Drivers that require a commercial driver’s license (CDL) to operate are subject to DOT testing rules, and a carrier must have at least one employee designated as a driver supervisor to detect the use of a controlled substance or alcohol and request a DOT reasonable suspicion test. This supervisor must meet the training requirements in §382.603, which requires at least one hour on the topic of signs and symptoms of drug use, and an additional hour of training on alcohol. Consider training your driver supervisors on the following three-step approach to reasonable suspicion testing.
Step 1: Observe
The person trained in reasonable suspicion must personally observe the unusual behavior displayed by a driver. Supervisors must confirm that the physical, behavioral, speech, and/or performance indicators being observed are consistent with what they know about drug use and alcohol misuse. Common signs and symptoms of drug use and alcohol misuse:
- Bloodshot eyes, pupils larger or smaller than usual
- Unusual smells on breath, body, or clothing
- Impaired coordination with routine tasks
- Engaging in erratic or suspicious behaviors
- Sudden mood swings and irritability
Step 2: Confront
The most difficult aspect of reasonable suspicion training is confronting an employee exhibiting unusual behavior. It may be awkward at first, but the supervisor must approach the driver and notify them of the suspicion. After confirming your suspicions, the supervisor must immediately order the appropriate test. Most carriers use third-party administrators to handle reasonable suspicion testing, but in-house testing is acceptable. Just remember that DOT regulations prohibit the supervisor who requested the test from conducting it.
Step 3: Test and document
Supervisors must document the observations leading to the alcohol or drug reasonable suspicion test and sign their names on the reports within 24 hours of the observed behavior or before the results of the alcohol or controlled substances tests are released, whichever is earlier. After the request for a drug test, it may take up to 72 hours to receive the official result. Your company policy would dictate what you do with the driver during this interim. Many companies place the employee out of service pending the results.
