevant federal or state laws

Upon completing the required mock collections, you must submit the forms filled out during training as a single PDF, and the instructor will review these documents to ensure they are complete, correct, and error-free. If any issues are found, the instructor will reject the assignment and provide instructions for correction. After making the necessary adjustments, rescan the forms and re-upload them to the same assignment, and after completing all required steps, a certificate will be awarded.

When learners complete drug and alcohol testing training, they receive a qualification certificate. To prove their eligibility to collect specimens for drug and alcohol testing, collectors must be ready to provide documentation to DOT agency inspectors, employers, and employer-designated service agents, including C/TPAs.

Qualification documentation should detail their initial training and proficiency demonstration. Examples include certificates and signed letters from the qualified trainer who conducted the mandatory mock collections, confirming that the collectors have completed initial proficiency and the mandatory mock collection as required by regulation 40.33(g).

To qualify as a DOT urine collector, a trainee must complete five consecutive error-free mock collections (49 CFR 40.33(c)). The five mock collections must include:

• Two uneventful collections.
• One collection with an insufficient quantity of urine (shy bladder).
• One collection with a temperature out of range.
• One collection in which the employee refuses to sign the CCF and initial the specimen bottle tamper-evident seal.

A qualified instructor must monitor each mock collection in person or by a means that provides real-time observation and interaction, and must attest in writing that the mock collections were error-free. Training also covers when a directly observed collection is required.

Proper mock collections for drug and alcohol testing proves that learners have acquired the necessary skills to conduct accurate and reliable tests, and simulating the collection process enables trainees to practice and demonstrate proficiency in handling specimens, maintaining the chain of custody, and adhering to regulatory procedures.

What employers and C/TPAs should ask for

Under 49 CFR 40.33(g), a urine collector must keep documentation that shows the collector currently meets the qualification, proficiency, refresher, and error correction rules in that section. The collector must provide that documentation on request to DOT agency representatives and to employers and C/TPAs who are using or negotiating to use the collector's services. Oral fluid collectors have the same duty under 49 CFR 40.35(g). Breath Alcohol Technicians (BATs) and Screening Test Technicians (STTs) have a parallel duty under 49 CFR 40.213(g).

Before a clinic, collection site, TPA, or regulated employer puts a collector on DOT collections, the organization can ask for records that show:

• Completion of qualification training that covers the subjects listed in 49 CFR 40.33(b) (or 40.35(b) for oral fluid, or 40.213(b) for alcohol testing).
• Five consecutive error-free mock collections for urine (40.33(c)), with the monitor's written attestation that the mocks were error-free. For oral fluid, five consecutive error-free mocks are required for each device the collector will use (40.35(c)). For BATs, seven consecutive error-free mock tests are required. For STTs, five are required (40.213(c)).
• The date of the last refresher. Refresher training is required no less frequently than every five years and must meet the same qualification and proficiency rules as the initial training (40.33(e), 40.35(e), 40.213(e)).
• Any error correction training completed after a fatal or uncorrected flaw that cancelled a test, including the three error-free mocks and the written attestation (40.33(f), 40.35(f), 40.213(f)).

49 CFR 40.15(b) states that the employer is responsible for making sure service agents meet the qualifications in Part 40, and that the employer may require documentation. 49 CFR 40.15(c) states that the employer remains responsible for compliance even when a service agent is used, and that good-faith use of a service agent is not a defense in an enforcement action.

A free lab module, a vendor product course, or an association exam is not a substitute for the documentation above. For the difference between vendor learning modules and DOT qualification, see the FAQ on free lab and vendor collector training versus DOT qualification and whether Quest Diagnostics' free collector training is enough for DOT qualification. For how a collector becomes qualified step by step, see what qualifies a specimen collector and how to become a DOT specimen collector.

Organizations that need several collectors trained and tracked in one place can enroll a team through a Training Manager account in the DOT Urine Specimen Collector Training course, or use the DOT Specimen Collector Training bundle.

Drug and alcohol abuse can have serious consequences, affecting both individuals dealing with addiction and employers. These issues are particularly concerning in the transportation sector, as they can compromise a driver's ability to safely transport passengers and lead to accidents, injuries, and legal repercussions. DOT (Department of Transportation) drug testing supervisor training is essential to address these challenges.

Who needs DOT drug testing supervisor training? According to U.S. government regulations, any supervisor responsible for making reasonable suspicion testing decisions must complete a qualifying training program. Furthermore, all transportation companies must adhere to these rules regardless of their size. Smaller employers with fewer than 50 covered drivers were never exempt. They were phased into FMCSA testing on January 1, 1996.

Covered employees have separate requirements. FMCSA requires employers to give drivers educational materials about the testing rules and the employer’s policy (49 CFR 382.601). Some agencies also require employee training. FTA requires at least 60 minutes (49 CFR 655.14(b)(1)), and FAA requires a reasonable initial training program for employees with no set length (14 CFR 120.115(c)(1)).

While DOT drug testing supervisor training programs may vary among providers, they must meet each DOT agency’s rule. FMCSA, FTA, PHMSA and FAA require at least 60 minutes on alcohol misuse and at least 60 minutes on controlled substance use (for example, 49 CFR 382.603). FRA sets required topics without a minimum length (49 CFR 219.11(g)), and USCG requires at least 60 minutes of supervisor training (46 CFR 16.401(b)). In these sessions, attendees will learn how to:

• Understand the impact of drug and alcohol abuse
• Recognize the potential consequences of unreported abuse
• Implement and enforce company-wide alcohol and drug use policies
• Report employees suspected of drug and alcohol abuse

DOT drug testing supervisor training aims to create a safer environment and provide support to employees struggling with substance abuse or alcohol addiction. Supervisors at DOT-regulated companies who make reasonable suspicion decisions need this training. A qualified program helps ensure compliance with federal and state requirements.

Reasonable suspicion training is mandatory for workplace safety and compliance, especially in sectors regulated by the Department of Transportation (DOT) and non-DOT-regulated industries. Each DOT agency sets this training in its own rule, such as 49 CFR 382.603 for FMCSA, to establish clear standards for reasonable suspicion among DOT-regulated employers. Testing itself follows 49 CFR Part 40.

In non-DOT sectors, reasonable suspicion training is just as important. While no specific federal regulations like the DOTs exist, this training equips employers and supervisors with the knowledge and skills to identify and manage situations where an employee might be under the influence of drugs or alcohol. This ensures a safe and productive workplace and helps businesses establish policies and procedures that align with state laws and best practices.

