A reasonable suspicion test is one of the most consequential calls a supervisor will make. Get it right and you protect your employees and the public. Get it wrong and you expose the company to safety risk, grievances and legal challenges. That's why DOT requires training.
What the rules require
Under FMCSA rules, supervisors who may make reasonable suspicion determinations must receive at least 60 minutes of training on alcohol misuse and at least 60 minutes on controlled substance use. The training covers the physical, behavioral, speech and performance indicators of probable misuse. Other DOT agencies have comparable supervisor training requirements under their own rules.
What the decision must rest on
A reasonable suspicion determination must be based on specific, contemporaneous, articulable observations about the employee's appearance, behavior, speech or body odors. Hunches, rumors and secondhand reports are not enough.
Common mistakes
• Acting on a coworker's report without a trained supervisor observing the employee directly
• Waiting too long to act, or letting the employee leave before testing
• Thin or late documentation
• Confronting the employee in a way that escalates the situation
Documentation matters
Write down what you observed, when and where, in plain factual language. Under FMCSA rules, if a reasonable suspicion alcohol test isn't administered within two hours, the employer must document why, and if it isn't done within eight hours, attempts stop and the reasons are recorded. For a controlled substances test, the supervisor's written and signed record of observations must be completed within 24 hours of the observed behavior or before results are released, whichever comes first.
How Stratellis Training can help
Our Reasonable Suspicion/Cause Training for Supervisors is online and self paced, and pairs with our FMCSA DER Training Addendum for motor carrier employers. We offer group pricing for supervisor teams and custom branded versions for larger organizations.