Reasonable Suspicion Training: 60 Minutes Plus 60

Who must be trained

382.603 applies to persons designated to supervise drivers. Those are the people who would look at a driver and decide whether reasonable suspicion exists to send them for a test under 382.307. If your fleet of three has one person who runs the board, that person is the supervisor who needs the training, even if their card says dispatcher. If nobody is trained, nobody is allowed to make the determination. The phone call that a driver looks high then has one lawful response: do not invent a test you are not trained to order, and do not ignore a safety problem you are not equipped to document. Get the training in place before you employ drivers, not the afternoon the call comes.

Drivers themselves are not the students 382.603 is aimed at. Driver awareness is a different, older topic. Do not hand every driver a two-hour supervisor course and call the company trained if the person who actually supervises never took it.

A one-truck owner-operator with no other drivers still needs the random program, the pre-employment structure if they ever hire, and the Clearinghouse queries described in the Clearinghouse guide. They do not satisfy 382.603 by taking a course and then ordering a suspicion test on themselves. The section is supervision of drivers. A self-test is not that section. Say so plainly so this page does not create a fake self-test.

60 minutes of alcohol and 60 minutes of drugs

The regulation's math is easy to shave and wrong to shave. At least 60 minutes of training on the indicators of alcohol misuse. At least 60 minutes of training on the indicators of controlled-substance use. That is two hours. A single hour that mentions both topics fails the sentence. A 45-minute module plus a quiz you can click through in five minutes is not 60 minutes if it is not 60 minutes.

The training has to cover the physical, behavioral, speech, and performance indicators of probable misuse, which is what the section points supervisors at. Keep the certificate or the roster that shows the date, the person's name, and that both hours were completed. An invoice for a course, with no name and no subjects, is a weak record. File the proof in the drug-and-alcohol file. An auditor asks for it when they ask whether anyone was qualified to order the reasonable-suspicion test you claim you gave.

One time, and what supervisor means for a tiny fleet

382.603 does not say the course repeats every year. It is a one-time requirement for the supervisor. The company may require refreshers. The company may not treat the absence of an annual rule as the absence of the initial rule. New supervisors train before they make determinations. A promotion on Friday does not include a retroactive skill the person did not learn.

In a tiny fleet the supervisor may also be the owner, the spouse who runs dispatch, or the only person in the office. Whoever will make the call gets the two hours. If that person refuses the training, they do not make the call. Hire or designate someone who will be trained, or accept that you cannot send drivers for reasonable-suspicion tests until someone is qualified. Operating without the ability to do a required test, when a trained supervisor is required and you have drivers to supervise, is a program hole. Fill it before the hole is the audit.

Keep the proof for the duration of the person's supervisory work and after, with the rest of the drug-and-alcohol records the retention rules require. Losing the certificate and insisting the course happened is a bad day. Reprint it from the trainer while the trainer still exists.

What the training lets you do

The training lets a supervisor make the observations 382.307 requires and decide whether to test. It does not let the supervisor diagnose a medical condition, search a truck as a private investigator, or accuse a driver in the dock in front of a customer. The determination is about whether to test, based on specific observations of appearance, behavior, speech, or body odors. It is made in the time the rule contemplates, about the driver's current presentation, not about a reputation.

Alcohol reasonable-suspicion observations have to be made during, just preceding, or just after the driver is performing safety-sensitive functions, which is the limit in 382.307. A Saturday-night story about a driver at a cookout is not an alcohol reasonable-suspicion test on Monday. Drug observations are tied to the work as well. Read 382.307 when you write the procedure. This page does not replace it and does not expand it into a surveillance program.

If the trained supervisor determines a test is required, the test is a DOT test under part 382, done promptly, with the observations written. If the supervisor determines the signs do not meet the rule, they do not order a DOT test to be safe. Extra company tests are a different program. They must not be labeled DOT, and they must not be sent to the Clearinghouse as DOT results.

The test after a determination, and the documentation

Write the observations before the test, while they are contemporaneous. What you saw, what you heard, what time, where, and who the trained supervisor is. Use short factual sentences. Slurred speech at 14:10 in the yard, odor of alcohol, unable to walk a straight line beside the trailer. Not I had a feeling, and not a paragraph of motive. The driver may disagree. The form still has to be specific enough that a stranger can see what the supervisor relied on.

Then send the driver for the test the program uses. Do not let the driver drive themselves to the clinic if alcohol is suspected. Arrange transportation. A driver who refuses the test is in refusal territory. Do not bargain the test away because the load is hot. Document the refusal if it happens.

Keep the form with the result. If the test is negative, you still keep the documentation of why you tested. Reasonable suspicion is not only proved by a positive. The record shows the determination was real. If you cannot find the form, the test looks arbitrary.

What an untrained hunch is not allowed to do

An untrained dispatcher, a customer, or a co-driver does not get to declare reasonable suspicion and order a DOT test. They can report facts to a trained supervisor. The supervisor looks, the same day, and decides. If no trained supervisor exists, you do not borrow the nearest driver who once sat through a safety meeting. You fix the training gap, and you deal with an immediate safety problem by not letting an impaired person drive, which you may always do as a matter of not requiring an unsafe trip, without pretending you completed a DOT reasonable-suspicion test you were not qualified to order.

Do not use this page as a field guide to pupils, pulse rates, or searches. Those are not the record 382.307 asks a supervisor to write, and a carrier that plays detective creates problems the training was supposed to prevent. Signs the course teaches are for the determination. They are not a script for a confrontation. Be specific. Be brief. Test if the trained person determines the rule is met. Stand down if it is not.

When a determination is made, the same day's file should contain the observations, the name of the trained supervisor, and the test record or the refusal. Three pieces. If you only have a text message that says he looked high, you do not have a DOT reasonable-suspicion file, and you should not report a company argument to the Clearinghouse as if it were one.

Frequently Asked Questions