Reasonable suspicion training involves making "articulable observations that can be objectively verified by some documentation, which, taken together with rational inferences from those observations, reasonably warrant further investigation." This is used to determine if an employee is under the influence of drugs or alcohol and can serve as sufficient grounds for reasonable suspicion testing.

Supervisors and managers in the following industries must undergo this training once in their lifetime, except for the FAA, which requires recurrent training for supervisors in later years with no fixed interval:

• Federal Motor Carrier Safety Administration (FMCSA)
• Federal Aviation Administration (FAA)
• Federal Transit Administration (FTA)
• Federal Railroad Administration (FRA)
• United States Coast Guard (USCG)
• Pipeline and Hazardous Materials Safety Administration (PHMSA)

Non-DOT Reasonable Suspicion Training is designed for supervisors in non-regulated industries and is similar to DOT training. It provides workplace supervisors with the legal knowledge to conduct drug and alcohol testing according to company policies and state laws. It ensures adherence to company guidelines and existing legal standards, helps maintain workplace safety, maintains consistent testing procedures, and reduces the risk of discrimination lawsuits.

Transportation companies have a responsibility to their customers and clients to provide safe, reliable transport from one place to another. That applies whether you run a bus company, a limo company, an airline, or something completely different. While there are several important aspects of safety that revolve around employee training and vehicle maintenance, drug and alcohol abuse can be a significant threat. DOT drug testing supervisor training provides managers and supervisors with the skills and knowledge to cope with this issue.

Is It Really Necessary?

Yes, DOT drug testing supervisor training is necessary. The federal government mandates that all transportation companies, regardless of the number of covered employees, provide supervisors with access to a qualified training program. The government also mandates that all transportation companies create a drug and alcohol abuse policy and supply all drivers/vehicle operators with a copy of that policy.

What is DOT Drug Testing Supervisor Training?

You’ll find a degree of variation in the training and education industry when it comes to this type of training, but all programs must provide participants with the same core knowledge. Programs generally include the following:

• 60 minutes of training on alcohol misuse
• 60 minutes of training on controlled substances

Under FMCSA, FTA and PHMSA rules, and for FAA initial training, the program must total at least 120 minutes, with separate blocks of at least 60 minutes on alcohol and 60 minutes on controlled substances. FRA lists required topics without a minimum length, and USCG requires at least 60 minutes on drugs.

The skills learned during these courses will provide supervisors with the ability to do several things. Chief among those is the ability to identify the signs and symptoms of drug and alcohol abuse on the part of drivers and other transportation employees. Supervisors will also be able to enforce the company’s policy regarding drug and alcohol use (usually a zero-tolerance policy), as well as provide help for employees struggling with drug and alcohol problems, such as addiction.

Finding the Right DOT Drug Testing Supervisor Training

There are two primary formats for delivering drug and alcohol supervisor training for transportation companies – classroom and online courses. Traditional classroom courses are beginning to fall by the wayside due to their inflexibility and cost. Online DOT drug testing supervisor training has become the most popular option because it can be tailored to meet specific scheduling needs, is very affordable, and can be completed from the office or even from home.

Transportation companies employ safety-sensitive employees. These might be airline pilots, bus drivers, railroad engineers, or some other type of professional. However, all employees of DOT companies play an important role in safeguarding passengers and customers. DOT mandatory drug and alcohol awareness training helps ensure that all employees have the information necessary to understand not only the impacts of drug and alcohol use on their lives but where to seek help and the company’s policy on drug and alcohol use on the job.

How Long Does Awareness Training Take?

The duration of any DOT mandatory drug and alcohol awareness training program depends on the company offering the program, or the training method the employer chooses. DOT companies are free to provide in-house training for their employees in several different ways, including video courses, live presentations, and information packets. They are also free to work with a qualified training provider to ensure accurate information dissemination for employees. Requirements differ by DOT agency. FTA requires at least 60 minutes of training for covered employees on the effects and consequences of prohibited drug use and the signs and symptoms that may indicate drug use (49 CFR 655.14(b)(1)). FAA requires a reasonable initial training program for employees but sets no minimum length and no recurrent training for employees (14 CFR 120.115(c)(1)). USCG requires drug and alcohol education and training for crewmembers without a set length (46 CFR 16.401). FMCSA, FRA and PHMSA require employers to give covered employees educational materials about the rules and the company policy (49 CFR 382.601, 49 CFR 219.23(c), and 49 CFR 199.113(b) and 199.239). Whatever the format, the program should leave time for employees to take in the information and ask questions.

What Should DOT Mandatory Drug and Alcohol Awareness Training Include?

Any DOT drug and alcohol awareness training program should include some specific information. This includes hotline telephone numbers for assistance, as well as information about the person or persons answering questions about the program. It should detail the conduct expected of employees, as well as the signs and symptoms of drug and alcohol use on the job. The program should also explain the ramifications and repercussions of abuse on the job, as well as what constitutes a refusal to test and what happens should an employee choose to refuse to test.

Supervisor Training

While employee education and training requirements vary by agency, supervisors who make reasonable suspicion decisions must complete more rigorous training before making those decisions. FMCSA, FTA, PHMSA and FAA require at least 60 minutes on drug use and at least 60 minutes on alcohol misuse. FRA sets required topics without a minimum length (49 CFR 219.11(g)), and USCG requires at least 60 minutes (46 CFR 16.401(b)). FAA also requires a reasonable recurrent training program for supervisors who make reasonable cause decisions, without a fixed interval (14 CFR 120.115(c)(4)). A reasonable suspicion test must be based on observations by a trained supervisor (for example, 49 CFR 382.307(c)).

The right DOT drug and alcohol awareness training company can provide invaluable benefits, and ensure that employees receive accurate, essential training.

Employers are lawfully allowed to implement in-house drug testing programs (with some exceptions) to maintain a safe and drug-free workplace. Compared to outsourcing, in-house drug and alcohol testing can be more efficient and financially beneficial.

Legal and Practical Advantages of On-Site Drug Testing

In-house drug testing provides an immediate and flexible approach to ensuring a drug-free environment in the workplace. It's important to understand the distinction between DOT and non-DOT drug testing:

1. DOT (Department of Transportation) Drug Testing: This pertains to specific regulations the U.S. Department of Transportation sets. It is mandatory for certain safety-sensitive positions, primarily in the transportation industry, such as truck drivers, pilots, and railroad workers. DOT tests have strict protocols regarding the drugs tested for, the testing methods, and how results are reported. On-site or instant screening is never allowed for DOT drug tests. An employer can run its own DOT collection site with qualified collectors, but every DOT specimen must be tested at an HHS-certified laboratory (49 CFR 40.210), and a Medical Review Officer must verify the result before any action is taken.

