Maintaining a drug-free workplace is essential to remain compliant with Department of Transportation (DOT) and Federal Motor Carrier Safety Administration (FMCSA) regulations. There are specific times when companies must complete drug and/or alcohol testing. One instance is if a supervisor has reasonable suspicion that a safety-sensitive worker is under the influence. Ensuring that your supervisors have proper training helps keep your fleet and the public safe.
What is Reasonable Suspicion?
Reasonable suspicion is when a supervisor believes they have identified symptoms of drug or alcohol abuse in a fleet driver. A supervisor who requests a reasonable suspicion test must base this on their own “specific, contemporaneous, articulable” observations of a driver. They cannot rely on any third-party information. These observations can be related to speech, appearance, behavior, or body odor as long as they match the indications of drug/alcohol use that are covered in training. Only the actual supervisor of a driver can order a test. A qualified individual from another motor carrier that the driver interacts with may ask them to cease safety-sensitive duties and contact the driver’s supervisor. However, the FMCSA does not require this.
What is the Reasonable Suspicion Testing Process?
Reasonable suspicion testing is necessary when a supervisor observes signs of alcohol or controlled substance use by a safety-sensitive employee. After seeing these indications, the employee will need to submit to a drug and/or alcohol test. A qualified technician must complete this screening and if the employee tests positive, they must cease all safety-sensitive functions immediately until they complete the return-to-duty process.
Why is Training Necessary?
The FMCSA requires anyone who supervises those who drive commercial motor vehicles (CMVs) to complete 120 minutes of reasonable suspicion training. This is included in Title 49 §382.603 of the Code of Federal Regulations (CFR). The training includes 60 minutes covering signs of alcohol use and 60 minutes about the indications of controlled substance use. Without completing this necessary course, supervisors are not qualified to order testing of employees when they are displaying signs of intoxication on the job. This not only puts your motor carrier at risk of large fines. It also endangers your drivers and others on the road.
Specific Requirements for Alcohol Testing
For controlled substances, withdrawal symptoms are valid for reasonable suspicion. However, this is not the case for alcohol. This is because alcohol use is acceptable for drivers so long as it is not in their system while operating a CMV. Comparatively, controlled substance use is strictly prohibited under all circumstances. Alcohol withdrawal symptoms do not indicate that the driver was using alcohol while performing safety-sensitive functions. As a result, they cannot be used to justify testing. Supervisors must also order alcohol testing just before the start of duty, during the time the driver is on duty, or just after they go off duty.
Comprehensive training for Your Supervisors
HDS Safety Services offers reasonable suspicion training both online and in-person. After completing this course, your supervisors will be certified by the DOT in Supervisor Reasonable Suspicion. Additionally, we offer other types of compliance training for supervisors and drivers.