Reasonable Suspicion Testing

Drug or alcohol testing conducted when a trained supervisor observes specific, articulable signs of drug use or alcohol misuse in an employee.

Key Facts

  • Supervisors need 60 min training on alcohol and 60 min on drug indicators
  • Observations must be documented before testing
  • Alcohol test within 2 hours (no later than 8 hours) of observation
  • Based on specific, articulable, contemporaneous observations

Reasonable suspicion testing is triggered by trained supervisor observations of appearance, behavior, speech, or body odor consistent with drug use or alcohol misuse. Under DOT regulations (49 CFR 382.307), the supervisor must have received at least 60 minutes of training on alcohol misuse indicators and 60 minutes on drug use indicators. The supervisor must document their observations before the test. For alcohol, the test must be administered within 2 hours if possible and no later than 8 hours after the observation. For drugs, there is no specific time limit, but testing should occur as soon as possible.

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