2. Non-DOT Drug Testing: These tests are not bound by DOT regulations and can be tailored to an organization's needs. While they ensure a safe and productive work environment, they don't have the stringent requirements of DOT tests. Instant on-site screening can be used for non-DOT tests where state law allows it. A non-negative screen should be sent to a laboratory for confirmation before any action is taken, and some states require this.

Drawbacks of Outsourced Drug Testing

Using an external lab can be cumbersome and expensive. It involves coordinating with the lab, incurring service costs, and potentially dealing with timing challenges for post-incident tests. In an accident, for example, waiting for a lab technician to arrive may delay testing, and substances like alcohol might no longer be detectable. After-hours services can also lead to significant additional charges.

Economic and Operational Benefits of In-House Testing

In-house testing, however, addresses these issues. By training existing staff to conduct these tests, employers get timely results at a fraction of the cost. For instance, running a urine test in-house costs approximately $15 instead of an average of $60 at an external lab. Over time, this difference can result in substantial savings, especially for a company that conducts regular screenings.

The lower cost is due to eliminating the need for an on-site technician visit from the lab, which adds to the expense of outsourced services. Also, given the scarcity of these labs, their prices can be pretty high. Once state-specific protocols and additional procedures are added, the costs can exceed the base amount.

Immediate Action for Safety

Most importantly, on-site testing facilitates rapid response when safety is concerned. If a non-DOT screen returns a non-negative result, immediate safety steps can be taken while the laboratory confirms it, as company policy and state law allow. For DOT tests, an employee may not be removed from safety-sensitive duty based on an unverified drug test result (49 CFR 40.21). This level of responsiveness is not achievable with external testing, where waiting for results could pose unnecessary risks.

The expanding focus on workplace safety and maintaining a drug and alcohol-free environment has created new career and business opportunities, including the role of a Breath Alcohol Technician (BAT). BATs conduct breath alcohol tests to determine impairment, essential for safety in industries regulated by the Department of Transportation (DOT).

Training

To become a BAT, a person must complete a qualifying training course. Course duration varies, with in-person training lasting up to seven hours and online courses typically shorter. The course covers equipment use, measurement reading, calibration, and managing individuals during tests. For those working with DOT-regulated companies, the training must comply with 49 CFR Part 40 and can be done on most modern DOT Breath Alcohol Testing devices (Breathalyzers).

Mock Tests

Qualification training, often called "Certification training," requires completing seven consecutive error-free mock tests (49 CFR 40.213(c)), simulating breath alcohol tests under a qualified instructor's observation. These mock tests not only officially qualify the technician to perform testing but also help them competently handle the equipment, follow procedures, and record results accurately.

Refresher Training

Breath Alcohol Technicians must undergo refresher training every five years to stay qualified and up to date with the latest procedures and regulatory changes. This process involves retaking the initial training course, which covers the fundamental aspects of breath alcohol testing, including equipment use, measurement reading, device calibration, and managing individuals during tests.

In addition to the course, BATs must complete another mock test series. These mock tests are crucial as they allow technicians to demonstrate their ongoing competency in handling the testing equipment, following proper procedures, and accurately recording results. By completing these mock tests under the supervision of a qualified instructor, technicians can ensure they continue to meet industry and regulatory standards.

Refresher training helps maintain high standards of testing accuracy and reliability, ensuring that all breath alcohol tests are conducted in accordance with the latest best practices and legal requirements. This continuous education is essential for upholding workplace safety and compliance across DOT-regulated and non-DOT-regulated environments.

Risks of Not Being Properly Qualified

Not being properly qualified as a Breath Alcohol Technician carries significant risks. Inaccurate test results can lead to false positives or negatives, potentially allowing impaired individuals to continue working in safety-sensitive positions or wrongly penalizing sober employees. This compromises workplace safety and increases the likelihood of accidents and injuries, and testing without being properly qualified will result in non-compliance with federal regulations, such as those mandated by the DOT, and can result in severe legal repercussions, including fines, sanctions, and lawsuits from employees claiming wrongful termination or discrimination.

BAT and STT qualification and refresher training

BATs and STTs receive qualification training that follows the DOT Model BAT or STT Course, or a course of instruction equivalent to it, and includes training to proficiency on the specific ASD or EBT the technician will use (49 CFR 40.213(b)). After qualification training, a BAT completes seven consecutive error-free mock tests and an STT completes five consecutive error-free tests (49 CFR 40.213(c)). Refresher training that repeats the qualification training and the proficiency demonstration is due at least once in each five-year period (49 CFR 40.213(e)).

Understanding why DOT drug testing training matters starts with the rules themselves. DOT drug testing rules began in 1988 and 1989. In 1991, Congress passed the “Omnibus Transportation Employee Testing Act of 1991,” which required drug and alcohol testing of safety-sensitive transportation employees to protect the American people from transportation workers who may be abusing substances while on the job. Pilots drinking on the job and truckers under the influence may be what comes to mind, but these regulations include a wide range of other safety-sensitive duties including railroad, transit, and pipeline workers. Nuclear power plant workers are tested under separate Nuclear Regulatory Commission rules (10 CFR Part 26). DOT procedures continue to set the bar for collection procedures and Drug-Free Workplace policies across the United States.

Highest Standards in the Industry

Since Congress passed the “Omnibus Transportation Employee Testing Act of 1991” the United States Department of Transportation has been a leader in drug testing regulation. It was among the first to adopt and require reliable standards for workplace testing, drug-free workplace policies, and collection procedures. Updated many times to address changes and procedural weaknesses, the DOT regulations in 49 CFR Part 40 are widely regarded as the benchmark for workplace drug testing in the United States, and many non-DOT programs model their procedures on them.

Safety and Security of the Collection Process

The DOT has been refining the collection process since the late 1980s and continues to update it. That ongoing improvement is one of the benefits of DOT training. Every five years, DOT collectors undergo refresher training (49 CFR 40.33(e)) to learn about changes and to “refresh” their memory on prior training procedures. Because the DOT has an important mandate to protect the public from accidents related to substance abuse, its procedures are built around collection safety, security, and specimen integrity.

