• Requesting a reasonable suspicion test may not be an easy task for some supervisors.
• Train on a common five-step approach to help in following DOT protocols.

The following five-step approach to requesting a DOT reasonable suspicion test will assist driver-supervisors in feeling more comfortable with requesting the test type. Its structure aids in following DOT procedures and is a good best practice to include in your training curriculum.

Step 1: Observe

The person trained in reasonable suspicion must personally observe the unusual/curious behavior displayed by a driver under the trained person’s supervision. If your company has more than one trained individual, the initial supervisor may ask another trained person to help determine if the symptoms being exhibited clearly indicated prohibited drug and/or alcohol activities.

Step 2: Confirm

The supervisor must confirm that the physical, behavioral, speech, and/or performance indicators being observed are consistent with the signs and symptoms of substance misuse. It does not matter whether the supervisor knows what substance may be involved. The supervisor just needs to believe the behavior or physical signs suggest the driver is under the influence.

Step 3: Confront

This is often the hardest step for many assigned the role of supervisor. For some, it may come down to personality and level of confidence. There is also the uncertainty of how the driver may react. Nevertheless, the supervisor must approach and notify the driver of the suspicion.

This entails describing exactly what was observed and why it prompted the ordering of a drug and/or alcohol test. Always stick to the facts, offering objective terms, and showing concern. For drivers who become defensive, simply listen respectively, but repeat the observations and how you are bound by the federal safety regulations to send the driver for the required DOT test. If the driver talks nonstop, the supervisor needs to regain control of the conversation. Also, the conversation needs to be documented.

Note that some medical emergencies or health problems may resemble symptoms of drug or alcohol use and may result in short health assessment at the site (if offered) to rule out medical issues. The driver must be immediately relieved from safety-sensitive functions at this point.

Step 4: Test

The supervisor must immediately order the appropriate test(s). If you have in-house testing, remember that DOT regulations prohibit the supervisor who requests the test from conducting it. In addition, for off-site tests, it may be a wise best practice — since it is not required — to have the supervisor or another company official accompany the driver to the facility. To allow the driver to drive puts the company at risk if the driver is, in fact, impaired.

Step 5: Document

The supervisor must document the observations leading to the alcohol or drug reasonable suspicion test and sign the report within 24 hours of the observed behavior or before the results of the alcohol or controlled substances tests are released, whichever is earlier. It is best to do it as soon as possible to keep the details fresh in your memory.

The report should be detailed and in objective terms. Avoid any “I” statements. For example, instead of saying, “I suspect this driver of using alcohol,” document what was observed. It might read, “The driver had difficulty concentrating, seemed uncoordinated, dropped a logbook twice, and fumbled the pen while writing. The driver, on (enter date), was late for delivery without an explanation. The driver’s breath smelled of alcohol as if the driver had been drinking beer.”

Waiting on test results

After the request of a drug test, it may take up to 72 hours or more to receive the official result. Your company policy would dictate what you do with the driver during this interim. Many companies place the employee on temporary suspension pending the results. To allow the driver to return to driving could open the carrier up to serious litigation in the event this driver is in a crash during this time period.