• A company’s SAP must be credentialed.
• The DOT requires SAPs to be knowledgeable in specific areas.
• A SAP’s basic responsibilities begin when an employee violates DOT drug or alcohol rules.

To be permitted to act as a substance abuse professional (SAP) in a Department of Transportation (DOT) drug and alcohol testing program, a person must have one of the following credentials:

• Licensed physician (Medical Doctor or Doctor of Osteopathy),
• Licensed or certified psychologist,
• Licensed or certified social worker,
• Licensed or certified employee assistance professional,
• State-licensed or certified marriage and family therapist, or
• Drug and alcohol counselor certified by an organization listed on the Office of Drug and Alcohol Policy & Compliance (ODAPC) website.

Knowledge

In order to act as an SAP, the credentialed individual must:

• Have knowledge of, and clinical experience in, the diagnosis and treatment of substance abuse;
• Be knowledgeable about the SAP function as it relates to employer interests in safety-sensitive duties;
• Be knowledgeable about Part 40, applicable DOT regulations affecting the employers, and the DOT SAP Guidelines; and
• Receive qualification training and continuing education.

The DOT requires SAPs to keep current on any changes to these materials. SAPs must subscribe to the Office of Drug & Alcohol Policy & Compliance (ODAP) list for email updates. DOT agency regulations, DOT SAP Guidelines, and other materials are also available to the SAP from ODAPC.

Note that an SAP, who is otherwise fully qualified under Part 40, must not perform evaluations outside the geographic jurisdiction for their credential(s). If the SAP who made an evaluation exceeds their geographic jurisdiction, the employee will not be required to seek the evaluation of a second SAP.

SAP’s role

The basic responsibility of the SAP is to:

• Provide a comprehensive assessment and clinical evaluation of an employee who has engaged in prohibited behavior (Subpart B to Part 382), and
• Determine whether the employee needs assistance resolving alcohol or drug abuse-related problems.

At the SAP’s discretion, the initial and follow-up evaluations may be performed face-to-face in-person or remotely. If a SAP is not prohibited from using technology within the parameters of the SAP’s state-issued license or other credential(s), a remote evaluation must be must be conducted in accordance with the following criteria:

• The technology must permit real-time audio and visual interaction between the SAP and the employee; and
• The quality of the technology (e.g., speed of the internet connection and clarity of the video display) must be sufficient to allow the SAP to gather all the visual and audible information the SAP would otherwise gather in an in-person, face-to-face interaction, while providing security to protect the confidentiality of the communications at the level expected by industry standards for remote substance abuse evaluations.

If the employee is found to need assistance as a result of the assessment, then the SAP recommends a course of treatment with which the employee must comply before returning to safety-sensitive functions. If the employee successfully completes the course of treatment, the SAP will provide the employer with a report with the follow-up program based on the evaluation of the driver.

SAP’s Clearinghouse recordkeeping

SAPs must register with the Clearinghouse to enter completed steps in the return-to-duty process onto a driver’s record.

Commercial drivers must use their personal Clearinghouse accounts to designate their SAP from a list. Without this designation, the SAP is unable to enter completed evaluations and treatment and eligibility for a return-to-duty test. This is different than the roles of medical review officers and employers, who can enter information without the driver’s permission.

If a driver’s SAP is not in the Clearinghouse list, it is important to verify that the professional is a DOT SAP, and not just a general SAP.