Reduce Liability

Consider Bob and John. Bob has his Driver’s License and John has a Driver’s License, a Racing License, and is a trained stunt driver. Both are legally able to drive on the highway, but who would be best able to handle a potential head-on collision? John’s training as a racer and a stunt driver would certainly give him the best chance at avoiding that serious accident. This situation can be used to compare the difference in risk and potential liability for drug testing collectors who simply have Non-DOT collection training (Bob) and those who are trained in both Non-DOT and DOT regulations (John). Even during Non-DOT collections, a trained DOT Collector is better able to recognize, handle, and avoid the risk of a potentially hazardous collection.

More Opportunity

Whether a person already owns a drug testing business, is starting one, or is a plan administrator, DOT training can improve that person’s opportunities and effectiveness. DOT training includes many procedural guidelines that can be crossed over easily into less regulated, non-DOT collections to improve the safety and security of the overall collection process. Even for a collector who never performs a DOT collection, the benefits for all future collections make DOT training a valuable investment, and DOT testing is common across the transportation industry. According to the Bureau of Transportation Statistics, transportation and transportation-related industries employed about 16.2 million people in 2025, including about 6.6 million in the transportation and warehousing industry (BTS Transportation Economic Trends). DOT agency and U.S. Coast Guard testing rules together cover approximately 6.5 million employees who perform safety-sensitive functions (ODAPC). In May 2025, there were about 2.1 million heavy and tractor-trailer truck drivers in the United States (BLS Occupational Employment and Wage Statistics). The opportunity is there for collectors with the skills, training, and ambition to take the first step.

A reasonable suspicion drug test may be conducted if an employer has a good faith belief that an employee is under the influence of drugs or alcohol while on the job. This belief must be based on specific, contemporaneous, articulable observations concerning the appearance, behavior, speech, or body odors of the employee.

These observations should be made by a supervisor or manager who has been trained to recognize the symptoms of drug and alcohol use. The employer must also have a written policy in place that outlines the circumstances under which a reasonable suspicion drug test may be conducted.

For reasonable suspicion training, go here: https://learnlaws.com/course/dot-reasonable-suspicion-training

A specimen collector, also known as a drug testing collector, is a trained individual responsible for performing drug testing and collecting samples from individuals. The specimen could be urine, hair, saliva, or even blood, though urine is the most commonly used sample for drug testing because it is regulated by the DOT under 49 CFR Part 40. However, the most popular drug testing method may change now that regulations allow for DOT Oral Fluid drug testing.

The role of a specimen collector is not just limited to the actual collection. Here's a brief overview of a collector's duties:

1. Preparing for the Collection: This involves setting up the collection site, ensuring all necessary supplies are available, and preparing all necessary documentation.

2. Verifying the Identity of the Individual: Before the collection process begins, the specimen collector must verify the identity of the tested individual. This is crucial to ensure the integrity of the testing process.

3. Explaining the Collection Process: The collector explains the collection process to the individual being tested to ensure they understand the procedure and their rights.

4. Collecting the Specimen (sample): The collector will provide the individual with the necessary materials and instruct them on collecting the sample. A urine drug test, for example, would typically involve the individual going into a private restroom and providing a urine sample in a collection container.

5. Maintaining Chain of Custody: The collector is responsible for maintaining the chain of custody, which is documenting the handling and storage of the sample from when it's collected until it's disposed of. This is crucial for ensuring the sample's integrity and the test results accuracy.

6. Shipping the Sample: Once the sample has been collected and sealed, the specimen collector prepares it for shipment to the laboratory, where it will be tested. The collector must follow specific procedures to ensure the sample is shipped safely and securely.

It's important to note that a specimen collector should be properly trained to perform these duties professionally, respectfully, and legally. Proper training helps ensure the testing process's integrity and respects the rights and dignity of the individuals being tested.

Yes, there is a difference between a DOT drug test and a non-DOT or regular drug test. A DOT drug test is a specific drug test required by the United States Department of Transportation (DOT) for employees in safety-sensitive positions. These positions include commercial drivers, pilots, and railroad workers.

A DOT-required drug test is designed to detect the presence of certain drugs in a person's system that could impair their ability to perform safety-sensitive functions. The tested drugs include marijuana, cocaine, amphetamines, opioids and phencyclidine (PCP), and they follow a strict set of guidelines and procedures set forth by the DOT. It requires a urine sample that a certified laboratory analyzes. The testing process is closely monitored to ensure accuracy and reliability.

On the other hand, a regular drug test (often called a non-DOT drug test) is a broader term that can refer to any drug test that the DOT does not specifically mandate. Employers may use regular drug tests in various industries to screen for drug use among employees or use them in other settings, such as in healthcare or legal contexts.

Regular drug tests may test for a broader range of drugs than a DOT drug or alcohol test and may use different testing methods, such as saliva, blood, or hair drug testing. However, the testing procedures and requirements may vary depending on the test's specific circumstances and state regulations.

No, the United States Department of Transportation (DOT) is not regulated by the Occupational Safety and Health Administration (OSHA). While both agencies are part of the United States federal government, they have different areas of jurisdiction and responsibility. Their rules can still meet on the same worksite. On wheel chocking, for example, OSHA says: “DOT's regulation preempts enforcement and DOT has authority. However, if the vehicle is an intrastate truck, OSHA has authority. Only another Federal agency may preempt OSHA's authority.” OSHA also notes that while trucks travel on public highways, DOT preempts OSHA only for hazards addressed by FMCSA regulations.

The DOT regulates transportation-related activities, including moving goods and people by truck, train, airplane, and other means. Its regulations cover a range of issues related to transportation safety, including drug and alcohol testing, security, and environmental concerns. At the same time, OSHA ensures safe and healthy working conditions for employees in all industries. Its regulations cover many workplace safety issues, such as using hazardous materials, equipment safety, and workplace ergonomics.

However, there are some areas where the regulations of the DOT and OSHA may overlap. For example, both agencies have rules related to handling hazardous materials and work together to ensure that these regulations are consistent and complementary.

While the DOT and OSHA are federal agencies that regulate different safety aspects, they have other areas of responsibility, and they are not directly controlled by one another.

Medical Review Officer (MRO) is a licensed physician specializing in interpreting and evaluating drug test results in the workplace. MROs play a critical role in the drug testing process for employers, particularly those in the transportation, healthcare, and manufacturing industries, where safety is a top priority.

MROs are responsible for verifying drug test results and determining whether an individual has a legitimate medical reason for a positive test result, such as a valid prescription for a medication that could cause a positive test. They also ensure the privacy and confidentiality of the drug test results and work closely with laboratories, employers, and employees to ensure compliance with applicable laws and regulations.

