Reasonable suspicion training is mandatory for maintaining workplace safety and compliance, particularly in sectors regulated by the Department of Transportation (DOT) and non-DOT-regulated industries. As outlined in 49 CFR Part 40, this training is critical for setting clear standards for what constitutes reasonable suspicion and the acceptable protocols for drug and alcohol testing among DOT-regulated employers.
In non-DOT sectors, reasonable suspicion training is equally vital. While no specific federal regulations like the DOTs exist, training provides employers and supervisors with the necessary knowledge and skills to identify and handle situations where an employee might be under the influence of drugs or alcohol, thereby ensuring a safe and productive workplace and helping businesses establish their policies and procedures in line with state laws and best practices.
Reasonable suspicion training is making "articulable observations that can be objectively verified by some documentation, which, taken together with rational inferences from those observations, reasonably warrant further investigation." This is used to determine if an employee is under the influence of drugs or alcohol and can serve as sufficient grounds for reasonable suspicion testing.
Supervisors and Managers regulated by the following industries must take training once in their lifetime. However, the FAA requires supervisors to take annual recurrent training for supervisors.
- Federal Motor Carrier Safety Administration (FMCSA),
- Federal Aviation Administration (FAA),
- Federal Transit Administration (FTA),
- Federal Railroad Administration (FRA),
- United States Coast Guard (USCG), and
- Pipeline and Hazardous Materials Safety Administration (PHMSA).
Non-DOT Reasonable Suspicion Training, while paralleling DOT training for supervisors, is for employers who are in non-regulated industries and provides supervisors and managers about their legal rights to conduct drug and alcohol testing in accordance with their company's policies and state laws and ensures supervisors adhere to company guidelines and pre-existing legal standards.
Training supervisors on drug and alcohol reasonable suspicion has several benefits. It's mandatory for all supervisors and managers in DOT-regulated sectors and is used to determine if an employee is under the influence, providing grounds for Reasonable Suspicion Testing. This training is critical in ensuring workplace safety, maintaining fair and reasonable drug and alcohol testing guidelines, and reducing the risk of discrimination lawsuits.
