Compliance Guide

Reasonable Suspicion Testing

One of the most consequential — and most mishandled — testing situations in DOT programs. Here's exactly what's required, who can act, and how to do it right.

Critical Rule: Only a supervisor who has completed the required DOT reasonable suspicion training may make a reasonable suspicion determination and refer an employee for testing. No training = no authority to refer.

Reasonable suspicion testing is triggered when a trained supervisor directly observes an employee exhibiting specific, articulable signs consistent with drug or alcohol use while on duty or just before performing safety-sensitive functions. It is not based on a hunch — it must be based on documented, observable facts.

Required Training

Supervisor Training Requirements

Before any supervisor can make a reasonable suspicion referral, they must complete the following DOT-mandated training:

60 min Drug Use Indicators Physical signs, behavioral changes, and performance indicators associated with controlled substance use
60 min Alcohol Misuse Indicators Physical signs, behavioral changes, and performance indicators associated with alcohol misuse
Supervisor training must be documented and records kept. Training completion should be logged in the employee's supervisory file with the date, duration, and training provider noted.
Observable Indicators

What Supervisors Are Trained to Observe

Observations must be specific and contemporaneous — general concerns or past behavior alone are not sufficient.

Physical Appearance

  • Bloodshot or glazed eyes
  • Constricted or dilated pupils
  • Flushed face or unusual pallor
  • Tremors or unsteady movements
  • Odor of alcohol on breath

Behavior & Speech

  • Slurred or incoherent speech
  • Unusually agitated or combative
  • Disoriented or confused
  • Erratic or unusual behavior
  • Inability to follow instructions

Performance

  • Near-miss accidents or close calls
  • Inability to complete routine tasks
  • Inconsistent or dangerous driving
  • Unexplained performance decline

Body Odor & Other

  • Smell of marijuana or other substances
  • Presence of drug paraphernalia
  • Admission of use
Step-by-Step

What Happens After a Determination Is Made

1
Document observations immediatelyThe supervisor must write down what was observed — what they saw, heard, and smelled — with specific details and the time. A second supervisor should co-sign if available. This document is critical if the test is disputed.
2
Remove the employee from safety-sensitive dutyThe employee must be removed from duty immediately. They may not perform any safety-sensitive functions while awaiting testing or pending results.
3
Arrange transportationThe employee must not drive themselves to the collection site. The employer is responsible for arranging a safe way to get the employee to the collection site and back home if needed.
4
Conduct the test within required timeframesAlcohol: attempt within 2 hours, document if not done in 2 hrs, stop after 8 hours. Drugs: attempt within 32 hours. Document the reason if any timeframe is missed.
5
Keep all documentationThe supervisor's written observation record, referral paperwork, and test results must all be retained. These records are subject to audit and may be needed if the employee challenges the referral.
Collector's role: When a reasonable suspicion referral arrives at the collection site, the collector treats it like any other collection. The collector does not make judgments about whether the referral was warranted — that determination has already been made by the employer. Follow the standard collection procedure and document the reason for test as "Reasonable Suspicion" on the CCF.
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