In addition to reviewing drug test results, MROs also serve as a resource for employers and employees on drug testing policies and procedures and drug and alcohol abuse prevention and treatment programs. Overall, the role of the MRO is to help maintain a safe and drug-free workplace by ensuring the accuracy and integrity of drug testing programs.

MRO qualifications

An MRO is a licensed physician (Doctor of Medicine or Osteopathy). A physician licensed in any U.S., Canadian, or Mexican jurisdiction may perform MRO services for covered employees in other jurisdictions (49 CFR 40.121(a)). The MRO has knowledge of and clinical experience in controlled substances abuse disorders, knowledge of adulterated and substituted specimens, and knowledge of Part 40, the DOT MRO Guidelines, and the DOT agency rules for the employers served (49 CFR 40.121(b)). Qualification training covers collection procedures, chain of custody, interpretation of drug and validity test results, and the MRO role, and it is followed by an examination given by a nationally recognized MRO certification board or subspecialty board. Requalification training and a new examination are required in each five-year period (49 CFR 40.121(c) and (d)).

DOT drug tests are federally regulated with strict guidelines for specific transportation industries, ensuring uniformity and compliance across safety-sensitive positions. These tests follow the Department of Transportation (DOT) standards, which include specific procedures, chain-of-custody protocols, and the use of HHS-certified laboratories to screen for substances like marijuana, cocaine, opioids, amphetamines, and PCP.

Non-DOT drug tests are governed by individual company policies and state laws, providing more flexibility in testing procedures and the range of substances screened. Non-DOT tests can include a broader spectrum of drugs, such as benzodiazepines and barbiturates, tailored to the specific needs and regulations of the employer.

Training in drug and alcohol testing is required for DOT collectors (49 CFR 40.33) and strongly recommended for non-DOT collectors to ensure drug screen compliance with both DOT and non-DOT. Training teaches collectors the specific procedures for DOT-regulated industries to maintain proper chain-of-custody, maintain compliance with federal regulations, and safeguard public safety. For non-DOT settings, adequate training also helps establish consistent and effective testing protocols that align with company policies and state laws. This training ensures the accuracy and reliability of test results, supports workplace safety, and minimizes legal risks by ensuring adherence to established guidelines and procedures.

The difference between DOT and non-DOT drug tests lies primarily in the regulatory standards and the industries they apply to:

Regulatory Authority:

• DOT Drug Tests: These tests are regulated by the Department of Transportation (DOT) and are mandated for employees in safety-sensitive positions within transportation industries, such as trucking, aviation, railroads, transit, and pipelines. The regulations are outlined in 49 CFR Part 40.
• Non-DOT Drug Tests: These tests are not regulated by the DOT. Instead, they are conducted according to company policies and state laws. Non-DOT tests apply to employees in industries outside the scope of DOT regulations.

Testing Procedures:

• DOT Drug Tests: Follow strict procedures and guidelines set by the DOT, including specific testing protocols, chain-of-custody requirements, and the use of HHS-certified laboratories. The test typically screens for five substances: marijuana, cocaine, opioids, amphetamines, and PCP.
• Non-DOT Drug Tests: The procedures vary widely depending on the employer's policies and state regulations. These tests can screen for a broader range of substances beyond the DOT's five-panel test, including additional drugs like benzodiazepines, barbiturates, and others.

Documentation and Reporting:

• DOT Drug Tests: Require detailed documentation and reporting to ensure compliance with federal regulations. Positive results must be verified by a Medical Review Officer (MRO), who reports them to the employer’s Designated Employer Representative (DER) (49 CFR 40.167(b)). For FMCSA-regulated drivers, the MRO also reports verified positives to the FMCSA Drug and Alcohol Clearinghouse (49 CFR 382.705). FAA has a similar rule for employees who hold airman medical certificates, whose verified positives the MRO also reports to the Federal Air Surgeon (14 CFR 120.113(d)).
• Non-DOT Drug Tests: Documentation and reporting are determined by the employer's policy and applicable state laws. There may be less stringent documentation requirements compared to DOT tests.

Consequences of Positive Results:

• DOT Drug Tests: Positive results can lead to immediate removal from safety-sensitive duties, mandatory evaluation by a Substance Abuse Professional (SAP), and completion of a return-to-duty process before resuming safety-sensitive functions.
• Non-DOT Drug Tests: Consequences of positive results vary by employer and state law. Employers may have more flexibility in handling positive tests, including disciplinary actions, rehabilitation programs, or termination.

Frequency of Testing:

• DOT Drug Tests: Employees are subject to various types of testing, including pre-employment, random, post-accident, reasonable suspicion, return-to-duty, and follow-up testing, all following DOT guidelines.
• Non-DOT Drug Tests: Testing frequency and types depend on the employer's policies. While some companies may adopt testing categories similar to the DOT, others may have different requirements.

DOT drug tests are federally regulated with strict guidelines for specific transportation industries. In contrast, non-DOT drug tests are governed by individual company policies and state laws, offering more flexibility in testing procedures and substances screened.

DOT regulations signify the stringent oversight exerted by the U.S. Department of Transportation (DOT), a federal agency established in 1966. The DOT is instrumental in fostering a safe, efficient, modern transportation ecosystem, unifying various transportation modes, including air, road, rail, and maritime. Regulations were implemented to mitigate the risks associated with the fast-evolving transportation landscape, ensuring safety, environmental sustainability, and operational efficiency. Various agencies under the DOT umbrella, like the FMCSA, FRA, FAA, FTA and PHMSA, enforce these regulations across different sectors of the transportation industry. The USCG is part of the Department of Homeland Security, not DOT, and follows DOT procedures for drug testing.

DOT drug and alcohol testing rules come from these agencies

• Federal Motor Carrier Safety Administration (FMCSA)
• Federal Railroad Administration (FRA)
• Federal Aviation Administration (FAA)
• Federal Transit Administration (FTA)
• Pipeline and Hazardous Materials Safety Administration (PHMSA)
• United States Coast Guard (USCG), part of the Department of Homeland Security, which follows DOT procedures for drug testing only

DOT regulations are intended to promote safety in transportation and prevent accidents, injuries, and fatalities. These regulations cover a wide range of topics, including driver qualification, vehicle maintenance and inspection, hours of service, hazardous materials transportation, and drug and alcohol testing.

Examples of how DOT regulates covered employers

Federal Motor Carrier Safety Administration (FMCSA):

• Drug and Alcohol Testing: FMCSA mandates testing for commercial drivers, including pre-employment, random, post-accident, and follow-up testing. It sets the protocols for the collection and handling of specimens and the reporting of results.
• Reasonable Suspicion Training: Supervisors must receive training on identifying signs of drug and alcohol use, leading to reasonable suspicion testing.
• Hours of Service Regulations: This regulation ensures that commercial drivers adhere to specified limits on the number of driving and working hours to prevent fatigue-related accidents.

Federal Railroad Administration (FRA):

• Drug and Alcohol Testing: It requires railroad employees performing safety-sensitive functions to undergo regular and random drug and alcohol testing.
• Reasonable Suspicion Training: Supervisors in the railroad industry are trained to identify and address employees who may be impaired by drugs or alcohol.
• Railroad Track Maintenance: Standards and regulations are enforced for the inspection, maintenance, and repair of railroad tracks to ensure safe and efficient railroad operations.

Federal Aviation Administration (FAA):

• Drug and Alcohol Testing: Airline employees, especially pilots and aircrew, are subject to stringent pre-employment, random, and post-accident drug and alcohol testing.
• Reasonable Suspicion Training: Supervisors and managers are trained to detect signs of drug and alcohol impairment.
• Aircraft Maintenance: The FAA sets and enforces standards for the maintenance and inspection of aircraft, ensuring they are safe to operate.

Federal Transit Administration (FTA):

• Drug and Alcohol Testing: Oversees the drug and alcohol testing of employees in public transportation, ensuring that operators are sober and fit for duty.
• Reasonable Suspicion Training: Supervisors are trained to make informed decisions for testing based on observable signs of impairment.
• Public Transportation Safety: Regulations are enforced to ensure the safety and security of public transportation systems, including buses and subways.

Pipeline and Hazardous Materials Safety Administration (PHMSA):

• Drug and Alcohol Testing: Mandates testing for individuals involved in the operation, maintenance, and emergency response of pipeline and hazardous materials transport.
• Reasonable Suspicion Training: Training supervisors to identify the symptoms and behavior associated with drug and alcohol use.
• Pipeline Safety Standards: PHMSA sets regulations for the design, construction, operation, and maintenance of pipelines to prevent leaks and other hazards.

United States Coast Guard (USCG):

• Drug and Alcohol Testing: Mandates rigorous drug and alcohol testing protocols for maritime employees to ensure safety at sea.
• Reasonable Suspicion Training: Supervisors are trained to identify signs of impairment to ensure maritime safety and compliance.
• Vessel Safety Checks: The USCG inspects vessels to ensure they are seaworthy, equipped with proper safety gear, and comply with federal laws and regulations.

Each of these agencies has a specific focus within the transportation sector, ensuring that not only are drug and alcohol regulations enforced but also that other safety, security, and operational standards are met. These additional examples are key aspects of each agency's broader regulatory framework.

The U.S. Department of Transportation (DOT) requires drug and alcohol testing for employees in safety-sensitive positions to help ensure the safety and security of transportation systems. Drug and alcohol use can impair an employee's ability to perform critical job functions, particularly in safety-sensitive positions such as commercial drivers, pilots, and railroad workers.

Drug and alcohol testing is designed to deter drug and alcohol use, identify employees who may have a substance abuse problem, and assist those employees in getting the help they need. DOT drug and alcohol testing also helps to identify and remove from safety-sensitive positions those employees who test positive for drugs or alcohol.

The specific drug and alcohol testing requirements for DOT-regulated employers are outlined in the DOT's regulations, which specify which substances must be tested for, the types of tests that must be used, the procedures for sample collection and testing, and the consequences of a positive test result.

Overall, the DOT requires drug and alcohol testing to promote safety in transportation industries by deterring substance abuse, identifying and assisting employees who may have a substance abuse problem, and removing from safety-sensitive positions those employees who test positive for drugs or alcohol.

Reasonable suspicion training is required for DOT-regulated supervisors to help them identify and respond to potential drug and alcohol use by employees in safety-sensitive positions.

The DOT requires that supervisors receive this training to ensure that they can recognize signs and symptoms of drug and alcohol use and take appropriate action when necessary.

Training is critical to maintaining a safe workplace and preventing accidents, injuries, and fatalities. Supervisors who receive this training are better equipped to identify potential substance abuse issues and take appropriate action, such as removing an employee from safety-sensitive duties, referring the employee for testing, and ensuring that the employee receives appropriate treatment and follow-up.

Overall, reasonable suspicion training is an essential component of the DOT's drug and alcohol testing program and helps to ensure that supervisors are prepared to take action when necessary to promote safety in transportation industries.

A DER, or Designated Employer Representative, plays a key role in many drug and alcohol-free workplace program functions[1]. A DER must remove an employee from safety-sensitive duties after a verified positive drug test, a refusal to test (including an adulterated or substituted result), or an alcohol test of 0.04 or higher (49 CFR 40.23). An alcohol result of 0.02 to 0.039 requires temporary removal under the DOT agency’s rules. DOT rules do not allow removing an employee just because a drug test was performed, before the MRO verifies the result (49 CFR 40.21). When further information is needed about the company’s alcohol and drug policies, the DER is responsible and is the best source of accurate information regarding drug and alcohol testing.

What Role Does the DER Play?

A DER is:

• A company employee (a contractor cannot be a DER).
• Someone who should be trained specifically to be a DER. Part 40 does not require DER training, but it is strongly recommended.
• Someone readily available to make crucial policy determinations for employees.

The main purpose of a DER is to be the authority on federal, state, and company drug and alcohol-free workplace policies. The DER is in charge of ensuring the safe and timely removal of any employee found in violation of company policy.

A company may have multiple DERs to ensure availability during shifts or in an emergency[2]. The owner or employer of a small business may also act personally as a DER[3] under §40.3, but the law does not permit one DER to be under contract for multiple companies.

A DER is responsible for the operation of the company's drug and alcohol-free workplace policy, meaning she is responsible for all of the following and more:

• Educating employees on the policy
• Ordering drug and alcohol tests
• Ensuring program compliance with applicable regulations
• Removing employees from safety-sensitive functions
• Making certain refusal to test determinations
• Offering advice to supervisors regarding suspicion determinations
• Maintaining all documentation
• Reviewing results from Medical Review Officers (MROs) and Breath Alcohol Technicians (BATs)[5]
• Ensuring employee and supervisor training and records are up-to-date and comprehensive.

Should a DER Take Reasonable Suspicion Training?

Yes, anyone designated as a DER should take reasonable suspicion training and be properly trained in best practices regarding drug and alcohol-free workplace policies. Since a DER is essentially the company drug and alcohol-free workplace guru, it is imperative that the DER not only learn the signs and symptoms of drug and alcohol use but that the DER become the company expert in reasonable suspicion determinations.

To register for the Reasonable Suspicion Training course, or for more information on DER training, visit our DER training page.

References:

[1] https://www.transportation.gov/sites/dot.gov/files/docs/ODAPC_Employer_Guidelines_%20June_1_2015_A.pdf

[2] https://www.transportation.gov/sites/dot.gov/files/docs/ODAPC_Employer_Guidelines_%20June_1_2015_A.pdf

[3] https://www.transportation.gov/odapc/part40QA/40_3

[5] https://www.transportation.gov/sites/dot.gov/files/docs/ODAPC_Employer_Guidelines_%20June_1_2015_A.pdf 

[6] https://www.transportation.gov/odapc/part40

DOT breath alcohol testing follows the procedures in 49 CFR Part 40, Subparts J through N. Only a qualified screening test technician (STT) or breath alcohol technician (BAT) may conduct a DOT alcohol test. An STT can conduct only screening tests. A BAT can conduct both screening and confirmation tests (49 CFR 40.211).

Approved Devices

A screening test may be done on an alcohol screening device (ASD) or an evidential breath testing device (EBT). Both must appear on ODAPC's lists of approved devices. An ASD, such as a saliva device, can be used only for screening tests and never for confirmation tests (49 CFR 40.229).

Only an approved EBT may be used for a confirmation test. The EBT must print each result in triplicate (or three consecutive identical copies), assign a unique number to each test, test an air blank and perform an external calibration check (49 CFR 40.231).

Qualification training must cover the particular ASD or EBT the technician will use. After training, a BAT must complete seven consecutive error-free mock tests, and an STT must complete five (49 CFR 40.213).

The Testing Site

The testing site must give the employee visual and aural privacy so that unauthorized persons cannot see or hear test results (49 CFR 40.221). The technician may test only one employee at a time. When a BAT will do both tests, the full screening and confirmation process for one employee must be finished before the next employee's screening begins (49 CFR 40.223).

The Screening Test

The technician checks the employee's photo ID, explains the procedure and completes Step 1 of the DOT Alcohol Testing Form (ATF). The employee then completes and signs Step 2. Refusing to sign Step 2 is a refusal to test. If the employee also has a DOT drug test, the alcohol test should be completed first whenever practicable (49 CFR 40.241).

On a breath device, the technician opens an individually wrapped or sealed mouthpiece in view of the employee. The employee blows steadily and forcefully for at least six seconds or until the device shows that enough breath was collected (49 CFR 40.243). On a saliva ASD, the technician shows the employee the expiration date, opens the sealed package in front of the employee and reads the result no sooner than the manufacturer allows and always within 15 minutes of the test (49 CFR 40.245).

A screening result below 0.02 ends the test. The technician signs the ATF and sends the result to the Designated Employer Representative (DER). A result of 0.02 or higher requires a confirmation test (49 CFR 40.247).

The 15-Minute Waiting Period

The confirmation test cannot start until at least 15 minutes after the screening test is completed. It should begin as soon as possible after that, and no more than 30 minutes after the screening test. The employee must be observed during the wait (49 CFR 40.251).

The BAT tells the employee not to eat, drink, put anything in the mouth or belch during the wait. The wait prevents mouth alcohol from causing an artificially high reading. The confirmation test goes ahead at the end of the wait even if the employee did not follow these instructions (49 CFR 40.251(a)(2)).

A confirmation test done before the 15 minutes are up is a fatal flaw, and the test must be cancelled (49 CFR 40.267). Starting after 30 minutes does not invalidate the test, but it may be a regulatory violation (49 CFR 40.251(g)).

The Confirmation Test

Before the confirmation test, the BAT runs an air blank on the EBT in front of the employee. The reading must be 0.00. If it is not, the BAT runs a second air blank. If the second reading is also above 0.00, the EBT must be taken out of service (49 CFR 40.253).

The BAT then opens a new individually wrapped or sealed mouthpiece in view of the employee. The BAT and the employee both read the unique test number on the EBT. The employee blows for at least six seconds, and the BAT shows the employee the displayed result and the printed result (49 CFR 40.253).

If the confirmation result is 0.02 or higher, the employee signs Step 4 of the ATF, and the BAT must notify the DER immediately and directly, not through a C/TPA. If it is below 0.02, nothing further is required of the employee (49 CFR 40.255).

Refusals

Refusals include failing to provide enough breath or saliva, failing to sign Step 2 of the ATF and failing to cooperate with any part of the testing process. The technician notes the conduct on the ATF and notifies the DER right away. The technician does not decide whether a refusal occurred. That decision belongs to the employer alone (49 CFR 40.261 and 40.355(i)).

Hygiene and Device Care

Several Part 40 steps also support hygiene. Mouthpieces must be individually wrapped or sealed and opened in view of the employee (49 CFR 40.243 and 40.253). A technician who places a saliva device in an employee's mouth must wear single-use gloves and change them after each test. Saliva devices, swabs and gloves are never reused (49 CFR 40.245).

EBT users must follow the manufacturer's instructions for use and care, including external calibration checks at the required intervals (49 CFR 40.233). Any cleaning product used on a device should be one the manufacturer's instructions allow.

The full rules are in 49 CFR Part 40 on eCFR.

Certain medications can result in false positives on drug tests. A false positive occurs when a drug test detects the presence of a substance that is chemically similar to an illicit drug, even though the individual has not used the illicit drug. Here are some common examples of medications and the substances they might be mistaken for:

Over-the-counter medications

• Pseudoephedrine (found in cold medications) can be mistaken for amphetamines.
• Ibuprofen (used for pain relief) has been known to cause false positives for THC, the active ingredient in marijuana.

Prescription medications

• Antibiotics such as amoxicillin can sometimes cause false positives for cocaine.
• Antidepressants like sertraline (Zoloft) can result in false positives for benzodiazepines or LSD.
• ADHD medications like methylphenidate (Ritalin) can be mistaken for amphetamines.

Other substances

• Certain antiretroviral drugs used to treat HIV can cause false positives for marijuana.
• Quinolone antibiotics can sometimes be mistaken for opiates.

When a drug test yields a non-negative result, it may be reviewed by a Medical Review Officer (MRO). An MRO is a licensed physician responsible for interpreting and evaluating test results, considering any legitimate medical explanations for a positive result. The MRO will review the individual's medical history, prescription medications, and other relevant information.

Proper drug and alcohol testing training is crucial for technicians to interpret test results and identify potential false positives correctly. While technicians can perform initial screenings, only Medical Review Officers (MROs) have the authority to determine if a result is a false positive or a legitimate non-negative.

An MRO is a licensed physician responsible for interpreting and evaluating test results in the context of an individual’s medical history, prescription medications, and other relevant factors are needed to ensure that any positive test result due to legitimate medications or other substances is accurately identified and that individuals are not unfairly penalized. Confirmatory testing, such as gas chromatography-mass spectrometry (GC-MS), is also used to verify initial test results and eliminate the possibility of false positives.

Drug and alcohol training has become pretty common across the board these days. Most businesses have a policy detailing their stance on alcohol and drug use on the property. Most also practice random drug testing to create a safer workplace for employees and a better customer environment. However, some people require something a bit more – DOT drug and alcohol training.

Drug and Alcohol Training For Those in Authority

This type of training is designed for managers, supervisors, team leaders, and others in positions of authority within the workplace. This applies to all transportation companies, regardless of the number of employees, including companies with fewer than 50 covered employees. Of course, it’s a good idea for all employees to go through this type of training if it’s financially feasible for the company.

What Does It Cover?

According to the FMCSA (Federal Motor Carrier Safety Administration), “Each employer shall ensure that all persons designated to supervise drivers receive at least 60 minutes of training on alcohol misuse and receive at least an additional 60 minutes of training on controlled substances use. The training will be used by the supervisors to determine whether reasonable suspicion exists to require a driver to undergo testing under § 382.307.” (49 CFR 382.603)

In terms of topics covered, DOT drug and alcohol training should provide students enrolled in the course with information concerning the speech, physical, performance, and behavioral indicators of alcohol or drug misuse in the workplace. Under FMCSA, FTA and PHMSA rules, supervisors who complete the 120 minutes of training are not required to repeat the course. FAA requires recurrent training in later years, and FRA and USCG set their own requirements.

Training Types

There are numerous types of DOT drug and alcohol training beyond previously mentioned, called “reasonable suspicion training.” In addition, there is breath alcohol training, certified urine specimen collector training, train-the-trainer courses, and drug-specific courses.

Determine Your Needs

Because there are so many different options in terms of available DOT drug and alcohol training, it’s important to understand the requirements that apply to you. If you’re a manager or supervisor within a transportation company, then reasonable suspicion training will be required. However, if you’re considering a career in this field, you’ll find that other training options are necessary depending on your specific goals (breath alcohol technician, certified urine specimen collector, etc.).

In addition, you’ll need to choose the course delivery method that fits your needs. While conventional classroom learning is available, online courses are preferable. They’re faster, more affordable, and deliver the same quality education.

There are numerous career possibilities within the field of DOT drug testing. Transportation companies are under a significant burden to ensure their employees are drug and alcohol-free, and the US government's regulations mean constant work in this area. That kind of demand means you can have your pick of employers or even start your own business. The first step is to become qualified. How do you become DOT certified to become a drug testing sample collector?

What's a Sample Collector?

Given the job title, a sample collector does what you imagine. It is this individual's responsibility to collect urine samples for testing at the laboratory. However, there's more to it than just handing over a plastic cup to DOT company employees – a good deal more.

Sample collectors must be familiar with several things, including the following:

Employees: You'll be responsible for dealing with the actual employees providing the sample. You need to be able to provide them with the information necessary to complete the process and obtain their identification.

Inspection: People will try many things to pass a drug test. You are the last line of defense here. You'll have to ask employees contributing samples to empty their pockets, check the contents for anything that might interfere with the sample, ask them to leave briefcases and purses outside, and possibly even supervise the sampling process.

Records: Sample collection requires a good bit of record-keeping and organization. Samples must be labeled per industry standards and documented at several steps along the way to the lab.

Proper Training

Training and certification are the first steps in becoming DOT-qualified to become a drug testing sample collector. This can be tricky – ensure the training provider you choose specializes in training DOT sample collectors. Non-DOT drug testing is very different, and the training process is not the same.

With the right education provider, you'll have everything you need to become DOT certified and a drug testing sample collector.

Do you employ safety-sensitive workers that must have DOT drug and alcohol tests, such as those who manage drivers or railroad workers? Do you manage a DOT drug or alcohol testing program? If the answer is yes to either of these questions, then it is likely that your managers or supervisors will require reasonable suspicion training [1].

What is Reasonable Suspicion Training?

Reasonable suspicion training, or reasonable cause training, helps a person understand the symptoms of drug and alcohol use. If a company employee in a managerial position suspects an employee is under the influence of alcohol or drugs, the supervisor must have been previously trained to detect the signs of drug use to order a DOT exam [2].

What are the Requirements for Drug Testing an Employee Once a Supervisor Has Become Suspicious?

Part of the reasonable suspicion training will include not only noticing the signs of drug use, but also how a manager must approach conducting a test for drugs or alcohol.  That process will look something like this:

• A trained supervisor (or company official) suspects an employee is on drugs or intoxicated by noting appearance, behavior, speech, or smell indicative of drug or alcohol use.
• Under FMCSA and FTA rules, one trained supervisor or company official may make the determination (49 CFR 382.307 and 655.43). FAA and FRA rules require a second supervisor to concur before a reasonable suspicion drug test (14 CFR 120.109 and 49 CFR 219.303(b)). Where it is not required, a second opinion is still a good practice.
• Then, and only then, can the supervisor that is present at the situation document his or her observations and make the decision to drug or alcohol test an employee.

Why Do My Supervisors Need Reasonable Suspicion Training?

In short, a company is required to test an employee if the manager observes signs that the employee is under the influence [3]. If the training has not been conducted, an otherwise competent supervisor may make mistakes that the company would then be liable for. Some of those mistakes include:

• Failing to properly notice that a person may be under the influence of drugs or alcohol. [4]
• Incorrectly making the call to drug test an employee based on a complaint from another person or an email or phone tip from a source that is not a trained supervisor.
• Failing to document the process that leads the supervisor to their conclusion that the employee may be under the influence of drugs or alcohol.
• Incorrectly identifying the correct and specific observations a supervisor (or company official) MUST make before recommending a drug test be done.
• Failing to get a second supervisor’s concurrence when FAA or FRA rules require it.

FMCSA 49 CFR 382.603 makes it clear that supervisors must receive at least 60 minutes of training on alcohol misuse and at least another 60 minutes on controlled substances use [5] to be considered trained for reasonable suspicion. Because the time commitment is so minor, there is not a reason not to get your supervisors trained as soon as possible.